## TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper contai ning at least 10% fibers from paper recycled by consumers 

# AIR EMISSION PERMIT NO. 06100004- 004 Major Amendment

IS ISSUED TO

MINNESOTA POWER DIVISION OF ALLETE INC

Wisconsin Public Power Inc System Minnesota Power Inc - Boswell Energy Ctr 1210 3rd Street Northwest Cohasset, Itasca County, MN 55721

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table.

This permit amendment supersedes Air Emission Permit No. 06100004-003 and authorizes the Permittee to construct the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the State Implementation Plan under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70/Major for NSR; Operating Permit Issue Date: March 28, 2007 Major Amendment Issue Date: August 12, 2009 Expiration Date: 03/28/2012 – Title I Conditions do not expire.

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

for Paul Eger Commissioner Minnesota Pollution Control Agency

# Permit Applications Table
Permit Type Application Date Permit Action Total Facility Operating Permit - Reissuance September 24, 2001 003 Major Amendment June 26, 2008 004 Major Amendment September 15, 2008 004 Major Amendment December 3, 2008 004 Major Amendment September 5, 2008 004 Reopening January 22, 2009 004 Reopening October 9, 2008 004 Reopening June 5, 2008 004

# TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Amendment Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices

# NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific pr ovision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

# FACILITY DESCRIPTION:

The Boswell Energy Center (facility) is a coal-fired electric utility steam generating plant. Emission units at the facility include four power boilers, emergency engine generators, and fuel, additive and ash handling equipment. The main fuel for all boilers is sub bituminous coal. They may also burn distillate oil, limited amounts of boiler cleaning agents, used oil, oily coal, oily paper-based floor dry, wastewater treatment plant sludge, and oily materials (earth substrate with petroleum product). Emissions are controlled by ba ghouses, over fire air, selective Non-Catalytic Reduction on Boilers 1 and 2. Low Nitrogen Oxide (NO X 

# ) burners, over fire air, selective catalytic reduction, baghouse filter a wet scrubber on Boiler 3, and a wet venturi scrubber / electrostatic precipitator, and sulfur dioxide spray towers on Boiler 4.

AMENDMENT DESCRIPTION:

This permit amendment authorizes installation of natural gas fired igniters/heat guns on all boilers; EU001, EU002, EU003, and EU004. All boilers currently ha ve a set of oil-fired igniter/heat guns. A Prevention of Significant Deterioration (PSD ) analysis was conducted for Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). A CO limit across the four boilers will be used to avoid a significant increase in CO.

This permit amendment revises the size of emergency generator (EU 023) from 100 kW to 300 kW. This emergency generator unit (EGU) is part of the retrofitting project for EU003, permit No. 06100004-003 issued March 28, 2007. The EGU is to provide power for safe shutdown of pollution control equipment during power outages. The original generator has not yet been installed. The original project was subject to PSD for CO. Because of the increase in CO emission due to the larger EGU the facility has submitted a revised PSD analysis for CO. This includes updated Best Available Control Technology and CO air dispersion modeling.

This permit amendment includes installation of new Continuous Emissions Monitors Systems. This would allow the facility to separately monitor the Nitrogen Oxides (NO X 

# ), Sulfur Oxides (SO X 

# ), Carbon Dioxide, Opacity, and Air Flow for EU001, EU002, and EU003. This change does not involve any emissions increases or change to emission permit limits.

This permit action incorporates multiply minor amendments and reopenings initiated by the MPCA. These are the incorporated Reopenings; Certified MR 040 to replace MR 005 for monitoring opacity for EU004, Certified MR 041 to replace MR 023 for monitoring air flow for EU004, March 21, 2008, letter from Jeff Smith to Minnesota Power. This permit incorporates the requirements that stem from Title V modeling that was done by the permittee. This permit also incorporates a propane fired slag shock system. This system qualifies as an insignificant modification due to emissions. The system will be installed to target tougher-to-remove slag deposits by using the percussion of a small controlled explosion to shock the deposits off of the boiler. Since the system will operate within the boiler propane has to be added to the allowable fuels list for all boilers at the facility. This permit amends the maximum achievable operating rates for boilers 3 and 4 (EU003, EU004). These updates stem from recent stack tests. This amendment corrects allowable fuel for emergency generator 1 (EU007).

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it
DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW hdr

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.2(r)(6)(vi)(a).

Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following:

1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-4 under Preconstruction Documentation, above) to the Agency. Title I Condition: 40 CFR Section 52.21(r)(6)(ii) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project analyzed as part of a hybrid test. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-2

For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual, plus potential used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

OPERATIONAL REQUIREMENTS hdr

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800, subp. 16(J)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state requirement only and is not federally enforceable. Minn. R. 7030.0010-7030.0080

Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, to enter the Permittee's premises, to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. The Permittee may require that MPCA inspectors be accompanied by MP staff during the inspection. Permittee's staff shall be available whenever the plant is operating. Minn. R. 7007.0800, subp. 9(A)

Comply with general conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16
Comply with Fugitive Emissions Control Plan: Follow the actions and record keeping specified in the control plan. The plan may be amended with the Commissioner's approval. If the Commissioner determines that you are out of compliance with Minn. R. 7011.0150 or the control plan, then you may be required to amend the control plan and/or install and operate particulate matter ambient monitors. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R. 7011.0150; Minn. R. 7009.0020

Oily Floor Dry: Limit combustion to: 1) cellulose based only, 2) 25 tons per year, and 3) 1.25 tons per hour. Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21and Minn. R. 7007.3000 The following does not apply to Boilers No. 001, 002, 003, and 004. These units contain specific operating and/or production limits requirements.

Operating and/or production limits will be placed on emission units based on operating conditions during compliance testing. Limits set as a result of a compliance test (conducted before or after permit issuance) apply until new operating/production limits are set following formal review of a performance test as specified by Minn. R. 7017.2025. Minn. R. 7017.2025

PERFORMANCE TESTING hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-3

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. R. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C. Minn. R. ch. 7017

MONITORING REQUIREMENTS hdr
Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr
Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)

Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

REPORTING HDR

A pplication for Permit Amendment: If you need a permit amendment, submit application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 through Minn. R. 7007.1500

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected ; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000 subp. 1

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-4

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

Shutdown and Breakdown Reporting Requirement for the Dust Collector Systems for Material Handling Equipment: Shutdowns and breakdowns shall be reported on a quarterly basis to the Agency. The quarterly report shall include an identification of the dust collector that broke down or was shutdown, the time and reason for the breakdown or shutdown, a description of any repairs made, and the date and time the dust collector was placed back in service. Minn. R. 7019.1000, subp. 2

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. To be submitted on a form approved by the Commissioner. Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill Minn. R. 7002.0005 through Minn. R. 7002.0095

Extension Requests: The permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

A CID RAIN PROGRAM REQUIREMENTS hdr

Emissions from the stationary source cannot exceed any allowances that the source lawfully holds under federal acid rain regulations, except as allowed by Minn. R. 7007.0800, subp. 7. Minn. R. 7007.0800, subp. 7

A cid Rain Certification Report: due 60 days after end of each calendar year. 40 CFR Section 72.90(b) and 40 CFR Section 72.90(c)

If the unit has excess emissions, the designated representative shall submit a proposed offset plan in accordance with 40 CFR Section 72.9(e). 40 CFR Section 72.9(e)

Keep the certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications and related submissions and all records made or required under the Acid Rain Program on site for a period of 5 years from the date the document was created. 40 CFR Section 72.9(f)

Hold allowances as of the allowance transfer deadline, in the facility's compliance account. Allowances may not be less than the total annual emissions of sulfur dioxide from the previous calendar year from the facility. 40 CFR Section 72.9(c)

DISPERSION MODELING REQUIREMENTS hdr
The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 40 CFR pt. 50; Minn. Stat. Sec. 116.07, subds. 4a and 9; Minn. R. 7007.0100, subps. 7A, 7L and 7M; Minn. R. 7007.0800, subps. 1, 2, and 4; Minn. R. 7009.0010-7009.0080 The parameters used in SO2, PM10, CO modeling 06100004-004 are listed in A ppendix B of this permit. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2 The parameters used in NOx modeling 06100004-004 are listed in Appendix B of this permit.

Modeling Triggers: For changes that do not require a permit amendment or that require a minor permit amendment, and that affect any modeled parameter or emission rate, a Remodeling Submittal requirement is not triggered. The Permittee shall keep updated records on site of all parameters and emission rates. The Permittee shall submit any changes to parameters and emission rates with the next required remodeling submittal.

For changes that require a moderate or major permit amendment and affect any modeled parameter or increase in an emission rate, a Remodeling Submittal requirement is triggered. The Permittee shall include previously made changes to parameters and emission rates that did not trigger a remodeling submittal with this modeling submittal. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-5

Remodeling Submittal: The Permittee must submit to the Commissioner for approval changes meeting the above criteria and must wait for a written approval (in the form of an issued permit amendment) before making such changes. The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emissions rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2

(continued)

The plume dispersion characteristics due to the revisions of the information must be equivalent to or better than the latest dispersion characteristics modeled. The Permittee shall demonstrate this equivalency in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must submit full remodeling. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2

CLEAN AIR INTERSTATE RULE hdr

A t the present time, the permittee must comply with all the applicable requirements in 40 CFR pt. 97 for a CAIR NOx source, a CAIR SO2 source, a CAIR NOx unit, and a CAIR SO2 unit as defined in 40 CFR Sections 97.102 and 97.202. If the US Environmental Protection Agency promulgates a rule to stay 40 CFR pt. 97 in Minnesota, this requirement will be of no further force and effect upon the effective date of the rule. 40 CFR pt. 97; 40 CFR Section 52.1240; Minn. R. 7007. 0800, subp. 2.

Oil & Natural Gas Carbon Monoxide Emissions Limit hdr
Carbon Monoxide: less than or equal to 319 tons/year using 12-month Rolling Sum

. This limit was taken to avoid a Air Emissions Increase Analysis when installing natural gas igniter/heat guns. This limit is derived from limited potential to emit increase of 95 tons/yr of CO.

Combined CO emissions from oil and natural gas combustion used in all igniters and warm-up guns in EU 001, EU 002, EU 003, and EU 004 shall not exceed 319 tons per year of CO. This excludes CO emissions from coal combustion and other permitted fuels. This limit applies on a 12-month rolling sum basis and must be evaluated monthly. The 12-month rolling sum becomes effective at the end of the 12th calendar month following issuance of permit 06100004-004. The following emission factors shall be used: Fuel Oil - 5 lbs CO/1000 gallons; Natural Gas - 84 lbs CO/million cubic feet. Minn. R. 7007.0800 subp. 2

Recordkeeping: evaluate 12-month rolling sum of Carbon Monoxide on a monthly basis. Minn. R. 7007.0800 subp. 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-6

Subject Item: GP 002 Opacity Monitors

Associated Items: MR 020 Blr 1 Opacity

MR 021 Blr 2 Opacity

MR 027 Boiler 3 Opacity

MR 040 Blr 4 Opacity

What to do Why to do it CONTINUOUS OPACITY MONITORING SYSTEMS (COMS) Requirements (Additional requirements are located under the associated MR subject items and in Table B) hdr

A ll COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. Minn. R. 7017.1200, subp. 1, 2 & 3; 40 CFR Section 60.13(e)(1); 40 CFR Section 60.13(h)

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1; 40 CFR Section 60.13(e)

COMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in Minn. R. 7017.1210. 40 CFR Section 60.13(a); Minn. R. 7017.1210

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity. Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). Minn. R. 7017.1210, subp. 2; 40 CFR Section 60.13(d)(l) regarding COMS and 60.13(d)(2)

A ttenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in Code of Federal Regulations, Title 40, Part 60, Appendix B, Section 7.1.3.1 within the time frame of opacity stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be on site available for inspection. Minn. R. 7017.1210, subp. 4

Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-7

Subject Item: GP 003 NOx and SO2 Monitors

Associated Items: MR 002 Blr 1, 2, and 3 SO2

MR 004 Blr 1 and 2 NOx

MR 007 Blr 4 SO2

MR 008 Blr 4 NOx

MR 016 Blr 3 NOx

MR 028 Blr 1 SO2

MR 029 Blr 1 NOx

MR 032 Blr 2 SO2

MR 033 Blr 2 NOx

MR 036 Blr 3 SO2

MR 037 Blr 3 NOx

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (Additional requirements are located under the associated MR subject items and in Table B) hdr

CEMS QA/QC: The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, appendix B as amended. 40 CFR Section 75.21

Daily Calibration error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, appendix B. 40 CFR pt. 75, Appendix B, section 2.1

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Part 75, Subpart F

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. 40 CFR Section 60.13(e); Minn. R. 7017.1090

A LTERNATIVE OPERATING SCENARIOS hdr
Operating Scenario 1: Use MR 002, MR 004, and MR 016 to continuously monitor emissions for SO2 and NOx from EU 001, EU 002, and EU 003. This scenario applies until EU 003 is shut down to tie in the new pollution control retrofit equipment permitted in 06100004-003.

Operating Scenario 2: Use MR 028, MR 032, and MR 036 to continuously monitor SO2 emissions from EU 001, EU 002, and EU 003. Use MR 029, MR 033, and MR 037 to continuously monitor NOx emissions from EU 001, EU 002, and EU 003. Requirements for MR 002, MR 004, and MR 016 no longer apply. This scenario will apply to EU 001 and EU 002 immediately at the time EU 003 is shut down to tie in the new pollution control retrofit equipment. Operating Scenario 2 will apply to EU003 once the unit is returned to service. Operating Scenario 1 will no longer apply once Operating Scenario 2 becomes effective. Minn. R. 7007.0800, subp. 4, 5 & 6

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-8

Subject Item: GP 004 Boilers 1-4 Sulfur Dioxide Limits

Associated Items: EU 001 Power Boiler 1

EU 002 Power Boiler 2

EU 003 Power Boiler 3

EU 004 Power Boiler 4

What to do Why to do it
BOILER 3 AND 4 COMBINED LIMITS hdr

When EU 001 and EU 002 are not operating, sulfur dioxide emissions are limited to less than or equal to the following:

Condition 1) 3.52 lb/mmBtu for SV 003 and 1.2 lb/mmBtu for SV 004, both on a one-hour average; OR,

Condition 2) 4.0 lb/mmBtu for SV 003 and 0.88 lb/mmBtu for SV 004, both on a one-hour average; OR,

Condition 3) 3.67 lb/mmBtu for SV 003 and 1.10 lb/mmBtu for SV 004, both on a one-hour average. Minn. R. ch. 7009; 40 CFR pt. 50

BOILER 1 EMISSION LIMITS hdr
When the EU 001 flue gasses are vented through SV 001: Sulfur Dioxide: less than or equal to 1.18 lbs/million BTU heat input using 1 Hour A verage Minn. R. 7009.0020

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour A verage and a 3-Hour Average for solid fuels, and 2.0 lbs/mmBtu when burning liquid fuels. When solid and liquid fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat from solid fuels. This limit applies only when EU001 is vented through SV003. Minn. R. 7011.0510, subp. 1 Minn. R. 7009

BOILER 2 EMISSION LIMITS hdr
When EU 002 flue gasses are vented through SV 001. Sulfur Dioxide: less than or equal to 1.18 lbs/million Btu heat input using 1-Hour A verage Minn. R. 7009.0020

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour A verage and a 3-Hour Average for solid fuels, and 2.0 lbs/mmBtu when burning liquid fuels. When liquid and solid fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat from solid fuels. This limit applies only when EU 002 is vented through SV 003. Minn. R. 7011.0510, subp. 1 Minn. R. 7009

BOILER 3 LIMITS hdr
Sulfur Dioxide: less than or equal to 2.97 lbs/million Btu heat input using 1-Hour A verage when EU 001 and EU 002 are operating, and the EU 001 and EU 002 emissions are vented through SV 001. Minn. R. 7009.0020

Sulfur Dioxide: less than or equal to 0.09 lbs/million Btu heat input based on a 30-day rolling average. This limit does not apply during times of startup, shutdown or malfunction. (Boiler 3 limit). This limit applies regardless of the operation and venting of the other boilers.

This limit applies after return to regular operation of Unit 3 following modification of the boiler and its pollution control equipment stream. Minn. R. 7007.0800, subp. 2

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour A verage and a 3-Hour Average for solid fuels, and 2.0 lbs/mmBtu when burning liquid fuels. When solid and liquid fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat from solid fuels. The EU003 sulfur dioxide limit applies regardless if EU001 and EU002 are operating. Minn. R. 7011.0510, subp. 1 Minn. R. 7009

BOILER 4 EMISSION LIMITS hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-9

Sulfur Dioxide: less than or equal to 1.2 lbs/million Btu heat input using 1-Hour A verage period for solid fossil fuel, and 0.8 lb/million BTU using 1 Hour Average period for liquid fossil fuel. When solid and liquid fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[0.8y+1.2z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat from solid fuels. Title I Condition: 40 CFR Section 52.21(j) PSD BACT limit and ambient impacts analysis; 40 CFR Section 60.43

Sulfur Dioxide: less than or equal to 0.33 lbs/million Btu heat input based on an annual average. Minn. R. 7021.0050, subp. 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-10

Subject Item: GP 005 Low Temperature Fabric Filters

Associated Items: CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

What to do Why to do it The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subp. 2 and 14

Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions once each day of operation during daylight hours. Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subp. 4, 5 and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-11

Subject Item: EU 001 Power Boiler 1

Associated Items: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F

GP 004 Boilers 1-4 Sulfur Dioxide Limits

MR 002 Blr 1, 2, and 3 SO2

MR 003 Blr 1, 2, and 3 CO2

MR 004 Blr 1 and 2 NOx

MR 020 Blr 1 Opacity

MR 028 Blr 1 SO2

MR 029 Blr 1 NOx

MR 030 Blr 1 CO2

MR 031 Blr 1 Air Flow

SV 001

SV 003

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.1 lbs/million BTU heat input Title I condition: 40 CFR Section 52.21(k) (ambient air impacts analysis); also meets the requirements of Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

See GP004 for sulfur dioxide limits. hdr
Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4) NOx Averaging Plan

Maintain an annual average NOx emission rate of 0.46 lbs/MMBtu and limit the annual heat input to less than or equal to 3,500,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11 Minn. R. 7011.0553

OPERATIONAL LIMITS AND REQUIREMENTS hdr

Fuel use: limited to sub-bituminous coal, boiler cleaning agents, distillate oil, oily coal, used oil, oily paper-based floor dry, pipeline quality nature gas, and propane. Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total mass input, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. R. 7007.0800, subp. 2

Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, not to exceed 17.5% of rated heat input on an hourly basis (equal to 963 gallons/hr.). Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-12

Vent all emissions to a fabric filter that meets the requirements of CE001 for particulate matter control when burning coal. The fabric filter may be bypassed during startup.

Bypassing of the fabric filter shall be for as short a time as is practicable while avoiding damage to the fabric filter and it components, but shall not exceed 8 hours. Title I Condition: control of particulate emissions.

CONTINUOUS MONITORING REQUIREMENTS hdr
The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions from affected units in accordance with 40 CFR Section 75.10. See GP002 for requirements regarding opacity monitoring, and GP003 for requirements regarding SO2 and NOx monitoring. The SO2 and NOx monitors shall be capable of producing emission rates in units of lb/mmBtu on a one-hour average, a three-hour average and on a 30-day rolling average. 40 CFR Section 75.10 Minn. R. 7017.1020

Operate and maintain the continuous opacity monitor as a partial indicator of compliance with the particulate matter limit. 40 CFR Part 64

PERFORMANCE TESTING hdr
Performance Test: due before end of each 60 months starting 09/16/1997 to determine compliance with the Title I condition particulate matter emission limit. The tests shall be conducted at an interval not to exceed 60 months between test dates. Title I Condition: monitoring for the particulate matter emission limit set under 40 CFR 52.21; Minn. R. 7017.2020, subp. 1, and 40 CFR Part 64

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, Subp. 2.

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, Subp. 2.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-13

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, Subp. 4.

Performance Test: due 180 days after Permit Issuance to measure PM10 emissions.

This test shall be conducted with the rotating opposed fired air and selective non-catalytic reduction control systems in operation.

Testing is required to confirm conclusion of the permitting assessment conducted in June 2008 for the addition of rotating opposed fired air and selective non-catalytic reduction. The Permittee shall submit a report updating the June 2008 permitting assessment incorporating results of this testing no later than 90 days following completion of testing. Title I condition: 40 CFR Section 52.21; Test to confirm the modification is not subject to PSD; Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-14

Subject Item: EU 002 Power Boiler 2

Associated Items: CE 002 Fabric Filter - High Temperature, i.e., T>250 Degrees F

GP 004 Boilers 1-4 Sulfur Dioxide Limits

MR 002 Blr 1, 2, and 3 SO2

MR 003 Blr 1, 2, and 3 CO2

MR 004 Blr 1 and 2 NOx

MR 021 Blr 2 Opacity

MR 032 Blr 2 SO2

MR 033 Blr 2 NOx

MR 034 Blr 2 CO2

MR 035 Blr 2 Air Flow

SV 001

SV 003

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.1 lbs/million BTU heat input Title I condition: 40 CFR Section 52.21(k) (ambient air impacts analysis); also meets the requirements of Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

See GP004 for sulfur dioxide limits. hdr
Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4) NOx Averaging Plan

Maintain an annual average NOx emission rate of 0.46 lbs/MMBtu and limit the annual heat input to less than or equal to 3,500,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11 Minn. R. 7011.0553

OPERATIONAL LIMITS AND REQUIREMENTS hdr

Fuel use: limited to sub-bituminous coal, boiler cleaning agents, distillate oil, oily coal, used oil, oily paper-based floor dry, pipeline quality natural gas, and propane. Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total mass input, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. R. 7007.0800, subp. 2

Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, not to exceed 17.5% of rated heat input on an hourly basis (equal to 963 gallons/hr.). Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-15

Vent all emissions to a fabric filter that meets the requirements of CE002 for particulate matter control when burning coal. The fabric filter may be bypassed during startup.

Bypassing of the fabric filter shall be for as short a time as is practicable while avoiding damage to the fabric filter and it components, but shall not exceed 8 hours. Title I Condition: control of particulate emissions.

CONTINUOUS MONITORING REQUIREMENTS hdr
The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions from affected units in accordance with 40 CFR Section 75.10. See GP002 for requirements regarding opacity monitoring, and GP003 for requirements regarding SO2 and NOx monitoring. The SO2 and NOx monitors shall be capable of producing emission rates in units of lb/mmBtu on a one-hour average, a three-hour average and on a 30-day rolling average. 40 CFR Section 75.10 Minn. R. 7017.1020

Operate and maintain the continuous opacity monitor as a partial indicator of compliance with the particulate matter limit. 40 CFR Part 64

PERFORMANCE TESTING hdr
Performance Test: due before end of each 60 months starting 09/16/1997 to determine compliance with the Title I condition particulate matter emission limit. The tests shall be conducted at an interval not to exceed 60 months between test dates. Title I Condition: monitoring for the particulate matter emission limit set under 40 CFR 52.21; Minn. R. 7017.2020, subp. 1, and 40 CFR Part 64

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, Subp. 2.

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, Subp. 2.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-16

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, Subp. 4.

Performance Test: due 180 days after Permit Issuance to measure PM10 emissions.

This test shall be conducted with the over-fire air and selective non-catalytic reduction control systems in operation.

Testing is required to confirm conclusion of the permitting assessment conducted in June 2008 for the addition of rotating opposed fired air and selective non-catalytic reduction. The Permittee shall submit a report updating the June 2008 permitting assessment incorporating results of this testing no later than 90 days following completion of testing. Title I condition: 40 CFR Section 52.21; Test to confirm the modification is not subject to PSD; Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-17

Subject Item: EU 003 Power Boiler 3

Associated Items: CE 012 Wet Scrubber - High Efficiency
CE 019 Modified Furnace or Burner Design

CE 020 Catalytic Reduction
CE 021 Fabric Filter - High Temperature, i.e., T>250 Degrees F

CE 022 Wet Limestone Injection

GP 004 Boilers 1-4 Sulfur Dioxide Limits

MR 002 Blr 1, 2, and 3 SO2

MR 003 Blr 1, 2, and 3 CO2

MR 016 Blr 3 NOx

MR 024 Boiler 3 CO

MR 025 Blr 3 Mercury
MR 027 Boiler 3 Opacity

MR 036 Blr 3 SO2

MR 037 Blr 3 NOx

MR 038 Blr 3 CO2

MR 039 Blr 3 Air Flow

SV 003

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input . This limit applies prior to modification of Boiler 3 and its pollution control stream. Minn. R. 7011.0510, subp. 1

Total Particulate Matter: less than or equal to 0.014 lbs/million Btu heat input for filterable PM. This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Minn. R. 7007.0800, subp. 2

Particulate Matter < 10 micron: less than or equal to 0.035 lbs/million Btu heat input filterable plus organic and inorganic condensables. This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Minn. R. 7007.0800, subp. 2

Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

NOx Averaging Plan

Maintain an annual average NOx emission rate of 0.40 lbs/MMBtu and limit the annual heat input to less than or equal to 19,000,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.8 Early election for Group 1, Phase II boilers and 40 CFR Section 76.5(a)(1) Minn. R. 7011.0553

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-18

Nitrogen Oxides: less than or equal to 0.07 lbs/million Btu heat input based on a 30-day rolling average. This limit does not apply during times of startup, shutdown or malfunction.

This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Minn. R. 7007.0800, subp. 2

See GP004 for sulfur dioxide limits. hdr
Hydrogen fluoride: less than or equal to 0.0018 lbs/million Btu heat input . This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000 Carbon Monoxide: less than or equal to 0.15 lbs/million Btu heat input on a 24-hour rolling average. This limit does not apply during periods of startup, shutdown, or malfunction. This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Title I Condition: 40 CFR Section 52.21 BACT limit

Lead: less than or equal to 0.00004 lbs/million Btu heat input . This limit applies upon return of Unit 3 to regular operation after modification of the boiler and its pollution control equipment stream. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000 OPERATING REQUIREMENTS hdr

Regular operation for Unit 3 is defined as operation at more than 200 net MW of load for more than 7 days in a row after modification of the boiler and its pollution control equipment stream. Minn. R. 7007.0800, subp. 2

Fuel use: limited to sub-bituminous coal, boiler cleaning agents, distillate oil, oily coal, used oil, wastewater treatment plant sludge, oily paper-based floor dry, pipeline quality natural gas, propane, and oily materials (includes mixtures of earth substrate (soil, rocks, sod, etc.) or man-made petroleum adsorption material and various petroleum derived fuels (hydraulic, transformer (less than 50 ppm PCB), crankcase or lubricating oils, diesel fuel, and crude oil)).

Note: the Permittee is prohibited from using oily materials or wastewater treatment plant sludge as fuel until the Permittee satisfactorily completes the performance testing requirements for these fuels under EU003. Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total mass input, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. R. 7007.0800, subp. 2

Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, and not to exceed 2,456 gallons per hour. Minn. R. 7007.0800, subp. 2

Vent all emissions to a scrubber for particulate control until the boiler and its pollution control equipment stream are modified. After return to regular operation vent all emissions to a selective catalytic reduction system, a fabric filter, and sulfur dioxide scrubber. Minn. R. 7007.0800, subp. 2

CONTINUOUS MONITORING hdr
Measure all Opacity, SO2, NOx, and CO2 emissions from affected units in accordance with 40 CFR Section 75.10. See GP002 for requirements regarding opacity monitoring, and GP003 for requirements regarding SO2 and NOx monitoring. The SO2 and NOx monitors shall be capable of producing emission rates in units of lb/mmBtu on a one-hour average, a three-hour average and on a 30-day rolling average.

The opacity monitor shall be installed upon return of Unit 3 to regular operation as defined in this permit, and shall be located after the fabric filter and prior to the flue gas desulfurization unit. 40 CFR Section 75.10 Minn. R. 7017.1020 40 CFR Part 64

Install and operate a continuous emission monitor to measure all CO emissions. The monitor shall be capable of producing emission rates in units of lb/mmBtu on a 24 hour rolling average. See GP003 for requirements regarding CO monitoring.

The carbon monoxide monitor shall be installed upon return of Unit 3 to regular operation as defined in this permit. Title I Condition: monitoring for BACT limit and Minn. R. 7007.0800, subp. 4

Operate and maintain the continuous opacity monitor as a partial indicator of compliance with the particulate matter limit after return to regular operation following modification of the boiler and its pollution control equipment stream. 40 CFR Part 64

Mercury Emissions Monitoring: Use a Hg CEMS to measure Hg emissions from EU 003 by July 1, 2007. Additional Hg monitoring requirements are located under subject item MR 025. Minn. Statute 216B.681

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-19

Establish Baseline Mercury Emission Rate: Use mercury monitors to establish the baseline mercury emission rate for EU 003.

This is a state only requirement and is not enforceable by the EPA administrator and citizens under the Clean Air Act. Minn. Stat. 216B.681

PERFORMANCE TESTING hdr

Initial Performance Test: due 180 days after achieving maximum capacity for PM and PM10 after modification of Boiler 3 and its pollution control equipment stream. Minn. R. 7017.2020, subp. 1 40 CFR Part 64 Initial Performance Test: due 180 days after achieving maximum capacity for hydrogen fluoride after modification of Boiler 3 and its pollution control equipment stream. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000 Initial Performance Test: due 180 days after achieving maximum capacity for Lead after modification of Boiler 3 and its pollution control equipment stream. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000 Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, Subp. 2.

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, Subp. 2.

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, Subp. 4.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-20

Performance Test: due 30 days after Performance Test Notification (written) of intent to conduct a performance test while burning waste water sludge. The test shall be for determining compliance with the particulate matter emission limit in Minn. R. 7011.0510, subp. 1. The Permittee shall also concurrently measure CO emissions. Except for the purpose of conducting this performance test, the Permittee shall not use this material as a fuel until the Permittee receives notification from the agency that compliance was demonstrated during the Waste Water Sludge Performance Test. Minn. R. 7017.2020, subp. 1.

Performance Test: due 30 days after Performance Test Notification (written) of intent to conduct a performance test while burning oily materials. The test shall be for determining compliance with the particulate matter emission limit in Minn. R. 7011.0510, subp. 1. The Permittee shall also concurrently measure CO emissions. Except for the purpose of conducting this performance test, the Permittee shall not use this material as a fuel until the Permittee receives notification from the agency that compliance was demonstrated during the Oily Materials Performance Test. Minn. R. 7017.2020, subp. 1.

Opacity monitoring alternative - monitor the following operating parameters for CE 003: 1) prequench slurry flow; 2) prequench slurry pressure; 3) high pressure slurry flow; 4) high pressure slurry pressure. (See requirements under CE 003). Minn. R. 7007.0800, subp. 4

Compliance Assurance Monitoring Plan: Sixty days after return to regular operation as defined in this permit, submit a plan for developing opacity magnitude and duration levels to be used as triggers for fabric filter investigation. This plan will also identify specific investigation actions to be taken by plant personnel when the triggers are reached.

Submit trigger levels and related specific actions with 180 days after return to regular operation in the form of a major amendment application. Implement plan upon submittal. Terms identified in the permit application will be incorporated as permit conditions. Minn. R. 7007.0800 , subp. 4 and 40 CFR Part 64

SUBMITTALS AND REPORTING hdr

See Table B. hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-21

Subject Item: EU 004 Power Boiler 4

Associated Items: CE 004 Venturi Scrubber
CE 005 Electrostatic Precipitator - High Efficiency

CE 006 Spray Tower

CE 011 Fly Ash Injection

GP 004 Boilers 1-4 Sulfur Dioxide Limits

MR 006 Blr 4 CO2

MR 007 Blr 4 SO2

MR 008 Blr 4 NOx

MR 026 Blr 4 Mercury
MR 040 Blr 4 Opacity

MR 041 Blr 4 Air Flow

SV 004

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.1 lbs/million BTU heat input Title I Condition: 40 CFR Section 52.21(j) PSD BACT limit and ambient impacts analysis; 40 CFR Section 60.42(a)(1) Opacity: less than or equal to 20 percent opacity based on a six minute average, except for one six-minute average per hour not to exceed 27% 40 CFR Section 60.42(a)(2) Minn. R. 7011.0555
See GP004 for sulfur dioxide limits. hdr
Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. Takes effect for years beginning January 1, 2000. 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4) Nitrogen Oxides: less than or equal to 0.7 lbs/million Btu heat input using 3-hour A verage for solid fossil fuels, less than 0.3 lb/mmBtu from liquid fossil fuels, and less then 0.2 lb/mmBtu for gaseous fossil fuels. When fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: PS = [0.2x + 0.3y + 0.7z]/(x+y+z) where PS is the prorated NOx standard, x is the % heat input from gaseous fossil fuels, y is the % heat input from liquid fossil fuels, and z is the % heat input from solid fossil fuels. Title I Condition: 40 CFR Section 52.21(j) PSD BACT limit and ambient impacts analysis; 40 CFR Section 60.44

NOx Averaging Plan

Maintain an annual average NOx emission rate of 0.40 lbs/MMBtu and limit the annual heat input to less than or equal to 33,000,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11 Minn. R. 7011.0553

OPERATING REQUIREMENTS hdr

Fuel use: limited to sub-bituminous coal, boiler cleaning agents, distillate oil, oily coal, oily paper-based floor dry, used oil, pipeline quality natural gas, and propane. Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total mass input, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-22

Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, not to exceed 3824 gallons/hour (approximately 10 percent of rated capacity of 5,109 mmBtu/hour) on an hourly basis. Minn. R. 7007.0800, subp. 2

Maintain SV 004 exit flue gas temperature at a minimum of 135 degrees F. Minn. R. 7009

Vent all emissions to a venturi scrubber, electrostatic precipitator and spray tower. Title I Condition: control of particulate matter and sulfur dioxide
PERFORMANCE TESTING hdr
Performance Test: due before end of each 60 months starting 09/27/1997 to determine compliance with the Title I condition particulate matter emission limit. The tests shall be conducted at an interval not to exceed 60 months between test dates. Title I Condition: monitoring for the particulate emission limit set under 40 CFR Section 52.21; Minn. R. 7017.2020, subp. 1

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, Subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, Subp. 2.

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, Subp. 2.

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, Subp. 4.

CONTINUOUS MONITORING REQUIREMENTS hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-23

Measure all Opacity, SO2, NOx, and CO2 emissions from affected units in accordance with 40 CFR Section 75.10. See GP002 for requirements regarding opacity monitoring, and GP003 for requirements regarding SO2 and NOx monitoring. The SO2 and NOx monitors shall be capable of producing emission rates in units of lb/mmBtu on a one-hour average, a three hour average and on a 30-day rolling average.

Using the 30-day averages for SO2, calculate and submit the annual SO2 emission rate along with the annual compliance certification. 40 CFR Section 75.10 and Minn. R. 7017

Operate and maintain the continuous opacity monitor as a partial indicator of compliance with the particulate matter limit. 40 CFR Part 64

Measure stack gas exit temperature. Minn. R. 7009
Mercury Emissions Monitoring: Use a Hg CEMS to measure Hg emissions from EU 004 by July 1, 2007. Additional Hg monitoring requirements are located under subject item MR 026. Minn. Stat. 216B.681

Establish Baseline Mercury Emission Rate: Use mercury monitors to establish the baseline mercury emission rate for EU 004.

This is a state only requirement and is not enforceable by the EPA administrator and citizens under the Clean Air Act. Minn. Stat. 216B.681

REPORTING hdr
Submit the calculations and annual average emission rate of sulfur dioxide along with the annual compliance certification. Minn. R. 7021.0050

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-24

Subject Item: EU 007 Emergency Generator 1

Associated Items: SV 007

What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2

Fuel type: liquid propane only Minn. R. 7005.0100, subp. 35a

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-25

Subject Item: EU 009 Emergency Generator 3

Associated Items: SV 009 Diesel Emergency Generator 3

What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2

Fuel type: Diesel fuel oil or distillate fuel oil only Minn. R. 7005.0100, subp. 35a

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of fuel oil, certifying that the sulfur content does not exceed 0.5% by weight. Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-26

Subject Item: EU 010 Emergency Generator 4

Associated Items: SV 010

What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2

Fuel type: Diesel fuel oil or distillate fuel oil only Minn. R. 7005.0100, subp. 35a

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of fuel oil, certifying that the sulfur content does not exceed 0.5% by weight. Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-27

Subject Item: EU 011 Coal Handling-Crusher Building

Associated Items: CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 011

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

Operate fabric filter when emissions from the equipment are vented to the atmosphere that meets the requirements of GP005. Minn. Stat. Section 116.07, subd. 4(a); Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-28

Subject Item: EU 012 Coal Handling-Crusher & Sampler House

Associated Items: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 012

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

Operate fabric filter when emissions from the equipment are vented to the atmosphere that meets the requirements of GP005. Minn. Stat. Section 116.07, subd. 4(a); Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-29

Subject Item: EU 013 Fly Ash - #1&2 Storage Silo

Associated Items: CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 013

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

Operate fabric filter when emissions from the equipment are vented to the atmosphere that meets the requirements of GP005. Minn. Stat. Section 116.07, subd. 4(a); Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-30

Subject Item: EU 014 Fly Ash - #1&2 Ash Hoppers

Associated Items: CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 014

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

Operate fabric filter when emissions from the equipment are vented to the atmosphere that meets the requirements of GP005. Minn. Stat. Section 116.07, subd. 4(a); Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-31

Subject Item: EU 015 Hg Additive Handling and Storage

Associated Items: CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
SV 015 Additive Handling and Storage

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.01 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000, also meets the requirements of Minn. R. 7011.0715 subp. 1(A) Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING CONDITIONS hdr

Vent all emissions to a fabric filter that meets the requirements of GP005. Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-32

Subject Item: EU 017 Fly Ash Storage - Bin Vent

Associated Items: CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
SV 017 Fly Ash Storage-Bin Vent

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Title I Condition: to limit potential emission increases to less than significant under 40 CFR 52.21 and Minn. R. 7007.3000, also meets the requirements of Minn. R. 7011.0715, subp. 1(A) Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING CONDITIONS hdr

Vent all emissions to a fabric filter that meets the requirements of GP005. Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-33

Subject Item: EU 018 Fly Ash Loadout

Associated Items: SV 018 Fly Ash Loadout via general vent

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING REQUIREMENTS hdr

A dd moisture to the flyash prior to loadout. Operation of the unit without moisture addition shall be a reportable deviation. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-34

Subject Item: EU 019 Limestone Storage - Bin Vent

Associated Items: CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
SV 019 Limestone Storage - Bin Vent

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Title I Condition: to limit potential emission increases to less than significant under 40 CFR 52.21 and Minn. R. 7007.3000, also meets the requirements of Minn. R. 7011.0715, subp. 1(A) Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING CONDITIONS hdr

Vent all emissions to a fabric filter that meets the requirements of GP005. Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-35

Subject Item: EU 020 Limestone Day Bin 1

Associated Items: CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 020 Limestone Day Bin 1 - Bin Vent

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Title I Condition: to limit potential emissions increases to less than significant under 40 CFR 52.21 and Minn. R. 7007.3000, also meets Minn. R. 7011.0715, subp. 1(A) Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING REQUIREMENTS hdr

Vent all emissions to a fabric filter that meets the requirements of GP005. Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-36

Subject Item: EU 021 Limestone Day Bin 2

Associated Items: CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 021 Limestone Day Bin 2 - Bin Vent

What to do Why to do it
EMISSION LIMITS hdr
Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic foot unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Title I Condition: to limit potential emission increases to less than significant under 40 CFR 52.21 and Minn. R. 7007.3000 , also meets Minn. R. 7011.0715, subp. 1(A) Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

OPERATING REQUIREMENTS hdr

Vent all emissions to a fabric filter that meets the requirements of GP005. Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-37

Subject Item: EU 023 Emergency Gen. Unit 3 - 300Kw - CI

Associated Items: SV 022 Emergency Generator - Unit 3

What to do Why to do it
EMISSION LIMITS hdr
Opacity: less than or equal to 20 percent once operating temperatures have been attained. Minn. R. 7011.2300, subp. 1

Opacity: less than or equal to 20 percent during accelartion mode; 15 percent during lugging mode; and 50 percent during the peaks in either the acceleration or lugging modes. 40 CFR Section 60.4205(b)

Carbon Monoxide: less than or equal to 3.0 grams per kilowatt-hour. Title I Condition: 40 CFR Section 52.21(j), BACT emission limit, also meets the requirements of 40 CFR Section 60.4202. Non-methane Hydrocarbons plus Nitrogen Oxides:

Less than or equal to 4.0 grams per kilowatt-hour 40 CFR Section 60.4205(b)

Total Particulate Matter: less than or equal to 0.20 grams per kilowatt-hour. 40 CFR Section 60.4205(b)

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input . Combustion of fuel with a sulfur content of 0.5 percent by weight or less meets this requirement. Minn. R. 7011.2300, subp. 2

OPERATING REQUIREMENTS hdr
Beginning October 1, 2007, use diesel fuel that meets the requirements of 40 CFR Section 80.510(a):

(1) Sulfur content. 500 parts per million (ppm) maximum.

(2) Cetane index or aromatic content, as follows:

(i) A minimum cetane index of 40; or

(ii) A maximum aromatic content of 35 volume percent. 40 CFR Section 60.4207(a)

Beginning October 1, 2010, use diesel fuel that meets the requirements of 40 CFR Section 80.510(b):

(1) Sulfur content. 15 ppm maximum for Non-Road diesel fuel.

(2) Cetane index or aromatic content, as follows:

(i) A minimum cetane index of 40; or

(ii) A maximum aromatic content of 35 volume percent. 40 CFR Section 60.4207(b)

Owners and operators of pre-2011 model year stationary CI ICE subject to this subpart may petition the Administrator for approval to use remaining non-compliant fuel that does not meet the fuel requirements of paragraphs (a) and (b) of this section beyond the dates required for the purpose of using up existing fuel inventories. If approved, the petition will be valid for a period of up to 6 months. If additional time is needed, the owner or operator is required to submit a new petition to the Administrator. 40 CFR Section 60.4207(c)

Operate and maintain the engine according to the manufacturer's written instructions or procedures developed by the owner or operator that are approved by the engine manufacturer. Only change those settings that are permitted by the manufacturer. The permittee shall also meet the requirements of 40 CFR parts 89, 94, and 1068 as they apply to you. 40 CFR Section 60.4211(a)

Meet the definition of "Emergency stationary internal combustion engine" - any stationary internal combustion engine whose operation is limited to emergency situations and required testing and maintenance. Examples include stationary ICE used to produce power for critical networks or equipment (including power supplied to portions of a facility) when electric power from the local utility (or the normal power source, if the facility runs on its own power production) is interrupted, or stationary ICE used to pump water in the case of fire or flood, etc. Stationary CI ICE used to supply power to an electric grid or that supply power as part of a financial arrangement with another entity are not considered to be emergency engines. 40 CFR Section 60.4219

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-38

Operate the emergency engine for the purpose of maintenance checks and readiness testing provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor; or the insurance company associated with the engine. Maintenance checks and readiness testing for the emergency engine is limited to 100 hours per year. Anyone may petition the A dministrator for approval of additional hours to be used for maintenance checks and readiness testing. A petition is not required if the owner or operator maintains records indicating that the Federal State, or local standards require maintenance and testing of emergency ICE beyond 100 hours per year.

There is no time limit of the use of emergency stationary ICE in emergency situations. Any operation other than emergency operation, maintenance and testing, as permitted in Section 60.4211, is prohibited. 40 CFR Section 60.4211(e)

A fter December 31, 2008, the permittee may not install a stationary CI ICE that does not meet the applicable requirements for 2007 model year engines. 40 CFR Section 60.4208(a)

MONITORING hdr

Install a non-resettable hour meter prior to startup of the engine. 40 CFR Section 60.4209(a)

PERFORMANCE TESTING hdr

If the permittee conduct performance tests, the tests must be completed in accordance with 40 CFR Section 60.4212(a) through 40 CFR Section 60.4212(d). 40 CFR Section 60.4212

Performance Test: due 180 days after achieving maximum capacity for CO emissions. Title I Condition: monitoring for CO BACT limit

COMPLIANCE DEMONSTRATION hdr
Operate and maintain the unit in accordance with the standards as required by 40 CFR Section 60.4205, according to the manufacturer's written instructions, or according to the procedures developed by the owner or operator that are approved by the engine manufacturer, for the entire life of the engine. Settings for the unit may not be changed unless permitted by the manufacturer. 40 CFR Section 60.4206 and 40 CFR Section 60.4211(a)

The permittee must demonstrate compliance by purchasing an engine certified to conform with the emission standards listed in 40 CFR Section 52.05(b) for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's specifications. 40 CFR Section 60.4211(c)

Recordkeeping - Hours of operation: The permittee shall maintain documentation on-site that the unit is to be used for emergency (including training and testing) purposes, only that qualifies under the limitation above of 100 hours per year for checks and readiness testing. (40 CFR Section 60.4211(e)). Minn. R. 7007.0800, subps. 4 and 5

Recordkeeping - Fuel Type: The permittee shall keep records of the type of fuel burned in this unit when in operation. Minn. R. 7007.0800, subp. 4 and 5

The permittee shall maintain records of the operation of the engine in emergency service that is recorded through the non-resettable hour meter. The record must include the time of operation and the reason the generator was in operation during that time. This requirement is applicable when using a generator whose model year is 2012 or later, if the emergency engine also does not meet the standards for non-emergency engines for the 2012 model. 40 CFR Section 60.4214(b)

40 CFR Part 63, Subp. ZZZZ hdr
Initial Notification: Submit an initial notification to the administrator as required by 40 CFR Section 63.9 within 120 days of initial startup. The initial notification shall include the following information:

(i) The name and address of the owner or operator;

(ii) The address (i.e., physical location) of the affected source;

(iii) An identification of the relevant standard, or other requirement, that is the basis of the notification and the source's compliance date;

(iv) A brief description of the nature, size, design, and method of operation of the source and an identification of the types of emission points within the affected source subject to the relevant standard and types of hazardous air pollutants emitted; and

(v) A statement of whether the affected source is a major source or an area source. 40 CFR Section 63.9(b)(2)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-39

In addition, the notification shall contain a statement that the facilities stationary RICE has no additional requirements and explain the basis of the exclusion of the unit from the requirements of 40 CFR Part 63, Subp. ZZZZ (for example, that it operates exclusively as an emergency/limited use stationary RICE or is less than 500 hp). continued from above

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-40

Subject Item: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F

Associated Items: EU 001 Power Boiler 1

What to do Why to do it The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent collection efficiency Title I Condition and Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

- the recorded opacity is outside the permitted range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the opacity to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for opacity. The owner or operator shall measure the opacity by means of a COM.

Parameter range indicating normal operation is opacity as a six-minute average less than or equal to 20 percent opacity. 40 CFR Section 64.3(b) or (d) 40 CFR Section 64.6(c)(1)(i) 40 CFR Section 64.6)c)(1)(ii) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under Section 64.7 and Section 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-41

Subject Item: CE 002 Fabric Filter - High Temperature, i.e., T>250 Degrees F

Associated Items: EU 002 Power Boiler 2

What to do Why to do it The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent collection efficiency Title I Condition and Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

- the recorded opacity is outside the permitted operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the opacity to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for opacity. The owner or operator shall measure the opacity by means of a COM.

Parameter range indicating normal operation is opacity as a six-minute average less than or equal to 20 percent opacity. 40 CFR Section 64.3(b) or (d) 40 CFR Section 64.6(c)(1)(i) 40 CFR Section 64.6)c)(1)(ii) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under Section 64.7 and Section 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-42

Subject Item: CE 003 Alkaline Fly Ash Scrubbing

What to do Why to do it Opacity monitoring alternative - monitor the following operating parameters for CE003: 1)prequench slurry flow; 2)prequench slurry pressure; 3)high pressure slurry flow; 4)high pressure slurry pressure.

These requirements apply until the modification of Boiler 3 and its pollution control equipment stream. Minn. R. 7007.0800, subp. 4

Operate CE003 wet scrubber in accordance with the following operating parameters, in order to determine compliance with the opacity limit under Minn. R. 7011.0510, subp. 2: a. Prequench slurry flow >4592 gpm Prequench slurry pressure >32 psig b. High pressure slurry flow >4536 gpm High pressure slurry pressure >158 psig Minn. R. 7007.0800, subp. 2

Record once each hour of operation of EU003 for CE003: 1)prequench slurry flow rate; 2)prequench slurry pressure; 3)high pressure slurry flow rate; 4)high pressure slurry pressure. Minn. R. 7007.0800, subp. 5

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under Section 64.7 and Section 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-43

Subject Item: CE 004 Venturi Scrubber

Associated Items: EU 004 Power Boiler 4

What to do Why to do it
A minimum of one venturi slurry pump for each particulate scrubber module in service shall be operated at all times during the operation of EU004. Title 1 Condition: monitoring for the particulate matter emission limit set under 40 CFR Section 52.21 and 40 CFR Section 60.42(a)(1)
COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for opacity. The owner or operator shall measure the opacity by means of a COM.

Parameter range indicating normal operation is opacity as a six-minute average less than or equal to 20 percent opacity. 40 CFR Section 64.3(b) or (d) 40 CFR Section 64.6(c)(1)(i) 40 CFR Section 64.6)c)(1)(ii) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under Section 64.7 and Section 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-44

Subject Item: CE 005 Electrostatic Precipitator - High Efficiency

Associated Items: EU 004 Power Boiler 4

What to do Why to do it When bypass reheat is required to maintain compliance with the minimum flue gas exit temperature specified under SV004 in this permit, a portion of the total flue gas from EU004 may bypass the particulate matter emissions scrubber (CE004) and sulfur dioxide absorber (CE006), and be treated by a minimum of one unit of CE005 (electrostatic precipitator). When required to operate, CE005 shall not be operated with more than three of the bus-sections de-energized.

When bypass reheat is not required to maintain compliance with the minimum flue gas exit temperature, all of the EU004 flue gas shall be treated by the particulate matter emissions scrubber (CE004) and sulfur dioxide absorber (CE006). After closing the inlet and outlet dampers to CE005, the Permittee may de-energize CE005. Title 1 Condition: To ensure compliance with the particulate matter emission limit set under 40 CFR Section 52.21 and 40 CFR Section 60.42(a)(1)

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for opacity. The owner or operator shall measure the opacity by means of a COM.

Parameter range indicating normal operation is opacity as a six-minute average less than or equal to 20 percent opacity 40 CFR Section 64.3(b) or (d) 40 CFR Section 64.6(c)(1)(i) 40 CFR Section 64.6)c)(1)(ii) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under Section 64.7 and Section 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-45

Subject Item: CE 021 Fabric Filter - High Temperature, i.e., T>250 Degrees F

Associated Items: EU 003 Power Boiler 3

What to do Why to do it The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent collection efficiency Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

- the recorded opacity is outside the permitted range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the opacity to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for opacity. The owner or operator shall measure the opacity by means of a COM.

Parameter range indicating normal operation is opacity as a six-minute average less than or equal to 20 percent opacity.

These requirements apply upon return of Unit 3 to regular operation. 40 CFR Section 64.3(b) or (d) 40 CFR Section 64.6(c)(1)(i) 40 CFR Section 64.6)c)(1)(ii) Minn. R. 7017.0200

A n excursion or exceedance from the specified parameter range occurs when:

1. the measured pressure drop (observed once per operating day) deviates from the specified minimum or maximum by 0.1 inch WC or more. 40 CFR Section 64.6(c)(2)

The owner or operator shall conduct the monitoring required under this part upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintaining necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data, monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

The owner or operator shall report exceedances or excursions under 64.7 and 64.8 when the exceedance or excursion are greater than the limit and averaging period with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-46

Subject Item: FS 004 Unpaved Roads

What to do Why to do it
OPERATING CONDITIONS

These requirements apply after 4/1/2007. hdr

Fugitive Dust Control - EU003 dry fly ash haul roads:

- apply at least 3 gallons for each 100 square feet every 24 hours, - a rainfall of at least 0.1 inch during the previous 24 hours shall substitute for one water application, - if the road cannot be watered because the ambient air temperature is less than 35 degrees F or if conditions due to weather, in combination with the application of water, could create hazardous driving conditions, then watering shall be postponed and accomplished as soon as the conditions preventing water application have abated, - water application is not required on days when there is no vehicle traffic, and - following any day when water is not applied based on the absence of traffic, water shall be applied within 3 hours of commencement of vehicle traffic, unless another criterion for not watering is met. Minn. R. 7011.0150

RECORDKEEPING hdr

Maintain daily records of:

- whether there was 0.1 inch or more of rainfall in the last 24 hours, - temperature, - if conditions exist where watering would create hazardous driving, - dates of watering and areas watered, and - amounts of water applied. Minn. R. 7007.0800, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-47

Subject Item: FS 007 Paved Roads

What to do Why to do it OPERATING REQUIREMENTS

These requirements apply after 4/1/2007. hdr

Under dry pavement conditions, if the temperature is less than 35 degrees, or if conditions due to weather in combination with the application of water, could create hazardous driving conditions, paved plant roads shall be swept weekly. Sweeping is not required if the pavement is snow or ice covered.

Under dry pavement conditions, if the temperature is greater than 35 degrees, and conditions due to weather in combination with the application of water will not create hazardous driving conditions, paved plant roads shall be swept and flushed weekly. Title I Condition: to avoid major modification classification under 40 CFR Section 52.21 and Minn. R. 7007.3000

RECORDKEEPING hdr

Maintain daily records of: - whether and which areas are snow and ice covered, - whether and which areas are dry, - dates of sweeping and areas swept, - dates of flushing and areas flushed, and - amounts of water applied when flushing. Minn. R. 7007.0800, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-48

Subject Item: MR 002 Blr 1, 2, and 3 SO2

Associated Items: EU 001 Power Boiler 1

EU 002 Power Boiler 2

EU 003 Power Boiler 3

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar half-year following CEMS Relative Accuracy Test Audit (RATA) in which a CEMs RATA was conducted for MR002. Minn. R. 7017.1180, subp. 3

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test (Acid Rain Program), if performed. Minn. R. 7007.0800, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-49

Subject Item: MR 004 Blr 1 and 2 NOx

Associated Items: EU 001 Power Boiler 1

EU 002 Power Boiler 2

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar half-year following CEMS Relative Accuracy Test Audit (RATA) in which a CEMs RATA was conducted for MR002. Minn. R. 7017.1180, subp. 3

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test (Acid Rain Program), if performed. Minn. R. 7007.0800, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-50

Subject Item: MR 007 Blr 4 SO2

Associated Items: CM 002 Boiler 4: 1.2 lbs SO2/mmBtu, EU004, 1-hr ave.

EU 004 Power Boiler 4

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (Additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test for MR007, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, Section 2.3.1, Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, Section 2.2.1 & Section 2.2.2; Minn. R. 7017.1020

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-51

Subject Item: MR 008 Blr 4 NOx

Associated Items: CM 003 Boiler 4: 0.7 lbs NOx/mmBtu, EU004, 3-hr ave.

EU 004 Power Boiler 4

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (Additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test for Monitor 008, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, Section 2.3.1, Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, Section 2.2.1 & Section 2.2.2; Minn. R. 7017.1020

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-52

Subject Item: MR 016 Blr 3 NOx

Associated Items: EU 003 Power Boiler 3

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar half-year following CEMS Relative Accuracy Test Audit (RATA) in which a CEMs RATA was conducted for MR002. Minn. R. 7017.1180, subp. 3

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test (Acid Rain Program), if performed. Minn. R. 7007.0800, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-53

Subject Item: MR 020 Blr 1 Opacity

Associated Items: CM 004 Boiler 1: 20% Opacity, EU001, 6-min ave.

EU 001 Power Boiler 1
GP 002 Opacity Monitors

What to do Why to do it CONTINUOUS OPACITY MONITORING SYSTEMS (COMS) Requirements (Additional requirements are located under the associated GP subject item) hdr

COMS Calibration Error Audit: due before end of each calendar half-year starting 03/28/2007 for MR020. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-54

Subject Item: MR 021 Blr 2 Opacity

Associated Items: CM 005 Boiler 2: 20% Opacity, EU002, 6-min ave.

EU 002 Power Boiler 2
GP 002 Opacity Monitors

What to do Why to do it CONTINUOUS OPACITY MONITORING SYSTEMS (COMS) Requirements (Additional requirements are located under the associated GP subject item and in Table B.) hdr

COMS Calibration Error Audit: due before end of each calendar half-year starting 03/28/2007 for MR021. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-55

Subject Item: MR 024 Boiler 3 CO

Associated Items: EU 003 Power Boiler 3

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (Additional requirements are located in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test for MR024. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section 5.1.1. Minn. R. 7017.1170, subp. 5

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Minn. R. 7017.1090

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-56

Subject Item: MR 025 Blr 3 Mercury

Associated Items: EU 003 Power Boiler 3
GP 006 Boilers 3 and 4 Mercury Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements: (Additional requirements are located under the Subject Item EU 003 and in Table B.) hdr

CEMS QA/QC: The owner or operator shall meet the applicable QA/QC requirements in 40 CFR Section 75.80(e) or as approved by the MPCA. Minn. Stat. 216B.681

CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs may be conducted using an alternate test method as approved by the MPCA. 40 CFR Section 75.80(e); Minn. R. 7017.1170, subp. 5

Recordkeeping and Recording: Follow the provisions listed under 40 CFR Section 75.84. This requirement is effective beginning January 1, 2009. Minn. Stat. 216B.681

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-57

Subject Item: MR 026 Blr 4 Mercury

Associated Items: EU 004 Power Boiler 4
GP 006 Boilers 3 and 4 Mercury Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (Additional requirements are found under the Subject Item EU 004 and in Table B) hdr

CEMS QA/QC: The owner or operator shall meet the applicable QA/QC requirements in 40 CFR Section 75.80(e) or as approved by the MPCA. Minn. Stat. 216B.681

CEMS Relative Accuracy Test Audit (RATA): due before end of each year starting 03/28/2007 A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs may be conducted using an alternative test method as approved by the MPCA. 40 CFR Section 75.80(e); Minn. R. 7017.1170, subp. 5

Recordkeeping and Recording: Follow the provisions listed under 40 CFR Section 75.84. This requirement is effective beginning January 1, 2009. Minn. Stat. 216B.681

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-58

Subject Item: MR 027 Boiler 3 Opacity

Associated Items: EU 003 Power Boiler 3
GP 002 Opacity Monitors

What to do Why to do it CONTINUOUS OPACITY MONITORING SYSTEMS (COMS) Requirements (Additional requirements are located under the associated GP subject item and in Table B.) hdr

COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test for MR027. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

REQUIREMENTS FOR INSTALLATION OF MR027, BOILER 3 FOR OPACITY. hdr
COMS Certification Test Pretest Meeting: due 7 days before COMS Certification Test. Minn. R. 7017.1060, subp. 3

COMS Certification Test: due 60 days after achieving maximum capacity. Minn. R. 7017.1050, subp.1
COMS Certification Test Report: due 45 days after COMS Certification Test. Minn. R. 7017.1080, subp. 1, 2 & 4
COMS Certification Test Report - Microfiche or CD Copy: due 105 days after COMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-59

Subject Item: MR 028 Blr 1 SO2

Associated Items: CM 009 Boilers 1, 2 & 3: SO2, 1-hr ave.

EU 001 Power Boiler 1

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-60

Subject Item: MR 029 Blr 1 NOx

Associated Items: CM 010 Boilers 1 & 2: NOx Title IV

EU 001 Power Boiler 1

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-61

Subject Item: MR 032 Blr 2 SO2

Associated Items: CM 009 Boilers 1, 2 & 3: SO2, 1-hr ave.

EU 002 Power Boiler 2

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-62

Subject Item: MR 033 Blr 2 NOx

Associated Items: CM 010 Boilers 1 & 2: NOx Title IV

EU 002 Power Boiler 2

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-63

Subject Item: MR 036 Blr 3 SO2

Associated Items: CM 009 Boilers 1, 2 & 3: SO2, 1-hr ave.

EU 003 Power Boiler 3

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-64

Subject Item: MR 037 Blr 3 NOx

Associated Items: CM 008 Boiler 3, Title IV NOx

EU 003 Power Boiler 3

GP 003 NOx and SO2 Monitors

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements (additional requirements are located under the associated GP subject item and in Table B.) hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

CEM Certification Test: due 60 days after achieving normal operation but not later than 180 days after initial startup or within 90 days after the due date of the first excess emissions report, whichever is more stringent. Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. Minn. R. 7017.1080, subp. 1, 2, & 4
CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test. Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days after CEMS Certification Test. Minn. R. 7017.1080, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 08/12/09
Minnesota Power Inc - Boswell Energy Ctr

06100004 - 004 Facility Name:

Permit Number: A-65

Subject Item: MR 040 Blr 4 Opacity

Associated Items: EU 004 Power Boiler 4
GP 002 Opacity Monitors

What to do Why to do it CONTINUOUS OPACITY MONITORING SYSTEMS (COMS) Requirements (Additional requirements are located under the associated GP subject item and in Table B.) hdr

COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test for MR040. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

## TABLE B: SUBMITTALS
Facility Name: Minnesota Power Inc - Boswell Energy Ctr

Permit Number: 06100004 - 004 08/12/09 B-1

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by part s 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separatel y list one-time only and recurrent submittal requirements.

## TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS
Facility Name: Minnesota Power Inc - Boswell Energy Ctr

Permit Number: 06100004 - 004 08/12/09 B-2

What to send When to send Portion of Facility Affected
A pplication for Permit Reissuance due 180 days before expiration of Existing Permit Total Facility

COMS Certification Test Notification due 30 days before COMS Certification Test for MR027, Boiler 3 Opacity. MR027

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup after modification of Boiler 3 and its pollution control equipment stream. EU003

Plans and Specifications due before 07/01/2011 for mercury removal. The plan shall contain the information specified in Minn. Stat. 216B.682, subd. 3. EU004

Testing Frequency Plan due 60 days after Initial Performance Test for Hydrogen Fluoride emissions. EU003

Testing Frequency Plan due 60 days after Initial Performance Test for Lead emissions. EU003

Testing Frequency Plan due 60 days after Initial Performance Test for PM and PM10 emissions. EU003

## TABLE B: RECURRENT SUBMITTALS
Facility Name: Minnesota Power Inc - Boswell Energy Ctr

Permit Number: 06100004 - 004 08/12/09 B-3

What to send When to send Portion of Facility Affected Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter following Initial Startup of the Monitor (Submit Deviations Reporting Form DRF-1 as amended). The EER must contain all of the information requested in 40 CFR60.7(c). The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. GP002, GP003, MR024

Linearity Test Results Summary due 30 days after end of each calendar quarter following CEM Certification Test in which a Linearity and Leak Check Test was conducted. MR028, MR029, MR032, MR033, MR036, MR037

Linearity Test Results Summary due 30 days after end of each calendar quarter following Linearity and Leak Check Test (Acid Rain Program), if performed. MR007, MR008

Quarterly Report due 30 days after end of each calendar quarter starting 01/01/2009 as referenced by 40 CFR Section 75.84(f). MR026

Quarterly Report due 30 days after end of each calendar quarter starting 01/01/2009 as required by 40 CFR Section 75.84(f). MR025

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar quarter following CEM Certification Test in which the CEMS RATA was conducted. MR028, MR029, MR032, MR033, MR036, MR037

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar quarter following CEMS Relative Accuracy Test Audit (RATA) MR025, MR026

COMS Calibration Error Audit Results Summary due 30 days after end of each calendar half-year following COMS Certification Test for MR027, Boiler 3 Opacity. MR027

COMS Calibration Error Audit Results Summary due 30 days after end of each calendar half-year following COMS Certification Test for MR040, Boiler 3 Opacity. MR040

COMS Calibration Error Audit Results Summary due 30 days after end of each calendar half-year starting 03/28/2007 for MR 020, Boiler 1 Opacity. MR020

COMS Calibration Error Audit Results Summary due 30 days after end of each calendar half-year starting 03/28/2007 for MR 021, Boiler 2 Opacity. MR021

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar half-year following CEMS Relative Accuracy Test Audit (RATA) in which the CEMs RATA was conducted for MR007, Boiler 4 SO2. MR007

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar half-year following CEMS Relative Accuracy Test Audit (RATA) in which the CEMs RATA was conducted for MR008, Boiler 4 NOx. MR008

Semiannual Deviations Report due 30 days after end of each calendar half-year starting 03/28/2007. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Total Facility

Compliance Certification due 31 days after end of each calendar year starting 03/28/2007 (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Total Facility

## TABLE B: RECURRENT SUBMITTALS
Facility Name: Minnesota Power Inc - Boswell Energy Ctr

Permit Number: 06100004 - 004 08/12/09 B-4

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar year following CEMS Relative Accuracy Test Audit (RATA) in which the CEMs RATA was conducted for MR024, Boiler 3 CO. MR024

# APPENDIX A Insignificant Activities Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

Insignificant Activities

Activity Rule Citation Applicable Regulations Grinders Minn. R. 7007.1300, s ubp. 3.D.(2) Minn. R. 7011.0715 Gasoline Tanks Minn. R. 7007.1300, subp. 3.E(1) NA Welding Equipment Minn. R. 7007.1300, subp. 3.H(4) Minn. R. 7011.0715

Sandblasting Minn. R. 7007.1300, s ubp. 4.B(2) Minn. R. 7011.0715 Coal Stockpile loading “ Minn. R. 7011.0150 Coal Stockpile, equipment traffic “ Minn. R. 7011.0150

Conveyor drop onto stockpile, reclaimer “ Minn. R. 7011.0150

Conveyor Drop onto Stockpile –Side Chute “ Minn. R. 7011.0150

Rail Car Unloading “ Minn. R. 7011.0150 Rail Car Load Out “ Minn. R. 7011.0150 Lab Hoods (4) “ Minn. R. 7011.0715 Coal Transfer Tower A “ Minn. R. 7011.0150 Coal Transfer Tower B “ Minn. R. 7011.0150 Coal Conveyer Belt C3 “ Minn. R. 7011.0150 Coal Rotary Car Dumper “ Minn. R. 7011.0150 Coal Rotary Car TP “ Minn. R. 7011.0150 Coal Transfer and Sampling House “ Minn. R. 7011.0150

Coal Storage Silo “ Minn. R. 7011.0715 Coal Tripper Transfer “ Minn. R. 7011.0715 #4 Coal Bunker “ Minn. R. 7011.0715APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004Dispersion Modeling Parameters*** N01 Itr 2; INL-INL, MN Metdata 1987 *** 17:19:28**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.11653E+03 450543.2 5234354.5 392.6 192.44 361.48 12.64 8.84 YES NO NOBEC_SV04 0 0.25749E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.63000E-01 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.60480E+01 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.60000E-02 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS ***** CONC OF NOX IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 59.05281 AT ( 450572.66, 5234629.00, 392.04, 392.04, 0.00) DC*** N04 Itr 2; INL-INL, MN Metdata 1987 *** 18:49:21**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.29590E+02 450543.2 5234354.5 392.6 192.44 329.26 8.50 8.84 YES NO NOAPPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004BEC_SV04 0 0.25749E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.63000E-01 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.60480E+01 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.60000E-02 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS ***** CONC OF NOX IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 59.05276 AT ( 450572.66, 5234629.00, 392.04, 392.04, 0.00) DC*** P01 Itr 2; INL-INL, MN Metdata 1990 *** 14:21:08***MODELOPTs: PAGE 2CONC DFAULT ELEV MULTYR*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.33695E+02 450543.2 5234354.5 392.6 192.44 361.48 12.64 8.84 YES NO NOBEC_SV04 0 0.64372E+02 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.78000E-01 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.94000E-01 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV15 0 0.27000E-01 450581.8 5234460.0 394.4 17.98 294.26 0.00 0.15 YES NO NOBEC_SV16 0 0.43000E-01 450296.8 5234813.5 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV17 0 0.15000E-01 450303.2 5234810.0 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV18 0 0.12000E-01 450298.0 5234808.0 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV20 0 0.18000E-01 450620.7 5234623.5 394.4 17.22 294.26 0.00 1.23 YES NO NOBEC_SV21 0 0.18000E-01 450617.9 5234627.0 394.4 17.22 294.26 0.00 1.23 YES NO NOBEC_SV22 0 0.80000E-02 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NOBEC_SV23 0 0.25200E+00 450736.8 5234139.0 397.5 6.40 294.26 46.04 1.42 YES NO NOAPPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004*** THE SUMMARY OF MAXIMUM PERIOD ( 8784 HRS) RESULTS ***** CONC OF OTHER IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 7.50431 AT ( 450543.22, 5234704.50, 391.86, 391.86, 0.00) DC*** THE SUMMARY OF HIGHEST 24-HR RESULTS ***** CONC OF OTHER IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 61.66373 ON 89112024: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 2ND HIGH VALUE IS 56.72338 ON 90011124: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 3RD HIGH VALUE IS 52.64199c ON 86011224: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 4TH HIGH VALUE IS 47.35564c ON 86011224: AT ( 450677.31, 5233790.50, 395.00, 396.24, 0.00) DCHIGH 5TH HIGH VALUE IS 34.63295 ON 90041624: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 6TH HIGH VALUE IS 30.75789 ON 89092224: AT ( 450657.31, 5233790.50, 396.03, 396.03, 0.00) DC*** P12 Itr 2; INL-INL, MN Metdata 1990 *** 02:18:27***MODELOPTs: PAGE 2CONC DFAULT ELEV MULTYR*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV01 0 0.47250E+01 450572.1 5234322.5 394.8 76.20 394.26 10.57 2.90 YES NO NOBEC_SV03 0 0.73980E+01 450543.2 5234354.5 392.6 192.44 305.37 4.25 8.84 YES NO NOBEC_SV04 0 0.32186E+02 450653.8 5234624.5 394.6 170.31 330.37 17.92 6.10 YES NO NOAPPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004BEC_SV15 0 0.27000E-01 450581.8 5234460.0 394.4 17.98 294.26 0.00 0.15 YES NO NOBEC_SV16 0 0.43000E-01 450296.8 5234813.5 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV17 0 0.15000E-01 450303.2 5234810.0 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV18 0 0.12000E-01 450298.0 5234808.0 396.2 46.33 294.26 0.00 0.15 YES NO NOBEC_SV20 0 0.18000E-01 450620.7 5234623.5 394.4 17.22 294.26 0.00 1.23 YES NO NOBEC_SV21 0 0.18000E-01 450617.9 5234627.0 394.4 17.22 294.26 0.00 1.23 YES NO NOBEC_SV23 0 0.25200E+00 450736.8 5234139.0 397.5 6.40 294.26 46.04 1.42 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8784 HRS) RESULTS ***** CONC OF OTHER IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 7.54244 AT ( 450543.22, 5234704.50, 391.86, 391.86, 0.00) DC*** THE SUMMARY OF HIGHEST 24-HR RESULTS ***** CONC OF OTHER IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 62.38565 ON 89112024: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 2ND HIGH VALUE IS 56.71721 ON 90011124: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 3RD HIGH VALUE IS 54.43631c ON 86011224: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 4TH HIGH VALUE IS 49.72771 ON 89050524: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 5TH HIGH VALUE IS 34.65719 ON 90041624: AT ( 450687.31, 5233790.50, 394.96, 394.96, 0.00) DCHIGH 6TH HIGH VALUE IS 31.19517 ON 89092224: AT ( 450667.31, 5233790.50, 395.46, 395.46, 0.00) DC*** S01 Annual Itr 2; INL-INL, MN Metdata 1987 *** 20:19:10**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.79403E+03 450543.2 5234354.5 392.6 192.44 361.48 12.64 8.84 YES NO NOBEC_SV04 0 0.21243E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.70000E-02 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.94500E+00 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.20000E-02 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 9.22156 AT ( 450572.66, 5234629.00, 392.04, 392.04, 0.00) DC*** S01 Short-term Itr 2; INL-INL, MN Metdata 1989 *** 22:23:50**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.24469E+04 450543.2 5234354.5 392.6 192.44 361.48 12.64 8.84 YES NO NOBEC_SV04 0 0.77246E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.12600E+00 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.94500E+00 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.35000E-01 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF HIGHEST 1-HR RESULTS ***APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 796.42310 ON 89032314: AT ( 449175.12, 5238113.50, 392.89, 392.89, 0.00) DCHIGH 2ND HIGH VALUE IS 548.07581 ON 89032314: AT ( 449935.44, 5237801.50, 392.58, 392.58, 0.00) DC*** THE SUMMARY OF HIGHEST 3-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 456.37442 ON 89071812: AT ( 450334.84, 5233172.50, 390.14, 390.14, 0.00) DCHIGH 2ND HIGH VALUE IS 424.45447 ON 89071412: AT ( 450334.84, 5233172.50, 390.14, 390.14, 0.00) DC*** THE SUMMARY OF HIGHEST 24-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 179.11818c ON 87070824: AT ( 450300.12, 5232976.00, 390.40, 390.40, 0.00) DCHIGH 2ND HIGH VALUE IS 157.92535 ON 87071224: AT ( 450230.66, 5232582.00, 390.14, 390.14, 0.00) DC*** S02 Annual Itr 2; INL-INL, MN Metdata 1990 *** 23:25:58**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BYAPPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.59552E+03 450543.2 5234354.5 392.6 192.44 355.37 9.48 8.84 YES NO NOBEC_SV04 0 0.15932E+03 450653.8 5234624.5 394.6 170.31 338.71 26.89 6.10 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 3.70379 AT ( 452275.28, 5233354.50, 388.01, 388.01, 0.00) DC*** S02 Short-term Itr 2; INL-INL, MN Metdata 1989 *** 23:50:43**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.18352E+04 450543.2 5234354.5 392.6 192.44 355.37 9.48 8.84 YES NO NOBEC_SV04 0 0.57935E+03 450653.8 5234624.5 394.6 170.31 338.71 26.89 6.10 YES NO NO*** THE SUMMARY OF HIGHEST 1-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 725.31946 ON 89032314: AT ( 449346.16, 5237643.50, 392.58, 392.58, 0.00) DCHIGH 2ND HIGH VALUE IS 468.49081 ON 89032713: AT ( 450022.28, 5237309.00, 392.28, 392.28, 0.00) DC*** THE SUMMARY OF HIGHEST 3-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 420.11865 ON 89072012: AT ( 450751.59, 5233172.50, 388.01, 388.01, 0.00) DCHIGH 2ND HIGH VALUE IS 387.68100 ON 89071412: AT ( 450334.84, 5233172.50, 390.14, 390.14, 0.00) DC*** THE SUMMARY OF HIGHEST 24-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 163.01523c ON 87070724: AT ( 450543.22, 5232954.50, 389.84, 389.84, 0.00) DCHIGH 2ND HIGH VALUE IS 139.78828c ON 87082724: AT ( 450334.84, 5233172.50, 390.14, 390.14, 0.00) DC*** S04 Annual Itr 2; INL-INL, MN Metdata 1987 *** 00:21:47**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.38045E+02 450543.2 5234354.5 392.6 192.44 329.26 8.50 8.84 YES NO NOBEC_SV04 0 0.21243E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.70000E-02 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.94500E+00 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.20000E-02 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -ALL 1ST HIGHEST VALUE IS 9.22035 AT ( 450572.66, 5234629.00, 392.04, 392.04, 0.00) DC*** S04 Short-term Itr 2; INL-INL, MN Metdata 1987 *** 01:51:37**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.12555E+04 450543.2 5234354.5 392.6 192.44 329.26 8.50 8.84 YES NO NOBEC_SV04 0 0.77246E+03 450653.8 5234624.5 394.6 170.31 343.15 35.85 6.10 YES NO NOBEC_SV09 0 0.12600E+00 450631.3 5234411.0 396.2 13.72 699.82 20.21 0.24 YES NO NOBEC_SV10 0 0.94500E+00 450683.1 5234583.0 395.4 8.23 699.82 8.80 0.64 YES NO NOBEC_SV22 0 0.35000E-01 450555.3 5234413.5 394.3 9.14 847.04 10.49 0.20 YES NO NO*** THE SUMMARY OF HIGHEST 1-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 688.04608 ON 87112214: AT ( 450543.22, 5237354.50, 392.88, 392.88, 0.00) DCHIGH 2ND HIGH VALUE IS 427.86185 ON 87072815: AT ( 449943.22, 5233315.50, 388.01, 388.01, 0.00) DC*** THE SUMMARY OF HIGHEST 3-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --APPENDIX BDispersion Modeling ParametersMinnesota Power - Boswell Energy CenterPermit Number: 06100004-004ALL HIGH 1ST HIGH VALUE IS 398.49915 ON 89072012: AT ( 450716.88, 5233369.50, 388.01, 388.01, 0.00) DCHIGH 2ND HIGH VALUE IS 363.01028 ON 89071412: AT ( 450369.56, 5233369.50, 388.01, 388.01, 0.00) DC*** THE SUMMARY OF HIGHEST 24-HR RESULTS ***** CONC OF SO2 IN MICROGRAMS/M**3 **DATE NETWORKGROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --ALL HIGH 1ST HIGH VALUE IS 155.74730c ON 87070724: AT ( 450543.22, 5232954.50, 389.84, 389.84, 0.00) DCHIGH 2ND HIGH VALUE IS 132.83893c ON 87082724: AT ( 450334.84, 5233172.50, 390.14, 390.14, 0.00) DC*** AERMOD - VERSION 07026 *** *** 0959-20 MN Power - Boswell Energy Center *** 08/14/08*** CO AERMOD Modeling; INL-INL, MN Metdata 1986 *** 16:34:23**MODELOPTs: PAGE 2CONC DFAULT ELEV*** POINT SOURCE DATA ***NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATESOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALARID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --BEC_SV03 0 0.63408E+03 450543.2 5234354.5 392.6 192.44 329.26 8.50 8.84 YES NO NOBEC_SV22 0 0.25000E+00 450519.0 5234415.0 394.3 9.14 772.59 22.92 0.25 YES NO NO

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004


# Phase II NOx Compliance Plan

For more information, see instructions and refer to 40 CFR 76.9

This submission is: New ( Renewal ) Revised

Step 1 Indicate plant name, State, and ORIS code from NADB, if applicable Clay Boswell

Plant Name MN

State 1893

ORIS Code

Step 2 Identify each affected Group 1 and Group 2 boiler using the boiler ID# from NADB, if applicable. Indicate boiler type: “CB” for cell bur ner, “CY” for cyclone, “DBW” for dry botton wall-fired, “T” for tangetially fired, “V” for vert ically fired, and “WB” for wet bottom. Indicate the compliance option selected for each unit

ID# 1 ID# 2 ID# 3 ID# 4 ID# ID#

DBW

Type DBW

Type T

Type T

Type Type Type

( a) Standard annual average emission limitation of 0.50 lb/mmBtu (for Phase I dry bottom wall-fired boilers) (b) Standard annual average emission limitation of 0.45 lb/mmBtu (for Phase I tangentially fired boilers) (c) EPA-approved early election plan under 40 CFR 76.8 through 12/31/07 (also indicate above emission limit specified in plan) (d) Standard annual average emission limitation of 0.46 lb/mmBtu (for Phase II dry X

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

bottom wall-fired boilers) (e) Standard annual average emission limitation of 0.40 lb/mmBtu (for Phase II tangentially fired boilers) (f) Standard annual average emission limitation of 0.68 lb/mmBtu (for cell burner boilers) (g) Standard annual average emission limitation of 0.86 lb/mmBtu (for cyclone boilers) (h) Standard annual average emission limitation of 0.80 lb/mmBtu (for vertically fired boilers) (i) Standard annual average emission limitation of 0.84 lb/mmBtu (for wet bottom boilers) (j) NOx Averaging Plan (include NOx Averaging form) X X X X

(k) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(A) (check the standard emission limitation box above for most stringent limitation applicable to any unit utilizing stack (l) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(B) with NOx Averaging (check the NOx Averaging Plan box and include NOx Averaging form) X X

(m) EPA-approved

common stack apportionment method pursuant to 40 CFR 75.17 (a)(2)(i)(C), (a)(2)(iii)(B), or

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

(b)(2) (n) AEL (include Phase II AEL Demonstration Period, Final AEL Petition, or AEL Renewal form as appropriate) (o) Petition for AEL demonstration period or final AEL under review by U.S. EPA or demonstration period ongoing (p) Repowering extension plan approved or under review

Standard Requirements

General. This source is subject to the standard requirements in 40 CFR 72.9 (consistent with 40 CFR 76.8(e)(1)(i)). These requirements are listed in th is source's Acid Rain Permit.

Special Provisions for Early Election Units

Nitrogen Oxides. A unit that is governed by an approved early election plan shall be s ubject to an emissions limitation for NO x as provided under 40 CFR 76.8(a)(2) except as provided under 40 CFR 76.8(e)(3)(iii).

Liability. The owners and operators of a unit governed by an approved early election plan shall be liable for any violation of the plan or 40 CFR 76.8 at that unit. T he owners and operators shall be liable, beginning January 1, 2000, for fulfilling the obligations specified in 40 CFR Part 77.

Termination. An approved early election plan shall be in effe ct only until the earlier of January 1, 2008 or January 1 of the calendar year for which a termination of the pl an takes effect. If the designated representative of the unit under an approved early election plan fails to demonstrate compliance with the applicable emissions limitation under 40 CFR 76.5 for any year during the period beginning J anuary 1 of the first year the early election takes effect and ending December 31, 2007, the permitting authority will terminate the plan. The termination will take effect beginning January 1 of the year after the year for wh ich there is a failure to demonstrate compliance, and the designated representative may not submit a new early el ection plan. The designated r epresentative of the unit under an approved early election plan may terminate the pl an any year prior to 2008 but may not submit a new early election plan. In order to terminate the plan, the designated representative must submit a notice under 40 CFR 72.40(d) by January 1 of the year for which the term ination is to take effec t. If an early election plan is terminated any year prior to 2000, the unit shall meet, begi nning January 1, 2000, the applicabl e emissions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7. If an early election plan is terminated on or after 2000, the unit shall meet, beginning on the effective date of the termination, the applicable em issions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7.

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004 

# Phase II NOx Averaging Plan

For more information, see instructions and refer to 40 CFR 76.11

This submission is: New Revised

Step 1

Identify the units participating in this averagi ng plan by plant name, State, and boiler ID# from NADB. In column (a), fill in each unit’s applicab le emission limitation from 40 CFR 76.5, 76.6, or 76.7. In column (b), assign an alternative contemporaneous annual emissions limitation in lb/mmBtu to each unit. In column (c), assign an annual heat input limitation in mmBtu to each unit. Continue to page 3 if necessary.

(b) (c) Alt. Annual (a) Contemp. Heat Emission Emission Input Plant Name State ID# Limitation Limitation Limit Cla y Boswell MN 1 0.46 0.45 3,500,000 Cla y Boswell MN 2 0.46 0.45 3,500,000 Cla y Boswell MN 3 0.40 0.39 19,000,000 Cla y Boswell MN 4 0.40 0.35 33,000,000

S y l Laskin MN 1 0.40 0.50 4,600,000 S y l Laskin MN 2 0.40 0.50 4,600,000 Taconite Harbor MN 1 0.40 0.45 5,600,000 Taconite Harbor MN 2 0.40 0.45 5,600,000 Taconite Harbor MN 3 0.40 0.45 5,600,000

Step 2

Use the formula to enter the Btu-weighted annual em ission rate averaged over the units if they are

operated in accordance with the proposed averaging plan and the Btu-weighted annual averge emission rate for the same units if they are operate d in compliance with 40 CFR 76.5, 76.6, or 76.7. The former must be less than or equal to the latter. Btu-weighted annual emission rate Btu-weighted annual average averaged over the units if they are emission rate for same units operated in accordance with the operated in compliance with proposed averaging plan 40 CFR 76.5, 76.6, or 76.7 X

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

n n 

# Σ (R Li 

## x 

# HI i 

# ) Σ [R li 

# x 

# HI i 

# ]

i=l i=l

________________ <

__________________ n n 

# Σ HI i 

# Σ HI i 

# i=l i=l

Where, R Li 

# = Alternative contemporaneous annual emission limitation unit i, in lb/mmBtu, as specified in column (b) of Step 1: R li 

# = Applicable emission limitation for unit i, in lb/mmBtu, as specified in column (a) of Step 1:

HI i 

# = Annual heat input for unit i, in mmBtu, as specified in column (c) of Step 1: n = Number of units in the averaging plan

This plan is effective for calendar year _2008_ through calendar year _2011_ unless notification to term inate the plan is given.

Treat this plan as identical plans, eac h effective for one calendar year for the following calendar years ______, ______, ______, ______, and ______ unless notif ication to terminate one or more of these plans is given.

Special Provisions 

## 0.40 0.40

X

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

Emission Limitations

Each affected unit in an approved averaging plan is in comp liance with the Acid Rain emission limitation for NO x 

### under the plan only if the fo llowing requirements are met: (i) For each unit, the unit's actual annual average emissi on rate for the calendar year, in lb/mmBtu, is less than or equal to its alternativ e contemporaneous annual emission limit ation in the averaging plan, and (a) For each unit with an alternative contem poraneous emission limitation less stringent than the applicable emission limitation in 40 CFR 76.5, 76.6, or 76.7, the actual annual heat input for the calendar year does not exceed the annual heat input limit in the averaging plan, (b) For each unit with an alternative contempor aneous emission limitation mo re stringent than the applicable emission limitation in 40 CFR 76.5, 76.6, or 76.7, the actual annual heat input for the calendar year is not less than the annual heat input limit in t he averaging plan, or (ii) If one or more of the units does not meet the requirements of (i), the des ignated represent ative shall demonstrate, in accordance with 40 CFR 76.11(d)(1)( ii)(A) and (B), that the actual Btu-weighted annual average emission rate for the units in the plan is less than or equal to the Bt u-weighted annual average rate for the same units had they each been operated, during the same period of time, in compliance with the applicable emission limitations in 40 CFR 76.5, 76.6, or 76.7. (iii) If there is a successful group showing of compliance under 40 CFR 76.11(d)(1)(ii)(A) and (B) for a calendar year, then all units in the averaging plan s hall be deemed to be in compliance for that year with their alternative contempor aneous emission limitations and annual heat input limits under (i).

Liability

The owners and operators of a unit gover ned by an approved averaging plan shall be liable for any violation of the plan or this section at that unit or any other unit in the plan, including liability for fulfilling the obligations specified i n part 77 of this chapter and se ctions 113 and 411 of the Act.

Termination

The designated representativ e may submit a notification to te rminate an approved averaging plan, in accordance with 40 CFR 72.40(d), no later than October 1 of the calendar year for which the plan is to be terminated.

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004



# Phase II Permit Application

For more information, see instruct ions and refer to 40 CFR 72.30 and 72.31

This submission is New Revised

Clay Boswell

Plant Name 

## MN

State 

## 1893

ORIS Code



## Compliance Plan

a Boiler ID# b Unit Will Hold Allowances in Accordance with 40 CFR 72.9(c)(1) c Repowering Plan d New Units

Commence Operation Date e New Units

Monitor Certification

Deadline 1 Yes no 2 Yes no 3 Yes no 4 Yes no Yes Yes Yes Yes Yes Yes Yes

Standard Requirements

Permit Requirements. 

## X

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

(1) The designated representative of each affected s ource and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (i ncluding a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental informati on that the permitting authority determines is necessary in order to review an Acid Rain permit applicat ion and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Ra in permit application or a super seding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit.

Monitoring Requirements.

(1) The owners and operators and, to the extent applicable, desi gnated representative of each affected source and each affected unit at the source shall comply with the monitori ng requirements as provided in 40 CFR parts 74, 75, and 76. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitat ions and emissions reduction requi rements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR parts 74 and 75 shall not affe ct the responsibility of the owners and operators to monitor emissions of other pollutants or other em issions characteristics at the unit under other applicable requirements of the Act and other provisions of the operati ng permit for the source.

Sulfur Dioxide Requirements.

(1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadli ne, in the unit's compliance s ubaccount (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the previous ca lendar year from the unit; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Ra in emissions limitations for sulf ur dioxide shall constitute a s eparate violation of the Act. (3) An affected unit shall be subject to the requirement s under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline fo r monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted fr om, or transferred among Allowance Tracki ng System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply wi th the requirements under paragraph (1)(i) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Ra in Program is a limited authorizat ion to emit sulfur dioxide i n accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no pr ovision of law shall be construed to limit the authority o f the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right.

Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides.

Excess Emissions Requirements.

(1) The designated representative of an affected unit that has ex cess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall: (i) Pay without demand the penalty required, and pay upon dem and the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77.

Recordkeeping and Reporting Requirements.

(1) Unless otherwise provided, the owners and operators of the s ource and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i) The certificate of representation for the designated representative for the s ource and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period

# APPENDIX C NOx Compliance Plan Minnesota Power - Boswell Energy Center Permit Number: 06100004-004

until such documents are superseded because of the submissi on of a new certificate of representation changing the designated representative; (ii) All emissions monitoring informat ion, in accordance with 40 CFR part 75; (iii) Copies of all reports, complianc e certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Pr ogram, including those under 40 CFR part 72 subpart I and 40 CFR part 75.

Liability.

(1) Any person who knowingly viol ates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be s ubject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pur suant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any viol ation of the requirements of the Acid Rain Program that occurs prior to the date th at the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a pr ovision applicable to the designat ed representative of an affected source) shall also apply to the ow ners and operators of such source and of the affected units at the

source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a prov ision applicable to the designated representative of an affected unit) shall also apply to the ow ners and operators of such unit. Ex cept as provided under 40 CFR 72.44 (Phase II repowering extens ion plans) and 40 CFR 76.11 (NO x averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit sha ll not be liable for any violation by any other affected un it of which they are not owners or operators or the designated representative and that is loca ted at a source of which they are not owners or operators or the designated representative. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act.

Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72. 7 or 72.8 shall be construed as:

(1) Except as expressly provided in titl e IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from co mpliance with any other provision of th e Act, including the provisions of title I of the Act relating to applicable Na tional Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold; provided, that the number of a llowances held by the unit shall not affec t the source's obligation to comply wi th any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating el ectric utility rates and charges, affecting any State law rega rding such State regulation, or limiting such State regulat ion, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authorit y of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established.

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# TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 06100004-004

This technical support document is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit.

1. General Information 1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 4911 ) Minnesota Power Division of Allete, Inc. 30 West Superior Street Duluth MN, 55802 Boswell Energy Center 1210 3rd St NW Cohasset Itasca County Contact: Misty Hanson Phone: 218-328-5036

1.2. Description of the Facility

The Boswell Energy Center (facility) is a coal-fired electric utility steam generating plant. Emission units at the facility include four power boilers, emergency engine generators, and fuel, additive and ash handling equipment. The main fuel for all boilers is sub bituminous coal. They may also burn distillate oil, limited amounts of boiler cleaning agents, used oil, oily coal, oily paper-based floor dry, wastewater treatment plant sludge, and oily materials (earth substrate withpetroleum product). Emissions are controlled by baghouses, over fire air, selective NonCatalytic Reduction on Boilers 1 and 2. Low Nitrogen Oxide (NO x 

# ) burners, over fire air, selective catalytic reduction, baghouse filter a wet scrubber on Boiler 3, and a wet venturi scrubber / electrostatic precipitator, and sulfur dioxide spray towers on Boiler 4.

1.3 Description of the Activities Allowed by this Permit Action

There are three separate major amendments rolled into this permit action.

An application for a major amendment was submitted September 5, 2008. This application was submitted to revise the size of an emergency generator (EU 023) from 100 kW to 300 kW. This is known as the Generator Project within this TSD. This emergency generator unit (EGU) is part of the retrofitting project for EU003, permit No. 06100004-003 issued March 28, 2007. The EGU is to provide power for safe shutdown of pollution control equipment during power

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# outages. The original generator has not yet been installed. The original project was subject to Prevention of Significant Deterioration (PSD ) for Carbon Monoxide (CO). Because of the increase in CO emission due to the larger EGU the facility has submitted a revised PSD analysis for CO. This includes updated Best Available Control Technology (BACT) and CO air dispersion modeling. (DQ 2218)

An application for a major amendment was submitted September 15, 2008. This application is for installation of natural gas fired igniters/heat guns on all boilers; EU001, EU002, EU003, and EU004. All boilers currently have a set of oil-fired igniter/heat guns. The existing oil and new gas fired igniters/guns will not be fired simultaneously. Either oil or gas will be used at any given time on a per igniter or gun basis. The installation will include electrical switches and signals to ensure that it is not possible to fire both the oil fired and gas fired igniter/guns. A PSD analysis was conducted for CO and Volatile Organic Compounds (VOC). A facility wide natural gas usage limit will be used to avoid a significant increase in CO. (DQ 2232)

An application for a major amendment was submitted December 3, 2008. This application is for the installation of new Continuous Emissions Monitors Systems (CEMS). This would allow the facility to separately monitor the NOx, SO x, CO2, Opacity, and Air Flow for EU001, EU002, and EU003. This change does not involve any emissions increases or change to emission permit limits. (DQ 2342)

An application for an administrative amendment was received by the MPCA. This amendment was submitted to correct allowable fuel for emergency generator 1 (EU007). This amendment does not authorize any changes to the facility. (Administrative amendment, DQ 1601)

This permit amends the maximum achievable operating rates for boilers 3 and 4 (EU003, EU004). These updates stem from recent stack tests.

This permit action also incorporates multiply Reopenings initiated by the MPCA. These are the incorporated Reopenings; Certified MR 040 to replace MR 005 for monitoring opacity for EU004, Certified MR 041 to replace MR 023 for monitoring air flow for EU004, March 21, 2008 letter from Jeff Smith to Minnesota Power.

This permit also incorporates the requirements that stem from Title V modeling that was done by the permittee.

This permit also incorporates a propane fired slag shock system. This system qualifies as aninsignificant modification due to emissions. The system will be installed to target tougher-toremove slag deposits by using the percussion of a small controlled explosion to shock the deposits off of the boiler. Since the system will operate within the boiler propane has to be added to the allowable fuels list for all boilers at the facility.

1.4. Facility Emissions:

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Table 1.1 Title I Emissions Increase Summary: NOx Re duction Project, Future-Projected Actual vs. Past Actual

Future-Projected Actual Emissions Past Actual Emissions Excludable Emissions

(tons/yr) Projected Emissions Increase PSD Threshold

Units 1

& 2 Paved Road Fugitives (Units 1

& 2) Units 1 & 2 Paved Road Fugitives (Units 1 & 2) Baseline Years Increase prior to excludable Pollutant

(tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)

PM 66.0 2.9E-01 52.6 NA 2005- 2006 13.7 13.1 0.6 25

PM 10 

## 60.7 5.7E-02 48.4 NA 2005- 2006 12.4 12.0 0.4 15

PM 2.5 

## 35.1 8.6E-03 27.9 NA 2005- 2006 7.2 6.9 0.3 15

SO 2 

## 7,372.7 --- 5,126.8 --- 2005- 2006 2,245.9 2,245.9 0.0 40

NO x 

## 1,116.9 --- 2,383.9 --- 2005- 2006 -1,267.0 1,393.6 -2,660.6 40

CO 182.5 --- 144.3 --- 2005- 2006 38.2 38.2 0.0 100

VOC 21.9 --- 17.3 --- 2005- 2006 4.6 4.6 0.0 40

Lead 0.153 --- 0.12 --- 2005- 2006 3.2E-02 0.0 0.00 0.6

H 2 

## SO 4 

## 169.3 --- 117.8 --- 2005- 2006 51.6 51.6 0.0 7.0

Fluorides 54.8 --- 43.2 --- 2005- 2006 11.5 11.5 0.0 3.0

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Table 1.2 Title I Emissions Increase Summary: Ignit er/warm-up Guns Project, Future-Projected Actual vs. Past Actual

Table 1.3 Non-Title I Emissions Increase Summary: Igni ter/warm-up Guns Project, Future Potential vs. Past Potential

Future Potential Past Potential Projected Emissions Increase EAW Threshol d AERA Pollutant (tpy) (tpy) (tpy) (tpy) (tpy)
PM 5.12 5.12 0 250 100 PM10 3.56 3.56 0 250 100 PM2.5 2.39 2.39 0 250 100 NOX 982.5 982.5 0 250 100 So2 703.9 703.9 0 250 100 CO 319.5 224.29 95.21 250 100 VOC 20.9 8.98 11.92 250 100 Lead 0.0088 0.0088 0 250 100



# Table 1.4 Total Facility Potential to Emit Summary

PM tpy PM 10 

# tpy SO 2 

# tpy NO x 

# tpy CO tpy VOC tpy Single HAP

tpy All HAPs

tpy Total Facility Limited Potential Emissions pre modification 3831 2545 61501 24090 3431 180 3582 4066

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# Total Facility Limited Potential Emissions post modification 3831 2545 61501 24090 3432 180 3582 4066

Total Facility Actual Emissions (2007) 2,869 3,354 21,580 14,430 3,075 95.3 HAPs not reported in

emission inventory

Table 1.5 Facility Classifications Classification Major/Affected Source Synthetic Minor Minor

PSD X Part 70 Permit Program X Part 63 NESHAP X

2. Regulatory and/or Statutory Basis

New Source Review The facility is an existing major source under New Source Review (NSR) regulations.

The igniter/gun project does not result in a significant increase in PSD regulated pollutants. An Actual to Projected Actual PSD analysis was conducted for all pollutants. Due to type of fuels involved there is an increase in emissions rate for only CO and Volatile Organic Compounds (VOC). Refer to Technical Information section for more details.

The Emergency Generator does not result in a significant increase in PSD regulated pollutants. The original project was subject to Preventi on of Significant Deterioration (PSD) for Carbon Monoxide (CO). Because of the increase in CO emission due to the larger EGU the facility has submitted a revised PSD analysis for CO. This includes updated Best Available Control Technology (BACT) and CO air dispersion modeling. Modeling was renewed by MPCA modeling staff. There were no problems with the modeling. Refer to Technical Information section for more details.

The NOx reduction project does not result in a significant increase in PSD regulated pollutants. An Actual to Projected Actual PSD analysis wa s conducted for all pollutants. The project added an Over-Fire-Air system and a Selective Non-Catalytic Reduction system to reduce NOx emissions. The only criteria pollutants that have a potential to increase are PM, PM 10 

# , and PM 2.5 

# . This permit includes stack tests for PM and PM10 to confirm that there was not a significant increase in these pollutants. A PM2.5 stack test was not included because there is no prior stack test to compare the results to. Refer to Technical Information section for more details.

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# Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) Boiler 4 is subject to 40 CFR pt. 60, Subpart D. The proposed new emergency engine generator is subject to 40 CFR pt. 60, Subp. IIII. National Emission Standards for Hazardous Air Pollutants (NESHAP) There is a NESHAP that applies to reciprocating internal combustion engines. The new emergency engine generator is exempted from the requirements of the standard, other than initial notification requirements in 40 CFR § 63.6600. Section 63.6600 exempts emergency/limited use engines, and engines that are smaller than 500 horsepower. The new proposed engine meets these two criteria. The other existing engines on site are exempt from the standard under the same criteria. There are no other NESHAPS that apply to the facility. 40 CFR Part 63 Subpart DDDDD for a major source of HAP has been vacated. When DDDDD is promulgated it will apply to the facility. Clean Air Mercury Rule CAMR Removed mercury monitor installation requirement from EU001 and EU002. The Clean Air Mercury (CAMR) has been vacated and these monitors are required by rule. Even if the rule was still in effect the facility would not be required to install the monitors because stack tests showed that the rule would not apply to EU001 and EU002. MPCA staff recommended the removal.

Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment

• Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment

• Minn. R. 7011.0710 Standards of Performance for Pre-1969 Industrial Process Equipment

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines
Mercury Reduction Act
In May of 2006, the State of Minnesota enacted the Mercury Emissions Reduction Act of 2006 (Minn. Stat. 216B.68 to 216B.687). The Act addre sses several methods of reducing mercury emissions within the state, including reducing emissions from large electric power generating plants. Power plants that have a total net capacity in excess of 500 MW from all units at the site must develop plans and implement them at the units that are greater than 100 MW. A schedule is established in the Act that differs for dry a nd wet methods of controlling SO2. This legislation affects the two larger units at the Boswell, Units 3 and 4. The Act will eventually require the reduction of mercury at targeted units.

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# There is a requirement for wet and dry scrubbed units to prepare plans for achieving 90 percent reduction of mercury from the unit by 2014. Minn. Stat. 216B.6851, subd. 5 encourage early action for wet scrubbed units, and sets December 31, 2010 as the early action target date to achieve the 90 percent reduction for power boiler No. 3.

Clean Air Interstate Rule On July 11, 2008, the DC Circuit Court of Appeals issued an opinion pointing out several “fatal flaws” with the Clean Air Interstate Rule. In the opinion, the Court vacated the existing rule. However, the Court never issued the mandate – the vehicle that would have explicitly prevented CAIR from taking effect. EPA petitioned for rehearing, asking the Court to make substantive changes to the July opinion, and to change the remedy from vacatur to simple remand.

On December 23, 2008, the Court issued a panel opinion that changed the remedy. CAIR was remanded to EPA to be rewritten, addressing the flaws identified in the July ruling. However, the Court made no substantive changes to its opinion; EPA must therefore address all the flaws identified in July. With the remedy changing to a simple remand, the entirety of CAIR goes into effect as previously planned (including all parts that the Court identified as flawed.)

One main issue that EPA needs to address on remand is whether Minnesota should continue to be included in CAIR. The Court ruled in July that EPA did not adequately respond to claims made by Minnesota Power that data on Minnesota emissions were inaccurate, and that using better data would result in Minnesota falling below the threshold impact on a non-attainment area that was used to determine inclusion.

In a letter dated October 31, 2008, from Robert Meyers (Principal Deputy Assistant Administrator, Office of Air and Radiation) a nd Granta Nakayama (Assistant Administrator, Office of Enforcement and Compliance Assurance) to Minnesota Power’s counsel, EPA stated:

[I]t is the U.S. Environmental Protection Agency’s (EPA) intention to publish in the Federal Register a rule amending the Clean Air Interstate Rule (CAIR) to stay the effectiveness of the rule with respect to sources located in the State of Minnesota. That administrative stay will remain in effect until such time as EPA determines through a rulemaking under the Clean Ai r Act whether Minnesota should be included in the CAIR region for fine particul ate matter. EPA believes that in light of the Court’s decision, sources in Minneso ta should not be required to make any additional expenditures to comply with CAIR prior to the expiration of the administrative stay of the rule.

The Court was aware of this letter when it made its December 23, 2008 decision.

EPA’s John Mooney from the Region V Office notified the MPCA that on January 15, 2009, the USEPA Administrator signed the notice for the proposed rule to stay CAIR requirements in Minnesota until the Agency determines whether Minnesota should be in the CAIR region. On January 20, 2009, Mr. Rahm Emanuel, Assistant to the President and Chief of Staff, signed a

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# “Memorandum for the Heads of Executive Departments and Agencies” on the subject of “Regulatory Review”. In this memorandum, Mr. Emanuel directs his staff to stop sending proposed and final regulations to the Office of the Federal Register (OFR) and to withdraw proposed and final regulations from the OFR that have not been published in the Federal Register. The proposed rule to stay CAIR requirements in Minnesota has not been published in the Federal Register. Copies of the signed proposed rule to stay CAIR requirements in Minnesota and its fact sheet can be found at http://epa.gov/cair/pdfs/20090114proposal.pdf

http://epa.gov/cair/pdfs/20090114fs.pdf

Please also note that under the proposed rule to stay CAIR in Minnesota, EPA requires that as of June 30, 2009, each Minnesota source with recorded allowance allocations under the annual NOX trading program must hold an amount of allowances issued for the same year as the recorded allowances (e.g., 2009) equal to the amount of the recorded allocations. EPA also proposes that the Administrator deduct, and retire, these required allowance holdings and that no additional allowance allocations from the state annual NOx trading budget for Minnesota be recorded. Although these provisions could be amended after review by staff in President Obama’s administration, this should be an important consideration for management of recorded allowances by CAIR sources in Minnesota.

The date for submitting allowances for the 2009 annual NO X 

# program is not until early 2010; EPA should be able to promulgate a stay of the rule by that time. However, it is likely to be in covered sources best interests to continue to report emissions data quarterly as required by the CAIR rule. In addition, Minnesota may be included in the re-promulgated CAIR rule.

It must be noted that after publication, this remains a proposed rule; a stay of the rule is not official until it has gone through the notice and comment rulemaking proceedings in the Federal Register. Such public participation and rule pr omulgation process could take several months. Until that time, CAIR is officially in effect in Minnesota.

Therefore, for the time being, the permits for CA IR affected facilities have a condition at the total facility level requesting compliance with CAIR with a sunset provision linked to EPA’s future regulatory actions. The MPCA will not go as far as to issue a CAIR permit given the current prospects of the CAIR program in Minnesota.

3. Technical Information

3.1 Clean Air Mercury Rule

Removed mercury monitor installation requirement from EU001 and EU002. The Clean Air Mercury (CAMR) has been vacated and these monitors are required by rule. Even if the rule was still in effect the facility would not be required to install the monitors because stack tests showed that the rule would not apply to EU001 and EU002. Anne Jackson recommended the removal.

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# 3.2 Vendor Certification of Sulfur Content

Removed requirement to calculate SO 2 

# emissions based on vendor certification from EU001 and EU002 when on bypass to SV001. The new CEMS for SO 2 

# will be placed after the bag houses rather then in SV003, which is the main stack shared by EU001, EU002, and EU003. The location of the new CEMS systems allows for continuous tracking whether being vented through the main stack SV003 or in the bypass stack SV001.

3.3 Igniter/Heat Gun Project – Actual To Projected Actual – PSD Analysis

There was sufficient data to determine the baseline actual emissions as defined at § 52.21(b)(48)(i). Baseline actual emissions are based on fuel usage records and AP-42 emission factors. The igniter/heat guns are only used duri ng the startup period of the boilers; they are not used during normal operation of the boilers. As a result actual use is less than 1% yearly capacity of the guns/igniters. This is why the capacity of the igniter/heat guns is not included on the MMBtu/hr design capacity of the boilers. This project does not remove the fuel oil fired igniter/guns from the boilers. This project adds a parallel natural gas fired igniter/gun to each of the existing fuel oil fired igniter/gun. There will be a physical and electric lockout that allows for the use of only one of each pair at any given time. This gives the facility the flexibility to use fuel oil or natural gas based on cost. Calculation spreadsheets are found in the attachments to this TSD.

Future projected actual fuel usage rate for the igniters/guns used for this analysis is twice the past maximum rate. There are no excludable emissions included in the analysis because the natural gas capacity that has been added could not have been “accommodated” prior to the installation of the NG igniters. There is not a reasonable possibility that the increase in emissions will be significant under §52.21(r)(6)(vi). No documentation or on-going monitoring is required.

A natural gas usage limit across all boilers is used to avoid a significant increase in CO Potential to emit; this can be found under GP 004. The fuel usage limit restricts the increase of CO to 95 tpy to keep the emissions from the modification under the threshold for a mandatory Air Emissions Risk Assessment (AERA).

3.4 NOx Reduction Project Actual To Projected Actual – PSD Analysis

The Minnesota Pollution Control Agency (MPCA) has received and reviewed the Minnesota Power March 21, 2008 letter regarding planned changes at the Minnesota Power (Company) Boswell Energy Center for the reduction of nitrogen oxides (NO X 

# ) emissions from Units 1, 2, and 4. To achieve NO X 

# emissions reductions, the Company intends to install ROFA/Rota Mix over-fire air and urea injection in units 1 and 2 in late 2008 and early 2009.

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# There was sufficient data to determine the baseline actual emissions as defined at §52.21(b)(48)(i). Boilers 1 & 2 have been, and will have a high rate of utilization at the facility. There is a possibility that the increase in emissions will be significant under § 52.21(r)(6)(vi). To verify the PM 10 

# emissions assumptions made in the analysis and the calculation of PM 10 

# future actual emissions, the MPCA will add requirements for units 1 and 2 PM 10 

# performance testing and re-verification of PM 10 

# emissions changes resulting from the addition of the NO X 

# controls. The March 21, 2008 letter from Jeff Smith to Minnesota Power which outlined that the MPCA had determined that the facility could install the control equipment

Table 1.1 is a summary of the changes of emissions due to the NOx reduction project. Paved road Fugitives are due to the increased truck traffic from hauling in the NOx reducing reagents. The pollutants of concern in this analysis are all sizes of particulate emissions. . The baseline years used in this analysis are appropriate, the years 05-06 are within the look back period of five years. The calculation and use of excludable emissions is correct. The units were permitted and capable of running at a higher rate during the baseline period. The theoretical increases of PM, PM10 and PM2.5 are well below their significance thresholds of 40, 25 and 15 respectively. The emissions factors of particulates are based on best engineering estimates. To ensure that this project has not crossed a PSD significance thresholds

3.5 Maximum achievable operating rate

This permit amends the maximum achievable operating rates for boilers 3 and 4 (EU003, EU004). These updates stem from recent stack tests. Further discussions with the facility revealed that these boilers are consistently run at these updated rates. The previous rates used for PTE calculations and modeling were based on the boiler manufacturer guaranteed rate. The updated MMBtu/hr values come from coal Btu tests and throughput during a stack test. The change in rated capacity does not change what regulations and limits that the facility and boilers are subject to.

3.6 Title V Modeling: Results and discussion Modeling results showed that the facility is well under the NAAQ and MAAQ standards. The parameters used in modeling have been reviewed and deemed expectable by the permitting and modeling staff. Results are summarized in the tables below.

Minnesota Ambient Air Quality Standards ( μ g/m3): Criteria Pollutants 1-Hour 3-Hour 8-Hour 24-Hour Annual Other CO 35,000 - 10,000 - - - NOX - - - - 100 - PM2.5 - - - 35 15 - PM10 - - - 150 50 - SO2 1,300 1,300 - 365 60 - SO2 (Northern MN) - 915 - - - -

Predicted Impacts including Monitored Background Concentrations ( μ g/m3):

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# - 004 Page 11 of 21 Date: 9/18/2009 Criteria Pollutants 1-Hour 3-Hour 8-Hour 24-Hour Annual Other CO NA - NA - - - NOX - - - - 72.7 - PM2.5 - - - NA NA - PM10 - - - 60.8 25.9 - SO2 692.9 NA - 205.9 13.2 - SO2 (Northern MN) - 526.9 - - - -


# The pollutant that is closest to the standard is NOx. The permit deviates from guidance by putting NOx under Tier 2 modeling rather than Tier 1. The cutoff value is normally 75% of standard and the modeling rate in under that at 72.7%. This permit amends the maximum operating rate for boiler 3 & 4. Using these amended values would most likely push the NOx impact above 75% of the standard. There is little to no chance that remodeling using the amended MMBtu/hr would result in NAAQS violations . Moving to Tier 2 is more stringent and will require remodeling if the facility submits a major amendment that increases NOx emissions.

3.7 Revised PSD Modeling For the Larger EGU (EU 023): Results and discussion

Modeling results showed that the facility is well under the NAAQ and MAAQ standards. The parameters used in modeling have been reviewed and deemed expectable by the permitting and modeling staff. Results are summarized in the tables below.

SIL Values ( μ g/m3): Criteria Pollutants 1-Hour 3-Hour 8-Hour 24-Hour Annual Other CO 2,000 - 500 - - - NOX - - - - 1.0 - PM2.5 (option 3) - - - 1.2 0.3 - PM10 - - - 5.0 1.0 - SO2 25.0 25.0 - 5.0 1.0 - SO2 (Northern MN) - 25.0 - - - - Other

Predicted Impacts ( μ g/m3): Criteria Pollutants 1-Hour 3-Hour 8-Hour 24-Hour Annual Other CO 241.3 - 118.4 - - - NOX - - - - NA - PM2.5 - - - NA NA - PM10 - - - NA NA - SO2 NA NA - NA NA - SO2 (Northern MN) - NA - - - - Other



# PSD modeling for CO was revised because of the resizing of an emergency generator that was involved in the original analysis. The contribution of CO from the emergency generator is relatively small. EU003 was the primary contributor to the CO increase was due to pollution

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# control added to reduce NOx and SO2 emissions. The resized emergency generator does not change the result of the PSD analysis and modeling conducted for PER 003.

3.8 Calculations of Potential to Emit and Emissions Increase Analysis Attachment 1 contains detailed spreadsheets of the facility’s potential to emit and emissions summary prepared by the MPCA and the Permittee.

Attachment 2 to this TSD contains the emissions calculations related to the NOx reduction project, which installed OFA and NSCR on boilers 1 and 2 including Title I net emissions increase calculations for this modification

. This demonstrates that this modification is not a major modification for PSD. The attachment also contains the non-Title I calculations for this modification which demonstrate that the modification trigger an AERA or EAW. Attachment 3 contains the emissions calculations related to the Igniter/heat gun project on all four boilers at the facility. Title I net emissions increase calculations for this modification. This demonstrates that this modification is not a major modification for PSD. The attachment also contains the non-Title I calculations for this modification which demonstrate that the modification is not submit to an AERA or EAW.

Attachment 4 contains the emissions calculations related to the revised CO PSD analysis due to the increased size of the emergency generator EU 023 for boiler 3. 3.9 slag shock system

This permit also incorporates a propane fired slag shock system. This system qualifies as aninsignificant modification due to emissions. The system will be installed to target tougher-toremove slag deposits by using the percussion of a small controlled explosion to shock the deposits off of the boiler. Since the system will operate within the boiler propane has to be added to the allowable fuels list for all boilers at the facility. Calculations for this system can be found in attachment 7 to this TSD.

4 Periodic Monitoring In accordance with the Clean Air Act, it is the re sponsibility of the owner or operator of a facility to have sufficient knowledge of the facility to cer tify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

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# • The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere. Table 4.1 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate. Table 4.1 Periodic Monitoring

Emission Unit or Group Requirement (basis) Additional Monitoring Discussion

GP004 SO2 limits for SV001, 002, 003, and 004 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.
SV004 SV004 gas exit temperature This minimum temperature requirement is necessary to ensure adequate emissions dispersion. Measured and recorded hourly Hourly gas temperature readings ensure that the facility is operating with dispersion characteristics used for modeling analysis

EU001 PM < 0.1 lb/MMBtu based on PSD modeling 40 CFR Section 52.21(k) Monitoring, I and M, stack emission testing, and recordkeeping for fabric filter plus CAM requirements Initial performance testing has been completed. Based on the results, a test frequency of every 60 months has been established. CAM requirements ensure that the control equipment is operated and maintained properly. Opacity < 20 % with exception Minn. R. 7011.0510, subp. 2 COM The use of a Continuous Opacity Monitor ensures that opacity limit will be followed.

SO2 < 4 lb/MMBtu for solid fuel, 2 lb/MMBtu for liquid Minn. R. 7011.0510, subp. 1 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits. Federal acid rain monitoring applies. Violation of this limit is unlikely.

SO2 < 1.18 lb/mmBtu when emissions are vented through SV001 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.
NOx limits and averaging plan CEM Continuous CEMs data ensures compliance with 

# NOx Limits . Federal acid

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## Emission Unit or Group Requirement (basis) Additional Monitoring Discussion

rain monitoring applies

EU002 PM < 0.1 lb/MMBtu based on PSD modeling 40 CFR Section 52.21(k) Monitoring, I and M, stack emission testing, and recordkeeping for fabric filter plus CAM requirements Initial performance testing has been completed. Based on the results, a test frequency of every 60 months has been established. CAM requirements ensure that the control equipment is operated and maintained properly. Opacity < 20 % with exception Minn. R. 7011.0510, subp. 2 COM The use of a Continuous Opacity Monitor ensures that opacity limit will be followed.

SO2 < 4 lb/MMBtu for solid fuel, 2 lb/MMBtu for liquid Minn. R. 7011.0510, subp. 1 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits. Federal acid rain monitoring applies. Violation of this limit is unlikely.

SO2 < 1.18 lb/mmBtu when emissions are vented through SV001 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.
NOx limits and averaging plan CEM Continuous CEMs data ensures compliance with 

# NOx Limits . Federal acid rain monitoring applies

EU003 Boiler 3 prior to modificatio

ns PM < 0.6 lb/MMBtu Minn. R. 7011.0510, subp. 1 Monitoring, I and M, and recordkeeping for wet scrubber plus CAM requirements Stack test due 180 after modification is complete will set a test frequency plan that will confirm continuous compliance with this limit. CAM requirements ensure that the control equipment is operated and maintained properly. Opacity < 20% with exceptions COM The use of a Continuous Opacity Monitor ensures that opacity limit will be followed.

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## Emission Unit or Group Requirement (basis) Additional Monitoring Discussion

SO2 < 4 lb/MMBtu for solid fuel, 2 lb/MMBtu for liquid Minn. R. 7011.0510, subp. 1 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits. Federal acid rain monitoring applies. Violation of this limit is unlikely.

SO2 < 2.97 lb/MMBtu as 1-hr avg. when EU001 and EU002 are also operating and vented through SV001

Minn. R. 7009.0020 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.

NOx < 0.45 lb/MMBtu annual
avg. CEM Continuous CEMs data ensures compliance with 

# NOx Limits

. EU003 After modificatio

ns PM < 0.014 lb/MMBtu

BART Monitoring, I and M, stack performance testing, and recordkeeping for fabric filer plus CAM requirements Stack test due 180 after modification is complete will set a test frequency plan that will confirm continuous compliance with this limit. CAM requirements ensure that the control equipment is operated and maintained properly.

PM10 < 0.035 lb/mmBtu

BART Monitoring, I and M, stack performance testing and recordkeeping for fabric filer plus CAM requirements Stack test due 180 after modification is complete will set a test frequency plan that will confirm continuous compliance with this limit. CAM requirements ensure that the control equipment is operated and maintained properly.

SO2 < 0.09 lb/MMBtu

BART CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.

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## NOx < 0.07 lb/MMBtu 30 day rolling

BART CEM Continuous CEMs data ensures compliance with 

# NOx Limits

. Hydrogen fluoride < 0.0018 lb/mmBtu

Title I Condition Periodic stack emission testing Initial stack test after modification will set a test frequency that will confirm compliance with this limit.

CO < 0.15 lb/mmBtu

BACT CEM Continuous CEMs data ensures compliance with 

# CO Limits

. Lead < 0.00004 lb/mmBtu Period stack emission testing, operation and monitoring of control equipment Initial stack test after modification will set a test frequency that will confirm compliance with this limit. Operation and maintenance of control equipment will ensure that this limit is met.

EU004 PM < 0.1 lb/MMBtu 40 CFR § 52.21 BACT limit Period stack emission testing, Monitoring, I and M, and recordkeeping for ESP plus CAM requirements Initial performance testing has been completed. Based on the results, a test frequency of every 60 months has been established. CAM requirements ensure that the control equipment is operated and maintained properly. Opacity < 20 % with exception 40 CFR Section 60.42(a)(2) COM The use of a Continuous Opacity Monitor ensures that opacity limit will be followed.

SO2 < 1.2 lb/MMBtu for solid fuel

SO2 < 0.8 lb/MMBtu for liquid fuel 40 CFR § 52.21 BACT limit and 40 CFR § 60.43 CEM Continuous CEMs data ensures compliance with 

# SO 2 

# Limits.

NOx < 0.7 lb/MMBtu for solid fuel

NOx < 0.3 lb/MMBtu for solid fuel CEM Continuous CEMs data ensures compliance with 

# NOx Limits

.

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## 40 CFR § 52.21 BACT limit

EU005 None None Particulate emissions due to drift loss are limited by proper operating practices to limit total dissolved solids in cooling water

EU006 None None Particulate emissions due to drift loss are limited by proper operating practices to limit total dissolved solids in cooling water

EU007

EU009

EU010 Opacity < 20 %

Minn. R. 7011.2300 None Internal combustion engines for backup electrical generators. Opacity unlikely to be exceeded with fuel specifications and engines are limited use.

SO2 < 0.5 lb/MMBtu None Use of diesel fuel oil guarantees compliance with the limit

EU011 PM < IPER

Minn. R. 7011.0710 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU012 PM < IPER

Minn. R. 7011.0710 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU013 PM < IPER

Minn. R. 7011.0710 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU014 PM < IPER

Minn. R. 7011.0710 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit

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## will be violated.

EU015 PM < 0.01 gr/dscf

Title I Condition Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU016 PM < 0.01 gr/dscf

Minn. R. 7009 and Minn. R. 7011.0715 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU017 PM < 0.005 gr/dscf

Minn. R. 7009 and Minn. R. 7011.0715 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU018 PM < IPER

Minn. R. 7009 and Minn. R. 7011.0715 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU019 PM < 0.005 gr/dscf

Title I Condition Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU020 PM < 0.005 gr/dscf

Minn. R. 7009 and Minn. R. 7011.0715 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated.

EU021 PM < 0.005 gr/dscf

Minn. R. 7009 and Minn. R. 7011.0715 Monitoring, I and M, and recordkeeping for fabric filter Due to the nature of the material that is being handled and the control equipment that is being used it is unlikely that the limit will be violated. EU023 Limits set by Subp. IIII Operation and

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## monitoring set by regulation

SO2 < 0.5 lb/MMBtu Sulfur content of fuel Use of diesel fuel oil guarantees compliance with the limit

Carbon Monoxide < 3.0 grams per kilowatt-hour. BACT limit Stack test, engine design. Stack test will confirm compliance with this limit.



# 4.2 Insignificant Activities Minnesota Power Boswell has several operations which are classified as insignificant activities. These are listed in the Appendix to the permit.

Activity Applicable Regulations Discussion



# Grinders Minn. R. 7007.1300, subp. 3.D.(2) Minn. R. 7011.0715 For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible. 

# Gasoline Tanks Minn. R. 7007.1300, subp. 3.E(1) Minn. R. 7007.1300, subp. 3.E(1) It is highly unlikely that they could violate the applicable requirement.



# Welding Equipment Minn. R. 7007.1300, subp. 3.H(4) Minn. R. 7011.0715 For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible. 

# Sandblasting Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0715 For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible. 

# Coal Stockpile loading Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Stockpile, equipment traffic Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Conveyor drop onto stockpile, reclaimer Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Conveyor Drop onto Stockpile –Side Chute Minn. Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the

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# R. 7007.1300, subp. 4.B(2) applicable requirement. 

# Rail Car Unloading Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Rail Car Load Out Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Lab Hoods (4) Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0715 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Transfer Tower A Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement.


# Coal Transfer Tower B Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Conveyer Belt C3 Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Rotary Car Dumper Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Rotary Car TP Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Transfer and Sampling House Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0150 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Storage Silo Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0715 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# Coal Tripper Transfer Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0715 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement. 

# #4 Coal Bunker Minn. R. 7007.1300, subp. 4.B(2) Minn. R. 7011.0715 This activity qualifies as conditional insignificant. It is highly unlikely that they could violate the applicable requirement.



# 5. Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any

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# requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of th e appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

Deviation from normal format: Alternate Operating Scenarios for SO2 and NOx monitors.

6. Comments Received

Public Notice Period: May 21, 2009 - June 22, 2009 EPA 45-day Review Period: May 21, 2009 - July 7, 2009

Comments were not received from the public during the public notice period.

Comments were not received from EPA during their review period.

7. Conclusion

Based on the information provided by <> , the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 06100004-004 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Benjamin klismith (permit writer/engineer) Steve Palzkill (enforcement) Andrew Place (stack testing) Marshall Cole (peer reviewer)

AQ File No. 73B; DQ 2218, 2232, 2342, 1601, 2007, 2085, 2261

Attachments: 1. PTE calculation and emissions summary 2. NOx reduction project calculation spreadsheets 3. Igniter/Heat gun project calculation spreadsheets 4. Generator project calculation spreadsheets 5. Facility description and CD-01 Forms 6. NOx reduction project letter from MPCA to facility 7. Slag shock system calculationsOMB 2060-0631 Part I Question 14aMinnesota Power Boswell Energy Center (1893)Materials listed in the permitBoswell "Other" Material Permitted to burn Actually burn Quantity / year Units5% of total mass inputoxygen limited to 3% or greateragents may only be burned while boileroperating at 75% of rated capacity or greaterOily coal NA no - -Used oilNot to exceed 17.5% of rated heat input on anhourly basis (equal to 963 gallsons/hr)no - -Oily paper-based floor dry NA yes 8525 lbsA total averagefor ALL oilymaterials (seenote below)Propane NA No - - Not burning yetUnit 3 Same as Units 1&2, plus...Used oil Not to exceed 2,456 gallons/hour no - -Wastewater treatment plant sludge Requires performance testing No - -Oily materials (includes mixtures of earth substrate (soil,rocks, sod, etc.)Requires performance testing No - -Man-made petroleum adsorption materialVarious petroleum derived fuels (hydraulic, transformer (lessthan 50ppm PCB)Crankcase or lubricating oilsno - -Diesel fuelno - -Crude oilno - -Unit 4Same as Units 1 & 2, butUsed oilNot to exceed 3824 gallons/hour (10% of ratedcapacity of 5,109 mmBtu/hour)no - -tracked with oily floor dry above (one log forwhole facility for spilled oils/floor dry)Boiler cleaning agents (EDTA type and Ammonium Bromate,generated onsite)If "other" was checked in questions 10 or 11 above indicating that any non-fossil fuel or other material (including, but not limited to, plastics, treated wood, rubber beltingor gaskets, whole tires, tire-derived fuel, boiler cleaning solutions, animal wastes, etc.) is either utilized or permitted tobe used, please indicate below what materials arecombusted in the boiler and in what quantities (specify whether this quantity is on a weight percentage or heat [Btu] basis).Also indicate (yes/no) whether you arepermitted to burn non-fossil fuel(s) or other material(s) even if you do not actually burn them.No - -Unit 1 andUnit 21

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29 A B C D E F G H I J OMB 2060-0631 Part I Question 15: Identification (or designation) of all coal- and oil-fired steam generating units (boilers) (as defined by Clean Air Act section 112(2)(8)) located at this facility) Minnesota Power Boswell Energy Center (1893)

Facility Name Subpart EIA Plant Code Q 15.01 Boiler ID Unit 1 Unit 2 Unit 3 Unit 4

Q 15.02 Original design fuel (i.e. coal rank or type of oil) Western subbituminous coal 2 Western subbituminous coal 2 Sub-bituminous coal Sub-bituminuous "C"
Q 15.03 Design heat input (mmBtu/hr) 1 654 654 3344 5062 Q 15.04 Present maximum heat input, (mmBtu/hr) 3 750 750 4115 5947 Q 15.05 MWe gross capacity summer 73 72 371.3 587.5 Q 15.06 MWe Net capacity summer 67.5 66.9 352 536 Q 15.07 Original design gross efficiency (%, HHV) 88 (11500btu/lb) 88 (11500btu/lb) 86.6 (8648btu/lb) 87.6 (8287btu/lb) Q 15.08 Present operating gross efficiency (%, HHV) 80 (9076btu/lb) 81 (9058btu/lb) 87.5 (8978btu/lb) 86 (9087btu/lb) Q 15.09 Design steam pressure (psig) 1 1450 1450 2520 2520 Q 15.10 Operating steam pressure (psig) 1450 1450 2520 2520 Q 15.11 Design steam temperature (°F) 1 1005 1005 1005 1005 Q 15.12 Operating steam temperature (°F) 1005 1005 1005 1005 Q 15.13 Design steam reheat temperature (°F) 1 1005 1005 1005 1005 Q 15.14 Operating steam reheat temperature (°F) 1005 1005 1005 1005 Q 15.15 Fuel Q 15.16 Hours/year operated 8001.67 7861 6830.33 7611.33 Q 15.17 Average annual capacity factor for the past 3 years 88.59 85.77 78.36 89.78

- - - 40 CFR pt. 60, Subpart D
Q 15.19 Estimated year of retirement Minnesota Power has no scheduled or planned retirement dates for any of our units

1 Original design values based on boiler acquisition contracts and/or heat balance drawings. Design heat input does not represent maximum capacity at the time of unit commissioning.

2 Boswell 1&2 were originally built to burn eastern bituminous coal, but were converted in the late 1960s to burn western sub-bituminous coal. Design HHV provided for the eastern coal.

3 Current heat input data from Title V permit application does not represent maximum heat input capacity. Q 15.18 Applicable NSPS Boswell Energy Center
1893

40 CFR Part 60 Subpart Y >99% coal, <1%otherOMB 2060-0631 Part I Question 16: Emission Control Technology

Minnesota Power Boswell Energy Center (1893)

Designate the order of the emission controls -- 1 for first control following the boiler, 2 for second control following the boiler, etc.

Plant ID Boiler

ID Type NOx Control In-service Date SO2 Control In-service Date PM Control In-service Date Other Control In-service Date

Boswell 1 Wall-fired 2 - ROFA / SNCR 2009 Low sulfur coal

- 3 - Baghouse 1977 None

- 1893 1 Wall-fired 1 - LNB 1998

2 Wall-fired 2 - ROFA / SNCR 2008 Low sulfur coal

- 3 - Baghouse 1977 None

- 2 Wall-fired 1 - LNB 1997
3 Tangentially-fired 1 - Low Nox Burners and 2 - SCR* 2009 3 - Wet (limestone) FGD 2009 4 - Baghouse 2009 3 - ACI for Hg 2010
4 Tangentially-fired 1 - SNCR 2009 3 - FGD 1980 2 - Wet venturi scrubber 1980 None

-

*More information on the Boswell Unit 3 SCR: Answers Type of material from which the catalyst is manufactured? Titanium Oxide Type of reductant used in with the SCR (e.g., anhydrous ammonia, aqueous ammonia, urea, other)? Aqueous ammonia Is the catalyst specifically designed to reduce SO3 formation? Yes, SO3 production was guaranteed at 3.1% or lessOMB 2060-0631 Part I Question 22: Guaranteed Emission Rate

Minnesota Power Boswell Energy Center (1893)

PM PM 10 PM 2.5 SO2 HCl and/or HF HCN Metal HAP Hg CO Other organics (specify) Other

pollutant (specify)

1 0.01

grains/SCF (99.3%) 2 0.01

grains/SCF (99.3%)

3 0.08 lb/mmBtu filterable plus condensible, 0.012 lb/mmBtu filterable 98% HF = 90% 200 ppm

4 0.03 grns/SCF

(dry basis) 450 ppm (by volume dry basis) 200 ppm Most recent guaranteed emission rate for each pollutant for which there is a permitted emission limit

Plant ID Boiler ID

Boswell (1893)

### OMB 2060-063 Part II Questions 2-3

Coal Shipments - Minnesota Power Boswell Energy Center (1893)

Train ID Tons Boiler ID# State County Coal Seam Fuel Ship Method Sulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel Other RBMCOB201 13,564.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.620 8,699 N/A N/A N/A N/A N/A RBMCOB202 14,041.000 1,2,3,4 MT Rosebud Rosebud RR 0.750 8.490 8,741 N/A N/A N/A N/A N/A RBMCOB203 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.720 8.410 8,749 N/A N/A N/A N/A N/A RBMCOB204 12,241.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 8.230 8,724 N/A N/A N/A N/A N/A RBMCOB205 13,204.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 9.050 8,600 N/A N/A N/A N/A N/A RBMCOB206 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 8.860 8,736 N/A N/A N/A N/A N/A RBMCOB207 14,040.000 1,2,3,4 MT Rosebud Rosebud RR 0.710 8.820 8,758 N/A N/A N/A N/A N/A RBMCOB208 13,200.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.530 8,686 N/A N/A N/A N/A N/A RBMCOB209 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 9.120 8,561 N/A N/A N/A N/A N/A RBMCOB210 14,522.000 1,2,3,4 MT Rosebud Rosebud RR 0.820 8.920 8,693 N/A N/A N/A N/A N/A RBMCOB211 12,960.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 8.410 8,683 N/A N/A N/A N/A N/A RBMCOB212 13,112.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 9.030 8,596 N/A N/A N/A N/A N/A RBMCOB213 14,760.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 9.520 8,599 N/A N/A N/A N/A N/A RBMCOB214 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 9.310 8,578 N/A N/A N/A N/A N/A RBMCOB215 14,400.000 1,2,3,4 MT Rosebud Rosebud RR 0.640 9.450 8,602 N/A N/A N/A N/A N/A RBMCOB216 12,807.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 9.110 8,533 N/A N/A N/A N/A N/A RBMCOB217 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 8.750 8,571 N/A N/A N/A N/A N/A RBMCOB218 14,280.000 1,2,3,4 MT Rosebud Rosebud RR 0.800 9.150 8,541 N/A N/A N/A N/A N/A RBMCOB219 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 8.480 8,673 N/A N/A N/A N/A N/A RBMCOB221 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.780 8.990 8,579 N/A N/A N/A N/A N/A RBMCOB222 13,560.000 1,2,3,4 MT Rosebud Rosebud RR 0.640 8.900 8,579 N/A N/A N/A N/A N/A RBMCOB220 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.780 8.930 8,551 N/A N/A N/A N/A N/A RBMCOB223 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.350 8,675 N/A N/A N/A N/A N/A RBMCOB224 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.150 8,656 N/A N/A N/A N/A N/A RBMCOB225 13,921.000 1,2,3,4 MT Rosebud Rosebud RR 0.680 8.480 8,670 N/A N/A N/A N/A N/A RBMCOB226 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.940 8,533 N/A N/A N/A N/A N/A RBMCOB227 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 9.080 8,536 N/A N/A N/A N/A N/A RBMCOB228 14,040.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.690 8,539 N/A N/A N/A N/A N/A RBMCOB229 14,160.000 1,2,3,4 MT Rosebud Rosebud RR 0.580 8.300 8,826 N/A N/A N/A N/A N/A RBMCOB230 13,921.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 8.360 8,739 N/A N/A N/A N/A N/A RBMCOB231 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 8.250 8,543 N/A N/A N/A N/A N/A RBMCOB232 13,810.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 8.380 8,625 N/A N/A N/A N/A N/A RBMCOB233 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 8.710 8,573 N/A N/A N/A N/A N/A RBMCOB234 13,808.000 1,2,3,4 MT Rosebud Rosebud RR 0.730 8.730 8,518 N/A N/A N/A N/A N/A RBMCOB235 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 8.390 8,554 N/A N/A N/A N/A N/A RBMCOB236 13,803.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 8.590 8,752 N/A N/A N/A N/A N/A RBMCOB237 13,804.000 1,2,3,4 MT Rosebud Rosebud RR 0.690 8.650 8,727 N/A N/A N/A N/A N/A RBMCOB238 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.740 8,828 N/A N/A N/A N/A N/A

### RBMCOB239 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 8.960 8,690 N/A N/A N/A N/A N/A

RBMCOB240 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 8.540 8,815 N/A N/A N/A N/A N/A RBMCOB241 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 8.980 8,712 N/A N/A N/A N/A N/A RBMCOB242 14,881.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.490 8,604 N/A N/A N/A N/A N/A RBMCOB243 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.520 8.120 8,790 N/A N/A N/A N/A N/A RBMCOB244 14,641.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 8.700 8,791 N/A N/A N/A N/A N/A RBMCOB233 300.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 8.360 8,887 N/A N/A N/A N/A N/A RBMCOB245 13,321.000 1,2,3,4 MT Rosebud Rosebud RR 0.870 9.710 8,667 N/A N/A N/A N/A N/A RBMCOB246 13,686.000 1,2,3,4 MT Rosebud Rosebud RR 0.870 9.860 8,738 N/A N/A N/A N/A N/A RBMCOB247 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.830 10.720 8,698 N/A N/A N/A N/A N/A RBMCOB248 13,924.000 1,2,3,4 MT Rosebud Rosebud RR 0.780 10.530 8,619 N/A N/A N/A N/A N/A RBMCOB249 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.520 9.670 8,722 N/A N/A N/A N/A N/A RBMCOB250 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.830 10.090 8,687 N/A N/A N/A N/A N/A RBMCOB251 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.770 9.360 8,768 N/A N/A N/A N/A N/A RBMCOB252 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.860 10.340 8,595 N/A N/A N/A N/A N/A RBMCOB253 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.810 10.190 8,720 N/A N/A N/A N/A N/A RBMCOB254 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.770 10.080 8,683 N/A N/A N/A N/A N/A RBMCOB255 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.730 9.370 8,780 N/A N/A N/A N/A N/A RBMCOB256 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.690 9.090 8,745 N/A N/A N/A N/A N/A RBMCOB257 14,160.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 9.010 8,858 N/A N/A N/A N/A N/A RBMCOB258 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 9.040 8,926 N/A N/A N/A N/A N/A RBMCOB259 13,809.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 9.770 8,683 N/A N/A N/A N/A N/A RBMCOB260 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.740 9.420 8,747 N/A N/A N/A N/A N/A RBMCOB261 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 9.280 8,866 N/A N/A N/A N/A N/A RBMCOB262 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 9.030 8,665 N/A N/A N/A N/A N/A RBMCOB263 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.710 9.510 8,923 N/A N/A N/A N/A N/A RBMCOB264 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 8.720 8,814 N/A N/A N/A N/A N/A RBMCOB265 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 9.210 8,828 N/A N/A N/A N/A N/A RBMCOB266 13,921.000 1,2,3,4 MT Rosebud Rosebud RR 0.710 9.500 8,793 N/A N/A N/A N/A N/A RBMCOB267 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.640 9.220 8,780 N/A N/A N/A N/A N/A RBMCOB268 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.830 8,650 N/A N/A N/A N/A N/A RBMCOB269 13,681.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.850 8,662 N/A N/A N/A N/A N/A RBMCOB270 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 9.610 8,707 N/A N/A N/A N/A N/A RBMCOB271 13,920.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.750 8,709 N/A N/A N/A N/A N/A RBMCOB272 13,921.000 1,2,3,4 MT Rosebud Rosebud RR 0.770 9.820 8,611 N/A N/A N/A N/A N/A RBMCOB273 14,044.000 1,2,3,4 MT Rosebud Rosebud RR 0.550 9.190 8,632 N/A N/A N/A N/A N/A RBMCOB274 13,920.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 8.750 8,791 N/A N/A N/A N/A N/A RBMCOB275 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.640 9.210 8,746 N/A N/A N/A N/A N/A RBMCOB276 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.660 9.350 8,715 N/A N/A N/A N/A N/A RBMCOB277 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 9.730 8,646 N/A N/A N/A N/A N/A RBMCOB278 13,560.000 1,2,3,4 MT Rosebud Rosebud RR 0.740 9.250 8,818 N/A N/A N/A N/A N/A RBMCOB279 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 8.420 8,898 N/A N/A N/A N/A N/A RBMCOB280 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 9.240 8,896 N/A N/A N/A N/A N/A

### RBMCOB281 13,803.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 9.150 8,883 N/A N/A N/A N/A N/A

RBMCOB282 14,161.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.930 8,564 N/A N/A N/A N/A N/A RBMCOB283 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.680 9.780 8,655 N/A N/A N/A N/A N/A RBMCOB284 14,043.000 1,2,3,4 MT Rosebud Rosebud RR 0.690 8.500 8,602 N/A N/A N/A N/A N/A RBMCOB285 14,280.000 1,2,3,4 MT Rosebud Rosebud RR 0.650 9.690 8,586 N/A N/A N/A N/A N/A RBMCOB286 14,040.000 1,2,3,4 MT Rosebud Rosebud RR 0.670 9.740 8,540 N/A N/A N/A N/A N/A RBMCOB287 13,561.000 1,2,3,4 MT Rosebud Rosebud RR 0.700 10.210 8,428 N/A N/A N/A N/A N/A RBMCOB288 14,160.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 10.130 8,457 N/A N/A N/A N/A N/A RBMCOB289 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 10.140 8,641 N/A N/A N/A N/A N/A RBMCOB290 13,801.000 1,2,3,4 MT Rosebud Rosebud RR 0.540 9.070 8,644 N/A N/A N/A N/A N/A RBMCOB291 13,681.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 9.000 8,763 N/A N/A N/A N/A N/A RBMCOB292 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.540 9.020 8,726 N/A N/A N/A N/A N/A RBMCOB293 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.710 9.820 8,554 N/A N/A N/A N/A N/A RBMCOB294 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 8.920 8,674 N/A N/A N/A N/A N/A RBMCOB295 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 9.190 8,631 N/A N/A N/A N/A N/A RBMCOB296 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 8.910 8,753 N/A N/A N/A N/A N/A RBMCOB297 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.640 10.370 8,417 N/A N/A N/A N/A N/A RBMCOB298 13,802.000 1,2,3,4 MT Rosebud Rosebud RR 0.580 9.070 8,634 N/A N/A N/A N/A N/A RBMCOB299 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.550 8.810 8,791 N/A N/A N/A N/A N/A RBMCOB200 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.590 9.660 8,585 N/A N/A N/A N/A N/A RBMCOB201 13,691.000 1,2,3,4 MT Rosebud Rosebud RR 0.550 9.710 8,597 N/A N/A N/A N/A N/A RBMCOB202 13,803.000 1,2,3,4 MT Rosebud Rosebud RR 0.560 8.990 8,764 N/A N/A N/A N/A N/A RBMCOB203 13,681.000 1,2,3,4 MT Rosebud Rosebud RR 0.620 9.790 8,558 N/A N/A N/A N/A N/A RBMCOB204 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.550 9.340 8,497 N/A N/A N/A N/A N/A RBMCOB205 13,607.000 1,2,3,4 MT Rosebud Rosebud RR 0.630 8.220 8,684 N/A N/A N/A N/A N/A RBMCOB206 12,842.000 1,2,3,4 MT Rosebud Rosebud RR 0.680 8.590 8,675 N/A N/A N/A N/A N/A RBMCOB207 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.560 8.840 8,732 N/A N/A N/A N/A N/A RBMCOB208 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.610 8.850 8,710 N/A N/A N/A N/A N/A RBMCOB209 13,800.000 1,2,3,4 MT Rosebud Rosebud RR 0.600 8.950 8,660 N/A N/A N/A N/A N/A DKMCOB301 13,323.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.350 4.680 9,370 N/A N/A N/A N/A N/A DKMCOB302 13,283.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 4.330 9,402 N/A N/A N/A N/A N/A DKMCOB303 13,887.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.400 4.510 9,360 N/A N/A N/A N/A N/A DKMCOB304 13,754.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.470 5.920 9,220 N/A N/A N/A N/A N/A DKMCOB305 13,625.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.540 4.670 9,488 N/A N/A N/A N/A N/A DKMCOB306 13,830.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 3.740 9,741 N/A N/A N/A N/A N/A DKMCOB307 13,614.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 5.050 9,377 N/A N/A N/A N/A N/A DKMCOB308 13,170.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.470 3.780 9,590 N/A N/A N/A N/A N/A DKMCOB309 13,852.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 5.570 9,344 N/A N/A N/A N/A N/A DKMCOB310 13,825.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.490 5.180 9,419 N/A N/A N/A N/A N/A DKMCOB311 13,133.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.430 4.390 9,643 N/A N/A N/A N/A N/A DKMCOB312 13,944.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.480 4.210 9,624 N/A N/A N/A N/A N/A DKMCOB313 13,770.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 4.080 9,715 N/A N/A N/A N/A N/A DKMCOB314 13,183.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.460 4.230 9,655 N/A N/A N/A N/A N/A

### DKMCOB315 13,865.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.350 4.040 9,398 N/A N/A N/A N/A N/A

DKMCOB316 13,861.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.400 4.920 9,280 N/A N/A N/A N/A N/A DKMCOB317 13,868.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.420 4.950 9,225 N/A N/A N/A N/A N/A DKMCOB318 13,849.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 5.070 9,281 N/A N/A N/A N/A N/A DKMCOB319 13,859.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.350 4.330 9,368 N/A N/A N/A N/A N/A DKMCOB320 13,738.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 4.690 9,342 N/A N/A N/A N/A N/A DKMCOB321 14,754.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.260 4.290 9,266 N/A N/A N/A N/A N/A DKMCOB322 13,819.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.320 4.640 9,249 N/A N/A N/A N/A N/A DKMCOB323 14,470.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.410 4.520 9,323 N/A N/A N/A N/A N/A DKMCOB324 14,701.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 4.370 9,454 N/A N/A N/A N/A N/A DKMCOB325 13,859.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 5.210 9,301 N/A N/A N/A N/A N/A DKMCOB326 14,236.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.520 4.380 9,533 N/A N/A N/A N/A N/A DKMCOB327 13,860.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 4.600 9,480 N/A N/A N/A N/A N/A DKMCOB328 14,128.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 4.190 9,473 N/A N/A N/A N/A N/A DKMCOB329 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 4.920 9,381 N/A N/A N/A N/A N/A DKMCOB330 13,855.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.390 5.050 9,334 N/A N/A N/A N/A N/A DKMCOB331 13,978.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 4.420 9,375 N/A N/A N/A N/A N/A DKMCOB332 13,859.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.390 4.350 9,439 N/A N/A N/A N/A N/A DKMCOB333 13,879.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 4.880 9,468 N/A N/A N/A N/A N/A DKMCOB334 13,869.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.430 4.530 9,528 N/A N/A N/A N/A N/A DKMCOB335 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.410 4.840 9,465 N/A N/A N/A N/A N/A DKMCOB336 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 5.240 9,282 N/A N/A N/A N/A N/A DKMCOB337 13,871.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 4.530 9,408 N/A N/A N/A N/A N/A DKMCOB338 15,182.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 4.880 9,241 N/A N/A N/A N/A N/A DKMCOB339 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 4.450 9,500 N/A N/A N/A N/A N/A DKMCOB340 13,869.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 3.970 9,649 N/A N/A N/A N/A N/A DKMCOB341 13,853.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 4.440 9,566 N/A N/A N/A N/A N/A DKMCOB342 14,219.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.390 4.460 9,456 N/A N/A N/A N/A N/A DKMCOB343 13,868.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.390 4.280 9,545 N/A N/A N/A N/A N/A DKMCOB344 14,587.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.480 4.180 9,568 N/A N/A N/A N/A N/A DKMCOB345 13,860.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.500 4.720 9,444 N/A N/A N/A N/A N/A DKMCOB346 13,845.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 3.880 9,631 N/A N/A N/A N/A N/A DKMCOB347 13,864.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.430 5.130 9,362 N/A N/A N/A N/A N/A DKMCOB348 13,850.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 6.000 9,249 N/A N/A N/A N/A N/A DKMCOB349 13,856.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.460 4.220 9,559 N/A N/A N/A N/A N/A DKMCOB350 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.560 5.240 9,422 N/A N/A N/A N/A N/A DKMCOB351 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.520 5.480 9,451 N/A N/A N/A N/A N/A DKMCOB352 13,839.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.520 5.290 9,418 N/A N/A N/A N/A N/A DKMCOB353 13,865.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 4.570 9,509 N/A N/A N/A N/A N/A DKMCOB354 13,881.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 4.320 9,499 N/A N/A N/A N/A N/A DKMCOB356 14,819.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.320 4.050 9,507 N/A N/A N/A N/A N/A DKMCOB355 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.450 4.280 9,414 N/A N/A N/A N/A N/A DKMCOB357 14,535.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.460 4.340 9,444 N/A N/A N/A N/A N/A

### DKMCOB358 13,855.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.410 4.220 9,383 N/A N/A N/A N/A N/A

DKMCOB359 14,539.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.400 4.140 9,389 N/A N/A N/A N/A N/A DKMCOB360 13,869.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 4.290 9,419 N/A N/A N/A N/A N/A DKMCOB361 14,223.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.320 3.840 9,423 N/A N/A N/A N/A N/A DKMCOB362 13,858.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.400 4.180 9,423 N/A N/A N/A N/A N/A DKMCOB363 13,870.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 3.990 9,488 N/A N/A N/A N/A N/A DKMCOB364 13,866.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.510 4.070 9,436 N/A N/A N/A N/A N/A DKMCOB365 13,862.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.370 3.930 9,386 N/A N/A N/A N/A N/A DKMCOB366 13,896.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.340 3.830 9,413 N/A N/A N/A N/A N/A DKMCOB367 13,860.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.470 5.070 9,361 N/A N/A N/A N/A N/A DKMCOB368 13,760.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.350 4.340 9,359 N/A N/A N/A N/A N/A DKMCOB369 13,873.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.340 4.770 9,604 N/A N/A N/A N/A N/A DKMCOB370 13,957.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.300 4.850 9,519 N/A N/A N/A N/A N/A DKMCOB371 13,738.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.320 4.400 9,740 N/A N/A N/A N/A N/A DKMCOB372 13,978.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.350 5.010 9,630 N/A N/A N/A N/A N/A DKMCOB373 13,625.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.360 4.960 9,633 N/A N/A N/A N/A N/A DKMCOB374 13,851.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.380 5.670 9,554 N/A N/A N/A N/A N/A DKMCOB375 13,746.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.400 4.610 9,673 N/A N/A N/A N/A N/A DKMCOB376 13,499.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.470 4.250 9,766 N/A N/A N/A N/A N/A DKMCOB377 13,736.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.430 4.520 9,592 N/A N/A N/A N/A N/A DKMCOB378 13,377.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.490 4.260 9,626 N/A N/A N/A N/A N/A DKMCOB379 14,007.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.460 4.150 9,541 N/A N/A N/A N/A N/A DKMCOB380 13,152.000 1,2,3,4 MT Big Horn Dietz 1 and Dietz 2 RR 0.440 4.290 9,569 N/A N/A N/A N/A N/A SCMCOB601 13,024.175 1,2,3,4 MT Big Horn Anderson Dietz RR 0.400 4.150 9,373 N/A N/A N/A N/A N/A SCMCOB602 13,123.775 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 4.370 9,352 N/A N/A N/A N/A N/A SCMCOB603 13,152.575 1,2,3,4 MT Big Horn Anderson Dietz RR 0.360 4.140 9,278 N/A N/A N/A N/A N/A SCMCOB604 12,907.250 1,2,3,4 MT Big Horn Anderson Dietz RR 0.360 4.200 9,465 N/A N/A N/A N/A N/A SCMCOB605 11,211.825 1,2,3,4 MT Big Horn Anderson Dietz RR 0.310 5.270 9,172 N/A N/A N/A N/A N/A SCMCOB606 12,467.525 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 3.860 9,364 N/A N/A N/A N/A N/A SCMCOB607 11,713.000 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.040 9,320 N/A N/A N/A N/A N/A SCMCOB608 13,835.800 1,2,3,4 MT Big Horn Anderson Dietz RR 0.280 3.880 9,436 N/A N/A N/A N/A N/A SCMCOB609 13,943.500 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.030 9,266 N/A N/A N/A N/A N/A SCMCOB610 14,829.850 1,2,3,4 MT Big Horn Anderson Dietz RR 0.280 4.460 9,432 N/A N/A N/A N/A N/A SCMCOB611 12,912.650 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.050 9,438 N/A N/A N/A N/A N/A SCMCOB612 14,139.450 1,2,3,4 MT Big Horn Anderson Dietz RR 0.280 4.230 9,297 N/A N/A N/A N/A N/A SCMCOB613 13,666.000 1,2,3,4 MT Big Horn Anderson Dietz RR 0.280 4.450 9,329 N/A N/A N/A N/A N/A SCMCOB614 14,057.975 1,2,3,4 MT Big Horn Anderson Dietz RR 0.270 4.410 9,427 N/A N/A N/A N/A N/A SCMCOB615 14,776.700 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 3.810 9,497 N/A N/A N/A N/A N/A SCMCOB616 13,825.100 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 5.500 9,300 N/A N/A N/A N/A N/A SCMCOB617 12,413.575 1,2,3,4 MT Big Horn Anderson Dietz RR 0.300 4.180 9,367 N/A N/A N/A N/A N/A SCMCOB618 13,880.325 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.340 9,387 N/A N/A N/A N/A N/A SCMCOB619 13,626.125 1,2,3,4 MT Big Horn Anderson Dietz RR 0.310 4.360 9,389 N/A N/A N/A N/A N/A SCMCOB620 13,995.050 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 4.620 9,404 N/A N/A N/A N/A N/A

### SCMCOB621 13,938.900 1,2,3,4 MT Big Horn Anderson Dietz RR 0.310 4.210 9,382 N/A N/A N/A N/A N/A

SCMCOB622 13,505.450 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.280 9,389 N/A N/A N/A N/A N/A SCMCOB623 13,921.750 1,2,3,4 MT Big Horn Anderson Dietz RR 0.310 4.070 9,494 N/A N/A N/A N/A N/A SCMCOB624 14,039.200 1,2,3,4 MT Big Horn Anderson Dietz RR 0.370 5.300 9,280 N/A N/A N/A N/A N/A SCMCOB625 13,566.750 1,2,3,4 MT Big Horn Anderson Dietz RR 0.390 4.930 9,287 N/A N/A N/A N/A N/A SCMCOB626 13,944.425 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.250 9,305 N/A N/A N/A N/A N/A SCMCOB627 13,953.625 1,2,3,4 MT Big Horn Anderson Dietz RR 0.360 4.920 9,194 N/A N/A N/A N/A N/A SCMCOB628 14,673.550 1,2,3,4 MT Big Horn Anderson Dietz RR 0.420 4.190 9,350 N/A N/A N/A N/A N/A SCMCOB629 13,959.050 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.470 9,308 N/A N/A N/A N/A N/A SCMCOB630 13,907.500 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.410 9,252 N/A N/A N/A N/A N/A SCMCOB631 14,017.625 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.300 9,319 N/A N/A N/A N/A N/A SCMCOB632 13,870.325 1,2,3,4 MT Big Horn Anderson Dietz RR 0.410 4.970 9,161 N/A N/A N/A N/A N/A SCMCOB633 14,903.575 1,2,3,4 MT Big Horn Anderson Dietz RR 0.410 4.730 9,318 N/A N/A N/A N/A N/A SCMCOB634 14,310.500 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 5.140 9,191 N/A N/A N/A N/A N/A SCMCOB635 14,104.000 1,2,3,4 MT Big Horn Anderson Dietz RR 0.250 3.840 9,464 N/A N/A N/A N/A N/A SCMCOB636 13,992.875 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.030 9,502 N/A N/A N/A N/A N/A SCMCOB637 13,988.625 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.170 9,419 N/A N/A N/A N/A N/A SCMCOB638 13,878.450 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.860 9,237 N/A N/A N/A N/A N/A SCMCOB639 14,048.875 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 3.800 9,440 N/A N/A N/A N/A N/A SCMCOB640 14,896.500 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.500 9,334 N/A N/A N/A N/A N/A SCMCOB641 14,851.150 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.080 9,246 N/A N/A N/A N/A N/A SCMCOB642 14,902.325 1,2,3,4 MT Big Horn Anderson Dietz RR 0.460 5.360 9,144 N/A N/A N/A N/A N/A SCMCOB643 14,121.400 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.110 9,357 N/A N/A N/A N/A N/A SCMCOB644 13,961.625 1,2,3,4 MT Big Horn Anderson Dietz RR 0.370 4.140 9,361 N/A N/A N/A N/A N/A SCMCOB645 14,911.325 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.620 9,270 N/A N/A N/A N/A N/A SCMCOB646 14,075.250 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 3.930 9,369 N/A N/A N/A N/A N/A SCMCOB647 14,935.300 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 4.650 9,226 N/A N/A N/A N/A N/A SCMCOB648 14,972.200 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.240 9,423 N/A N/A N/A N/A N/A SCMCOB649 13,864.250 1,2,3,4 MT Big Horn Anderson Dietz RR 0.360 4.730 9,205 N/A N/A N/A N/A N/A SCMCOB650 13,997.450 1,2,3,4 MT Big Horn Anderson Dietz RR 0.310 3.930 9,422 N/A N/A N/A N/A N/A SCMCOB651 14,560.300 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.380 9,254 N/A N/A N/A N/A N/A SCMCOB652 13,973.775 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 3.890 9,334 N/A N/A N/A N/A N/A SCMCOB653 13,994.275 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.040 9,393 N/A N/A N/A N/A N/A SCMCOB654 13,701.975 1,2,3,4 MT Big Horn Anderson Dietz RR 0.280 3.930 9,408 N/A N/A N/A N/A N/A SCMCOB655 14,271.950 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.580 9,174 N/A N/A N/A N/A N/A SCMCOB656 13,958.625 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 4.700 9,277 N/A N/A N/A N/A N/A SCMCOB657 13,253.875 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.110 9,324 N/A N/A N/A N/A N/A SCMCOB658 13,961.275 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 4.040 9,351 N/A N/A N/A N/A N/A SCMCOB659 13,969.900 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.230 9,417 N/A N/A N/A N/A N/A SCMCOB660 14,312.000 1,2,3,4 MT Big Horn Anderson Dietz RR 0.320 4.020 9,348 N/A N/A N/A N/A N/A SCMCOB661 13,951.525 1,2,3,4 MT Big Horn Anderson Dietz RR 0.370 4.370 9,325 N/A N/A N/A N/A N/A SCMCOB662 13,740.325 1,2,3,4 MT Big Horn Anderson Dietz RR 0.370 4.830 9,185 N/A N/A N/A N/A N/A SCMCOB663 13,974.100 1,2,3,4 MT Big Horn Anderson Dietz RR 0.290 4.390 9,188 N/A N/A N/A N/A N/A

### SCMCOB664 14,598.150 1,2,3,4 MT Big Horn Anderson Dietz RR 0.340 4.400 9,235 N/A N/A N/A N/A N/A

SCMCOB665 13,986.375 1,2,3,4 MT Big Horn Anderson Dietz RR 0.460 5.000 9,022 N/A N/A N/A N/A N/A SCMCOB666 14,281.400 1,2,3,4 MT Big Horn Anderson Dietz RR 0.270 5.570 9,178 N/A N/A N/A N/A N/A SCMCOB667 14,005.700 1,2,3,4 MT Big Horn Anderson Dietz RR 0.390 4.990 9,237 N/A N/A N/A N/A N/A SCMCOB668 14,208.275 1,2,3,4 MT Big Horn Anderson Dietz RR 0.350 5.080 9,259 N/A N/A N/A N/A N/A SCMCOB669 14,965.225 1,2,3,4 MT Big Horn Anderson Dietz RR 0.430 4.710 9,318 N/A N/A N/A N/A N/A SCMCOB670 14,105.800 1,2,3,4 MT Big Horn Anderson Dietz RR 0.330 4.290 9,369 N/A N/A N/A N/A N/A SCMCOB671 13,968.675 1,2,3,4 MT Big Horn Anderson Dietz RR 0.390 5.240 9,351 N/A N/A N/A N/A N/A SCMCOB672 13,992.650 1,2,3,4 MT Big Horn Anderson Dietz RR 0.490 4.640 9,331 N/A N/A N/A N/A N/A SCMCOB673 13,876.200 1,2,3,4 MT Big Horn Anderson Dietz RR 0.400 4.360 9,464 N/A N/A N/A N/A N/A SCMCOB674 13,900.000 1,2,3,4 MT Big Horn Anderson Dietz RR 0.450 4.500 9,397 N/A N/A N/A N/A N/A TRAXCOB101 236.080 1,2,3,4 MT Big Horn Anderson Dietz RR 0.460 5.030 9,214 N/A N/A N/A N/A N/A BTMCOB101 13,980.250 1,2,3,4 WY Campbell N/A RR 0.340 5.130 8,936 N/A N/A N/A N/A N/A BTMCOB102 13,503.300 1,2,3,4 WY Campbell N/A RR 0.340 5.280 8,765 N/A N/A N/A N/A N/A BTMCOB103 13,972.700 1,2,3,4 WY Campbell N/A RR 0.300 5.020 8,844 N/A N/A N/A N/A N/A BTMCOB104 13,988.650 1,2,3,4 WY Campbell N/A RR 0.240 4.810 8,910 N/A N/A N/A N/A N/A BTMCOB105 13,997.100 1,2,3,4 WY Campbell N/A RR 0.370 5.340 8,903 N/A N/A N/A N/A N/A CAMCOB101 13,949.000 1,2,3,4 WY Campbell N/A RR 0.300 5.000 8,503 N/A N/A N/A N/A N/A CAMCOB102 13,891.000 1,2,3,4 WY Campbell N/A RR 0.320 4.900 8,606 N/A N/A N/A N/A N/A CAMCOB103 13,940.000 1,2,3,4 WY Campbell N/A RR 0.300 4.800 8,656 N/A N/A N/A N/A N/A CAMCOB104 13,934.000 1,2,3,4 WY Campbell N/A RR 0.360 5.400 8,513 N/A N/A N/A N/A N/A CAMCOB105 14,001.000 1,2,3,4 WY Campbell N/A RR 0.360 5.300 8,486 N/A N/A N/A N/A N/A CAMCOB106 13,970.000 1,2,3,4 WY Campbell N/A RR 0.310 5.200 8,518 N/A N/A N/A N/A N/A CAMCOB107 13,978.000 1,2,3,4 WY Campbell N/A RR 0.340 4.800 8,622 N/A N/A N/A N/A N/A ATMCOB101 12,987.225 1,2,3,4 WY Converse N/A RR 0.240 5.720 8,755 N/A N/A N/A N/A N/A ATMCOB102 13,743.825 1,2,3,4 WY Converse N/A RR 0.260 5.100 8,802 N/A N/A N/A N/A N/A ATMCOB103 13,983.775 1,2,3,4 WY Converse N/A RR 0.290 4.660 8,963 N/A N/A N/A N/A N/A ATMCOB104 13,948.175 1,2,3,4 WY Converse N/A RR 0.330 4.980 8,953 N/A N/A N/A N/A N/A

Oil Shipments - Boswell Energy Center OMB 2060-063 Part II Questions 2-3

ID Gallons Boiler ID# State County Coal Seam Fuel Ship Method Sulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel Other COMO01621 7,513.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO01706 7,513.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO105827 7,494.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO105840 7,200.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO105936 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO105956 7,200.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO106982 7,499.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A

### COMO107086 7,299.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A

COMO107092 7,517.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109050 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109051 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109054 7,504.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109135 7,200.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109136 7,197.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109146 7,711.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109234 7,501.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109256 7,201.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO109264 7,601.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO110290 7,302.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO110302 7,703.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO110424 7,300.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO110432 7,600.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111015 7,304.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111019 7,600.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111062 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111064 7,508.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111752 7,104.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111763 7,102.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111769 7,303.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111830 7,101.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO111842 7,301.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO112951 7,297.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO112952 7,507.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114511 7,202.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114528 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114593 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114601 7,508.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114707 7,201.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114723 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114847 7,199.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114862 7,506.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO114980 7,200.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO116624 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO116635 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO116752 7,202.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO116762 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO118562 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO118583 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO118732 7,300.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO118752 7,504.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A

### COMO118924 7,303.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A

COMO118947 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO120036 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO120047 7,509.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO120208 7,300.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO120221 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122347 7,202.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122507 7,514.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122569 7,199.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122580 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122723 7,197.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122729 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122858 7,299.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO122863 7,500.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO125740 7,201.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO125753 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO125917 7,206.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO125932 7,503.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO128103 7,202.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO128120 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO130398 7,300.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO130403 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO130534 7,202.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO130542 7,502.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO655869 300.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO95290 7,513.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO95349 7,513.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO95878 7,514.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO95904 7,514.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO95923 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A COMO96898 7,505.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/A EDW94211 7,200.00 1,2,3,4 MN N/A N/A TR 0.200 0.100 137,000 N/A N/A N/A N/A N/AOMB 2060-0631 Part I, Question 8a, 8b, 8f Minnesota Power Boswell Energy Center (1893)

Boiler ID (as listed in Part I question 15) Question 8a Emission test report, parametric monitoring data, or other data or monitoring Question 8b Date of testing Question 8b Type of testing Question 8b Constituents Question 8f Did the unit's control configuration differ for that shown in Part I, questions 16 at the time of the test? Boiler ID Type NO x Control SO 2

Control PM Control Other Control

Boiler 1 and Boiler 2 GE Energy Mercury Engineering Study 3/28-29/2006 stack mercury yes B1 & B2 LNB none Baghouse none

Boiler 1, Boiler 2, Boiler 3 and Boiler 4 GE Energy PM & PM10 Testing 5/22-24/2007 stack PM & PM10 yes B3 B4 none
none none

FGD Wet Scr

Boiler 1 and Boiler 2 Platt Environmental Services, Inc Mercury Testing 6/24/2008 stack mercury yes B1 & B2 LNB none Baghouse none

Boiler 4 Alstom Mercury Testing 5/19/2022 stack mercury no

Boiler 1 and Boiler 2 GE Energy PM & PM10 Testing 7/22-24/2009 stack PM & PM10 no

Boiler 3 GE Energy SCR Inlet and Outlet 1/6-8/2010 Emission study H 2 SO 4 , NH 4 , NO x and SO 2 no

Boiler 3 GE Energy PM Engineering Study 2/11/2010 Baghouse Outlet PM noOMB 2060-0631 Part II, Question 12Minnesota Power Boswell Energy Center (1893)Boiler ID Test Date PM* SO2 HCL/HF/HCN Metal HAP Hg* CO* Other organicUnit Load(MW)NetMWH NET)Moisture(%) Flow(dscfm or Nm3/hr)Flue gas oxygen(%, dry) Flue gas CO2 (%, dry)Flue gas temp(oF)Flue gas pressure(atm)Standard temp(F)Standard pressure(atm)Boiler 1 and Boiler 2 3/28-29/2006Unit 1 total Hg = 0.00169 lb/hr2.82E-6 lb/mmBtuparticle = 0.0 lb/hr0.00E-6 lb/mmBtuoxidized = 0.00144 lb/hr2.39E-6 lb/mmBtuelemental = 0.00026Unit 1 = 69.5Unit 2 = 52.4Unit 1 = 12.0Unit 2 = 11.2Unit 1 = 171,972 dscfmUnit 2 = 155,640 dscfmUnit 1 = 6.6Unit 2 = 6.5Unit 1 = 10.7Unit 2 = 10.1Unit 1 = 357.6Unit 2 = 313.0Unit 1 = 29.34Unit 2 = 28.77Unit 1 = 68Unit 2 = 68Unit 1 = 29.92Unit 2 = 29.92Boiler 1, Boiler 2,Boiler 3 and Boiler 45/22-24/2007 Unit 1 & 2 filterable PM = 0.01 lb/mmBtutotal PM10 =0.08 lb/mmBtuUnit 3 filterable PM = 0.13 lb/mmBtutotal PM10 =0.13 lb/mmBtuUnit 4 filterable PM10 = 0.06 lb/mmBtutotal PM =0.07 lb/mmBtuUnit 1 & 2 = 140.7Unit 3 = 353Unit 4 = 356Unit 1 & 2 = 10.3Unit 3 = 12.4Unit 4 = 14.3Unit 1 & 2 = 322,753 dscfmUnit 3 = 1,204,743 dscfmUnit 4 = 1,452,877 dscfmUnit 1 & 2 = 5.7Unit 3 = 5.7Unit 4 = 6.7Unit 1 & 2 = 12.3Unit 3 = 12.2Unit 4 = 11.3Unit 1 & 2 = 341.2Unit 3 = 183.8Unit 4 = 172.4Unit 1 & 2 = 29.65Unit 3 = 29.71Unit 4 = 29.77Unit 1 = 68Unit 2 = 68Unit 4 = 68Unit 1 = 29.92Unit 2 = 29.92Unit 4 = 29.92Boiler 1 and Boiler 2 6/24/2008Boiler 4 5/19/2022Mercury control testing at econimizeroutlet and stack68 29.92Boiler 1 and Boiler 2 7/22-24/2009 No UREA filterable PM = 0.01 lb/mmBtucondensible PM = 0.20 lb/mmBtuUREA on filterable PM = 0.01 lb/mmBtucondensible PM = 0.19 lb/mmBtuNo UREA = 137.8UREA on = 138.0No UREA = 10.5UREA on = 11.1No UREA = 327,342 dscfmUREA on = 328,206 dscfmNo UREA = 4.5UREA on = 4.6No UREA = 14.8UREA on = 14.6No UREA = 355.9UREA on = 350.8No UREA = 28.50UREA on = 28.28No UREA = 68UREA on = 68No UREA = 29.92UREA on = 29.92Boiler 3 1/6-8/2010 SCR inlet = 0.80 ppmSCR outlet = 11.40ppmNH4SCR outlet= 0.04 ppmNH4SCR outlet= 27.50ug/dscmNOxSCR inlet =103.22 ppmvdNOxSCR outlet= 19.87 ppmvd68 29.92Boiler 3 2/11/2010 Unit 3 PM concentration filterable = 0.0019gr/dscfUnit 3 PM concentration aqueouscondensible = 0.0013 gr/dscfUnit 3 PM concentration organiccondensible = 0.0021 gr/dscfUnit 3 PM concentration total = 0.0053gr/dscfUnit 3 PM emission rate filterable = 12.97lb/hrUnit 3 PM emission rate aqueouscondensible = 8.91 lb/hrUnit 3 PM emission rate organiccondensible = 13.90 lb/hrUnit 3 PM emission rate total = 35.79 lb/hrUnit 3 PM emission rate filterable = 0.0038lb/mmBtuUnit 3 PM emission rate aqueouscondensible = 0.0026 lb/mmBtuUnit 3 PM emission rate organiccondensible = 0.0041 lb/mmBtuUnit 3 PM emission rate total = 0.0105lb/mmBtu9.7 781,327 dscfm 6 13.4 273.3 28.18 68 29.92* Averaging Time = 3 - 1 hour rounds

## TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper contai ning at least 10% fibers from paper recycled by consumers 

## AIR EMISSION PERMIT NO. 13700015 - 004 Administrative Amendment

IS ISSUED TO

Minnesota Power Division of Allete Inc

Minnesota Power Inc - Hibbard Renewable Energy Center 4913 Main Street Duluth, St. Louis County, MN 55807

The emission units, control equipment and emission stack s at the stationary source authorized in this permit amendment are as described below in the Permit Applications Table.

This permit amendment supersedes Air Emission Permit No. 13700015-003 and authorizes the Permittee to operate the stationary source at the address lis ted above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indicated, all the Minnesota rules cite d as the origin of the permit terms are incorporated into the State Implementation Plant under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70/Major for NSR Operating Permit Issue Date: August 15, 2006 Administrative Amendment Issue Date: December 23, 2009 Expiration Date: August 15, 2011 – Title I Conditions do not expire.

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

for Paul Eger Commissioner Minnesota Pollution Control Agency

## Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit - Reissuance January 14, 2002 003

Administrative Amendment August 18, 2008, with supplemental information submitted October 5, 2009 004

## TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Amendment Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices Appendix I – Insignificant Activities

Appendix II – Phase II Permit Application (federal Acid Rain regulations)

## NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requi rements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafa yette Road North, St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about ai r quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, complia nce with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifyi ng compliance practices for applicable requirements, any person (including the Permittee) may also use ot her credible evidence to establish compliance or noncompliance with applicable requirements.

## FACILITY DESCRIPTION:

Permit Action 003 - Reissuance The Hibbard Renewable Energy Center (Facility) steam and power generating facility was jointly owned by Minnesota Power (MP) and the City of Duluth. Boilers 3 & 4 and their associated equipment were owned by the City of Duluth, whereas MP owned th e remaining portion of the facility. The facility is located in the City of Duluth, ad jacent to the NewPage paper mill. The facility combusts a mixture of wood, coal, natural gas and paper mill sludge. The prim ary mission of the facility is to produce steam for NewPage Duluth Paper Mill and its associated paper r ecycling facility. The facility is also capable of producing electrical energy for the MP system. The site contains four steam generating boilers, four steam turbines, coal handling facilities, wood handling facilities, a 3.4 million gallon fuel oil storage tank and natural gas supply lines. The two oldest boilers and th eir associated turbine-generators (Boilers No. 1 and No. 2), and the fuel oil supply tank have been out of service since 1981, but can be used if future plans were to change.

All operations and equipment within the facility bounda ry are established to: (1) provide steam and/or electrical power for on-site and off-site utilization; (2) provide fuel for steam and/or electrical power production or support activities; (3) monitor and cont rol air emissions generated from electrical power production; (4) handle waste heat, wastes and materi als produced from the on-site operations; and (5) provide support activities. The description of these operations and equipment are described below.

Steam and Power Generation Steam and power generation is accomplished primarily through steam generation in two boilers (Boilers No. 3 and No. 4). Both units have spreader stokers and traveling grates. Emissions are discharged through a common 331 foot stack (Stack No. 1). Boilers No. 1 a nd No. 2 are smaller units and if used would also discharge air emissions through Stack No. 1.

Fuel for Steam and Power Generation and Support Equipment/Activities Boilers No. 3 and No. 4 are capable of combusting a mixture of wood, sub-bituminous coal, natural gas and sludge. The primary fuel is wood, which may in clude wood chips, sawdust, sanderdust, wood bark, chipped railroad ties and other various forms of waste wood from regional suppliers. The wood fuel is supplemented with low-sulfur, sub-bituminous coal a nd natural gas. Boilers No. 3 and No. 4 are capable of combusting wood, coal, and various combinations of wood, coal, and natural gas. This permit allows for the addition of oily coal (coal with oil spilled on it), oily cellulose-based sorbents (including rags), activated charcoal, boiler cleaning agents, and ce llulose fill from mattress recycling as permitted fuels.

The wood fuel is delivered directly to the plant in covered trucks, unloaded and conveyed directly to the A-frame storage building. The wood fuel is conveyed to the wood metering bins and transferred to the boiler’s traveling grate through the auger feed and spreader stoker systems. Combustion occurs in suspension and on the grate.

Coal is delivered to the facility in trucks and unloa ded in a three sided enclosure maintained at negative pressure and vented through a fabric filter. Coal is transferred from the unloading facility to storage bunkers by a bucket conveyor system. Air from the bunkers and coal transfer system is vented through a fabric filter. Coal transfer from the bunker to the bo ilers is accomplished by a totally enclosed conveyor.

Natural gas is supplied to Boilers No. 3 and No. 4 through a pipeline. Natural gas could be supplied to Boilers No. 1 and No. 2 by the same system.

If used in the future as fuel, oil would be delivered by truck and stored in the 3.4 million gallon tank. Piping, which would connect the fuel oil stor age to the boilers is currently disconnected.

## Air Emission Monitoring and Control Air emissions from the facility are released primarily as a result of the combustion of wood and coal. Smaller amounts of criteria pollutants are emitted fro m the combustion of natural gas and the handling and storage of coal and wood fuels. The combustion of wood and coal also results in the emission of some hazardous air emissions.

Continuous Emission Monitors have been installed, tested and certified to measure and record the combustion emissions from Boilers No. 3 and No. 4 exiting via the common stack, Stack No. 1. The monitors measure and record information on the following parameters: Sulfur Dioxide, Nitrogen Oxides, opacity, Carbon Monoxide, Carbon Dioxi de, and volumetric flow and are located in the breaching leading to the stack.

Particulate emissions from Stack No. 1 due to combus tion in Boilers No. 3 and No. 4 are controlled by multiple cyclones in series with an electrostatic precip itator for each unit. Boilers No. 1 and No. 2 do not have associated pollution control equipment. Particulates from coal unloading, transfer, and storage are controlled with fabric filter baghouses. Additional particulate c ontrol is accomplished through the use of enclosures to limit fugitive emissions from coal and wood unloading operations.

Waste Heat, Wastes, and Materials The facility is designed to operate with a once-through cooling system to dissipate waste heat in the production of electrical energy. Water from St. Louis Ba y is pumped through the intake structure, used to condense steam from the back side of the turb ine generator and discharged to the bay.

The combustion of wood and coal also produces ash, whic h is collected off the traveling grates, wetted and transferred to a truck. The ash is used as agricultural soil enhancement or is landfilled.

Support Activities Support activities include the building elevator, vehicl e maintenance, general facility activities, energy production equipment maintenance, piping installa tion and maintenance. These activities can include painting, welding, and cleaning operations. In te rms of air emission regulations, these activities are considered insignificant activities for these purposes.

AMENDMENT DESCRIPTION:

Permit Action 004 – Administrative Administration This administrative amendment is for a change in ow nership. Minnesota Power has purchased the City of Duluth’s portion of the Facility and now has sole ownership of the Facility.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it
SOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains 2 appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. Minn. R. 7007.0800, subp. 2

Comply with the Fugitive Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R. 7011.0150; Minn. R. 7009.0020.

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW hdr

These requirements apply where there is a reasonable possibility that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test and found to not be part of a major modification, may result in a significant emissions increase. If the ATPA test is not used for a particular project, or if there is not a reasonable possibility that the proposed project could result in a significant emissions increase, then these requirements do not apply to that project.

Even though a particular modification is not subject to New Source Review, a permit amendment, recordkeeping, or notification may still be required under Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following information:

1. A description of the project 2. Identification of the emission unit(s) whose emissions of an NSR pollutant could be affected 3. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the potential emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the unit(s) could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-3 under Preconstruction Documentation, above) to the Agency. Title I Condition: 40 CFR Section 52.21(r)(6)(ii) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-2

For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project and analyzed using potential emissions c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual plus potential, if applicable) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual plus potential, if any part of the project was analyzed using potential emissions) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply and upon written request demonstrate compliance, with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, supbs. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0100-7009.0080.
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, supb. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R. 7007.0800, subp. 14 & subp. 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not federally enforceable. Minn. R. 7030.0010-7030.0080

Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, to enter the Permittee's premises, to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. The Permittee may require that MPCA inspectors be accompanied by MP staff during the inspection. Permittee's staff shall be available whenever the plant is operating. Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-3

Coal handling: not to exceed 241,200 tons on a 12-month rolling sum. Coal handling operations limited to 8 hours per day. Title I Conditions: PSD total facility permit application & impacts and Minn. R. 7007.3000 Wet all ash and cover ash haul trucks leaving the facility. Minn. R. 7007.0800, subp. 2
Cover all wood hauling systems except for unloading. Minn. R. 7007.0800, subp. 2

A ccess areas, roads, parking facilities

A ll paved roads and areas shall be cleaned to minimize the discharge to the atmosphere of fugitive particulate emissions. Such cleaning shall be accomplished in a manner which minimizes resuspension of particulate matter. Access areas surrounding coal stockpiles and parking facilities which are located within a coal handling facility shall be treated with water or chemical agents. Minn. R. 7011.1105

Truck and hauler unloading stations: Control fugitive particulate emissions from the unloading of trucks or haulers by dust suppression methods so that emissions from such sources are minimized. Minn. R. 7011.1105

Enclosed coal handling facilites or emissions units not specifically covered by any other provision in these parts. If exhaust gases from any enclosed coal handling facility exceed 20 percent opacity, then the owner or operator of such facility shall select and implement one of the following further controls:

(1) install exhaust air system and control exhaust gases so that particulate emissions in such gases do not exceed 0.020 gr/dscf;

(2) control exhaust gases using dust suppression methods so that particulate emissions do not exhibit greater than 20 percent opacity. Minn. R. 7011.1105

Operating practices: Clean up all coal spilled on roads or access areas as soon as practicable using methods that minimize the amount of dust suspended.

Maintain air pollution control equipment in proper operating condition and utilize air pollution control systems as designed. Minn. R. 7011.1105

For all baghouses controlling emissions from enclosed coal handling equipment including those listed an insignificant activity: 1. Inspect quarterly, or as required by manufacturing specifications, all components that are not subject to wear or plugging, including structural components, housing, ducts, and hoods. Maintain a written record of the inspection and any action resulting from the inspection. 2. Inspect monthly, or as required by manufacturing specifications, all components that are subject to wear or plugging. Maintain a written record of the inspection and any action resulting from the inspection. 3. Check visible emissions once every 48 hours. If visible emissions exist, inspect equipment for evidence of malfunction, including broken bags. Record the results of the inspection, and any action taken. Minn. R. 7011.1105

Oily Floor Dry: Limit combustion to (for entire facility): 1) cellulose based only (including rags), 2) 25 tons per year, and 3) 1.25 tons per hour. Title I Condition: to ensure that the emissions increase from the addition of the fuel type is less than significant as defined by 40 CFR Section 52.21; Minn. R. 7007.3000
A ctivated Charcoal: Limit combustion to (for entire facility): 1) material generated on site, material received from Newpage Duluth Paper Mill, or material received from other off-site facilities that is representative of the same material, 2) 25 tons per year, and 3) 3 tons per hour. Title I Condition: to ensure that the emissions increase from the addition of the fuel type is less than significant as defined by 40 CFR Section 52.21; Minn. R. 7007.3000
PERFORMANCE TESTING hdr
Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C. Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD or Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-4

Operating and/or production limits will be placed on emission units based on operating conditions during compliance testing. Limits set as a result of a compliance test (conducted before or after permit issuance) apply until new operating/production limits are set following formal review of a performance test as specified by Minn. R. 7017.2025. Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr
Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, such as for system breakdowns, repairs, calibration checks, and zero and span adjustments (as applicable). Monitoring records should reflect any such periods of process shutdown. Minn. R. 7007.0800, subp. 4(D)

Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr
Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, fuel analyses and certifications, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

Record keeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200.For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

Recordkeeping to demonstrate compliance with coal handling limit: By the 15th day of each month, the Permittee shall calculate and record the total coal handled in the previous month, and calculate and record the total coal handled during the previous 12-month period. Title I Conditions: PSD total facility permit application & impacts analysis and Minn. R. 7007.3000

REPORTING hdr
Shutdowns: Notify the Commissioner at least 24 hours in advance of shutdown of any process or control equipment, if the shutdown would cause an increase in the emission of air contaminants. At the time of notification, notify the Commissioner of the cause of the shutdown and the estimated duration. Notify the Commissioner again when the shutdown is over. Minn. R. 7019.1000, subp. 1

Breakdowns: Notify the Commissioner immediately of a breakdown of more than one hour duration of any process or control equipment, if the breakdown causes an increase in the emission of air contaminants. At the time of notification or as soon thereafter as possible, the Permittee shall also notify the Commissioner of the cause of the breakdown and the estimated duration. Notify the Commissioner again when the breakdown is over.

Shutdown and Breakdown Reporting Requirements for the Dust Collector Systems for Material Handling Equipment: Shutdowns and breakdowns shall be reported on a quarterly basis to the Agency. The quarterly report shall include an identification of the dust collector that broke down or was shutdown, the time and reason for the breakdown or shutdown, a description of any repairs made, and the date and time the dust collector was placed back in service. Minn. R. 7019.1000, subp. 2

Oral Notification of Deviations Endangering Human Health or the Environment: Within 24 hours of discovery, orally notify the Commissioner of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7007.0800, subp. 6(A)

Discovery of Deviations Endangering Human Health or the Environment Report (written): due two working days after discovery of deviation, submit a written description of any deviation endangering human health or the environment to the Commissioner. Include the following information in this written description: cause of the deviation; exact dates of the period of the deviation; if the deviation has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7007.0800, subp. 6(A)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-5

A pplication for Permit Amendment: If you need a permit amendment, submit application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 through Minn. R. 7007.1500

For changes that do not require a permit amendment: - The Permittee shall submit a Part 1 MACT application within 30 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(a). - The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(b). 112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance, 112(j) affected sources include industrial, commercial, and institutional boilers and process heaters; brick and structural clay products manufacturing; clay ceramics manufacturing. 40 CFR Section 63.52(b)(1) and 63.52(e)(1)

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. To be submitted on a form approved by the Commissioner. Minn. R. 7019.3000 through Minn. R. 7019.3010

Emission Fees: due 60 days after receipt of an MPCA bill Minn. R. 7002.0065

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-6

Subject Item: GP 001 Boilers 3 and 4

Associated Items: EU 003 Boiler 3

EU 004 Boiler 4
MR 101 SO2 monitor - low range

MR 102 NOx monitor

MR 103 CO2 monitor
MR 104 SO2 monitor - high range

MR 107 flow monitor

MR 108 opacity monitor

What to do Why to do it
TRIAL BURN REQUIREMENTS hdr

Waste wood fuel limit: The Permittee may burn up to 28,500 tons of woodwaste consisting of rejects and/or trimmings consisting primarily of wood with some glues and/or adhesives and backings. After 28,500 tons are burned, if the Permittee wishes to continue burning waste wood as described herein, the Permittee shall determine what permit amendment (if any) is necessary to continue as outlined below. Minn. 7007.0800, subp. 2

Notification/Reporting: The Permittee shall: 1) submit notification of the commencement of the trial burn, within 15 days of such date; 2) submit notification of the completion of the trial burn, within 15 days of such date; 3) complete a report within 180 days of the completion of the trial burn that examines the impact of burning waste wood as described herein on emissions using records from the CEM/COM equipment at the facility and other information.

A fter the trial burn is complete, if the Permittee wishes to continue burning waste wood as described herein a permit applicability determination should be made using the information in the report required by # 3). If a permit amendment is necessary, a copy of this report shall be included with the application. Minn. 7007.0800, subps. 5 and 6

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-7

Subject Item: EU 001 Boiler 1

Associated Items: SV 001 Main Stack

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.01 lbs/million BTU heat input based on a 24-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); most stringent, meets limit set by Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity except up to 60% opacity for four minutes in any 60-minute period and up to 40% opacity for four additional minutes in any 60-minute period Minn. R. 7011.0510, subp. 2

Sulfur Dioxide: less than or equal to 0.24 lbs/million BTU heat input on a one-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k), ; most stringent, meets limit set by Minn. R. 7011.0510, subp. 1 Nitrogen Dioxide: less than or equal to 0.49 lbs/million BTU heat input on a 30-day rolling average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 Carbon Monoxide: less than or equal to 0.04 lbs/million BTU heat input on a one-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000
OPERATIONAL LIMITS hdr

Fuel limited to No. 2 Fuel oil only, except natural gas may be used as necessary for initial firing only. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a minimum heating value of 136,598 Btu per gallon. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a maximum ash content of 0.00141 lbs ash per gallon. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a maximum sulfur content of 0.23% by weight. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 MONITORING, RECORDKEEPING AND REPORTING HDR

The Permittee shall maintain records of No. 2 fuel oil sampling results or vendor certifications, for a minimum of 5 years. Title I Condition: PSD permit application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 Collect and analyze a fuel oil sample from each delivery of fuel oil, or shall obtain and keep copies of vendor certifications from each delivery. The information from the vendor certification or analysis must give the fuel oil sulfur content, ash content, and heating value for the purposes of demonstrating compliance with the sulfur dioxide emission limit, the sulfur content limit, the ash content limit, and the minimum heating value limit. All analyses shall be completed no later than 30 days after the sampling date. Samples shall be collected from the fuel oil prior to the oil being placed in the storage tank. The sample shall be analyzed for sulfur wt%, heating value in Btu/lb, density in lb/gal, and ash content in wt%, following ASTM methods D-1552, D-240, D-1481, and D-482, respectively, or equivalent methods approved by the Commissioner. Title I Condition: PSD permit application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000

Notify: due 30 days after Startup . Written notification of startup is required to trigger the Initial Performance Test for Boiler No. 1. Minn. R. 7007.0800, subp. 2

Initial Performance Test: due 180 days after Startup to determine compliance with the particulate matter emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the opacity limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the nitrogen oxides emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the carbon monoxide emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-8

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD or Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2.A. and 3.B.

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3.B.

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emision limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-9

Subject Item: EU 002 Boiler 2

Associated Items: SV 001 Main Stack

What to do Why to do it
EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.01 lbs/million BTU heat input based on a 24-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); most stringent, meets limit set by Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity except up to 60% opacity for four minutes in any 60-minute period and up to 40% opacity for four additional minutes in any 60-minute period Minn. R. 7011.0510, subp. 2

Sulfur Dioxide: less than or equal to 0.24 lbs/million BTU heat input on a one-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); most stringent, meets limit set by Minn. R. 7011.0510, subp. 1 Nitrogen Dioxide: less than or equal to 0.49 lbs/million BTU heat input on a 30-day rolling average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 Carbon Monoxide: less than or equal to 0.04 lbs/million BTU heat input on a one-hour average Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000
OPERATIONAL LIMITS hdr

Fuel limited to No. 2 Fuel oil only, except natural gas may be used as necessary for initial firing only. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a minimum heating value of 136,598 Btu per gallon. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a maximum ash content of 0.00141 lbs ash per gallon. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 No. 2 fuel oil shall have a maximum sulfur content of 0.23% by weight. Title I Conditions: PSD Permit Application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 MONITORING, RECORDKEEPING AND REPORTING hdr

The Permittee shall maintain records of No. 2 fuel oil sampling results or vendor certifications, for a minimum of 5 years. Title I Condition: PSD permit application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000 Collect and analyze a fuel oil sample from each delivery of fuel oil, or shall obtain and keep copies of vendor certifications from each delivery. The information from the vendor certification or analysis must give the fuel oil sulfur content, ash content, and heating value for the purposes of demonstrating compliance with the sulfur dioxide emission limit, the sulfur content limit, the ash content limit, and the minimum heating value limit. All analyses shall be completed no later than 30 days after the sampling date. Samples shall be collected from the fuel oil prior to the oil being placed in the storage tank. The sample shall be analyzed for sulfur wt%, heating value in Btu/lb, density in lb/gal, and ash content in wt%, following ASTM methods D-1552, D-240, D-1481, and D-482, respectively, or equivalent methods approved by the Commissioner. Title I Condition: PSD permit application and impacts analysis, 40 CFR Section 52.21(k); Minn. Rule 7007.3000

Notify: due 30 days after Startup . Written notification of startup is required to trigger the Initial Performance Test for Boiler No. 2. Minn. R. 7007.0800, subp. 2

Initial Performance Test: due 180 days after Startup to determine compliance with the particulate matter emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the opacity limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the nitrogen oxides emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Startup to determine compliance with the carbon monoxide emission limit based on PSD modeling. Compliance shall be determined based on the average of three runs per Minn. R. 7017.2020, subp. 5. Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-10

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD or Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2.A. and 3.B.

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3.B.

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emision limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-11

Subject Item: EU 003 Boiler 3

Associated Items: CE 001 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones
CE 002 Electrostatic Precipitator - High Efficiency

GP 001 Boilers 3 and 4

SV 001 Main Stack

What to do Why to do it Total Particulate Matter: less than or equal to (0.025x + 0.027y)/(x+y) lb/mmBtu based on a 24-hour average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu Title I Conditions: Limit to restrict potential emission increases to less than significant as defined by 40 CFR Section 51.165 and 40 CFR Section 52.24. Also ensures compliance with 40 CFR Section 60.43b. Minn. R. 7007.4000 - 7007.4030

Opacity: less than or equal to 20 percent opacity using 6 Minute Average except for one 6-minute period per hour of not greater than 27% opacity. 40 CFR Section 60.43b(f) Minn. R. 7011.0565 Nitrogen Oxides: less than or equal to (0.6x + 0.4y +0.1z)/(x+y+z) lb/mmBtu based on a 30 day rolling average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z = heat input from natural gas in mmBtu

Once each hour, the Permittee shall use the NOx emission limit equation to calculate the effective NOx emission limit. Title I Conditions: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50. Also ensures compliance with 40 CFR Section 60.44b. Minn. R. 7007.3000

Carbon Monoxide: less than or equal to (0.35x + 0.45y + 0.04z)/(x+y+z) lb/mmBtu based on a one-hour average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z = heat input from natural gas in mmBtu Title I Conditions: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50 Minn. R. 7007.3000

Sulfur Dioxide: less than or equal to (2.03Sx + 0.17y)/(x+y) lb/mmBtu based on a one hour averaging period, where:

S = the allowed sulfur content in coal in percent by weight determined by fuel sampling and analysis (see the following requirement for more detail) x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu

Once each hour, the Permittee shall use the SO2 emission limit equation to calculate the effective SO2 emission limit. Title I Conditions: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50. Also ensures compliance with 40 CFR Section 60.43(a) Minn. R. 7007.3000

Limit of coal sulfur content (by weight):

- 0.58% when burned alone or with natural gas or sludge, - may not exceed 0.9% at any time - When coal is being burned in combination with wood, the sulfur content limit shall vary as follows:

S = 8.13 X rE

S = allowable percent sulfur by weight r = coal feed rate in tons per hour. E = the exponent (-0.88) of "r" For use of this equation, r must be greater than or equal to 12. When r is less than 12, S = 0.9%. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

The Permittee shall only burn wood (including creosoted railroad ties), coal, natural gas, sludge from NewPage Duluth Paper Mill clarifier, oily cellulose-based sorbents (including oily rags), oily coal and oily wood (coal or wood with oil spilled on it), boiler cleaning agents, activated charcoal, hardboard rejects, and cellulose fill from mattress recycling in EU003. Other materials may be combusted in this emission unit for a short period of time during a trial burn as approved by an amendment to this permit. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-12

Boiler cleaning agents burn requirements: agents must be EDTA type or A mmonium Bromate, agents generated on-site, maximum of 5% of total fuel mass input, oxygen must be 3% or greater, and agents may be burned only while the boiler is operating at 75 percent of rated capacity or greater.

During the initial burn (after issuance of this permit) in EU 003 of boiler cleaning agents, the Permittee shall monitor CO and opacity emissions to deterimine the compliance status of CO and opacity emissions during the burn. Monitoring results for the initial burn shall be submitted to the Agency. If compliance with the EU 003 CO and opacity limitations is shown, CO monitoring is not required during subsequent boiler cleaning agent combustion events. Minn. R. 7007.0800, subp. 2

Fuel usage limits: - 22 tons per hour for coal; - 67 tons per hour for wood; - 0.305 MMCF per hour for natural gas. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Fuel Sampling: The Permittee shall sample solid fuel as follows: 1) Daily composite sampling for wood fuel; and 2) sample one coal delivery each week according to the Permittee's sampling plans approved by the MPCA on November 18, 1987 (except the need for a duplicate gross 240 pound sample is not required). Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Fuel Analysis: The Permittee shall analyze solid fuel samples using ASTM methods or equivalent methods approved by the Commissioner. Samples shall be analyzed for the following parameters:

Coal: Sulfur content in wt. %, heating value in Btus per lb. Wood: Heating value in Btus per lb.

The average heating value for natural gas may be obtained from the vendor.

The Permittee shall maintain the records of all analyses for a period of 5 years from the date of recording. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Maximum allowable heat input (based on 8-hour block averages): - 590 mmBtu/hour at any time - 380 mmBtu/hr from coal - 590 mmBtu/hr from wood - When wood fuel = 100% chipped railroad ties: maximum total heat input from all fuels = 326 mmBtu/hr, chipped railroad tie heat input shall not exceed 86% of total heat input, and coal heat input shall not be less than 14% of total heat input. - 305 mmBtu/hr from natural gas Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Total heat input shall be determined using the following equations: Total heat input to EU003 = x + y + z (not to exceed 590 mmBtu/hr) x = 380 - [(22-r) X (17.2)] y = 590 - [(67-s) X (8.8)] z = 305 - [(0.305-t) X (1000)] x= heat derived from the burning of coal over any hour in mmBtu y= heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z= heat derived from the burning of natural gas over any hour in mmBtu r = coal feed rate to boiler in tons per hour s = wood feed rate to boiler in tons per hour t = natural gas feed rate to boiler in million cubic feet per hour Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Monitoring and Recordkeeping for fuel usage and heat input:

The Permittee shall record the usage rate of each solid fuel on a daily basis, and calculate and record the hourly average fuel use for each solid fuel by dividing the daily fuel use by the number of hours of operation for that day. The Permittee shall measure the natural gas usage rate, in million cubic feet per hour, using a fuel meter. The Permittee shall calculate and record the heat input during any hour from each fuel, as well as the total heat input for that hour.

Heat content value of solid fuel shall be obtained from fuel sampling as required in this permit. Heat content value of natural gas shall be obtained from the natural gas vendor.

The Permittee shall maintain all fuel usage and heat input records for five years from the date of recording. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Record type and usage rate of each fuel on a daily basis, and calculate the hourly average fuel use for each fuel type by dividing the daily fuel use by the number of hours of operation for that day. Records shall be maintained for a minimum of 5 years. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-13

Performance Test: due before end of each 60 months starting 04/01/2002 to determine compliance with the Title I particulate matter emission limit while burning coal, wood chips (including railroad ties), sludge, or any combination thereof. Tests shall be conducted at intervals not to exceed 60 months between tests. Particulate emissions testing shall be conducted in accordance with the procedures in 40 CFR Section 60.46b(d) and Minn. R. 7017.2001 - 7017.2060 so that test results can also be used to determine compliance with 40 CFR Section 60.43b. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months following Initial Performance Test to determine compliance with Title I CO emission limit while burning coal, wood chips (including railroad ties), sludge, or any combination thereof. Tests shall be conducted at intervals not to exceed 60 months between tests. Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD or Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-14

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emision limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

CONTINUOUS EMISSION MONITOR REQUIREMENTS hdr
The owner or operator of an affected facility (EU003) shall install, calibrate, maintain, and operate a continuous emission monitoring system for measuring and recording sulfur dioxide emissions. 40 CFR Section 60.45(a) Minn. R. 7011.0565

The owner or operator of an affected facility (EU003) shall install, calibrate, maintain, and operate a continuous monitoring system for measuring and recording nitrogen oxides emissions. 40 CFR Section 60.48b(b) Minn. R. 7011.0565

The owner or operator of an affected facility (EU003) shall install, calibrate, maintain and operate a continuous monitoring system for measuring and recording opacity emissions. 40 CFR Section 60.48b(a) Minn. R. 7011.0565

The Permittee shall use the data from the NOx CEM on SV001 to determine the 30-day rolling average NOx emission rate. 40 CFR Section 60.46b(e)(2) Minn. R. 7011.0565 The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affect unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10; Minn. R. 7017.1020

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-15

Subject Item: EU 004 Boiler 4

Associated Items: CE 003 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones
CE 004 Electrostatic Precipitator - High Efficiency

GP 001 Boilers 3 and 4

SV 001 Main Stack

What to do Why to do it Total Particulate Matter: less than or equal to (0.025x + 0.027y)/(x+y) lb/mmBtu based on a 24-hour average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu Title I Condition: Limit to restrict potential emission increases to less than significant as defined by 40 CFR Section 51.165 and 40 CFR Section 52.24. Also ensures compliance with 40 CFR Section 60.43b. Minn. R. 7007.4000 - 7007.4030

Opacity: less than or equal to 20 percent opacity using 6 Minute Average except for one 6-minute period per hour of not greater than 27% opacity. 40 CFR Section 60.43b(f) Minn. R. 7011.0565 Nitrogen Oxides: less than or equal to (0.6x + 0.4y +0.1z)/(x+y+z) lb/mmBtu based on a 30 day rolling average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z = heat input from natural gas in mmBtu

Once each hour, the Permittee shall use the NOx emission limit equation to calculate the effective NOx emission limit. Title I Condition: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50. Also ensures compliance with 40 CFR Section 60.44b. Minn. R. 7007.3000

Carbon Monoxide: less than or equal to (0.35x + 0.45y + 0.04z)/(x+y+z) lb/mmBtu based on a one-hour average, where:

x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z = heat input from natural gas in mmbtu Title I Condition: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50 Minn. R. 7007.3000

Sulfur Dioxide: less than or equal to (2.03Sx + 0.17y)/(x+y) lb/mmBtu based on a one hour averaging period, where:

S = the allowed sulfur content in coal in percent by weight determined by fuel sampling and analysis (see the following requirement for more detail). x = heat derived from the burning of coal over any hour in mmBtu y = heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu

Once each hour, the Permittee shall use the SO2 emission limit equation to calculate the effective SO2 emission limit. Title I Condition: 40 CFR Section 52.21 BACT Limit; 40 CFR pt. 50. Also ensures compliance with 40 CFR Section 60.43(a) Minn. R. 7007.3000

Limit of coal sulfur content (by weight):

- 0.58% when burned alone or with natural gas or sludge, - may not exceed 0.9% at any time - When coal is being burned in combination with wood, the sulfur content limit shall vary as follows:

S = 8.13 X rE

S = allowable percent sulfur by weight r = coal feed rate in tons per hour. E = the exponent (-0.88) of "r" For use of this equation, r must be greater than or equal to 12. When r is less than 12, S = 0.9%. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

The Permittee shall only burn wood (including creosoted railroad ties), coal, natural gas, sludge from NewPage Duluth Paper Mill clarifier, oily cellulose-based sorbents (including oily rags), oily coal and oily wood (coal or wood with oil spilled on it), boiler cleaning agents, activated charcoal, hardboard rejects, and cellulose fill from mattress recycling in EU004. Other materials may be combusted in this emission unit for a short period of time during a trial burn as approved by an amendment to this permit. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-16

Boiler cleaning agents burn requirements: agents must be EDTA type or A mmonium Bromate, agents generated on-site, maximum of 5% of total fuel mass input, oxygen must be 3% or greater, and agents may be burned only while the boiler is operating at 75 percent of rated capacity or greater.

During the initial burn (after issuance of this permit) in EU 004 of boiler cleaning agents, the Permittee shall monitor CO and opacity emissions to deterimine the compliance status of CO and opacity emissions during the burn. Monitoring results for the initial burn shall be submitted to the Agency. If compliance with the EU 004 CO and opacity limitations is shown, CO monitoring is not required during subsequent boiler cleaning agent combustion events. Minn. R. 7007.0800, subp. 2

Fuel usage rate limits: - 22 tons per hour for coal; - 67 tons per hour for wood; - 0.305 MMCF per hour for natural gas. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Fuel Sampling: The Permittee shall sample solid fuel as follows: 1) Daily composite sampling for wood fuel; and 2) sample one coal delivery each week according to the Permittee's sampling plans approved by the MPCA on November 18, 1987 (except the need for a duplicate gross 240 pound sample is not required). Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Fuel Analysis: The Permittee shall analyze solid fuel samples using ASTM methods or equivalent methods approved by the Commissioner. Samples shall be analyzed for the following parameters:

Coal: Sulfur content in wt. %, heating value in Btus per lb. Wood: Heating value in Btus per lb.

The average heating value for natural gas may be obtained from the vendor.

The Permittee shall maintain the records of all analyses for a period of 5 years from the date of recording. Minn. R. 7007.0800, subp. 2 and subp. 4

Maximum allowable heat input (based on 8-hour block averages): - 590 mmBtu/hour at any time - 380 mmBtu/hr from coal - 590 mmBtu/hr from wood - When wood fuel = 100% chipped railroad ties: maximum total heat input from all fuels = 326 mmBtu/hr, chipped railroad tie heat input shall not exceed 86% of total heat input, and coal heat input shall not be less than 14% of total heat input. - 305 mmBtu/hr from natural gas Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Total heat input shall be determined using the following equations: Total heat input to EU003 = x + y + z (not to exceed 590 mmBtu/hr) x = 380 - [(22-r) X (17.2)] y = 590 - [(67-s) X (8.8)] z = 305 - [(0.305-t) X (1000)] x= heat derived from the burning of coal over any hour in mmBtu y= heat derived from the burning of wood and wood waste portion of sludge and railroad ties over any hour in mmBtu z= heat derived from the burning of natural gas over any hour in mmBtu r = coal feed rate to boiler in tons per hour s = wood feed rate to boiler in tons per hour t = natural gas feed rate to boiler in million cubic feet per hour Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Monitoring and Recordkeeping for fuel usage and heat input:

The Permittee shall record the usage rate of each solid fuel on a daily basis, and calculate and record the hourly average fuel use for each solid fuel by dividing the daily fuel use by the number of hours of operation for that day. The Permittee shall measure the natural gas usage rate, in million cubic feet per hour, using a fuel meter.

The Permittee shall calculate and record the heat input during any hour from each fuel, as well as the total heat input for that hour.

Heat content value of solid fuel shall be obtained from fuel sampling as required in this permit. Heat content value of natural gas shall be obtained from the natural gas vendor.

The Permittee shall maintain all fuel usage and heat input records for five years from the date of recording. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-17

Record type and usage rate of each fuel on a daily basis, and calculate the hourly average fuel use for each fuel type by dividing the daily fuel use by the number of hours of operation for that day. Records shall be maintained for a minimum of 5 years. Title I Conditions: PSD permit application and impacts analysis Minn. R. 7007.3000

Performance Test: due before end of each 60 months starting 04/01/2002 to determine compliance with the Title I particulate matter emission limit while burning coal, wood chips (including railroad ties), sludge, or any combination thereof. Tests shall be conducted at intervals not to exceed 60 months between tests. Particulate emissions testing shall be conducted in accordance with the procedures in 40 CFR Section 60.46b(d) and Minn. R. 7017.2001 - 7017.2060 so that test results can also be used to determine compliance with 40 CFR Section 60.43b. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months following Initial Performance Test to determine compliance with Title I CO emission limit while burning coal, wood chips (including railroad ties), sludge, or any combination thereof. Tests shall be conducted at intervals not to exceed 60 months between tests. Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD or Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2(A) and 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-18

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% any applicable emision limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

CONTINUOUS EMISSION MONITOR REQUIREMENTS hdr
The owner or operator of an affected facility (EU004) shall install, calibrate, maintain, and operate a continuous emission monitoring system for measuring and recording sulfur dioxide emissions. 40 CFR Section 60.45(a)

The owner or operator of an affected facility (EU004) shall install, calibrate, maintain, and operate a continuous monitoring system for measuring and recording nitrogen oxides emissions. 40 CFR Section 60.48b(b) Minn. R. 7011.0565

The owner or operator of an affected facility (EU004) shall install, calibrate, maintain and operate a continuous monitoring system for measuring and recording opacity emissions. 40 CFR Section 60.48b(a) Minn. R. 7011.0565

The Permittee shall use the data from the NOx CEM on SV001 to determine the 30-day rolling average NOx emission rate. 40 CFR Section 60.46b(e)(2) Minn. R. 7011.0565 The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affect unit in accordance with 40 CFR Section 75.10 40 CFR Section 75.10; Minn. R. 7017.1020

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-19

Subject Item: CE 002 Electrostatic Precipitator - High Efficiency

Associated Items: EU 003 Boiler 3

What to do Why to do it Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subp. 2 and 14
The Permittee shall operate and maintain CE002 at all times that any emission unit controlled by CE002 is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subp. 2 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - excessive visible emissions are observed; - any recorded operating parameter is outside the required operating range; or - CE002 or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range, eliminate excessive visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for CE002. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

Periodic Inspections: At least once per calendar year, or as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subp. 4, 5 and 14

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for Total Secondary Power. The owner or operator shall measure the indicators with a Distributed Control System.

Parameter range indicating normal operation is: Total Secondary power greater than or equal to 25 kw as a 3-hour average

Secondary Power for a field is calculated from measurement of seconday voltage and current. Total Seconday Power is the sum of the power for all fields. Voltage and current are measured digitally on a continuous basis and used to calculate power every 15 minutes. Hourly average power is calculated using 4 consecutive 15-minute calculated values. An excursion from the specfied minimum of 25 kw is based on a three-hour rolling average. 40 CFR Section 64.3(b) or (d) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under 40 CFR pt. 64 upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintainig necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit and/or air pollution control equipment to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitiation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-20

The owner or operator shall report exceedances or excursions under 64.7 and 64.8 when the exceedance or excursion are greater than the limit and averaging period. The owner/operator shall submit this report with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-21

Subject Item: CE 004 Electrostatic Precipitator - High Efficiency

Associated Items: EU 004 Boiler 4

What to do Why to do it Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subp. 2 and 14
The Permittee shall operate and maintain CE004 at all times that any emission unit controlled by CE004 is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subp. 2 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - excessive visible emissions are observed; - any recorded operating parameter is outside the required operating range; or - CE004 or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range, eliminate excessive visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for CE004. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subp. 4, 5, and 14

Periodic Inspections: At least once per calendar year, or as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subp. 4, 5 and 14

COMPLIANCE ASSURANCE MONITORING hdr

The owner or operator shall comply with the approved monitoring for Total Secondary Power. The owner or operator shall measure the indicators with a Distributed Control System.

Parameter range indicating normal operation is: Total Secondary power greater than or equal to 25 kw as a 3-hour average

Secondary Power for a field is calculated from measurement of seconday voltage and current. Total Seconday Power is the sum of the power for all fields. Voltage and current are measured digitally on a continuous basis and used to calculate power every 15 minutes. Hourly average power is calculated using 4 consecutive 15-minute calculated values. An excursion from the specfied minimum of 25 kw is based on a three-hour rolling average. 40 CFR Section 64.3(b) or (d) Minn. R. 7017.0200

The owner or operator shall conduct the monitoring required under 40 CFR pt. 64 upon permit issuance. 40 CFR Section 64.7(a) Minn. R. 7017.0200 The owner or operator shall maintain the monitoring instruments and recorders, including but not limited to maintainig necessary parts for routine repairs of the monitoring equipment. 40 CFR Section 64.7(b) Minn. R. 7017.0200

Continuous Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities, the owner or operator shall conduct all monitoring in continuous operation at all times the pollutant-specific emissions unit is operating. 40 CFR Section 64.7(c) Minn. R. 7017.0200

Response to excursions or exceedances: Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit and/or air pollution control equipment to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 40 CFR Section 64.7(d)(1) Minn. R. 7017.0200

Documentation of need for improved monitoring: After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitiation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the part 70 permit to address the necessary monitoring changes. 40 CFR Section 64.7(e) Minn. R. 7017.0200

The owner or operator shall maintain records of monitoring data monitor performance data, corrective actions taken, any written quality improvement plan required pursuant to 64.8 and any activities undertaken to implement a quality improvement plan, and other supporting information required to be maintained. The owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-22

The owner or operator shall report exceedances or excursions under 64.7 and 64.8 when the exceedance or excursion are greater than the limit and averaging period. The owner/oprator shall submit this report with the Semiannual Deviations Report. 40 CFR Section 64.9(a)(2)(i) Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-23

Subject Item: MR 101 SO2 monitor - low range

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, A ppendix B as amended. 40 CFR Section 75.21; Minn. R. 7017.1020

Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1; Minn. R. 7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 40 CFR Section 60.7(b)

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Section 75.50

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. 40 CFR section 60.13(e), subp. 6; Minn. R. 7017.1090, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-24

Subject Item: MR 102 NOx monitor

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, A ppendix B as amended. 40 CFR Section 75.21; Minn. R. 7017.1020

Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1; Minn. R. 7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 40 CFR Section 60.7(b)

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Section 75.50

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. 40 CFR section 60.13(e), subp. 6; Minn. R. 7017.1090, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-25

Subject Item: MR 103 CO2 monitor

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, A ppendix B as amended. 40 CFR Section 75.21; Minn. R. 7017.1020

Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1; Minn. R. 7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 40 CFR Section 60.7(b)

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Section 75.50

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. 40 CFR section 60.13(e), subp. 6; Minn. R. 7017.1090, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-26

Subject Item: MR 104 SO2 monitor - high range

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, A ppendix B as amended. 40 CFR Section 75.21; Minn. R. 7017.1020

Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1; Minn. R. 7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 40 CFR Section 60.7(b)

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Section 75.50

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. 40 CFR section 60.13(e), subp. 6; Minn. R. 7017.1090, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-27

Subject Item: MR 107 flow monitor

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each continuous monitor according to the QA/QC procedures in 40 CFR pt. 75, Appendix B as amended. 40 CFR Section 75.21; Minn. R. 7017.1020

Daily Calibration Error (CE) Test: conduct daily CE testing on all continuous monitors required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA required by the Acid Rain Program, in accordance with 40 CFR pt. 75, A ppendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, A ppendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, section 2.2.1 & section 2.2.2; Minn. R. 7017.1020

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 40 CFR Section 60.7(b)

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

Relative Accuracy Test Audit (RATA) Notification: due 30 days before continuous monitor Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the RATA was conducted. Minn. R. 7017.1180, subp. 3

Recordkeeping: The owner or operator must retain records of all monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130; and 40 CFR Section 75.50

Continuous Operation: Continuous monitors must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A monitor must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. 40 CFR section 60.13(e), subp. 6; Minn. R. 7017.1090, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09
Minnesota Power Inc - Hibbard Renewable Energy Ctr

13700015 - 004 Facility Name:

Permit Number: A-28

Subject Item: MR 108 opacity monitor

Associated Items: GP 001 Boilers 3 and 4

What to do Why to do it

A ll COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. Minn. R. 7017.1200, subp. 1, 2 & 3; 40 CFR Section 60.13(e)(1); 40 CFR Section 60.13(h)

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1; 40 CFR Section 60.13(e)

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1. For COMS without automatic zero adjustments, the optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift adjustments. For COMS with automatic zero adjustments, the optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity.

Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). Minn. R. 7017.1210, subp. 2; 40 CFR Section 60.13(d)(l) regarding COMS and 60.13(d)(2)

COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test or Permit Issuance. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. Minn. R. 7017.1220

Notification that Continuous Opacity Monitoring System (COMS) data will be used to determine compliance with opacity standard during performance test: due 30 days prior to the date of performance test. 40 CFR Section 60.7(a)(7)

Permittee is allowed to measure the combined effluent from two or more affected facilities subject to the same emission standard. 40 CFR Section 60.13(g)

## TABLE B: SUBMITTALS
Facility Name: Minnesota Power Inc - Hibbard Renewable Energy Ctr

Permit Number: 13700015 - 004 12/23/09 B-1

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

## TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS
Facility Name: Minnesota Power Inc - Hibbard Renewable Energy Ctr

Permit Number: 13700015 - 004 12/23/09 B-2

What to send When to send Portion of Facility Affected
A pplication for Permit Reissuance due 180 days before expiration of Existing Permit Total Facility

Relative Accuracy Test Audit (RATA) Notification due 30 days before CEMS Relative Accuracy Test Audit (RATA) . MR101, MR102, MR103, MR104, MR107

Testing Frequency Plan due 60 days after Initial Performance Test for particulate matter, nitrogen oxide, opacity and carbon monoxide emission limits required by PSD modeling. The plan shall specify a testing frequency using the test data based on MPCA guidance. Future performance tests based on year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required on written approval of MPCA per Minn. R. 7017.2020, subp. 1. EU001, EU002

## TABLE B: RECURRENT SUBMITTALS
Facility Name: Minnesota Power Inc - Hibbard Renewable Energy Ctr

Permit Number: 13700015 - 004 12/23/09 B-3

What to send When to send Portion of Facility Affected Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter starting 07/14/1997 (Submit Deviations Reporting Form DRF-1). The EER shall indicate all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. MR101, MR102, MR103, MR104

Linearity Test Results Summary due 30 days after end of each calendar quarter following Linearity and Leak Check Test (Acid Rain Program) if performed. MR101, MR102, MR103, MR104, MR107

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar quarter following CEMS Relative Accuracy Test Audit (RATA) . MR101, MR102, MR103, MR104, MR107

Semiannual Deviations Report due 30 days after end of each calendar half-year starting 03/14/2002 . A mid-year report, covering deviations which occurred during the period from January 1 through June 30, is due by July 30 of each year. An end-of-year report, covering deviations which occurred during the period from July 1 through December 31, is due by January 30 of each year. The report must be submitted even if there were no deviations for the reporting period. To be submitted on a form approved by the Commissioner. Total Facility

Compliance Certification due 30 days after end of each calendar year starting 03/14/2002 (for the previous calendar year). To be submitted on a form approved by the Commissioner. Total Facility

# APPENDIX MATERIAL Minnesota Power Inc – Hibbard Renewable Energy Center

Appendix I – Insignificant Activities

Appendix II – Phase II Permit Application (federal Acid Rain regulations)

# Appendix I – Insignificant Activities

Coal unloading

Coal bunker to coal transfer

Fuel oil storage tank

Analysis laboratory

Welding

Parts washer

Natural gas vents

Propane space heating

Ash handling

## These activities must be listed more specifically in the permit applicat ion (and the permit), if any of the following are true: 1) the emissions units are subject to additi onal requirements under Section 114(a)(3) of the Clean Air Act (CAM); 2) the emissions units are subject to Hazardous Air Pollutant requirements under Section 112 of the Clean Air Ac (part 63 NESHAPs); 3) the emissions units are part of a Title I modification (NSR, pt 61 or 63 NESHAP mods, or NSPS mod); 4) if accounted for, the emissions units make the stationary source subject to a part 70 permit;

or 5) the unit is required to do periodic monitoring. If none of the above are true, the activity can be list ed in a general way in the permit with its applicable requirements (per White Paper Number 2). Make sure the TSD addresses why no periodic monitoring is necessary per September 1998 guidance on periodic monitoring. The following table lists likely applicable requirements for subpart 3 insignificant ac tivities (IAs). It is assumed that subpart 2 IAs are consistent with EPA’ s “trivial” activity list and “may be presumptively omitted from part 70 applications” per White Paper Number 1. Subpart 4 IAs would need to be included in the permit as well, but can not easily be addre ssed generically. So, they are not listed below.



# Insignificant Activities and Applicable Requirements
Under Minn. R. 7007.1250, subp. 1(A), the Permittee ma y add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp.2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Pe rmittee is somewhat likely to add and their associated applicable requirements.

Minn. R. 7007.1300,

subpart Rule Description of the Activity Applicable Requirement

3(A) Fuel use: space heaters fuel ed by, kerosene, natural gas, or propane. Minn. R. 7011.0510/0515

3(B) Furnaces, boilers, and incinerators:
nfrared electric ovens; and Minn. R. 7011.0105/0110

f uel burning equipment with a capacity less than 500,000

Btu/hour but only if the total combined capacity of all fuel burning equipment at the stationary source with a capacity less than 500,000 Btu per hour is less than or equal to 2,000,000 Btu/hour. Minn. R. 7011.0510/0515 OR Minn. R. 7011.0610 + Minn. R. 7011.1215, subp. 3 (if pathwaste combustor)

3(C) f abrication operations: equipment us ed exclusively for forging, pressing, drawing, spinning, or extruding hot metals. Minn. R. 7011.0710/0715

3(D) Processing operations: open tumblers with a batch capacity of 1,000 pounds or less; and Minn. R. 7011.0710/0715

3(E) Storage tanks:

## Minn. R. 7007.1300,

subpart Rule Description of the Activity Applicable Requirement

1. gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and Minn. R. 7011.0710/0715 OR Minn. R. 7011.1505, subp. 2(B)/1505, subp. 3(B) OR

Minn. R. 7011.0105/0110 (if not associated with industrial process per the IPE definition) 2. non-hazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of non-hazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. Minn. R. 7011.0710/0715 OR Minn. R. 7011.1505, subp. 2(B)/1505, subp. 3 (B)

OR Minn. R. 7011.0105/0110 (if not associated with industrial process per the IPE definition)
3(F) Cleaning operations: commercial laundries, not including dry cleaners and industrial launderers. Minn. R. 7011.0105/0110

3(G) Emissions from a laboratory, as defined in the subpart. Minn. R. 7011.0510/0515 + Minn. R. 7011.0610 + Minn. R. 7011.0710/0715
3(H) Miscellaneous:

1. equipment used exclusivel y for packaging lubricants or greases; Minn. R. 7011.0710/0715 OR Minn. R. 7011.0105/0110
2. equipment used for hydraulic or hy drostatic testing; Minn. R. 7011.0710/0715
3. brazing, soldering or welding equipment; Minn. R. 7011.0510/.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0710/0715
4. blueprint copiers and photographic processes; Minn. R. 7011.0105/0110
5. equipment used exclusively for melting or application of
wax; Minn. R. 7011.0510/.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0710/0715 6. nonasbestos equipment used exclusively for bonding lining to brake shoes; and Minn. R. 7011.0710/0715

7. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners. Minn. R. 7011.0510/.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0710/0715 3(I) Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; and 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, Case-by-case determination

## Minn. R. 7007.1300,

subpart Rule Description of the Activity Applicable Requirement

volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone. 3(J) Fugitive Emissions from roads and parking lots. Minn. R. 7011.0150
3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment. Minn. R. 7011.0710/0715



# Insignificant Activities Required to Be Listed for Part 70 sources

Minn. R. 7007.1300,

subpart Rule Description of the Activity Applicable Requirement

4 Individual emissions units at a stationary source, each of which has: A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide; B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and C. For hazardous air pollutants, emissions units with: (1) potential emissions of 25 percent or less of the hazardous air pollutant threshol ds listed in subp. 5; or (2) combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart.



# Conditionally Insignificant Activities

Rule Description of the Activity Applicable Requirement

Minn. R. 7008.4100 Total VOC Usage at the stationary source less than 200 gallons or 2000 pounds in each calendar year. See Minn. R. 7008.4100 for recordkeeping and calculation requirements for this activity. Minn. R. 7011.0710/0715

Minn. R. 7008.4110 Emissions from equipment venting particulate matter (PM) or particulate matter less than 10 microns (PM-10) inside a building, provided that emissi ons from the equipment are: a). filtered through an air cleaning system; and b). vented inside of the building 100% of the time. Minn. R. 7011.0710/0715

# Appendix II – Phase II Permit Application (federal Acid Rain regulations)

### Acrobat Document

## Technical Support Document, Permit Action Number: 13700015-004 Page 1 of 3 Date: 12/24/2009 

## TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 13700015 - 004

This technical support document (TSD) is intended for a ll parties interested in the permit and to meet the requirements that have been set forth by the federa l and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision consid ered in the determination to issue the permit.

1. General Information 1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address
Applicant/Address Stationary Source/Address (SIC Code: 4961/4911 ) Minnesota Power 30 West Superior Street Duluth, MN 55807 Minnesota Power – Hibbard Renewable Energy Center 4913 Main St Duluth St. Louis County Contact: Melissa Weglarz Phone: 218.355.3321

1.2 Facility Description The Hibbard Renewable Energy Center steam and power generating facility was jointly owned by Minnesota Power (MP) and the City of Duluth. Boile rs 3 & 4 and their associated equipment were owned by the City of Duluth, whereas MP owned the remaining portion of the facility. The facility is located in the City of Duluth, adjacent to the NewPage paper m ill. The facility combusts a mixture of wood, coal, natural gas and paper mill sludge. The primary mission of the facility is to produce steam for NewPage and its associated paper recycling facility. The facility is also capable of producing electrical energy for the MP system. The site contains four steam gene rating boilers, four steam turbines, coal handling facilities, wood handling facilities, a 3.4 million gallon fuel oil storage tank and natural gas supply lines. The two oldest boilers and their associated turbine-gene rators (Boilers No. 1 and No. 2), and the fuel oil supply tank have been out of service since 1981, but can be used if future plans were to change.

All operations and equipment within the facility bounda ry are established to: (1) provide steam and/or electrical power for on-site and off-site utilization; (2) provide fuel for steam and/or electrical power production or support activities; (3) monitor and cont rol air emissions generated from electrical power production; (4) handle waste heat, wastes and materi als produced from the on-site operations; and (5) provide support activities. These operations and equipment are described below.

Steam and Power Generation Steam and power generation is accomplished primarily through steam generation in two boilers (Boilers No. 3 and No. 4). Both units have spreader stokers and traveling grates. Emissions are discharged through a common 331 foot stack (Stack No. 1). Boilers No. 1 a nd No. 2 are smaller units and if used would also discharge air emissions through Stack No. 1.

Fuel for Steam and Power Generation and Support Equipment/Activities

## Technical Support Document, Permit Action Number: 13700015-004 Page 2 of 3 Date: 12/24/2009 

## Boilers No. 3 and No. 4 are capable of combusting a mixture of wood, sub-bituminous coal, natural gas and sludge. The primary fuel is wood which may include wood chips, sawdust, sander dust, wood bark, chipped railroad ties and other various forms of waste wood from regional suppliers. The wood fuel is supplemented with low-sulfur, sub-bituminous coal a nd natural gas. Boilers No. 3 and No. 4 are capable of combusting wood, coal, and various combinations of wood, coal, and natural gas. This permit allows for the addition of oily coal (coal with oil spilled on it), oily cellulose-based sorbents (including rags), activated charcoal, boiler cleaning agents, and ce llulose fill from mattress recycling as permitted fuels.

The wood fuel is delivered directly to the plant in covered trucks, unloaded and conveyed directly to the A-frame storage building. The wood fuel is conveyed to the wood metering bins and transferred to the boiler’s traveling grate through the auger feed and spreader stoker systems. Combustion occurs in suspension and on the grate.

Coal is delivered to the facility in trucks and unloa ded in a three sided enclosure maintained at negative pressure and vented through a fabric filter. Coal is transferred from the unloading facility to storage bunkers by a bucket conveyor system. Air from the bunkers and coal transfer system is vented through a fabric filter. Coal transfer from the bunker to the bo ilers is accomplished by a totally enclosed conveyor.

Natural gas is supplied to Boilers No. 3 and No. 4 through a pipeline. Natural gas could be supplied to Boilers No. 1 and No. 2 by the same system.

If used in the future as fuel, oil would be delivered by truck and stored in the 3.4 million gallon tank. Piping which would connect the fuel oil storage to the boilers is disconnected.

Air Emission Monitoring and Control Air emissions from the facility are released primarily as a result of the combustion of wood and coal. Smaller amounts of criteria pollutants are emitted fro m the combustion of natural gas and the handling and storage of coal and wood fuels. The combustion of wood and coal also results in the emission of some hazardous air emissions.

Continuous Emission Monitors have been installed, tested and certified to measure and record the combustion emissions from Boilers No. 3 & No. 4 exiting via the common stack, Stack No. 1. The monitors measure and record inform ation on the following parameters: Sulfur Dioxide, Nitrogen Oxides, opacity, Carbon Monoxide, Carbon Dioxi de, and volumetric flow and are located in the breaching leading to the stack.

Particulate emissions from Stack No. 1 due to combus tion in Boilers No. 3 and No. 4 are controlled by multiple cyclones in series with an electrostatic precipitator for each unit. Boilers No. 1 and No. 2 do not have associated pollution control equipmen t. Particulates from coal unloading, transfer, and storage are controlled with fabric filter baghouses. A dditional particulate control is accomplished through the use of enclosures to limit fugitive emissi ons from coal and wood unloading operations.

Waste Heat, Wastes, and Materials The facility is designed to operate with a once-through cooling system to dissipate waste heat in the production of electrical energy. Water from St. Louis Ba y is pumped through the intake structure, used to condense steam from the back side of the turb ine generator and discharged to the bay.

## Technical Support Document, Permit Action Number: 13700015-004 Page 3 of 3 Date: 12/24/2009 

## The combustion of wood and coal also produces ash, whic h is collected off the traveling grates, wetted and transferred to a truck. The ash is used as agricultural soil enhancement or is landfilled.

Support Activities Support activities include the building elevator, vehicl e maintenance, general facility activities, energy production equipment maintenance, piping installa tion and maintenance. These activities can include painting, welding, and cleaning operations. In te rms of air emission regulations, these activities are considered insignificant activities for these purposes.

1.3 Description of Changes Made through this Permit Action This administrative amendment (Permit Action 004) is for a change in ownership of the facility. The Hibbard Energy Center is owned and operated by Minnesota Power, due to purchasing the City of Duluth’s portion of the facility. This amendment was initiated through an administrative amendment application received by MPCA on August 18, 2008, w ith supplemental information received October 15, 2009. This change is made in accordance with Minn. R. 7007.1400, subp. 1(E).

Stora Enso North America paper mill was purchased by NewPage. Therefore, references to Stora Enso North America in the permit have been replaced with NewPage Duluth Paper Mill.

Other updates to the permit to reflect current MPCA policy:

• A recordkeeping requirement that applies to major HAPs sources was added.

• A recordkeeping requirement was added for changes not requiring a permit amendment.

• Since the permit has appendices, a requirement to comply with appendices was added.

• The Delta facility description for control equipment has been updated.

1.4. Facility Emissions There are no emissions increases associated with this permit action.

2. Conclusion Based on the information provided by Minnesota Po wer, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 13700015-004 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Sarah Sevcik (permit writer/engineer) Steve Palzkill (enforcement) Tarik Hanafy (peer reviewer)

AQ File No. 73A; DQ # 2199, 2873

Attachments: Facility Description and CD-01 FormsOMB 2060-0631 Part I Question 14aMinnesota Power Hibbard Renewable Energy Center (1897)Materials listed in the permitHIBBARD "Other" Materials permitted to burn Permitted to burnActuallyburn?(Yes/No)Quantity /yearunitsUnit 3Wood, including creosoted railroad ties 67 tons per hour, also must comply with heat input restrictions yes 106,294 tonsUnit 4Wood, including creosoted railroad ties 67 tons per hour, also must comply with heat input restrictions yes 106,294 tonsHardboard Rejects / Waste wood (consisting of rejectsand/or trimmings consisting primarily of wood with someglues and/or adhesives and backings)up to 28,500 tons yes 1,188 tonsestimated based on last 8yearsSludge from NewPage Duluth Paper Mill clarifier NA yes 7,500 tonstotalOily cellulose-based sorbents (including oily rags) NA yes >1 tonOily coal and oily wood (coal or wood with oil spilled on it) NA yes >1 tonBoiler cleaning agents (must be EDTA type or AmmoniumBromate, and agents generated on-site)Maximum of 5% of total fuel mass input, oxygen must be 3% orgreater, and agents may be burned only while the boiler isoperating at 75 percent of rated capacity or greater.no - -Activated charcoal NA yes 12 tonsmaximum yearly estimateCellulose fill from mattress recycling NA no - -NA = No numerical limit specifically listed in permit, however permit contains complicated formulas for appropriating emissionsdue to each fuel typeU3&4combinedIf "other" was checked in questions 10 or 11 above indicating that any non-fossil fuel or other material (including, but not limited to, plastics, treated wood, rubber belting or gaskets, whole tires, tire-derived fuel, boiler cleaningsolutions, animal wastes, etc.) is either utilized or permitted to be used, please indicate below what materials are combustedin the boiler and in what quantities (specify whether this quantity is on a weight percentage or heat[Btu] basis). Also indicate (yes/no) whether you are permitted to burn non-fossil fuel(s) or other material(s) even if you donot actually burn them.123456789101112131415161718192021222324252627282930313233A B C D E F GH I J KLMOMB 2060-0631 Part I, Question 15:Identification (or designation) of all coal- and oil-fired steam generating units (boilers) (as defined by Clean Air Act section 112(2)(8)) located at this facility)Minnesota Power Hibbard Renewable Energy Center (1897)Facility NameSubpart EIA Plant CodeQ 15.01 Boiler IDUnit 3 Unit 4Q 15.02 Original design fuel (i.e. coal rank or type of oil)Waste wood, coal, and natural gas2Waste wood, coal, and natural gas2Q 15.03Design heat input (mmBtu/hr)1590 590Q 15.04Present maximum heat input, (mmBtu/hr)3518 471Q 15.05 MWe gross capacity summer 35 36Q 15.06 MWe net capacity summer 33 34Q 15.07 Original design gross efficiency (%, HHV)Q 15.08Present operating gross efficiency (%, HHV)4NA NAQ 15.09Design steam pressure (psig)1925 925Q 15.10 Operating steam pressure (psig) 835 835Q 15.11Design steam temperature (°F)1750 750Q 15.12 Operating steam temperature (°F) 725 725Q 15.13Design steam reheat temperature (°F)5NA NAQ 15.14Operating steam reheat temperature (°F)5NA NAQ 15.15 FuelQ 15.16 Hours/year operated 6951 6628.33Q 15.17 Average annual capacity factor for the past 3 years 20.04 01.0Q 15.18 Applicable NSPS Subpart Db Subpart DbQ 15.19 Estimated year of retirement Minnesota Power has no scheduled or planned retirement dates for any of our units1Original design values based on boiler acquisition contracts and/or heat balance drawings. For Hibbard, these values are the retrofitted condition. Design heat input value does not represent maximum capacity at the time of unit commissioning.Design heat input and present maximum heat input are based on blend of the different fuels.2All Hibbard units were originally built as bituminous coal-fired units and later retrofitted to burn waste wood, coal, & natural gas.3Current heat input data from Title V permit application does not represent maximum heat input capacity. We do not partition heat input measurements/calculations out amongst fuel types - this is an overall value of the blend.4We do not measure or calculate boiler efficiency on either unit at this facility.5Units do not have a reheat cycle33% coal, 60% wood, 7% gas, <1% other73.4 on wood (4400btu/lb), coal (8600btu/lb), gas (1000btu/scf)HIBBARD189767.7 on wood (4400 btu/lb)OMB 2060-0631 Part I, Question 16: Emission Control TechnologyMinnesota Power Hibbard Renewable Energy Center (1897)Designate the order of the emission controls -- 1 for first control following the boiler, 2 for second control following the boiler, etc.Plant IDBoilerIDType NOx ControlIn-serviceDateSO2 ControlIn-serviceDatePM ControlIn-serviceDateOther ControlIn-serviceDateHibbard 3 Stoker fired1 - Low NOx Burners, when firing gascontrolled combustion techniques1987 Low sulfur PRB coal 1987 2 - Mechanical Dust Collector, 3 - ESP 1949, 1987 None -1897 4 Stoker-fired1 - Low NOx Burners, when firing gascontrolled combustion techniques1987 Low sulfur PRB coal 1987 2 - Mechanical Dust Collector, 3 - ESP 1951, 1987 None -OMB 2060-0631 Part I Question 22: Guaranteed Emission RateMinnesota Power Hibbard Renewable Energy Center (1897)PMPM10PM2.5SO2HCl and/orHFHCN Metal HAP Hg COOtherorganics(specify)Otherpollutant(specify)1 0.1 lbs/mmBtu or 99%2 0.1 lbs/mmBtu or 99%HibbardMostrecent guaranteed emission rate for each pollutant for which there is a permitted emission limitPlant ID Boiler IDOMB 2060-063 Part II Questions 2-3Coal Shipments - Minnesota Power Hibbard Renewable Energy Center (1897)date_delivered tons Boiler ID# State County Coal SeamFuel ShipMethod Sulfur % Ash % BTU/lb Mercury Chlorine Fluorine Nickel Other01-Jan-09 360.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Jan-09 538.923,4MT Big Horn Anderson Dietz TR0.273.509,303.00N/A N/A N/A N/A N/A03-Jan-09 474.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Jan-09 487.973,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Jan-09 702.413,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Jan-09 403.033,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Jan-09 301.833,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Jan-09 398.963,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Jan-09 297.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Jan-09 462.303,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Jan-09 471.873,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Jan-09 249.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Jan-09 502.153,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Jan-09 400.593,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Jan-09 508.923,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Jan-09 452.903,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Jan-09 222.223,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Jan-09 140.363,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Jan-09 111.033,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Jan-09 56.063,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Jan-09 340.133,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Jan-09 84.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Jan-09 194.723,4MT Big Horn Anderson Dietz TR0.334.229,254.00N/A N/A N/A N/A N/A24-Jan-09 112.593,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Jan-09 57.523,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Jan-09 27.273,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Jan-09 239.963,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Jan-09 106.553,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Jan-09 494.623,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Jan-09 301.703,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Jan-09 198.473,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Feb-09 82.063,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Feb-09 285.723,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Feb-09 369.543,4MT Big Horn Anderson Dietz TR0.335.328,984.00N/A N/A N/A N/A N/A04-Feb-09 314.203,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Feb-09 396.143,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Feb-09 230.733,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Feb-09 230.673,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Feb-09 82.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Feb-09 57.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Feb-09 140.183,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Feb-09 171.673,4MT Big Horn Anderson Dietz TR0.313.959,076.00N/A N/A N/A N/A N/A12-Feb-09 198.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Feb-09 56.363,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Feb-09 57.363,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Feb-09 81.913,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Feb-09 54.543,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Feb-09 55.753,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Feb-09 55.893,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Feb-09 55.263,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Feb-09 111.513,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Feb-09 27.733,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Feb-09 27.293,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Feb-09 222.173,4MT Big Horn Anderson Dietz TR0.183.159,449.00N/A N/A N/A N/A N/A24-Feb-09 142.433,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Feb-09 27.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Feb-09 54.253,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Feb-09 251.013,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Mar-09 198.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Mar-09 197.673,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Mar-09 169.203,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Mar-09 57.653,4MT Big Horn Anderson Dietz TR0.354.748,787.00N/A N/A N/A N/A N/A05-Mar-09 224.483,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Mar-09 143.423,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Mar-09 227.553,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Mar-09 113.663,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Mar-09 184.783,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Mar-09 136.693,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Mar-09 245.283,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Mar-09 215.433,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Mar-09 215.823,4MT Big Horn Anderson Dietz TR0.343.639,313.00N/A N/A N/A N/A N/A14-Mar-09 132.923,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Mar-09 137.463,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Mar-09 138.663,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Mar-09 138.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Mar-09 96.893,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Mar-09 219.803,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Mar-09 269.803,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Mar-09 219.303,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Mar-09 294.323,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Mar-09 197.323,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Mar-09 224.443,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Mar-09 150.083,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Mar-09 222.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Mar-09 245.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Mar-09 381.733,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Apr-09 382.603,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Apr-09 165.843,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Apr-09 188.913,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Apr-09 142.523,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Apr-09 168.323,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Apr-09 219.053,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Apr-09 195.213,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Apr-09 169.483,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Apr-09 147.763,4MT Big Horn Anderson Dietz TR0.343.849,224.00N/A N/A N/A N/A N/A10-Apr-09 170.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Apr-09 142.723,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Apr-09 143.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Apr-09 123.473,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Apr-09 147.383,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Apr-09 169.653,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Apr-09 99.633,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Apr-09 196.523,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Apr-09 73.413,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Apr-09 49.623,4MT Big Horn Anderson Dietz TR0.323.749,265.00N/A N/A N/A N/A N/A21-Apr-09 217.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Apr-09 96.533,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Apr-09 122.283,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Apr-09 49.293,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Apr-09 122.353,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Apr-09 147.053,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Apr-09 169.263,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Apr-09 71.563,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Apr-09 167.423,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Apr-09 98.033,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-May-09 71.563,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-May-09 71.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-May-09 71.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-May-09 73.133,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-May-09 121.413,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-May-09 73.133,4MT Big Horn Anderson Dietz TR0.334.258,956.00N/A N/A N/A N/A N/A07-May-09 48.923,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-May-09 197.773,4MT Big Horn Anderson Dietz TR0.354.338,903.00N/A N/A N/A N/A N/A09-May-09 98.593,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-May-09 49.383,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-May-09 97.463,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-May-09 147.183,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-May-09 119.343,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-May-09 146.593,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-May-09 74.343,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-May-09 142.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-May-09 95.843,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-May-09 119.353,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-May-09 119.613,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-May-09 119.283,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-May-09 120.073,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-May-09 95.813,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-May-09 218.023,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-May-09 144.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-May-09 145.553,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-May-09 48.773,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-May-09 343.873,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-May-09 98.693,4MT Big Horn Anderson Dietz TR0.253.039,743.00N/A N/A N/A N/A N/A29-May-09 98.213,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-May-09 146.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-May-09 121.023,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Jun-09 96.453,4MT Big Horn Anderson Dietz TR0.353.929,359.00N/A N/A N/A N/A N/A02-Jun-09 95.773,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Jun-09 119.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Jun-09 119.363,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Jun-09 70.663,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Jun-09 122.393,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Jun-09 95.583,4MT Big Horn Anderson Dietz TR0.303.839,232.00N/A N/A N/A N/A N/A08-Jun-09 143.153,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Jun-09 95.663,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Jun-09 118.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Jun-09 72.233,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Jun-09 143.213,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Jun-09 95.373,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Jun-09 48.233,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Jun-09 73.643,4MT Big Horn Anderson Dietz TR0.283.429,293.00N/A N/A N/A N/A N/A16-Jun-09 98.173,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Jun-09 74.563,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Jun-09 73.133,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Jun-09 73.473,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Jun-09 73.103,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Jun-09 123.793,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Jun-09 119.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Jun-09 70.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Jun-09 47.343,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Jun-09 143.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Jun-09 72.613,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Jun-09 122.783,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Jun-09 171.593,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Jun-09 96.143,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Jun-09 96.183,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Jul-09 144.733,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Jul-09 144.623,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Jul-09 144.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Jul-09 96.203,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Jul-09 144.883,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Jul-09 47.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Jul-09 97.723,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Jul-09 171.653,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Jul-09 195.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Jul-09 149.353,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Jul-09 121.073,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Jul-09 48.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Jul-09 200.743,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Jul-09 173.583,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Jul-09 242.883,4MT Big Horn Anderson Dietz TR0.333.989,117.00N/A N/A N/A N/A N/A18-Jul-09 123.553,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Jul-09 122.103,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Jul-09 96.703,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Jul-09 94.883,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Jul-09 94.583,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Jul-09 70.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Jul-09 94.223,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Jul-09 142.413,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Jul-09 94.633,4MT Big Horn Anderson Dietz TR0.394.419,163.00N/A N/A N/A N/A N/A27-Jul-09 97.673,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Jul-09 122.783,4MT Big Horn Anderson Dietz TR0.363.789,254.00N/A N/A N/A N/A N/A29-Jul-09 147.213,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Jul-09 49.583,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Jul-09 123.263,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Aug-09 96.573,4MT Big Horn Anderson Dietz TR0.323.709,349.00N/A N/A N/A N/A N/A02-Aug-09 99.003,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Aug-09 97.253,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Aug-09 72.993,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Aug-09 168.183,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Aug-09 49.833,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Aug-09 121.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Aug-09 161.993,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Aug-09 165.393,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Aug-09 70.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Aug-09 70.933,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Aug-09 95.193,4MT Big Horn Anderson Dietz TR0.314.399,204.00N/A N/A N/A N/A N/A14-Aug-09 46.563,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Aug-09 70.843,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Aug-09 94.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Aug-09 122.843,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Aug-09 74.603,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Aug-09 98.523,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Aug-09 146.013,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Aug-09 98.623,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Aug-09 98.773,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Aug-09 73.873,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Aug-09 72.383,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Aug-09 97.383,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Aug-09 24.173,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Aug-09 118.373,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Aug-09 95.953,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Aug-09 165.753,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Aug-09 72.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Aug-09 118.813,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Sep-09 71.193,4MT Big Horn Anderson Dietz TR0.304.308,983.00N/A N/A N/A N/A N/A02-Sep-09 118.723,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Sep-09 94.093,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Sep-09 164.573,4MT Big Horn Anderson Dietz TR0.304.459,296.00N/A N/A N/A N/A N/A05-Sep-09 118.793,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Sep-09 94.333,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Sep-09 74.003,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Sep-09 99.503,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Sep-09 49.183,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Sep-09 98.433,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Sep-09 98.073,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Sep-09 121.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Sep-09 73.763,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Sep-09 97.373,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Sep-09 73.973,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Sep-09 121.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Sep-09 144.893,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Sep-09 73.993,4MT Big Horn Anderson Dietz TR0.274.678,970.00N/A N/A N/A N/A N/A19-Sep-09 120.333,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Sep-09 70.473,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Sep-09 262.953,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Sep-09 262.873,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Sep-09 266.173,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Sep-09 265.813,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Sep-09 143.723,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Sep-09 120.333,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Sep-09 122.183,4MT Big Horn Anderson Dietz TR0.304.3110,072.00N/A N/A N/A N/A N/A28-Sep-09 220.553,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Sep-09 197.693,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Sep-09 247.463,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Oct-09 293.233,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A02-Oct-09 144.593,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A03-Oct-09 146.563,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A04-Oct-09 97.513,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A05-Oct-09 70.773,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A06-Oct-09 170.383,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A07-Oct-09 291.623,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A08-Oct-09 245.503,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A09-Oct-09 223.563,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A10-Oct-09 221.063,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A11-Oct-09 240.883,4MT Big Horn N/A TR0.314.148,923.00N/A N/A N/A N/A N/A12-Oct-09 217.113,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A13-Oct-09 170.023,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A14-Oct-09 167.293,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A15-Oct-09 118.213,4MT Big Horn N/A TRN/A N/A N/A N/A N/A N/A N/A N/A16-Oct-09 71.133,4MT Big Horn N/A TR0.325.099,177.00N/A N/A N/A N/A N/A17-Oct-09 141.703,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Oct-09 117.833,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Oct-09 99.193,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Oct-09 390.653,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Oct-09 196.643,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Oct-09 364.363,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Oct-09 316.883,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Oct-09 266.023,4MT Big Horn Anderson Dietz TR0.314.098,879.00N/A N/A N/A N/A N/A25-Oct-09 245.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Oct-09 291.083,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Oct-09 222.983,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Oct-09 146.503,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Oct-09 221.463,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Oct-09 266.243,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Oct-09 171.733,4MT Big Horn Anderson Dietz TR0.293.758,655.00N/A N/A N/A N/A N/A01-Nov-09 332.063,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Nov-09 385.093,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Nov-09 288.273,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Nov-09 459.573,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Nov-09 335.323,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Nov-09 286.623,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A07-Nov-09 265.553,4MT Big Horn Anderson Dietz TR0.313.919,928.00N/A N/A N/A N/A N/A08-Nov-09 287.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Nov-09 340.103,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Nov-09 268.753,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Nov-09 392.603,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Nov-09 291.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A13-Nov-09 121.683,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Nov-09 170.813,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Nov-09 147.153,4MT Big Horn Anderson Dietz TR0.094.048,969.00N/A N/A N/A N/A N/A16-Nov-09 191.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Nov-09 238.113,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Nov-09 263.113,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Nov-09 336.253,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A20-Nov-09 261.743,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Nov-09 238.033,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Nov-09 263.383,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Nov-09 313.833,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Nov-09 412.953,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Nov-09 457.703,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Nov-09 387.243,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A27-Nov-09 439.113,4MT Big Horn Anderson Dietz TR0.344.099,233.00N/A N/A N/A N/A N/A28-Nov-09 315.313,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Nov-09 265.443,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Nov-09 320.693,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A01-Dec-09 218.893,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A02-Dec-09 537.333,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A03-Dec-09 537.083,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A04-Dec-09 363.653,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A05-Dec-09 310.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A06-Dec-09 219.733,4MT Big Horn Anderson Dietz TR0.293.509,118.00N/A N/A N/A N/A N/A07-Dec-09 408.863,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A08-Dec-09 477.913,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A09-Dec-09 261.633,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A10-Dec-09 476.223,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A11-Dec-09 543.443,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A12-Dec-09 357.823,4MT Big Horn Anderson Dietz TR0.313.679,110.00N/A N/A N/A N/A N/A13-Dec-09 281.333,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A14-Dec-09 438.563,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A15-Dec-09 442.413,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A16-Dec-09 496.753,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A17-Dec-09 252.053,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A18-Dec-09 109.243,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A19-Dec-09 82.193,4MT Big Horn Anderson Dietz TR0.334.689,139.00N/A N/A N/A N/A N/A20-Dec-09 222.733,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A21-Dec-09 223.493,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A22-Dec-09 285.803,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A23-Dec-09 480.743,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A24-Dec-09 358.933,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A25-Dec-09 298.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A26-Dec-09 418.083,4MT Big Horn Anderson Dietz TR0.364.669,369.00N/A N/A N/A N/A N/A27-Dec-09 512.123,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A28-Dec-09 560.073,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A29-Dec-09 471.533,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A30-Dec-09 509.853,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/A31-Dec-09 387.303,4MT Big Horn Anderson Dietz TRN/A N/A N/A N/A N/A N/A N/A N/AOil Shipments - Hibbard Energy CenterOMB 2060-063 Part II Questions 2-3ID Gallons Boiler ID# State County Coal SeamFuel ShipMethod Sulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel OtherNo deliveries of oil received for boiler usage at Hibbard Energy Center.Fuel SourceOMB 2060-0631 Part II, Question 8a, 8b, 8dMinnesota Power Hibbard Renewable Energy Center (1897)Boiler ID(as listed in Part I question15)Question 8aEmission test report,parametric monitoring data,or other data or monitoringQuestion 8bDate of testingQuestion 8bType of testingQuestion 8bConstituentsQuestion 8dWere test conducted whilenon-fossil fuels fired inboiler?yes/noBoiler 3 Pace AnalyticalPM and CO Compliance Test3/19-22/2007 stack PM and CO yesBoiler 4 Pace AnalyticalPM and CO Compliance Test3/15-16/2007 stack PM and CO yesOMB 2060-0631 Part II, Question 12 EPA NESHAPS ICR - Responses prepared by Dale Kreage r Minnesota Power Hibbard Renewable Energy Center (1897 )

Boiler ID Test Date PM* SO2 HCL/HF/HCN Metal HAP Hg CO Other organic Unit Load (MW) Net MWH NET) Moisture (%) Flow (dscfm or Nm3/hr) Flue gas oxygen (%, dry) Flue gas CO2 (%, dry) Flue gas temp (oF) Flue gas pressure (atm) Standard temp (F) Standard pressure (atm)

Boiler 3 3/19-22/2007 Test 1 Particulate = 0.022 lb/mmBtu CO = 0.18 lb/mmBtu Test 2 Particulate = 0.022 lb/mmBtu CO = 0.13 lb/mmBtu Test 3 Particulate = 0.014 lb/mmBtu CO = 0.15 lb/mmBtu Test 1 = 10.9 Test 2 = 14.3 Test 3 = 14.1 Test 1 = 138,500 dscfm Test 2 = 147,000 dscfm Test 3 = 142,700 dscfm Test 1 = 10.5 Test 2 = 12.6 Test 3 = 10.1 Test 1 = 9.4 Test 2 = 8.3 Test 3 = 10.2 Test 1 = 412 Test 2 = 410 Test 3 = 417 Test 1 = 68 Test 2 = 68 Test 3 = 68 Test 1 = 29.92 Test 2 = 29.92 Test 3 = 29.92

Boiler 4 3/15-16/2007 Test 1 Particulate = 0.0061 lb/mmBtu CO = 0.14 lb/mmBtu Test 2 Particulate = 0.0091 lb/mmBtu CO = 0.26 lb/mmBtu Test 3 Particulate = 0.016 lb/mmBtu CO = 0.20 lb/mmBtu Test 4 Particulate = 0.0050 lb/mmBtu CO Test 1 = 8.9 Test 2 = 11.7 Test 3 = 12.8 Test 4 = 14.9 Test 5 = 13.7 Test 1 = 137,100 dscfm Test 2 = 140,300 dscfm Test 3 = 135,900 dscfm Test 4 = 126,800 dscfm Test 5 = 125,500 dscfm Test 1 = 10.5 Test 2 = 11.3 Test 3 = 11.2 Test 4 = 7.4 Test 5 = 8.4 Test 1 = 9.6 Test 2 = 9.4 Test 3 = 9.5 Test 4 = 12.7 Test 5 = 12.0 Test 1 = 454 Test 2 = 464 Test 3 = 465 Test 4 = 478 Test 5 = 472 Test 1 = 68 Test 2 = 68 Test 3 = 68 Test 4 = 68 Test 5 = 68 Test 1 = 29.92 Test 2 = 29.92 Test 3 = 29.92 Test 4 = 29.92 Test 5 = 29.92

* Averaging Time = 3 - 1 hour rounds

## TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper contai ning at least 10% fibers from paper recycled by consumers 

## AIR EMISSION PERMIT NO. 13700013-006

IS ISSUED TO

Minnesota Power Division of ALLETE Inc

MINNESOTA POWER - LASKIN ENERGY CENTER 5699 Colby Lake Road Hoyt Lakes, St. Louis County, MN 55750

The emission units, control equipment and emission stack s at the stationary source authorized in this permit are as described in the following permit application(s):

Permit Type Application Date Total Facility Reissuance 11/14/2001 Supplemental Information No. 1 7/11/2008 Supplemental Information No. 2 8/26/2008 Administrative Amendment 4/6/2007 Administrative Amendment 5/30/2008

This permit supersedes Air Emission Permit No. 13700013- 005 and authorizes the Permittee to operate the stationary source at the address listed above unless othe rwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007. 1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Permit Type: Federal; Pt 70/Major for NSR Issue Date: November 25, 2008

Expiration: November 25, 2013 All Title I Conditions do not expire.

Don Smith, P.E. Manager Air Quality Permits Section Industrial Division

for Brad Moore Commissioner Minnesota Pollution Control Agency

## TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals

Table C: not used in this permit

Appendix A: not used in this permit

Appendix B: Acid Rain Permit Application

Appendix C: Insignificant Activities Required to be Listed

Appendix D: Compliance Assurance Monitoring Plan

Appendix E: SO 2 

## Modeling Parameters

Appendix F: NO X 

## and PM 10 

## Modeling Parameters

## NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requi rements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North,St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about ai r quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, complia nce with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 a nd 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for a pplicable requirements, any person (including the Permittee) may also use other credible eviden ce to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: The Laskin Energy Center is an electric generating facility located near Aurora, Minnesota. This electric power facility contains two identical steam genera ting boilers, coal receiving, handling, and storage facilities, and ash handling and storage capabilities. E ach boiler has twelve 4 mmBtu/hr natural gas/oilfired ignitors and dry low Nitrogen Oxides (NO X 

## )combustors. Each boiler vents emissions to a highefficiency wet scrubber that discharges to the atmo sphere through a common stack. The scrubbers control Particulate Matter (PM), Particulate matter smaller than 10 microns (PM 10 

## ), Sulfur dioxide (SO 2 

## ), and lead. The net generating capacity is 110 megawatts.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it MODELING REQUIREMENTS hdr

Parameters Used in Modeling: The parameters used in the modeling performed for determining emission and/or operational limits for this facility are listed in Appendix E of this permit. If the Permittee intends to change any of these parameters, the Permittee must submit the revised parameters to the Commissioner and receive written approval before making any changes. The revised parameter information submittal must include, but is not limited to: the locations, heights and diameters of the stacks; locations and dimensions of nearby buildings; velocity and temperatures of the gases emitted; and the emission rates. The plume dispersion characteristics due to the parameter revisions must equal or exceed the dispersion characteristics modeled for this permit, and the Permittee shall demonstrate this in the proposal. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. CONTINUED

Parameters Used in Modeling (continued):

For changes that do not involve an increase in an emission rate and that do not require a permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before making the change to any parameter.

For changes involving increases in emission rates and that require a minor permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before making the change to any parameter.

For changes involving increases in emission rates and that require a permit amendment other than a minor amendment, the proposal must be submitted prior to or with the permit amendment application.

This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. CONTINUED

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW hdr

These requirements apply where there is a reasonable possibility (as defined in 40 CFR Section 52.21(r)(6)(vi)) that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test described in Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase. If the ATPA test is not used for a particular project, or if there is not a reasonable possibility that the proposed project could result in a significant emissions increase, then these requirements do not apply to that project.

Even though a particular modification is not subject to New Source Review, or where there isn't a reasonable possibility that a proposed project could result in a significant emissions increase, a permit amendment, recordkeeping, or notification may still be required under Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following:

1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-2

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-4 under Preconstruction Documentation, above) to the Agency. Title I Condition: 40 CFR Section 52.21(r)(6)(ii); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project analyzed as part of a hybrid test. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual, plus potential used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-3

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C. Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)

When the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-4

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

Shutdown and Breakdown Reporting Requirement for the Dust Collector Systems for Material Handling Equipment:

Shutdowns and breakdowns shall be reported on a quarterly basis to the Agency. The quarterly report shall include an identification of any dust collector that experienced a breakdown and/or shutdown, the time and reason for the breakdown or shutdown, a description of any repairs made, and the date and time the dust collector was placed back in service. Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected ; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

A pplication for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. The Permittee shall submit this on a form approved by the Commissioner. Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-5

Subject Item: GP 001 Boilers

Associated Items: CE 004 Low Nox Burners

CE 005 Low Nox Burners

CE 006 Overfire Air

CE 007 Overfire Air

EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006

EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007

SV 001 Common Boiler Stack

What to do Why to do it The Permittee shall meet either option 1 or option 2:

1.a. Individually validate EU 001 and EU 002 CO emissions are less than or equal to the EU 001 and EU 002 CO 0.126 lb/mmBtu emission factor, and 1.b. Monitor, record, and report GP 001 emissions as required by 40 CFR Section 52.21(r)(6);

OR

2. Meet the GP 001 630 ton per year (12-month rolling sum basis) CO limit and all associated monitoring, recordkeeping, and reporting requirements in table A of this permit.

If either EU 001 or EU 002 CO emission factor testing results in a factor greater than 0.126 lb/mmBtu, the Permittee shall follow option 2 and associated CO monitoring and recordkeeping requirements in EU 001, EU 002, and GP 001 in table A of this permit. Title I Condition: 40 CFR Sections 52.21(b) & 52.21(r)(6) and Minn. R. 7007.3000

Reverting From Option 2 To Option 1: The Permittee may revert from option 2 to option 1 under the following conditions:

1. a subsequent CO performance test on the same emission unit that previously tested above 0.126 lb/mmBtu measures CO emissions no greater than 0.126 lb/mmBtu;

2. the Permittee continues to follow Section 52.21(r)(6) requirements during the five-year period following the resumption of regular operation after completion of modifications of both units, regardless if option 2 applies.

If both units previously tested above 0.126 lb/mmBtu, subsequent CO performance tests must show CO emissions no greater than 0.126 lb/mmBtu for both units in order to revert to option 1. This permit provision expires 5 years following resumption of regular operations after completion of modifications of both units. Title I Condition: 40 CFR Sections 52.21(b) & 52.21(r)(6) and Minn. R. 7007.3000

Carbon Monoxide: less than or equal to 630 tons/year using 12-month Rolling Sum for both boilers combined. This limit applies at the end of the twelfth month after initial startup of the first modified boiler, if the Permittee elects or is required to meet this limit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

Carbon Monoxide: If the Permittee elects to or is required to meet the GP 001 630 ton per year CO limit, the following cumulative limit as of month 'n' where n = 1, 2, 3, etc. applies after initial startup of the first modified boiler:

Month 1: 100 tons Month 2: 200 tons Month 3: 275 tons Month 4: 350 tons Month 5: 400 tons Month 6: 450 tons Month 7: 490 tons Month 8: 520 tons Month 9: 550 tons Month 10: 580 tons Month 11: 610 tons

Month 1 includes the month of initial startup of the first modified boiler. This requirement terminates at the end of the twelfth month following initial startup of the first modified boiler. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-6

Carbon Monoxide: less than or equal to 738.0 tons/year on a calendar year basis for both boilers combined. This limit and associated recordkeeping is suspended if CO emission factor testing of EU 001 and EU 002 demonstrates a CO emission factor less than or equal to 0.124 lb/mmBtu for each emission unit. This limit is re-instated if a subsequent EU 001 or EU 002 CO emission factor test measures CO in excess of 0.124 lb/mmBtu. Minn. R. 7007.0800, subp. 2 to avoid 100 tpy environmental review potential emission increase threshold

GP 001 CO Emissions Monitoring and Recordkeeping: If the Permittee elects to or is required to meet the 630.0 ton per year GP 001 CO limit, by the last day of each month the Permittee shall calculate and record:

1. monthly GP 001 CO emissions for the previous calendar month by summing the EU 001 CO and EU 002 CO emissions determined according to the requirements listed under EU 001 and EU 002, respectively, from the previous calendar month;

2. GP 001 CO emissions from the previous twelve-month period by summing the monthly GP 001 CO emissions from the previous twelve months. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

GP 001 CO Emissions Monitoring and Recordkeeping: The Permittee shall calculate and record the GP 001 calendar year CO emissions by January 30 of each year, for the previous calendar year. Minn. R. 7007.0800, subp. 4 and 5 to avoid 100 tpy environmental review potential emission increase threshold If either EU 001 or EU 002 CO emission factor testing results in a factor greater than 0.126 lb/mmbtu, the Permittee may opt to perform additional analyses to demonstrate that the CO emissions performance satisfies Prevention of Significant Deterioration requirements under 40 CFR Section 52.21, and obtain a permit according to 40 CFR Section 52.21. 40 CFR Section 52.21(a)(2)(iii)

Combustion Of Oily Cellulose-Based Sorbents (including rags): The Permittee is permitted to burn oily cellulose-based sorbent and rags in both boilers. The materials must be cellulose-based and are subject to the following limits:

1) 1.25 tons per hour; and 2) 25 tons per year (on a 12-month rolling sum basis).

The Permittee shall record the quantity of sorbent materials burned on an hourly and 12-month rolling sum basis. Title I Condition: to ensure that the emissions increase from the addition of the fuel type is less than significant as defined by 40 CFR Section 52.21 and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-7

Subject Item: GP 002 Scrubbers

What to do Why to do it THE FOLLOWING REQUIREMENTS APPLY TO EACH SCRUBBER INDIVIDUALLY hdr

The Permittee shall operate and maintain the scrubbers (CE 001 and CE 002) at all times that any emission unit controlled by the scrubbers (EU 001 and EU 002) is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the scrubbers in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. 40 CFR Section 64.7(b); Minn. R. 7017.0200

Temperature: less than or equal to 175 degrees F using 3-hour Average at the common stack, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is above the maximum temperature limit, the PM emitted during that time shall be considered uncontrolled until the average temperature is below the maximum temperature limit. This shall be reported as a deviation. Minn. R. 7007.0800, subps. 2 and 14

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the stack temperature. The monitoring equipment must be in use and properly maintained whenever operation of the monitored control equipment is required. The monitoring device shall have a margin of error less than +/- 2.0 percent of the temperature being measured. The recording device shall also calculate the three-hour rolling average temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017.0200; 40 CFR Section 64.7(b); Minn. R. 7017.0200

Opacity: less than or equal to 20 percent using 3-hour average, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average opacity is above the maximum opacity limit, the PM emitted during that time shall be considered uncontrolled until the average opacity is below the maximum opacity limit. This shall be reported as a deviation. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017.0200

Opacity Monitoring: The Permittee shall maintain and operate an opacity monitoring device that continuously indicates and records the opacity of the stack. The monitoring equipment must be in use and properly maintained whenever operation of the monitored control equipment is required. The monitoring device shall have a margin of error less than +/- 2.0 percent. The recording device shall also calculate the three-hour rolling average. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017.0200; 40 CFR Section 64.7(b); Minn. R. 7017.0200

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written or electronic record of the daily verifications. The Permittee shall maintain a high temperature alarm for the boiler operator. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3(b); Minn. R. 7017.0200

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature and opacity readings and calculated three hour rolling average temperatures and opacity at the common stack. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.9(b); Minn. R. 7017.0200

A nnual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. 40 CFR Section 64.3; Minn. R. 7017.0200

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. 40 CFR Section 64.3; Minn. R. 7017.0200

A nnual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. 40 CFR Section 64.3; Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-8

For periods when the scrubber exhaust is below the maximum temperature and opacity, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (90%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Minn. R. 7007.0800, subp. 4 and 5

Corrective Actions: If the temperature and/or opacity is above the maximum specified by this permit or if the scrubber or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature and/or opacity to at least the permitted maximum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubbers. The Permittee shall keep a record of the type and date of any corrective action taken. 40 CFR Section 64.7(d); Minn. R. 7017.0200

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing maximum exhaust temperature, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. 40 CFR Section 64.7(e); Minn. R. 7017.0200

A s required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. 40 CFR Section 64.9(a)(2); Minn. R. 7017.0200

The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b); Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-9

Subject Item: SV 001 Common Boiler Stack

Associated Items: EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006

EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007

GP 001 Boilers

MR 002

MR 005

MR 006 Flow X-pattern

MR 007 Opacity

MR 008 SO2

MR 009 NOx

MR 010 CO2

What to do Why to do it
A DDITIONAL MR REQUIREMENTS LOCATED AT THE INDIVIDUAL MR LEVEL hdr

Sulfur Dioxide: less than or equal to 2.04 lbs/million Btu heat input using 1-Hour A verage .
Refer to EU 001 and EU 002 for the SO2 limit applicable to each emission unit. Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 365-day Rolling Average Minn. R. 7007.0800, subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citizens under the Clean Air Act COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to a one-minute averaging period. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the one-minute averaging period. Minn. R. 7017.1200, subps. 1, 2 and 3

COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

COMS Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1. The COMS must be adjusted whenever the calibration drift (CD) exceeds twice the specification of 40 CFR 60, Appendix B, PS-1. Minn. R. 7017.1210, subp. 2

Recordkeeping: The owner or operator must retain records of all COMS/CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement, or report. Records shall be kept at the

source. Minn. R. 7017.1130

CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, A ppendix B as amended. 40 CFR Section 75.21

Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. 40 CFR pt. 75 App B, section 2.1

CEMS Relative Accuracy Test Audit (RATA): due before the end of each calendar half year following CEM Certification Test (or due each year, depending on the results of the previous test). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. If the RATA results indicate a relative accuracy of 7.5% or less, the next RATA is not required for another year. 40 CFR pt. 75 App B, section 2.3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-10

Linearity and Leak Check Test (Acid Rain Program): due before end of each calendar quarter following CEM Certification Test. Conduct a quarterly linearity test on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 A pp B. 40 CFR pt. 75 App B, section 2.2

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA). Minn. R. 7017.1180, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-11

Subject Item: EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006

Associated Items: CE 004 Low Nox Burners

CE 006 Overfire Air

GP 001 Boilers

SV 001 Common Boiler Stack

What to do Why to do it LIMITS AND OPERATING REQUIREMENTS hdr

Total Particulate Matter: less than or equal to 0.60 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour A verage period for solid fuels, and 2.0 lb/mmBtu when burning liquid fuels. When fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat input from solid fossil fuels.

Refer to SV 001 for additional SO2 limit applicable to the common stack. Minn. R. 7011.0510, subp. 1

Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 365-day Rolling Average Minn. R. 7007.0800, subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citizens under the Clean Air Act Carbon Monoxide: less than or equal to 0.126 lbs/million Btu heat input (this is an emission factor and not a limit). The Permittee shall validate this factor through performance testing. If performance testing shows a factor greater than 0.126 lb/mmBtu, the Permittee shall meet the GP 001 630.0 tpy limit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

Fuel use: limited to sub-bituminous and bituminous coal, distillate oil, natural gas, boiler cleaning agents, non-hazardous petroleum distillate solvents and derived fuels, used oil, oily coal (coal with oil spilled on it), and oily cellulose-based sorbents (including rags). Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

Fuel Usage: less than or equal to 720 gallons/hour and less than 2,500,000 gallons annually of off-specification and on-specification used oil. Used oil shall be burned in accordance with Minn. R. ch. 7045. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

EU 001 Bituminous Coal Operations: If the Permittee combusts any bituminous coal, the Permittee shall conduct a CO performance test while burning bituminous coal. The Permittee may continue burning bituminous coal in EU 001 after completion of testing. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 001 CO Emissions Indicator: The Permittee shall operate EU 001 so that CO (ppm) measured by the emissions indicator does not exceed a value based on values measured during the most recent MPCA-approved performance stack test for evaluating the EU 001 CO emission factor. The current CO emission indicator is 100 ppm on a 30-day rolling average based on July 2007 test data. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

A CID RAIN PROGRAM REQUIREMENTS hdr

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. Takes effect for years beginning January 1, 2000. 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4)
A pplication for NOx limits: Submit a complete permit application and compliance plan for NOx emissions in accordance with 40 CFR Section 76.9. 40 CFR Section 76.9(b)(2)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-12

NOx Averaging Plan

Beginning January 1, 2000 either:

Maintain an annual average NOx emission rate of 0.40 lbs/mmBtu and limit the annual heat input to less than or equal to 4,600,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

A pply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). 40 CFR Section 72.30(c)

Certify Acid Rain Program Submittals. Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section 72.21. 40 CFR Section 72.21

Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, 2000. A llowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. 40 CFR Section 72.9(c)(1)(i), 40 CFR Section 72.9(g)(4)

The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

PERFORMANCE TESTING hdr

Performance Test: due before end of each calendar 60 months starting 07/25/2007 to evaluate compliance with the CO emission factor to avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000. The tests shall be conducted at an interval not to exceed 60 months between test dates. The test shall be conducted while combusting coal as a single fuel, a combination of coal and fuel oil, and a combination of coal and natural gas.

A

one-time 60-day extension was granted in 2007. Minn. R. 7017.2020, subp.1

Performance Test: due before end of each 60 months starting 06/03/1997 to determine compliance with the particulate matter emissions limit in Minn. R. 7011.0510 subp 1. The tests shall be conducted at an interval not to exceed 60 months between test dates.

A

one-time 120-day extension was granted in 2007. Minn. R. 7017.2020, subp. 1

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2.A. and 3.B.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-13

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3.B.

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% of any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

MONITORING AND RECORDKEEPING hdr

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. Minn. R. 7007.0800, supb. 2

Excess emissions and monitoring system performance reports shall include the information required in 40 CFR Section 60.7(c) and (d). MPCA supplied forms DRF-1 and DRF-2 may be used to meet this requirement. Minn. R. 7007.0800, subp. 2

EU 001 CO Emissions Indicator Monitoring and Recordkeeping: Calculate the arithmetic average of all hourly emission rates for CO for 30 calendar days. The 30-day rolling hourly average is calculated once each calendar day by summing the hourly CO emission concentrations measured during the previous 30 calendar days, and dividing by the number of hourly data values. Downtime of greater than one hour duration shall not be included in the 30-day rolling average. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 001 CO Emissions Indicator Monitoring and Recordkeeping: The Permittee shall install, operate, and maintain a process CO monitor (ppm monitor primarily for the boiler operator) upstream of the EU 001 air heater, and record the indicator measurements. The monitoring and recordkeeping equipment shall be operated and maintained at all times during EU 001 operation.

CO concentration will not exceed a value based on values recorded during the most recent MPCA-approved performance test. The measurement frequency and averaging period associated with this emissions indicator will be derived by the Permittee through analysis of the correlation between indicator readings and the first performance test results. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-14

EU 001 CO Emissions Monitoring and Recordkeeping: If the Permittee elects or is required to meet the 630 tpy (on a 12-month rolling sum basis) limit in GP 001, by the last day of each month commencing with the month of initial startup of the first boiler after LNB and OFA modifications are completed, the Permittee shall:

1. calculate and record EU 001 monthly fuel usage of bituminous and sub-bituminous coal; 2. calculate and record monthly EU 001 CO emissions using the following equation:

EU 001 CO = (FU * HC * EF)/2000

where:

EU 001 CO = monthly EU 001 CO emissions for each coal type (tons) FU = EU 001 monthly fuel consumption for each coal type (tons) HC = fuel heat content for each coal type (mmBtu/ton) EF = current EU 001 CO emission factor for each coal type (lb/mmBtu) Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 001 Bituminous Coal CO Monitoring: If the Permittee combusts bituminous coal, the Permittee shall calculate bituminous coal CO emissions using the EU 001 subbituminous coal CO emission factor until receipt of written MPCA confirmation of the EU 001 bituminous coal CO test results.

A fter receipt of written MPCA confirmation of the EU 001 bituminous coal CO test results, the Permittee shall determine EU 001 bituminous coal CO emissions using the approved EU 001 bituminous coal emission factor. The Permittee shall also recalculate EU 001 bituminous coal CO emissions that were initially determined using the subbituminous coal CO emission factor, using the approved EU 001 bituminous coal emission factor. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-15

Subject Item: EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007

Associated Items: CE 005 Low Nox Burners

CE 007 Overfire Air

GP 001 Boilers

SV 001 Common Boiler Stack

What to do Why to do it LIMITS AND OPERATING REQUIREMENTS hdr

Total Particulate Matter: less than or equal to 0.60 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour A verage period for solid fuels, and 2.0 lb/mmBtu when burning liquid fuels. When fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat input from solid fossil fuels.

Refer to SV 001 for additional SO2 limit applicable to the common stack. Minn. R. 7011.0510, subp. 1

Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 365-day Rolling Average Minn. R. 7007.0800, subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citizens under the Clean Air Act Carbon Monoxide: less than or equal to 0.126 lbs/million Btu heat input (this is an emission factor and not a limit). The Permittee shall validate this factor through performance testing. If performance testing shows a factor greater than 0.126 lb/mmBtu, the Permittee shall meet the GP 001 630 tpy limit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

Fuel use: limited to sub-bituminous and bituminous coal, distillate oil, natural gas, boiler cleaning agents, non-hazardous petroleum distillate solvents and derived fuels, used oil, oily coal (coal with oil spilled on it), and oily cellulose-based sorbents (including rags). Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

Fuel Usage: less than or equal to 720 gallons/hour and less than 2,500,000 gallons annually of off-specification and on-specification used oil. Used oil shall be burned in accordance with Minn. R. ch. 7045. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2

EU 002 Bituminous Coal Operations: If the Permittee combusts any bituminous coal, the Permittee shall conduct a CO performance test while burning bituminous coal. The Permittee may continue burning bituminous coal in EU 002 after completion of testing. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 002 CO Emissions Indicator: The Permittee shall operate EU 002 so that CO (ppm) measured by the emissions indicator does not exceed a value based on values measured during the most recent MPCA-approved performance stack test for evaluating the EU 002 CO emission factor. The current CO emission indicator is 100 ppm on a 30-day rolling average based on July 2007 test data. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

A CID RAIN PROGRAM REQUIREMENTS hdr

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. Takes effect for years beginning January 1, 2000. 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4)
A pplication for NOx limits: Submit a complete permit application and compliance plan for NOx emissions in accordance with 40 CFR Section 76.9. 40 CFR Section 76.9(b)(2)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-16

NOx Averaging Plan

Beginning January 1, 2000 either:

Maintain an annual average NOx emission rate of 0.40 lbs/MMBtu and limit the annual heat input to less than or equal to 4,600,000 MMBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/MMBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

A pply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). 40 CFR Section 72.30(c)

Certify Acid Rain Program Submittals. Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section 72.21. 40 CFR Section 72.21

Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, 2000. A llowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. 40 CFR Section 72.9(c)(1)(i), 40 CFR Section 72.9(g)(4)

The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

PERFORMANCE TESTING hdr

Performance Test: due before end of each 60 months starting 06/03/1997 to determine compliance with the particulate matter emissions limit in Minn. R. 7011.0510 subp. 1. The tests shall be conducted at an interval not to exceed 60 months between test dates.

A

one-time 120-day extension was granted in 2007. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 36 months starting 07/25/2007 to evaluate compliance with the CO emission factor to avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000. The tests shall be conducted at an interval not to exceed 36 months between test dates while combusting coal as a single fuel or a combination of coal and fuel oil. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 07/25/2007 to determine compliance with the CO emission factor to avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000. The tests shall be conducted at an interval not to exceed 60 months between test dates while combusting a combination of natural gas and coal. Minn. R. 7017.2020, subp.1

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 2.A. and 3.B.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-17

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

(1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate.

(2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3.B.

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results demonstrate compliance at greater than 80% of any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.2001 - 7017.2060. Minn. R. 7017.2020, subp. 4

MONITORING AND RECORDKEEPING hdr

Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. Minn. R. 7007.0800, subp. 2

Excess emissions and monitoring system performance reports shall include the information required in 40 CFR Sections 60.7(c) and (d). MPCA supplied forms DRF-1 and DRF-2 may be used to meet this requirement. Minn. R. 7007.0800, subp. 2

EU 002 CO Emissions Indicator Monitoring and Recordkeeping: Calculate the arithmetic average of all hourly emission rates for CO for 30 calendar days. The 30-day rolling hourly average is calculated once each calendar day by summing the hourly CO emission concentrations measured during the previous 30 calendar days, and dividing by the number of hourly data values. Downtime of greater than one hour duration shall not be included in the 30-day rolling average. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 002 CO Emissions Indicator Monitoring and Recordkeeping: The Permittee shall install, operate, and maintain a process CO monitor (ppm monitor primarily for the boiler operator) upstream of the EU 002 air heater, and record the indicator measurements. The monitoring and recordkeeping equipment shall be operated and maintained at all times during EU 002 operation.

CO concentration will not exceed a value based on values recorded during the most recent MPCA-approved performance test. The measurement frequency and averaging period associated with this emissions indicator will be derived by the Permittee through analysis of the correlation between indicator readings and the first performance test results. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-18

EU 002 CO Emissions Monitoring and Recordkeeping: If the Permittee elects or is required to meet the 630 tpy (on a 12-month rolling sum basis) limit in GP 001, by the last day of each month commencing with the month of initial startup of the first boiler after LNB and OFA modifications are completed, the Permittee shall:

1. calculate and record EU 002 monthly fuel usage of bituminous and sub-bituminous coal; 2. calculate and record monthly EU 002 CO emissions using the following equation:

EU 002 CO = (FU * HC * EF)/2000

where:

EU 002 CO = monthly EU 002 CO emissions for each coal type (tons) FU = EU 002 monthly fuel consumption for each coal type (tons) HC = fuel heat content for each coal type (mmBtu/ton) EF = current EU 002 CO emission factor for each coal type (lb/mmBtu) Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

EU 002 Bituminous Coal CO Monitoring: If the Permittee combusts bituminous coal, the Permittee shall calculate bituminous coal CO emissions using the EU 002 subbituminous coal CO emission factor until receipt of written MPCA confirmation of the EU 002 bituminous coal CO test results.

A fter receipt of written MPCA confirmation of the EU 002 bituminous coal CO test results, the Permittee shall determine EU 002 bituminous coal CO emissions using the approved EU 002 bituminous coal emission factor. The Permittee shall also recalculate EU 002 bituminous coal CO emissions that were initially determined using the subbituminous coal CO emission factor, using the approved EU 002 bituminous coal emission factor. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 11/25/08
Minnesota Power - Laskin Energy Center

13700013 - 006 Facility Name:

Permit Number: A-19

Subject Item: EU 003 Coal Crusher

Associated Items: CE 003 6% or Greater Moisture Content

SV 002 Coal Crusher

What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to meet the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

## TABLE B: SUBMITTALS
Facility Name: Minnesota Power - Laskin Energy Center

Permit Number: 13700013 - 006 11/25/08 B-1

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separatel y list one-time only and recurrent submittal requirements.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by part s 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

## TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS
Facility Name: Minnesota Power - Laskin Energy Center

Permit Number: 13700013 - 006 11/25/08 B-2

What to send When to send Portion of Facility Affected
A pplication for Permit Reissuance due 180 days before expiration of Existing Permit Total Facility

## TABLE B: RECURRENT SUBMITTALS
Facility Name: Minnesota Power - Laskin Energy Center

Permit Number: 13700013 - 006 11/25/08 B-3

What to send When to send Portion of Facility Affected
COMS Calibration Error Audit Results Summary due 30 days after end of each calendar quarter following Permit Issuance if performed. MR007

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter starting 05/12/1997 (Submit Deviations Reporting Form DRF-1 as amended). The EER shall indicate all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. SV001

Linearity Test Results Summary due 30 days after end of each calendar quarter starting 06/26/1997 if Linearity and Leak Check is performed. MR009, MR010

Linearity Test Results Summary due 30 days after end of each calendar quarter starting 06/26/1997 if Linearity and Leak Check Test is performed. MR008

Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar quarter starting 06/26/1997 if RATA is performed. MR008, MR009, MR010

Semiannual Deviations Report due 30 days after end of each calendar half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Total Facility

Compliance Certification Report (Acid Rain Program) due 60 days after end of each calendar year starting 01/01/2000 an annual compliance certification report for the unit in accordance with 40 CFR Section 72.90(a). The report shall include all information required by 40 CFR Sections 72.90(b) and (c). EU001, EU002

Compliance Certification due 30 days after end of each calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Total Facility

# APPENDIX B - Acid Rain Permit Application 

# Facility Name: Minnesota Power - Laskin Energy Center Permit Number: 13700013-006

2007 NOx Compliance and Aver a

# APPENDIX C - Insignificant Activi ties Required to be Listed Facility Name : Minnesota Power – Laskin Energy Center Permit Number : 13700013-006

Insignificant Activities and Applicable Requirements

Minn. R. Rule Description of the Activity Applicable Requirement

Minn. R. 7007.1300, subp. 4(B) Emissions units with emissions less than all the following limits but not included in subpart 2 must be listed in a part 70 permit application: potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitr ogen oxide, sulfur dioxide, and VOCs.

The facility performs the following operations that emit less than 1 ton per year of listed pollutants.

 Railcar unloading

 Coal conveying to crusher house

 Coal conveying to tripper

 Coal conveying from tripper to bunkers

 Coal conveying drop-off fugitives

 Ash storage wind erosion

 Fuel oil handling fugitives from pumps and piping. Minn. R. 7011.0710/0715

Minn. R. 7007.1300, subp. 3(H)(3) Miscellaneous: brazing, soldering or welding equipment;

Facility performs some welding activities. Minn. R. 7011.0710/0715

Minn. R. 7007.1300, subp. 3(J) Fugitive Emissions from roads and parking lots. Facility has unpaved roads. Minn. R. 7011.0150

Minn. R. 7008.4110 Conditionally insignificant PM And PM10 emitting operations Facility has a lime bin vent for lime storage and delivery with controls that meet the requirements for conditionally insignificant. Minn. R. 7011.0710/0715

# APPENDIX D - Compliance Assurance Monitoring Plan Facility Name : Minnesota Power – Laskin Energy Center Permit Number : 13700013-006

Laskin Ener g y Center CAM Plan.pdf

# APPENDIX E - SO 2 

## Modeling Parameters 

# Facility Name : Minnesota Power – Laskin Energy Center Permit Number : 13700013-006

** MN Power - Laskin Energy Center - SO2 Modeling *** 05/30/02

*** *** *** *** *** *** POINT SOURCE DATA *** *** *** *** ***

NO. EMISSION COORD COORD BA SE STACK STACK STACK STACK
SOURCE PART. RATE X Y ELEV. HE IGHT TEMP. EXIT VEL DIAMETER ID CATS. (G/S) (M) (M) (M) (M) (DEG.K) (M/SEC) (M)
Scenario S01 LECSV001 0 3.40E+ 02 563085 5264402 442.2 91.4 330.8 14.5 3.2 Scenario S02 LECSV001 0 2.55E+ 02 563085 5264402 442.2 91.4 326.3 10.9 3.2 Scenario S03 LECSV001 0 1.70E+ 02 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario S04 LECSV001 0 1.70E+ 02 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario S05 LECSV001 0 1.28E+ 02 563085 5264402 442.2 91.4 317.4 5.4 3.2 Scenario S06 LECSV001 0 8.50E+01 563085 5264402 442.2 91.4 313 3.6 3.2

# APPENDIX F - NO X 

## and PM 10 

## Modeling Parameters 

# Facility Name : Minnesota Power – Laskin Energy Center Permit Number : 13700013-006

** MN Power - Laskin Energy Center - NOx Modeling *** 06/13/02

*** *** *** *** *** *** POINT SOURCE DATA *** *** *** ***
NUMBER EMISSION COORD COORD BASE STACK STACK STACK STACK SOURCE PART. RATE X Y ELEV. HEIGHT TEMP. EX VEL DIA. ID CATS. (G/S) (M) (M) (M) (M) (DEG.K) (M/SEC) (M)

Scenario N01 LECSV001 0 8.32E+01 563085 5264402 442.2 91.4 330.8 14.5 3.2 Scenario N02 LECSV001 0 6.24E+01 563085 5264402 442.2 91.4 326.3 10.9 3.2 Scenario N03 LECSV001 0 4.16E+01 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario N04 LECSV001 0 4.16E+01 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario N05 LECSV001 0 3.13E+01 563085 5264402 442.2 91.4 317.4 5.4 3.2 Scenario N06 LECSV001 0 2.08E+01 563085 5264402 442.2 91.4 313 3.6 3.2 *** *** *** *** *** *** *** *** *** *** *** *** *** *** *** ** * *** *** *** *** ***

** MN Power - Laskin Energy Center - PM10 Modeling *** 06/09/02

*** *** *** *** *** *** POINT SOURCE DATA *** *** *** ***
NUMBER EMISSION COORD COORD BASE STACK STACK STACK STACK

SOURCE PART. RATE X Y ELEV. HEIGHT TEMP. EXIT VEL DIA. ID CATS. (G/S) (M) (M) (M) (M) (DEG.K) (M/SEC) (M)
Scenario P01 LECSV001 0 9.98E+01 563085 5264402 442.2 91.4 330.8 14.5 3.2 Scenario P02 LECSV001 0 7.48E+01 563085 5264402 442.2 91.4 326.3 10.9 3.2 Scenario P03 LECSV001 0 4.99E+01 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario P04 LECSV001 0 4.99E+01 563085 5264402 442.2 91.4 321.9 7.2 3.2 Scenario P05 LECSV001 0 3.74E+01 563085 5264402 442.2 91.4 317.4 5.4 3.2 Scenario P06 LECSV001 0 2.50E+01 563085 5264402 442.2 91.4 313 3.6 3.2

*** *** *** *** *** *** VOLUME SOURCE DATA *** *** *** ***
NUMBER EMISSION COORD COORD BASE RELEASE INIT. INIT. SOURCE PART. RATE X Y ELEV. HEIGHT SY SZ ID CATS. (G/S) (M) (M) (M) (M) (M) (M)
Scenario P01-P06 LECSV002 0 3.97E-03 563186.1 5264463 441.6 16.76 0.85 9.91 Scenario P01-P06 LECSV009 0 1.19E-02 563079.9 5264381 442.2 11.9 0.14 5.52

** MN Power - Laskin Energy Center - PM10 Modeling parameters continued on next page ****** *** *** *** *** *** AREA SOURCE DATA *** *** *** *** *** ***

NUMBER EMISSION COORD COORD BASE RELEASE X-DIM Y-DIM ORIENT.
SOURCE PART. RATE X Y ELEV. HEIGHT OF AREA AREA AREA ID CATS. (G/S/M^2) (M) (M ) (M) (M) (M) (M) (DEG.)

Scenario P01-P06 LECFS101 0 6.99E-07 563210.1 5264430 440.3 7.01 79 180 8
Scenario P01-P06 LECFS201 0 7.08E-06 563210.1 5264430 440.3 7.01 79 180 8
Scenario P01-P06 LECFS202 0 7.11E-06 562515.9 5264566 445.2 0 20.1 20.1 0
Scenario P01-P06 LECFS301 0 3.63E-07 563210.1 5264430 440.3 7.01 79 180 8
Scenario P01-P06 LECFS302 0 1.62E-07 562242.8 5264649 443.1 3 50.8 10 -38
Scenario P01-P06 LECFS303 0 1.62E-07 562282.8 5264680.5 444.3 3 72 10 -45.7
Scenario P01-P06 LECFS304 0 1.62E-07 562333.4 5264732 446.1 3 28.5 10 -31.3
Scenario P01-P06 LECFS305 0 1.62E-07 562357.8 5264747 447 3 43.6 10 2.5
Scenario P01-P06 LECFS306 0 1.62E-07 562401.2 5264745 449.2 3 100 10 17.7
Scenario P01-P06 LECFS307 0 1.62E-07 562496.1 5264714.5 450.7 3 100 10 17.1
Scenario P01-P06 LECFS308 0 1.62E-07 562591.4 5264685.5 450.7 3 100 10 19.6
Scenario P01-P06 LECFS309 0 1.62E-07 562685.3 5264652 451.3 3 100 10 24.6
Scenario P01-P06 LECFS310 0 1.62E-07 562643.4 5264562 452.8 3 100 10 -57.2
Scenario P01-P06 LECFS311 0 1.62E-07 562633.8 5264541 452.8 3 23 10 -65.7
Scenario P01-P06 LECFS312 0 1.62E-07 562541.8 5264550.5 451.3 3 83.3 10 4.6
Scenario P01-P06 LECFS313 0 1.62E-07 562775.8 5264610 451.3 3 100 10 21.9
Scenario P01-P06 LECFS314 0 1.62E-07 562868.9 5264573 448.3 3 100 10 30.5
Scenario P01-P06 LECFS315 0 1.62E-07 562955.3 5264522.5 445.2 3 80 10 -7.9
Scenario P01-P06 LECFS316 0 1.62E-07 563034.9 5264533.5 442.2 3 100 10 -5.2
Scenario P01-P06 LECFS317 0 1.62E-07 562212.6 5264714.5 442.2 3 495.6 227 -90
Scenario P01-P06 LECFS318 0 1.62E-07 562016 5264454.5 445.2 3 526 157.2 -0.2
Scenario P01-P06 LECFS319 0 1.62E-07 562238 5264658 443.1 3 10 63 -33
Scenario P01-P06 LECFS401 0 6.31E-08 561969.4 5263083 447.3 3 53.9 10 -53.8
Scenario P01-P06 LECFS402 0 6.31E-08 562001.2 5263126.5 449.2 3 100 10 -84.8
Scenario P01-P06 LECFS403 0 6.31E-08 562010.8 5263226 451.6 3 100 10 -71.5
Scenario P01-P06 LECFS404 0 6.31E-08 562044.8 5263322.5 452.2 3 100 10 -69.6
Scenario P01-P06 LECFS405 0 6.31E-08 562079.9 5263416.5 451.3 3 100 10 -69.9
Scenario P01-P06 LECFS406 0 6.31E-08 562114.4 5263510.5 451.3 3 100 10 -69.2
Scenario P01-P06 LECFS407 0 6.31E-08 562150.7 5263604.5 448.3 3 45.7 10 -66.2
Scenario P01-P06 LECFS408 0 6.31E-08 562169.1 5263646.5 446.7 3 51.2 10 -52.5
Scenario P01-P06 LECFS409 0 6.31E-08 562199.7 5263687 445.2 3 100 10 -41.3
Scenario P01-P06 LECFS410 0 6.31E-08 562274.9 5263753.5 446.7 3 100 10 -40
Scenario P01-P06 LECFS411 0 6.31E-08 562351.8 5263817.5 448.3 3 100 10 -37.4
Scenario P01-P06 LECFS412 0 6.31E-08 562431 5263878.5 446.1 3 100 10 -38.6
Scenario P01-P06 LECFS413 0 6.31E-08 562509 5263941 446.1 3 59.4 10 -51.1
Scenario P01-P06 LECFS414 0 6.31E-08 562546.9 5263987.5 443.7 3 100 10 -61.5
Scenario P01-P06 LECFS415 0 6.31E-08 562594.2 5264075.5 447.3 3 100 10 -63.6
Scenario P01-P06 LECFS416 0 6.31E-08 562638.2 5264165 446.1 3 27.2 10 -80.5
Scenario P01-P06 LECFS417 0 6.31E-08 562642.2 5264191.5 446.1 3 84 10 -95.7
Scenario P01-P06 LECFS418 0 6.31E-08 562633.8 5264275 447 3 28.1 10 -72.6
Scenario P01-P06 LECFS419 0 6.31E-08 562642.7 5264301 449.2 3 34 10 -38
Scenario P01-P06 LECFS420 0 6.31E-08 562669.6 5264322 449.2 3 92 10 -15
Scenario P01-P06 LECFS421 0 6.31E-08 562758.5 5264346 447.3 3 100 10 -1
Scenario P01-P06 LECFS422 0 6.31E-08 562858.6 5264347 445.2 3 100 10 -9.3
Scenario P01-P06 LECFS423 0 6.31E-08 562957.2 5264362.5 443.7 3 100 10 -8.5
Scenario P01-P06 LECFS424 0 6.31E-08 563055.7 5264377.5 442.2 3 62.9 10 -10.2
Scenario P01-P06 LECFS425 0 6.31E-08 563117.6 5264389 441.6 3 44.2 10 -40.7
Scenario P01-P06 LECFS426 0 6.31E-08 563151.6 5264418 440.9 3 42.5 10 -69.8
Scenario P01-P06 LECFS427 0 6.31E-08 563166.3 5264458.5 440.3 3 88.9 10 -108.2
Scenario P01-P06 LECFS428 0 6.31E-08 563043.7 5264386 442.2 3 18.7 10 -99.9
Scenario P01-P06 LECFS429 0 6.31E-08 563039.4 5264404 442.2 3 62.3 30 -97.2
Scenario P01-P06 LECFS501 0 2.78E-04 563195.6 5264561 442.2 1.5 4.6 12.8 8

## Technical Support Document, Permit Action Number: 13700013-006 Page 1 of 7 Date: 1/7/2009 

## TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 13700013-006

This Technical Support Document (TSD) is for all parties interested in the permit and meets the requirements of 40 CFR § 70.7(a)(5) and Minn. R. 7007. 0850, subp. 1. This document provides the legal and factual justification for each applicable requireme nt or policy decision considered in the preliminary determination to issue the permit.

1 General Information

1.1 Applicant and Stationary Source Location

Applicant/Address Stationary Source/Address (SIC Code: 4911 ) Minnesota Power Division of ALLETE, Inc. 30 West Superior Street Duluth, MN 55802-2093 Laskin Energy Center 5699 Colby Lake Rd Hoyt Lakes, St. Louis County, MN 55750 Contact: Brandon Krogh Senior Engineer 218-723-3954

1.2 Facility Description
This facility is composed of two electric utility st eam boilers, each rated at 660 mmBtu/hr. Each boiler has twelve 4 mmBtu/hr gas/oil-fired ignitors and dry low NO X 

## combustors. Each boiler vents emissions to a high-efficiency wet scrubber that discharges to the atmosphere through a common stack. The scrubbers control PM, PM 10 

## , SO 2 

## , and lead. Net electric production is 55 MW per boiler. Boiler ratings were previously listed as 660 mmBtu/h r for bituminous coal and 525 for sub-bituminous coal. However, the Permittee states the 525 mmBtu/h r capacity was measured in the 1980s using old wet sub-bituminous coal, and that 660 mmBtu/hr can be ach ieved when combusting dry sub-bituminous coal.

1.3 Description of the Current Permit Action and All Amendments Issued since the Last Total Facility Permit
This permit is a reissuance of the Part 70 operati ng permit. Two administrative amendments, submitted April 6, 2007 and May 30, 2008, reques ting extensions for performance tests were incorporated with this permit issuance. No other changes are authorized by this permit action.

Permit Number and Issuance Date Action Authorized 13700013-002 March 5, 1999 Addition of the NO x 

## requirements to the Phase II Acid Rain portion of the Title V operating permit 13700013-003 June 4, 2002 Replacement of the distillate oil-fired ignitors in Boilers 1 and 2 with ignitors that can burn distillate oil and natural gas 13700013-004 Permit not issued 13700013-005 September 18, 2006 Install low-NO X 

## burners and overfire ai r controls on Boilers 1 and 2

## Technical Support Document, Permit Action Number: 13700013-006 Page 2 of 7 Date: 1/7/2009 

## 1.4 Facility Emissions
Table 1 - Total Facility Potential to Emit Summary 1



## PM tpy PM 10 

## tpy SO 2 

## tpy NO X 

## tpy CO tpy VOC tpy Total HAP tpy Total Facility Limited Potential Emissions 1,488 341 2,865 997 630 18.2 353.4

Total Facility Actual Emissions (2007) 298 298 1,341 932 100 12.0 HAPs not reported in emission inventory

1 

### Limited emissions based on 12-month rolling sum 630 tp y CO emission limit excludi ng insignificant sources.



## Table 2 - Facility Classification
Classification Major/Affected Source Synthetic Minor Minor PSD PM, PM 10 

## , SO 2 

## , NO X 

## , CO VOC Part 70 Permit Program PM 10 

## , SO 2 

## , NO X 

## , CO VOC Part 63 NESHAP Single & Total HAP

1.5 Changes to Permit
No significant changes have been made to the requi rements in the permit. The following changes have been made:

• the permit has been updated to reflect current MPCA policy, templates and standard citation formatting;

• completed requirements and the requirements for equipment that has been removed have been deleted;

• performance test frequency plan has been incorporated;

• Continuous Emissions Monitoring System (CEMS) Re lative Accuracy Test Audit requirements have been moved from emission units to monitors;

• compliance assurance monitoring (CAM) plan requi rements have been added to the permit; and

• the requirement to update the fugitive dust control plan has been removed.

## Technical Support Document, Permit Action Number: 13700013-006 Page 3 of 7 Date: 1/7/2009 

## 2 Regulatory and/or Statutory Basis

New Source Review The facility is an existing major source under Ne w Source Review regulations. No changes are authorized by this permit. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) There are no New Source Performance Standards app licable to the operations at this facility. National Emission Standards for Hazardous Air Pollutants (NESHAP) There are no NESHAPs applicable to the operations at this facility. Acid Rain Program Both boilers, EU 001 and EU 002, are subject to the acid rain program requirements to monitor and report SO 2 

## , NO X 

## , and CO 2 

## emissions and to hold sufficient SO 2 

## allowances for SO 2 

## emissions. 40 CFR Part 75 offers several monitoring provisions in addition to the general operating requirements (CEMS), and alternative monitoring systems under Subpart E. The aci d rain permit application is included in the permit as Appendix B. Compliance Assurance Monitoring (CAM) This permit action is a re-issuance of a Part 70 permit. Therefore CAM applies to any emission units with air pollution control equipment which meet the CAM applicability requirements. 40 CFR Part 64 requires CAM for emission units that meet the following criteria:

• The unit is subject to an emission limitation or sta ndard for the applicable regulated air pollutant,

• The unit uses a control device to achieve compliance, and

• The unit has potential pre-control device emissions of the pollutant that are equal to or greater than 100 percent of the amount, in tons per year, required for the source to be classified as a major source. The Permittee uses add-on controls (wet scrubbers) to reduce emissions from both boilers to meet emission limits for PM, NO X 

## and SO 2 

## . The facility satisfies the requirements of CAM for NO X 

## and SO 2 

## through the use of CEMS to measure NO X 

## and SO 2 

## . The wet scrubbers (CE 001 and CE 002) for boilers 1 and 2 (EU 001 and EU 002) are subject to CAM for PM only. The CAM plan is included in the permit as Appendix D. To assure compliance with the PM emission limit, scrubber exhaust temperature and opacity will be monitored. Scrubber exhaust temperature was selected as an indicator because it is indicative of the scrubber operation and appropriate scr ubber water flow. Opacity was selected as an indicator because performance testing has demonstrated that opacity is a limiting pollutant with respect to PM emissions; opacity will exceed the opacity limit before PM will exceed the PM limit. Monitoring systems for temperature and opacity are located in the co mmon stack at the 150-foot stack elevation.

Minnesota State Rules The two steam-electric boilers are subject to PM, SO 2 

## , and opacity limits in Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating E quipment. The coal crusher is subject to the PM and opacity limits in Minn. R. 7011.0715 Standards of Performance for Industrial Process Equipment.
Table 3 - Regulatory Overview of Units

## Technical Support Document, Permit Action Number: 13700013-006 Page 4 of 7 Date: 1/7/2009 

## EU, GP,

or SV Applicable Regulations Comments:

GP 001 Title I Condition: to avoid major modification under § 52.21 and/or § 52.21(r)(6) for CO CO limits, monitoring, and recordkeeping to avoid PSD and Minnesota Environmental Review requirements.

GP 002 40 CFR pt. 64 CAM requirements: the scrubbers are used to comply with the Standards of Performance for Indirect Heating Equipment PM limit, and the uncontrolled potential from each of the boilers is greater than 100 tpy, so CAM applies.

EU 001 and EU 002 Title I Condition: to avoid major modification under § 52.21 and/or § 52.21(r)(6) for CO

Minn. R. 7007.0800, subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citizens under the Clean Air Act

Minn. R. 7011.0510 Standards of Performance for Indirect Heating Equipment

Acid Rain requirements CO emission factor limit, monitoring, recordkeeping, and testing to avoid PSD and Minnesota Environmental Review requirements.

NO X 

## limit: The Permittee secured a rate rider to pay for the NO X 

## controls as a part of the Arrowhead Regional Emissions Abatement (AREA) plan. This ensures the rate payer gets the reduced emissions for the additional cost of electricity.

PM, SO 2 

## and Opacity standards.

The acid rain permit application is included as an appendix to the permit. Some requirements are listed in Table A of the permit.

EU 003 Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment Opacity and PM standards.

SV 001 Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080; this is a state-only requirement not enforceable by the EPA Administrator or citizens under the Act. SO 2 

## limit (lower than applicable performance standard) based on Title V modeling. The most recently modeled parameters are included in Appendix E to the permit and the Permittee must receive written approval prior to making changes to the parameters.

## Technical Support Document, Permit Action Number: 13700013-006 Page 5 of 7 Date: 1/7/2009 

## 3 Technical Information

3.1 Emission Analysis and Calculations Attachment 1 to this TSD contains the summary of the permitted PTE of the Facility and detailed spreadsheets with supporting information prepared by the MPCA and the Permittee.

3.2 Periodic Monitoring In accordance with the Clean Air Act, it is the responsib ility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that th e facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere. Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable re quirement is nonexistent or inadequate.

Table 4 - Periodic Monitoring

Emission Unit or Group Requirement (basis) Additional Monitoring Discussion

GP 001 CO emission factor ≤ 0.126 lb/mmBtu

OR

CO ≤ 630 tpy on a 12-month rolling sum basis

(Title I Condition to avoid major modification under § 52.21) CO stack testing to verify emission factor, CO ppm emissions indicator, and monthly calculation of 12- month CO emissions if factor >0.126 lb/mmBtu. The Permittee has two options for demonstrating the CO emissions increase is not significant. The first option requiring the verification of the CO factor has less recordkeeping than the second option of meeting a 12-month rolling sum CO limit. Both options restrict the CO increase to less than the 100 tpy significant level.

EU 001 and EU 002 NO X 

## ≤ 0.20 lb/mmBtu on a 365-day rolling average

(Minn. R. 7007.0800, subp. 2) NO X 

## is measured by a CEMS on the common stack This is a state-only requirement not enforceable by the EPA administrator or citizens under the Clean Air Act. The Permittee secured a rate rider to pay for the NO X 

## controls. This ensures the rate payer gets the reduced emissions for the additional cost of electricity.

## Technical Support Document, Permit Action Number: 13700013-006 Page 6 of 7 Date: 1/7/2009 

## Emission Unit or Group Requirement (basis) Additional Monitoring Discussion

PM ≤ 0.60 lb/mmBtu

(Minn. R. 7011.0510) Control equipment has a CAM plan to ensure control efficiency. PM limit from Standards of Performance for Existing Indirect Heating Equipment.

Opacity ≤ 20%

(Minn. R. 7011.0510) Opacity is monitored by a COMS on the common stack . Opacity limit from Minnesota Standards of Performance for Existing Indirect Heating Equipment.

SO 2 

## ≤ 4.0mmBtu - solid fuels

SO 2 

## ≤ 2.0mmBtu – liquid fuels

(Minn. R. 7011.0510) SO 2 

## is measured by a CEMS on the common stack. SO 2 

## limit for each emission unit for solid and liquid fuels from Minnesota Standards of Performance for Existing Indirect Heating Equipment.

SV 001 SO 2 

## ≤ 2.04 mmBtu

(Minn. Stat. § 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010- 7009.0080) SO 2 

## is measured by a CEMS on the common stack. SO 2 

## limit on the common stack (lower than applicable performance standard) is based on title V modeling. This is a state-only requirement not enforceable by the EPA Administrator or citizens under the Act.

3.3 Comments Received

Public Notice Period: October 4, 2008 – November 3, 2008 EPA 45-day Review Period: Oc tober 4, 2008 - November 18, 2008

## Technical Support Document, Permit Action Number: 13700013-006 Page 7 of 7 Date: 1/7/2009 

## 4 Conclusion Based on the information provided by Minnesota Power Division of ALLETE, Inc., the MPCA has reasonable assurance that the operation of the emissi on facility, as described in the Air Emission Permit No. 13700013-006 and this technical support document, w ill not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Adriane Lenshek (permit writer/engineer) Steve Palzkill, (enforcement) Andy Place (stack testing) Chris Buntjer (peer reviewer)

Attachments: 1. PTE Summary and Calculation Spreadsheets 2. Facility Description and CD-01 Forms

AQ File No. 73D; DQ 101, 1467, 1545; ID: 13700013

## Attachment 1 - PTE Summary and Calculation Spreadsheets

## Attachment 2 - Facility Description and CD-01 FormsOMB 2060-0631 Part I Question 14aMinnesota Power Laskin Energy Center (1891)Materials listed in the permitLaskin "Other" Materials Permitted to burnActually burn?(yes/no)Quantity /yearUnitsBoiler cleaning agents (EDTA type and Ammonium Bromate),generated on-site5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned whilethe boiler is operating at 75 percent of rated capacity or greater.*no - -Non-hazardous petroleum distillate solvents and derived fuels NAnoUsed oil720 gallons/hour and 2,500,000 gallons annually of off-specification and on-specificationused oiYes 103,417 GallonsOily coal (coal with oil spilled on it) NAno - -Oily cellulose-based sorbents (including rags) 1.25 tons per hour and 25 tons per year (on a 12-month rolling sum basis) no - -Boiler cleaning agents (EDTA type and Ammonium Bromate),generated on-site5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned whilethe boiler is operating at 75 percent of rated capacity or greater.*no - -Non-hazardous petroleum distillate solvents and derived fuels NAno - -Used oilFuel Usage: less than or equal to 720 gallons/hour and less than 2,500,000 gallonsannually of off-specification and on-specification used oil. Used oil shall be burnedinaccordance with Minn. R. ch. 7045.Yes 103,417 GallonsOily coal (coal with oil spilled on it) NAno - -Oily cellulose-based sorbents (including rags) 1.25 tons per hour and 25 tons per year (on a 12-month rolling sum basis) no - -*Permitted to burn but have yet to execise that option at LECNA=no specific numerical limit listed in permit for this materialUnit 1Unit 2If "other" was checked in questions 10 or 11 above indicating that any non-fossil fuel or other material (including, but not limited to, plastics, treated wood, rubber belting or gaskets, whole tires, tire-derivedfuel, boiler cleaning solutions, animal wastes, etc.) is either utilized or permitted to be used, please indicate below what materials are combusted in the boiler and in what quantities (specify whether thisquantity is on a weight percentage or heat [Btu] basis). Also indicate (yes/no) whether you are permitted to burn non-fossil fuel(s) or other material(s) even if you do not actually burn them.OMB 2060-0631 Part I, Question 15: Identification (or designation) of all coal- and oil-fired steam generating units (boilers)(as defined by Clean Air Act section 112(2)(8)) located at this facility)Minnesota Power Laskin Energy Center (1891)Facility NameSubpart EIA Plant CodeQ 15.01 Boiler IDUnit 1 Unit 2Q 15.02 Original design fuel (i.e. coal rank or type of oil)Bituminous coal or oil Bituminous coal or oilQ 15.03Design heat input (mmBtu/hr)1501 501Q 15.04Present maximum heat input, (mmBtu/hr)3725 660Q 15.05 MWe gross capacity summer 60 55Q 15.06 MWe net capacity summer 55.8 50.7Q 15.07 Original design gross efficiency (%, HHV) 87.8 (12,150btu/lb) 87.8 (12,150btu/lb)Q 15.08Present operating gross efficiency (%, HHV)4NA NAQ 15.09Design steam pressure (psig)11250 1250Q 15.10 Operating steam pressure (psig) 1250 1250Q 15.11Design steam temperature (°F)1950 950Q 15.12 Operating steam temperature (°F) 950 950Q 15.13Design steam reheat temperature (°F)5NA NAQ 15.14Operating steam reheat temperature (°F)5NA NAQ 15.15 FuelQ 15.16 Hours/year operated 7494.86 7744.33Q 15.17 Average annual capacity factor for the past 3 years 61.56 64.05Q 15.18 Applicable NSPSQ 15.19 Estimated year of retirement Minnesota Power has no scheduled or planned retirement dates for any of our units1Original design values based on boiler acquisition contracts and/or heat balance drawings. Design heat input value does not represent maximum capacity at the time of unit commissioning.2Each Laskin unit was originally built as 44MWn nominal. The units were upgraded to 55MWn output in the mid-1960s.Laskin units are permitted to burn either eastern bituminous coal or a combination of western sub-bituminous coal with oil topping. Sub-bituminous coal is now the primary fuel being used.3Current heat input data from Title V permit application does not represent maximum heat input capacity.4We do not measure or calculate boiler efficiency on either unit at this facility.5Units do not have a steam reheat cycle.LASKIN2189140 CFR Part 60 Subpart Y>99% coal, <1%otherOMB 2060-0631 Part I, Question 16: Emission Control TechnologyMinnesota Power Laskin Energy Center (1891)Designate the order of the emission controls -- 1 for first control following the boiler, 2 for second control following the boiler, etc.Plant IDBoilerIDType NOx ControlIn-serviceDateSO2 ControlIn-serviceDatePM ControlIn-serviceDateOtherControlIn-serviceDateLaskin 1 Tangentially-fired 1 - Low NOx burners 2007 2 - Wet particulate scrubber 1971 2 - Wet particulate scrubber 1971 None -1891 2 Tangentially-fired 1 - Low NOx burners 2006 2 - Wet particulate scrubber 1971 2 - Wet particulate scrubber 1971 None -OMB 2060-0631 Part I, Question 22: Guaranteed Emission RateMinnesota Power Laskin Energy Center (1891)PMPM10PM2.5SO2HCl and/orHFHCN Metal HAP Hg COOtherorganics(specify)Otherpollutant(specify)1 0.03 grains/ACFBaseline + 100ppm2 0.03 grains/ACFBaseline + 100ppmLaskinMost recent guaranteed emission rate for each pollutant for which there is a permitted emission limitPlant ID Boiler IDOMB 2060-063 Part II Questions 2-3Coal Shipments - Minnesota Power Laskin Energy Center (1891)Train ID Tons Boiler ID# State CountyCoal SeamFuelShipMethodSulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel OtherDKMVIL301 1,2 MT Big HornDietz 1 and Dietz 2RR 0.370 4.100 9,265N/A N/A N/A N/A N/ADKMVIL302 1,2 MT Big HornDietz 1 and Dietz 3RR 0.420 4.410 9,304N/A N/A N/A N/A N/ADKMVIL303 1,2 MT Big HornDietz 1 and Dietz 4RR 0.380 4.200 9,498N/A N/A N/A N/A N/ADKMVIL304 1,2 MT Big HornDietz 1 and Dietz 5RR 0.420 4.490 9,346N/A N/A N/A N/A N/ADKMVIL305 1,2 MT Big HornDietz 1 and Dietz 6RR 0.420 4.640 9,386N/A N/A N/A N/A N/ADKMVIL306 1,2 MT Big HornDietz 1 and Dietz 7RR 0.370 3.990 9,370N/A N/A N/A N/A N/ADKMVIL307 1,2 MT Big HornDietz 1 and Dietz 8RR 0.430 4.710 9,287N/A N/A N/A N/A N/ADKMVIL308 1,2 MT Big HornDietz 1 and Dietz 9RR 0.420 4.770 9,377N/A N/A N/A N/A N/ADKMVIL309 1,2 MT Big HornDietz 1 and Dietz 10RR 0.390 4.800 9,222N/A N/A N/A N/A N/ADKMVIL310 1,2 MT Big HornDietz 1 and Dietz 11RR 0.320 3.880 9,267N/A N/A N/A N/A N/ADKMVIL311 1,2 MT Big HornDietz 1 and Dietz 12RR 0.460 4.850 9,549N/A N/A N/A N/A N/ADKMVIL312 1,2 MT Big HornDietz 1 and Dietz 13RR 0.520 5.460 9,349N/A N/A N/A N/A N/ADKMVIL313 1,2 MT Big HornDietz 1 and Dietz 14RR 0.460 3.810 9,666N/A N/A N/A N/A N/ADKMVIL314 1,2 MT Big HornDietz 1 and Dietz 15RR 0.320 3.530 9,591N/A N/A N/A N/A N/ADKMVIL315 1,2 MT Big HornDietz 1 and Dietz 16RR 0.340 3.850 9,577N/A N/A N/A N/A N/ADKMVIL316 1,2 MT Big HornDietz 1 and Dietz 17RR 0.390 4.480 9,331N/A N/A N/A N/A N/ADKMVIL317 1,2 MT Big HornDietz 1 and Dietz 18RR 0.380 4.470 9,375N/A N/A N/A N/A N/ADKMVIL318 1,2 MT Big HornDietz 1 and Dietz 19RR 0.400 5.140 9,258N/A N/A N/A N/A N/ADKMVIL319 1,2 MT Big HornDietz 1 and Dietz 20RR 0.480 5.080 9,449N/A N/A N/A N/A N/ADKMVIL320 1,2 MT Big HornDietz 1 and Dietz 21RR 0.280 3.060 9,705N/A N/A N/A N/A N/ADKMVIL321 1,2 MT Big HornDietz 1 and Dietz 22RR 0.300 3.990 9,278N/A N/A N/A N/A N/ADKMVIL322 1,2 MT Big HornDietz 1 and Dietz 23RR 0.460 3.940 9,357N/A N/A N/A N/A N/ADKMVIL323 1,2 MT Big HornDietz 1 and Dietz 24RR 0.390 4.670 9,252N/A N/A N/A N/A N/ADKMVIL324 1,2 MT Big HornDietz 1 and Dietz 25RR 0.420 4.090 9,530N/A N/A N/A N/A N/ABTMVIL101 12,083.200 1,2 WY Campbell N/A RR 0.220 4.360 8,982N/A N/A N/A N/A N/ABTMVIL102 11,477.500 1,2 WY Campbell N/A RR 0.310 5.230 8,834N/A N/A N/A N/A N/AETMVIL101 9,780.900 1,2 WY Carbon N/A RR 0.590 10.720 10,748N/A N/A N/A N/A N/AATMVIL101 11,597.325 1,2 WY Converse N/A RR 0.260 5.950 8,778N/A N/A N/A N/A N/AATMVIL102 12,341.050 1,2 WY Converse N/A RR 0.260 5.990 8,763N/A N/A N/A N/A N/AOil Shipments - Laskin Energy CenterOMB 2060-063 Part II Questions 2-3ID Gallons StateCountyCoalSeam Fuel Ship MethodSulfur Ash Btu/Lb MercuryChlorine Fluorine Nickel OtherNo deliveries of oil received for boiler usage at Laskin Energy Center.11,223.00012,670.00012,569.00012,651.00012,463.00010,300.00012,154.00011,681.00012,344.00012,356.000Fuel Source11,628.00012,468.00012,300.00010,505.00012,875.00010,816.00011,022.00012,362.00012,360.00012,265.00010,842.00011,949.00011,809.00011,864.000OMB 2060-0631 Part II, Question 8a, 8b, 8fMinnesota Power Laskin Energy Center (1891)Boiler ID(as listed in Part I question15)Question 8aEmission test report,parametric monitoring data,or other data or monitoringQuestion 8bDate of testingQuestion 8bType of testingQuestion 8bConstituentsQuestion 8fDid the unit's controlconfiguration differ forthat shown in Part I,questions 16 at the timeof the test? Boiler IDNOxControlSO2Control PM ControlOtherControlBoiler 1 and Boiler 2 GE EnergyCarbon Monoxide EmissionsEngineering Study3/16/2006 stack CO yesB1 & B2 none noneWetParticulateScrubber noneBoiler 1 and Boiler 2 GE EnergyEmission Compliance Study7/24-25/2007 stack CO noBoiler 1 and Boiler 2 GE EnergyEmission Compliance Study2/27/2007 & 7/24/2007 stack PM noBoiler 1 and Boiler 2 Platt Environmental Services,IncMercury Testing6/30/2008 stack mercury noBoiler 1 and Boiler 2 GE EnergyPM Correlation Emission Study2/24-26/2009 & 3/2-3/2009 stack PM noBoiler 1 and Boiler 2 GE EnergyEmission Compliance Study7/7/2009 stack PM and CO noBoiler 1 and Boiler 2 GE EnergyMercury Emission Study7/7/2009 stack mercury noOMB 2060-0631 Part II, Question 12Minnesota Power Laskin Energy Center (1891)Boiler ID Test Date PM* SO2 HCL/HF/HCN Metal HAP Hg* CO* Other organicUnit Load(MW)NetMWH NET)Moisture(%) Flow(dscfm or Nm3/hr)Flue gas oxygen(%, dry) Flue gas CO2 (%, dry)Flue gas temp(oF)Flue gas pressure(atm)Standard temp(F)Standard pressure(atm)Boiler 1 and Boiler 2 3/16/2006Unit 1 & 2 = 0.108 lb/mmBtuUnit 1 & 2 = 93.28 lb.hr99.93 310,370 dscfm 6.6 1368 29.92Boiler 1 and Boiler 2 GE EnergyEmission ComplianceStudyUnit 1 coal = 0.056 lb/mmBtucoal/fuel oil = 0.033lb/mmBtucoal/nat gas = 0.043lb/mmBtuUnit 2 coal = 0.096 lb/mmBtucoal/fuel oil = 0.077lb/mmBtucoal/nat gas = 0.042lb/mmBtuUnit 1 coal = 51.9coal/fuel oil = 53.7coal/nat gas = 53.4Unit 2 coal = 51.1coal/fuel oil = 53.7coal/nat gas = 51.7Unit 1 coal = 6.4coal/fuel oil= 5.9coal/nat gas= 5.9Unit 2 coal = 5.6coal/fuel oil= 5.5coal/nat gas= 5.8Unit 1 coal = 13.2coal/fuel oil =13.5coal/nat gas =13.2Unit 2 coal = 14.1coal/fuel oil =14.0coal/nat gas =13.5Unit 1 coal = 68coal/fuel oil= 68coal/natgas = 68Unit 2 coal = 68coal/fuel oil= 68coal/natgas = 68Unit 1 coal = 29.92coal/fuel oil =29.92coal/nat gas =29.92Unit 2 coal = 29.92coal/fuel oil =29.92coal/nat gas =29.92Boiler 1 and Boiler 2 GE EnergyEmission ComplianceStudyCoal only = 0.08 lb/mmBtuCoal/Fuel oil = 0.07 lb/mmBtuCoal only = 109.3Coal/Fuel oil = 109.3Coal only = 5.0Coal/Fuel oil = 10.2Coal only = 325,867 dscfmCoal/Fuel oil = 302,539 dscfmCoal only = 7.7Coal/Fuel oil = 5.6Coal only = 11.6Coal/Fuel oil = 13.5Coal only = 128.3Coal/Fuel oil = 125.1Coal only = 29.87Coal/Fuel oil =29.49Coal only = 68Coal/Fuel oil =68Coal only = 29.92Coal/Fuel oil =29.92Boiler 1 and Boiler 2 6/30/2008Total Hg = 0.32 ppb 90.9 10.6 11.18 28.97 68 29.92Boiler 1 and Boiler 2 2/24-26/2009 and 3/2-3/20021 samples for filterable PM concentrations94.3 5.6 301,180 dscfm 7.2 11.3 103.9 28.62 68 29.92Boiler 1 and Boiler 2 7/7/2009 Unit 1 & 2 filterable PM = 0.05 lb/mmBtuUnit 1 CO = 0.005 lb/mmBtuUnit 2 CO = 0.004 lb/mmBtuPM test = 107.2CO test = 107.1PM test = 7.4 353,080 dscfm PM test = 6.0Unit 1 CO = 6.1Unit 2 CO = 7.113 132 28.26 68 29.92Boiler 1 and Boiler 2 11/17/2009Boiler 1 and Boiler 2 7/7/2009Run 1 = 8.360E-10 lb/dscfRun 2 = 8.339E-10 lb/dscfRun 3 = 8.315E-10 lb/dscf107.53118.7 68 29.92* Averaging Time = 3 - 1 hour rounds

## TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper contai ning at least 10% fibers from paper recycled by consumers 

# AIR EMISSION PERMIT NO. 03100001- 008 Major Amendment

IS ISSUED TO

MINNESOTA POWER DIVISION OF ALLETE INC Cliffs Erie LLC Minnesota Power - Tac Harbor Energy Ctr 8124 West Highway 61 Schroeder, Cook County, MN 55613

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table.

This permit amendment supersedes Air Emission Permit No. 03100001-007 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the State Implementation Plan under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70/Limits to Avoid NSR; Major Amendment Issue Date: October 19, 2009 Expiration Date: 04/07/2004*– Title I Conditions do not expire.

*The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received 10/10/2003.

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

for Paul Eger Commissioner Minnesota Pollution Control Agency

# Permit Applications Table Permit Type Application Date Issue Date Action Total Facility Operating Permit June 14, 1995 May 19, 1997 001 Major Amendment November 30, 1998 April 7, 1999 002 Major Amendment March 23, 2006 January 8, 2007 006 Major Amendment January 18, 2008 May 20, 2008 007 Major Amendment October 10, 2008 NA 008

# TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Amendment Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices

# NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific pr ovision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

# FACILITY DESCRIPTION:

Minnesota Power’s Taconite Harbor Energy Center consists of three 75 megawatt (net) coal-fired units located in Schroeder, Minnesota. The units have tangentially fired boilers that are permitted to burn both bituminous and sub-bituminous coals. Coal for the boilers is stored in an outdoor storage pile. Prior to the coal being conveyed to the boilers it is crushed. The crusher is located in a building that currently is not vented to the atmosphere. This permit action is to allow the crusher building to be vented to the atmosphere through a fabric filter for dust collection. Since the crusher had previously not been vented to the atmosphere, it was not listed as an emission unit in the existing operating permit. This permit action will add the coal crusher and conveyor transfer points to the operating permit as an emission unit. The fabric filter serving the ventilation will be added as control equipment to the permit with requirements to limit opacity.

AMENDMENT DESCRIPTION:

03100001-002 This permit action allows the Permittee to discontinue operation of their Total Suspended Particulate (TSP) ambient air quality monitors. The original Title V permit (Air Emission Permit No. 03100001-001) had a condition that allowed for the discontinuation after one more year of continued ambient compliance shown by the monitors. The one more year of continued compliance was shown and the Permittee has applied for the permit change. It should also be noted that the original monitors showed no violations for three (3) plus years of monitoring prior to permit issuance.

03100001-006 This permit authorizes installation of additional pollution controls on boiler No. 2. The project is one of the Permittee’s Arrowhead Regional Emissions Abatement (AREA) emission reduction projects and will result in voluntary emission reduc tions not required by rule or statute. The Permittee has received approval from the Minnesota Public Utilities Commission to recapture costs from its customer base that are associated with the project.

The Permittee proposes to install Nitrogen Oxides (NO X 

# ), Sulfur Dioxide (SO 2 

# ), and mercury controls on boiler No. 2 as a pilot test to ensure efficacy of the control technology. The control technology known as “Mobotec” is a multi-pollutant control technology. The Mobotec mercury control system is a developing technology than has not been previously installed on subbituminous coal-fired boilers.

03100001-007 This permit action is a major permit amendment because it increases the emissions of particulate from coal preparation and triggers a Standard of Performance for Coal Preparation Plants (40 CFR pt. 60 subp. Y). The modification allowed by this permit action is the addition of existing coal crusher and coal conveyor transfer points as an emission unit controlled by a fabric filter dust collection system. This permit action also incorporates an administrative amendment to extend the initial performance test deadline for Boiler No. 2 (EU 002) an additional 120 days.

# 03100001-008 No physical changes will occur as part of this permit amendment. The permit amendment is primarily a revision to the State-Only (Non Title-I) emission limits of SO 2 

# and NO X 

# for EU002. In 2006, Minnesota Power installed Mobotec’s multi pollution control technologies as a pilot test project on Taconite Harbor Unit 2 boiler to reduce SO 2 

# , NO X 

# , and Mercury. There was a possibility of a significant increase in Particulate Matter (PM) and Particulate Matter smaller than 10 mincrons (PM 10 

# ) emissions due to the injection of lime based alkali into the boiler for SO 2 

# control. There were various permit conditions put in the permit to avoid a significant increase of PM and PM 10 

# under Prevention of Significant Deterioration Program. This permit amendment revises the state-only emissions limits due to uncertainties surrounding the control devices and technologies involved. It has proven necessary to operate the control system at a reduced hydrate injection rate in order to reliably meet the PM and PM 10 

# limits. These reduced injection rates has caused the facility to be unable to achieve the level of SO 2 

# expected by the pilot project. Likewise, the actual efficiency of the NO X 

# reduction system is slightly less then anticipated. The revised emissions limits are 0.45 lbs/MMBtu SO2 and 0.17 lbs/MMBtu NO X


# . This permit amendment allows the facility to discontinue use of molten sulfur ejection as an Electrostatic Precipitator conditioning agent. Molten sulfur has been shown to have an inverse relationship with mercury removal. Stack tests have also shown that the facility can meet particulate limits without the use of Sulfur Trioxide injection.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it
DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW hdr

These requirements apply where there is a reasonable possibility that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test and found to not be part of a major modification, may result in a significant emissions increase. If the ATPA test is not used for a particular project, or if there is not a reasonable possibility that the proposed project could result in a significant emissions increase, then these requirements do not apply to that project.

Even though a particular modification is not subject to New Source Review, a permit amendment, recordkeeping, or notification may still be required under Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following information:

1. A description of the project 2. Identification of the emission unit(s) whose emissions of an NSR pollutant could be affected 3. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the potential emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the unit(s) could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-3 under Preconstruction Documentation, above) to the Agency. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain:

1. The name and ID number of the facility, and the name and telephone number of the facility contact person 2. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project and analyzed using potential emissions 3. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
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03100001 - 008 Facility Name:

Permit Number: A-2

For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual plus potential, if applicable) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain:

1. The name and ID number of the facility, and the name and telephone number of the facility contact person 2. The annual emissions (actual plus potential, if any part of the project was analyzed using potential emissions) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. 3. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

OPERATING REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010 - 7009.0080 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

Comply with Fugitive Emissions Control Plan: Follow the actions and recordkeeping specified in the control plan. The plan may be amended with the Commissioner's approval. If the Commissioner determines that you are out of compliance with Minn. R. 7011.0150 or the control plan, then you may be required to amend the control plan. The Commissioner may also require re-installation and operation of particulate matter ambient air monitors. Minn. R. 7007.0800, subp. 2

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subps. 2 & 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O&M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R. 7007.0800, subps. 14 & 16(J)

Noise: The Permittee shall comply with noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during operation of any emission units. This is a state requirement only and is not federally enforceable. Minn. R. 7030.0010 - 7030.0080

Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, such as for system breakdowns, repairs, calibration checks, and zero and span adjustments (as applicable). Monitoring records should reflect any such periods of process shutdown. Minn. R. 7007.0800, subp. 4(D)

Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). Minn. R. 7007.0800, subp. 9(A)

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A and/or B. Minn. R. ch. 7017

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-3

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tes t Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4; Minn. R. 7017.2035, subps. 1-2

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Minn. R. 7017.2025, subp. 3

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

NOTIFICATIONS AND SUBMITTALS hdr

Notification of Deviations Endangering Human Health or the Environment: A s soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. The cause of the deviation; 2. The exact dates of the period of the deviation, if the deviation has been corrected; 3. Whether or not the deviation has been corrected; 4. The anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B, and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
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03100001 - 008 Facility Name:

Permit Number: A-4

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B, and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

A pplication for Permit Amendment: If you need a permit amendment, submit application in accordance with the requirements of Minn. R. 7007.1150-7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 - 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

Emission Fees: due 60 days after receipt of an MPCA bill Minn. R. 7002.0005 - 7002.0095

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. To be submitted this on a form approved by the Commissioner. Minn. R. 7019.3000 - 7019.3010

A t the present time, the permittee must comply with all the applicable requirements in 40 CFR pt. 97 for a CAIR NOx source, a CAIR SO2 source, a CAIR NOx unit, and a CAIR SO2 unit as defined in 40 CFR Sections 97.102 and 97.202. If the US Environmental Protection Agency promulgates a rule to stay 40 CFR pt. 97 in Minnesota, this requirement will be of no further force and no longer in effect upon the effective date of the rule. 40 CFR pt. 97; 40 CFR Section 52.1240; Minn. R. 7007. 0800, subp. 2.

Water flow rate: less than or equal to 5.0 gallons/minute of coal pile run off.

this limit is based on a submittal by the permittee that shows that the additional Btu input required to boil off this coal pile rain water run off does not constute a significant increase in emission.

This permittee shall not dispose of the coal pile rain water run off in this manner if this meathod voilates any other permit that the facilty holds or other Minnesota law. Minn. R. 7007.0800, subp. 3

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
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03100001 - 008 Facility Name:

Permit Number: A-5

Subject Item: GP 001 Three 745 MMBtu/hr coal-fired boilers

Associated Items: EU 001 Boiler No. 1

EU 002 Boiler No. 2

EU 003 Boiler No. 3

What to do Why to do it Total GP 001 Sulfur Dioxide: less than or equal to 1743 lbs/hour using 3-hour A verage Minn. R. 7009.0020 to avoid causing or contributing to a violation of the SO2 ambient air quality standards in Minn. R. 7009.0080 Mercury content of coal: Less than or equal to 0.20 parts per million on an annual average basis. The agency will refrain from enforcement action for exceedance of this mercury limit if the Permittee is able to demonstrate, to the satisfaction of the agency, that the Permittee has used best efforts to comply with the mercury limit. Minn. R. 7007.0800, subp. 2

Coal sampling for mercury content: Collect a daily coal sample, and analyze a composite sample of the coal at least once a week according to the most current A STM method (currently ASTM Method D-6722). The Permittee shall maintain a record of all analyses for at least 5 years from the date of analysis. Results of the analyses shall be reported semiannually with the Semiannual Deviations Report. Minn. R. 7007.0800, subp. 2

Boiler Cleaning Agents: The Permittee is authorized to incinerate boiler cleaning agents in any of the three boilers. Boiler cleaning agents are limited to EDTA type and Ammonium bromate, must be generated on-site, can not exceed 5 percent of total fuel mass input, and oxygen must be to 3 percent or greater. Agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-6

Subject Item: GP 002 Reagent Handling and Storage

Associated Items: CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 008 Alkaline Reagent Silo (SV 008/CE 013)

EU 009 Mercury Reagent Silo (SV 009/CE 014)

EU 010 Trona Silo (SV 010/CE 015)

What to do Why to do it Total Particulate Matter: less than or equal to 0.01 grains/dry standard cubic foot for each GP 002 emission unit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; meets requirements of Minn. R. 7011.0735 Particulate Matter < 10 micron: less than or equal to 0.01 grains/dry standard cubic foot for each GP 002 emission unit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000 Opacity: less than or equal to 20 percent opacity for each GP 002 emission unit. Minn. R. 7011.0715, subp. 1.B

The Permittee shall operate and maintain each fabric filter so that it achieves an overall control efficiency for filterable Total Particulate Matter: greater than or equal to 99 percent control efficiency Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 The Permittee shall operate and maintain each fabric filter so that it achieves an overall control efficiency for filterable PM < 10 micron: greater than or equal to 99 percent control efficiency Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 The Permittee shall operate and maintain each fabric filter at all times that any emission unit controlled by the fabric filter is in operation. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 Visible Emissions: The Permittee shall check the CE 013, CE 014, and CE 015 stack/vent for any visible emissions during each delivery to the emission unit storage silo controlled by the fabric filter, but not more frequently than once each calendar week for a specific storage silo.

A

calendar week starts each Sunday. All observations shall be made during daylight hours. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14

Recordkeeping of Visible Emissions: The Permittee shall record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5 Periodic Inspections: The Permittee shall inspect the fabric filter components once per calendar quarter or as required by the manufacturer. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5, & 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

1. Visible emissions are observed; 2. During an inspection, the fabric filter or any of its components are found to need repair.

Corrective actions shall eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O&M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, & 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-7

Subject Item: GP 003 Hauling on Paved Roads

Associated Items: CE 016 Paved Road Sweeping

FS 009 Mercury Reagent Truck Hauling - Paved Road

FS 010 Alkaline (or Trona) Reagent Truck Hauling - Paved Road

FS 011 Molten Sulfur Truck Hauling - Paved Road

FS 012 Ammonia Truck Hauling - Paved Road

FS 013 Urea Truck Hauling - Paved Road

What to do Why to do it Paved Haul Road Fugitive Emissions Control: The Permittee shall follow the practices described in the revised fugitive emissions control plan, for control of fugitive emissions from GP 003 fugitive emission sources. The practices at a minimum shall include sweeping of paved road surfaces at the frequency specified in the revised plan. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
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03100001 - 008 Facility Name:

Permit Number: A-8

Subject Item: GP 004 Pellet and Material Handling

Associated Items: FS 001 Pellet Drop From Railcars into Dock Storage Bins

FS 005 Ship Loading of Taconite Pellets

FS 006 Railcar Material Loading

What to do Why to do it The Permittee shall follow the practices described in the revised fugitive emissions control plan for control of fugitive emissions from GP 004 fugitive emission sources, if these sources become active. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-9

Subject Item: SV 001 Boiler 1 stack

Associated Items: EU 001 Boiler No. 1

MR 028 COMS

MR 029 SO2 Monitor

MR 030 NOx Monitor

MR 031 CO2 Monitor

MR 032 Flow Monitor

What to do Why to do it COMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure the opacity of the emission unit using a COMS. 40 CFR Section 75.10; Minn. R. 7017.1006
A ll COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. Minn. R. 7017.1200, subps. 1, 2 & 3

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. The optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift adjustments. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity.

Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). Minn. R. 7017.1210, subp. 2

COMS Calibration Error Audit: due before end of each calendar half-year following Permit Issuance. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

A ttenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in 40 CFR Part 60, Appendix B, Section 7.1.3.1 within the time frame of opacity stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be available on-site for inspection. Minn. R. 7017.1210, subp. 4

COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. Minn. R. 7017.1220

Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

PART 75 CEMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure opacity, SO2, NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

Daily Calibration Error (CE) Test: Conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. 40 CFR pt. 75, Appendix B, section 2.1

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, sections 2.2.1 & 2.2.2; Minn. R. 7017.1020

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-10

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

CEMS QA/QC: The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFR pt. 75, Appendix B as amended. 40 CFR Section 75.21

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. 40 CFR Section 75.50; Minn. R 7017.1130

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-11

Subject Item: SV 002 Boiler 2 stack

Associated Items: EU 002 Boiler No. 2

MR 033 COMS

MR 034 SO2 Monitor

MR 035 NOx Monitor

MR 036 CO2 Monitor

MR 037 Flow Monitor

What to do Why to do it COMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure the opacity of the emission unit using a COMS. 40 CFR Section 75.10; Minn. R. 7017.1006
A ll COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. Minn. R. 7017.1200, subps. 1, 2 & 3

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. The optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift adjustments. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity.

Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). Minn. R. 7017.1210, subp. 2

COMS Calibration Error Audit: due before end of each calendar half-year following Permit Issuance. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

A ttenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in 40 CFR Part 60, Appendix B, Section 7.1.3.1 within the time frame of opacity stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be available on-site for inspection. Minn. R. 7017.1210, subp. 4

COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. Minn. R. 7017.1220

Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

PART 75 CEMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure opacity, SO2, NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

Daily Calibration Error (CE) Test: Conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. 40 CFR pt. 75, Appendix B, section 2.1

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, sections 2.2.1 & 2.2.2; Minn. R. 7017.1020

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-12

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

CEMS QA/QC: The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFR pt. 75, Appendix B as amended. 40 CFR Section 75.21

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. 40 CFR Section 75.50; Minn. R 7017.1130

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
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03100001 - 008 Facility Name:

Permit Number: A-13

Subject Item: SV 003 Boiler 3 stack

Associated Items: EU 003 Boiler No. 3

MR 038 COMS

MR 039 SO2 Monitor

MR 040 NOx Monitor

MR 041 CO2 Monitor

MR 042 CO2 Monitor

MR 043 Flow Monitor

What to do Why to do it COMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure the opacity of the emission unit using a COMS. 40 CFR Section 75.10; Minn. R. 7017.1006
A ll COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. Minn. R. 7017.1200, subps. 1, 2 & 3

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

A cceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2. Minn. R. 7017.1090, subp. 1

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. The optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift adjustments. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity.

Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). Minn. R. 7017.1210, subp. 2

COMS Calibration Error Audit: due before end of each calendar half-year following Permit Issuance. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R. 7017.1210, subp. 3. Minn. R. 7017.1210, subp. 3

A ttenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in 40 CFR Part 60, Appendix B, Section 7.1.3.1 within the time frame of opacity stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be available on-site for inspection. Minn. R. 7017.1210, subp. 4

COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. Minn. R. 7017.1220

Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

PART 75 CEMS REQUIREMENTS hdr

Emissions Monitoring: The owner or operator shall measure opacity, SO2, NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

Daily Calibration Error (CE) Test: Conduct daily CE testing on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. 40 CFR pt. 75, Appendix B, section 2.1

Linearity and Leak Check Test (Acid Rain Program): due before end of each QA operating quarter (as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2. Perform a leak check at least once during each QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) and no less than 30 days apart. 40 CFR pt. 75, Appendix B, sections 2.2.1 & 2.2.2; Minn. R. 7017.1020

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-14

Linearity Test Results Summary: due 30 days after end of each calendar quarter following Linearity and Leak Check Test if performed. Minn. R. 7017.1180, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar half-year following CEM Certification Test, i.e., once every two successive QA operating quarters (calendar quarter in which there are at least 168 unit operating hours). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i) are met. 40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R. 7017.1020

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)). Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which the CEMS RATA was conducted. Minn. R. 7017.1180, subp. 3

CEMS QA/QC: The owner or operator of an affected facility shall operate, calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFR pt. 75, Appendix B as amended. 40 CFR Section 75.21

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. 40 CFR Section 75.50; Minn. R 7017.1130

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-15

Subject Item: EU 001 Boiler No. 1

Associated Items: CE 001 Electrostatic Precipitator - High Efficiency

GP 001 Three 745 MMBtu/hr coal-fired boilers

SV 001 Boiler 1 stack

What to do Why to do it Refer To Subject Item SV 001 for NOx and SO2 CEMS Requirements and COMS Requirements. hdr

Total Particulate Matter: less than or equal to 0.3 lbs/million Btu heat input (excluding condensible particulate matter). Minn. R. 7007.0800, subp. 2; meets requirements of Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

Sulfur Dioxide: less than or equal to 0.78 lbs/million Btu heat input using 3-hour A verage Minn. R. 7009.0020 to not cause or contribute to a violation of the SO2 ambient air standard in Minn. R. 7009.0080; meets the requirements of Minn. R. 7011.0510, subp. 1 Fuels allowed: bituminous coal, sub-bituminous coal, distillate fuel oil, used oil, used oil sorbents, propane, and boiler cleaning agents. Minn. R. 7007.0800, subp. 2

Performance Test: due before end of each 60 months starting 05/25/2005 to measure particulate matter emissions. The tests shall be conducted at an interval not to exceed 60 months between test dates. Minn. R. 7017.2020, subp. 1

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subps. 2(A) & 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

1. If the results of the performance test are greater than 80% of any applicable emission limit for which emissions are measured, then boiler operation will be limited to the tested operating rate.

2. If results are less than or equal to 80% of all applicable emission limits for which emissions are measured, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Documentation of all STET operation shall be maintained. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results measure emissions at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results measure emissions at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-16

A CID RAIN PROGRAM REQUIREMENTS hdr

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Sections 72.9(c)(1)(ii) & 72.9(g)(4)

NOx Averaging Plan:

Beginning January 1, 2002, either:

Maintain an annual average NOx emission rate of 0.40 lbs/mmBtu and limit the annual heat input to less than or equal to 5,600,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created:

1. The certificate of representation; 2. All emissions monitoring information; 3. Copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program; 4. Copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

A pply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). 40 CFR Section 72.30(c)

Certify Acid Rain Program Submittals.

Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section 72.21. 40 CFR Section 72.21

Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, 2002. A llowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. 40 CFR Sections 72.9(c)(1)(i) & 72.9(g)(4)

The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-17

Subject Item: EU 002 Boiler No. 2

Associated Items: CE 002 Electrostatic Precipitator - High Efficiency

CE 010 Selective Noncatalytic Reduction for NOX

CE 011 Dry Sorbent Injection

CE 012 Dry Sorbent Injection

CE 017 Ammonia Injection

CE 018 SO3 Injection

GP 001 Three 745 MMBtu/hr coal-fired boilers

SV 002 Boiler 2 stack

What to do Why to do it Refer To Subject Item SV 002 for NOx and SO2 CEMS Requirements and COMS Requirements.

EU 002 control equipment:

CE 010 is EU 002 furnace overfire air and SNCR with ammonia/urea/other reagent injection CE 011 is EU 002 furnace alkaline/sodic/other reagent injection for SO2 control CE 012 is EU 002 furnace sorbent/reagent injection for mercury control CE 017 is ammonia injection upstream of CE 002 for particulate agglomeration CE 018 is SO3 injection upstream of CE 002 to reduce particulate resistivity hdr

LIMITS AND OPERATING REQUIREMENTS hdr

Nitrogen Oxides: less than or equal to 0.17 lbs/million Btu heat input using 365-day Rolling Average effective 3/20/2009. Each daily value used in calculating the 365-day rolling average is determined by averaging all lb/mmBtu measurements made by the SV 002 NOx CEMS during the calendar day. This is a state-only requirement and is not enforceable under the Clean Air Act by citizens or the EPA administrator. Minn. R. 7007.0800, subp. 2

Sulfur Dioxide: less than or equal to 0.45 lbs/million Btu heat input using 365-day Rolling Average effective 3/20/2009. Each daily value used in calculating the 365-day rolling average is determined by averaging all lb/mmBtu measurements made by the SV 002 SO2 CEMS during the calendar day. This is a state-only requirement and is not enforceable under the Clean Air Act by citizens or the EPA administrator. Minn. R. 7007.0800, subp. 2

Sulfur Dioxide: less than or equal to 0.78 lbs/million Btu heat input using 3-hour A verage Minn. R. 7009.0020 to not cause or contribute to a violation of the SO2 ambient air standard in Minn. R. 7009.0080; meets requirements of Minn. R. 7011.0510, subp. 1 Particulate Matter < 10 micron (PM10) and Front-half Particulate Matter (PM) Emission Limits and Compliance Options:

The Permittee shall follow option 1 or option 2 described below for each pollutant. If only one pollutant qualifies for option 1, the Permittee may implement option 1 for the qualifying pollutant while following option 2 for the other pollutant. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; 40 CFR Section 52.21(r)(6)

Particulate Matter < 10 micron Compliance Options:

Option 1 1.a. Stack test to validate EU 002 PM10 emissions are less than or equal to the EU 002 0.120 lb/mmBtu PM10 emission factor, and 1.b. Monitor, record, and report EU 002 PM10 emissions as required by 40 CFR Section 52.21(r)(6); or

Option 2 2. Meet the EU 002 327 ton per year (12-month rolling sum basis) PM10 limit and all associated monitoring, recordkeeping, and reporting requirements in table A of this permit.

PM 10: If the most recent EU 002 PM10 emission factor testing results in a factor greater than 0.120 lb/mmBtu, the Permittee shall follow option 2 for PM10. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; 40 CFR Section 52.21(r)(6)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-18

Front-half Particulate Matter Compliance Options:

Option 1 1.a. Stack test to validate EU 002 PM emissions are less than or equal to the EU 002 0.039 lb/mmBtu PM emission factor, and 1.b. Monitor, record, and report EU 002 PM emissions as required by 40 CFR Section 52.21(r)(6); or

Option 2 2. Meet the EU 002 106 ton per year (12-month rolling sum basis) PM limit and all associated monitoring, recordkeeping, and reporting requirements in table A of this permit.

Front-half PM: If the most recent EU 002 PM emission factor testing results in a factor greater than 0.039 lb/mmBtu, the Permittee shall follow option 2 for PM. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; 40 CFR Section 52.21(r)(6)

Front-half Particulate Matter: less than or equal to 106 tons/year using 12-month Rolling Sum .

This limit is in effect when operating under Option 2. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000;

Total Particulate Matter: less than or equal to 0.3 lbs/million Btu heat input (excluding condensible particulate matter). Minn. R. 7007.0800, subp. 2; meets requirements of Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2

Fuels allowed: bituminous coal, sub-bituminous coal,distillate fuel oil, used oil, Propane, used oil sorbents, and boiler cleaning agents. Minn. R. 7007.0800, subp. 2

Control Equipment Operation During Startup and Shutdown: The Permittee is not required to operate CE 010, CE 011, CE 012, CE 017, and CE 018 during startup and shutdown as follows:

1. CE 010, CE 011, and CE 012 operation is not required if flue gas temperature in the injection zone is less than approximately 2000 degrees F; 2. CE 017 and CE 018 operation is not required during startup or shutdown when fuel oil is combusted. Minn. R. 7007.0800, subp. 2

MONITORING AND RECORDKEEPING hdr

EU 002 Monthly Fuel Usage Monitoring and Recordkeeping: If the Permittee elects or is required to meet option 2 PM and/or PM10 limits, by the last day of each month, the Permittee shall calculate and record EU 002 monthly fuel usage of sub-bituminous coal and bituminous coal. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

EU 002 PM Emissions Monitoring and Recordkeeping: If the Permittee elects or is required to meet the option 2 PM limit, no later than 45 days after then end of each month, the Permittee shall:

1. Calculate and record EU 002 monthly PM emissions as follows:

EU 002 PM = (FC * HC * EF)/2000

where: EU 002 PM = monthly EU 002 PM emissions for each coal type (tons) FC = EU 002 monthly fuel consumption for each coal type (tons) HC = fuel heat content for each coal type (mmBtu/ton) determined by determined by the most current ASTM method (presently ASTM D5865) EF = current EU 002 PM emission factor for each coal type (lb/mmBtu)

2. Calculate and record the total EU 002 12-month rolling sum PM emissions for all coal combusted by summing the 12 most-recent monthly PM emissions calculations for each coal type. Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-19

EU 002 PM10 Emissions Monitoring and Recordkeeping: If the Permittee elects or is required to meet the option 2 PM10 limit, no later than 45 days after then end of each month, the Permittee shall:

1. Calculate and record EU 002 monthly PM10 emissions as follows:

EU 002 PM10 = (FC * HC * EF)/2000

where: EU 002 PM10 = monthly EU 002 PM10 emissions for each coal type (tons) FC = EU 002 monthly fuel consumption for each coal type (tons) HC = fuel heat content for each coal type (mmBtu/ton) determined by determined by the most current ASTM method (presently ASTM D5865) EF = current EU 002 PM10 emission factor for each coal type (lb/mmBtu)

2. Calculate and record the total EU 002 12-month rolling sum PM10 emissions for all coal combusted by summing the 12 most-recent monthly PM10 emissions calculations for each coal type. Minn. R. 7007.0800, subps. 4 & 5

PM10 Periodic Monitoring: The PM CAM plan requirements shall fulfill periodic monitoring for PM10 emissions, unless PM and PM10 performance testing demonstrates no consistent relationship between PM and PM10 emission rates (for example, on a lb/mmBtu basis and the same coal type, PM test results from an agency-approved test are less than those for PM10, but in another agency-approved performance test PM results exceed those for PM10). Minn. R. 7007.0800, subps. 4(B) & 5(A)

COMPLIANCE ASSURANCE MONITORING hdr

Compliance Assurance Monitoring: Continuously monitor and record ESP total secondary power, molten sulfur feed rate (surrogate for SO3 injection rate), and ammonia flow rate (surrogate for ammonia injection rate) whenever EU 002 is operating. 40 CFR Sections 64.6(c), 64.7(c), & 64.9(b)

Total Power Input: greater than or equal to 95 kilowatts using 3-hour Rolling A verage for ESP total power. This is the value measured during the most recent PM performance test that demonstrated compliance. ESP total power is the sum of the input power measured for each ESP electrical field. Field input power is measured in kilowatts and is the product of the secondary voltage and secondary current for each field. Secondary voltage and secondary current are measured using digital metering onboard the power supplies for each electrical field. The average must be recalculated once every hour to determine an average for the previous three hours.

This limit applies unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. 40 CFR Section 64.6(c)

A mmonia: greater than or equal to 0 parts per million using 3-hour Rolling Average measured at stack for Ammonia Injection. This is the value measured during the most recent PM performance test that demonstrated compliance. Determined by flow from the ammonia flowmeter amperage reading converted to parts per million ammonia.

This limit applies unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. 40 CFR Section 64.6(c)

Liquid Flow Rate: greater than or equal to 0 parts per million using 3-hour Rolling A verage measured at stack of Molten Sulfur. This is the value measured during the most recent PM performance test that demonstrated compliance. Determined by sulfur pump speed cenveted to parts per million SO3. This limit applies unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. 40 CFR Section 64.6(c)

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-20

Excursions: An excursion is defined as any of the following:

1. ESP total power (3-hour rolling average) less than 95 kilowatts or value determined during most recent PM performance test. 2. Molten sulfur feed rate (3-hour rolling average) measured as pump signal milliamps less than the value determined during most recent certified PM performance test. 3. Ammonia flow rate (3-hour rolling average) less than the flow meter milliamps less than the value determined during most recent certified PM performance test.

Respond to excursions as required by section 64.7(d) including inspection, evaluation, and corrective action. 40 CFR Sections 64.6(c) & 64.7(d)

ESP Total Power CAM Performance Criteria:

1. ESP secondary voltage and current are measured using the instrumentation provided by the ESP power supply manufacturer. These signals are brought into the plant DCS/DAHS systems for recording and indication.

2. On an annual basis, confirm meter zero power readings when the ESP power supplies are not operating.

3. Voltage and current are measured continuously and used to calculate the power output every 15 minutes.

4. Hourly average power input is calculated and recorded based on the four 15-minute readings.

5. Hourly averages are used to determine the 3-hour rolling average total power input. 40 CFR Section 64.6(c)

Molten Sulfur Feed Rate CAM Performance Criteria:

1. The molten sulfur pump Variable Frequency Drive (VFD) kilowatt output will be measured using the instrumentation provided by the flue gas conditioning system supplier.

2. In the event that the molten sulfur pump motor fails, the SO3 production controls will alarm.

3. On an annual basis, confirm kilowatt feedback from the VFD reads 0 kilowatts during standby mode for the flue gas conditioning system, or when EU 002 is not operating.

4. The pump VFD kilowatt output feedback is measured continuously and brought into the plant DCS/DAHS systems for recording and indication.

5. The averaging period is a 3-hour rolling average. 40 CFR Section 64.6(c)

A mmonia Flow Rate CAM Performance Criteria:

1. Measure the analog signal using the instrumentation and control system provided by the flue gas conditioning system supplier.

2. If ammonia flow is interrupted, the NH3 production controls will alarm based on NH3 flow failure.

3. On an annual basis, confirm ammonia flowmeter feedback reads zero flow during standby mode for the flue gas conditioning system, or when EU 002 is not operating.

4. The ammonia flowmeter feedback is measured continuously and brought into the plant DCS/DAHS systems for recording and indication.

5. The averaging period is a 3-hour rolling average. 40 CFR Section 64.6(c)

CAM Excursions Reporting: The Permittee shall report all ESP total power, molten sulfur injection, and ammonia injection excursions in the semiannual deviations report required by this permit. 40 CFR Section 64.9(a)

Documentation For Need of Improved Monitoring: As required by Section 64.8(e), promptly notify the agency and submit a permit application to address necessary monitoring changes if the Permittee identifies noncompliance with the total particulate matter limit (the 0.3 lb/mmBtu limit that meets Minn. R. 7011.0510, subp. 1) . 40 CFR Section 64.7(e)

PARTICULATE MATTER CONTROL EQUIPMENT REQUIREMENTS (CE 002, CE 017, AND CE 018) hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-21

A mmonia Injection: Initial performance tests indicate ammonia injection is not necessary to meet applicable EU 002 Option 1 or Option 2 PM or PM10 requirements. If the Permittee chooses to suspend ammonia injection or chooses to operate it on a voluntary basis, all compliance assurance monitoring (CAM) requirements pertaining to the ammonia injection system no longer apply. If future tests indicate that ammonia injection is required to meet the Option 1 or Option 2 PM or PM10 requirements, then the CAM requirements apply. Minn. R. 7007.0800, subp. 2

Notification Of Discontinuation of Use of Ammonia Injection: If the Permittee discontinues use of the ammonia injection system, the Permittee shall submit written notification of such to the agency, no later than 15 days after discontinuation. Minn. R. 7007.0800, subp. 2

Molten Sulfur Injection: Initial performance tests indicate molten sulfur injection is not necessary to meet applicable EU 002 Option 1 or Option 2 PM or PM10 requirements. If the Permittee chooses to suspend molten sulfur injection or chooses to operate it on a voluntary basis, all compliance assurance monitoring (CAM) requirements pertaining to the molten sulfur injection system no longer apply. If future tests indicate that molten sulfur injection is required to meet the Option 1 or Option 2 PM or PM10 requirements, then the CAM requirements apply. Minn. R. 7007.0800, subp. 2

Notification Of Discontinuation of Use of molten sulfur Injection: If the Permittee discontinues use of the molten sulfur injection system, the Permittee shall submit written notification of such to the agency, no later than 15 days after discontinuation. Minn. R. 7007.0800, subp. 2

MERCURY CONTROL EQUIPMENT (CE 012) REQUIREMENTS hdr

Mercury Control: Permittee is authorized to install and operate a furnace sorbent or reagent injection system for the injection of mercury control sorbents or reagents. The Permittee may use calcium bromide, activated carbon, or other mercury reagents/sorbents provided a mercury emissions performance test is conducted no later than 90 days after any new sorbent is installed and tuned, and the measured mercury emissions rate is less than or equal to that measured by the most recent MPCA-approved performance test.

If Permittee changes the mercury sorbent/reagent, the Permittee shall submit written notification of such to the agency no later than 15 days after making the change. Minn. R. 7007.0800, subp. 2

Mercury additive feedrate: greater than or equal to 6 gallons/hour using 3-hour Rolling Average . Calcium bromide with a density of 14.1 pounds per gallon. If a supplemental reagent such as activated carbon is also used, then based on subsequent stack performance testing, the calcium bromide injection rate may be adjusted. If a different density reagent is procured, the injection rate may also be adjusted in order to yield an equivalent Calcium bromide delivery rate as outlined above. Minn. R. 7007.0800, subp. 2

Mercury Reagent Injection: Immediately upon discovery of a drop of mercury reagent injection rate below the value measured during the most recent mercury performance test, initiate corrective actions to restore the mercury reagent injection rate as soon as possible. Minn. R. 7007.0800, subp. 2

Mercury Reagent Injection Monitoring: The Permittee shall install, maintain, and operate at all times that EU 002 is operating, a system for monitoring and recording the mercury reagent feed rate. Record the time periods, reasons, and corrective actions taken for all EU 002 operating periods when mercury reagent flow rate is below the required minimum. Minn. R. 7007.0800, subp. 2

PERFORMANCE TESTING hdr

Performance Test: due before end of each 36 months starting 07/15/2008 to measure mercury emissions.

The Permittee shall calculate mercury control efficiency based on results of each performance test and uncontrolled mercury emissions determined by concurrent fuel sampling, and submit the calculation in the report for each performance test. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 36 months starting 07/11/2008 to measure particulate matter emissions. The tests shall be conducted at an interval not to exceed 36 months between test dates. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months starting 07/11/2008 to measure PM10 emissions. The tests shall be conducted at an interval not to exceed 60 months between test dates. Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-22

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subps. 2(A) & 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

1. If the results of the performance test are greater than 80% of any applicable emission limit for which emissions are measured, then boiler operation will be limited to the tested operating rate.

2. If results are less than or equal to 80% of all applicable emission limits for which emissions are measured, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Documentation of all STET operation shall be maintained. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results measure emissions at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results measure emissions at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

A CID RAIN PROGRAM REQUIREMENTS hdr

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Sections 72.9(c)(1)(ii) & 72.9(g)(4)

NOx Averaging Plan:

Beginning January 1, 2002, either:

Maintain an annual average NOx emission rate of 0.40 lbs/mmBtu and limit the annual heat input to less than or equal to 5,600,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-23

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created:

1. The certificate of representation; 2. All emissions monitoring information; 3. Copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program; 4. Copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

A pply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). 40 CFR Section 72.30(c)

Certify Acid Rain Program Submittals.

Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section 72.21. 40 CFR Section 72.21

Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, 2002. A llowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. 40 CFR Sections 72.9(c)(1)(i) & 72.9(g)(4)

The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-24

Subject Item: EU 003 Boiler No. 3

Associated Items: CE 003 Electrostatic Precipitator - High Efficiency

GP 001 Three 745 MMBtu/hr coal-fired boilers

SV 003 Boiler 3 stack

What to do Why to do it Refer To Subject Item SV 003 for NOx and SO2 CEMS Requirements and COMS Requirements. hdr

Total Particulate Matter: less than or equal to 0.3 lbs/million Btu heat input (excluding condensible particulate matter). Minn. R. 7007.0800, subp. 2; meets requirements of Minn. R. 7011.0510, subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0510, subp. 2;

Sulfur Dioxide: less than or equal to 0.78 lbs/million Btu heat input using 3-hour A verage Minn. R. 7009.0020 to not cause or contribute to a violation of the ambient SO2 standards in Minn. R. 7009.0080; meets the requirements of Minn. R. 7011.0510, subp. 1 Fuels allowed: bituminous coal, sub-bituminous coal, distillate fuel oil, used oil, used oil sorbents, propane, and boiler cleaning agents. Minn. R. 7007.0800, subp. 2

Performance Test: due before end of each 60 months starting 05/25/2005 to measure particulate matter emissions. The tests shall be conducted at an interval not to exceed 60 months between test dates. Minn. R. 7017.2020, subp. 1

Boiler Alternative Operating Conditions for Performance Testing:

A lternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subps. 2(A) & 3(B)

Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing:

If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following:

1. If the results of the performance test are greater than 80% of any applicable emission limit for which emissions are measured, then boiler operation will be limited to the tested operating rate.

2. If results are less than or equal to 80% of all applicable emission limits for which emissions are measured, boiler operation will be limited to 110% of the tested operating rate.

In no case will the new operating rate limit be higher than allowed by an existing permit condition. Minn. R. 7017.2025, subp. 3(B)

STET (Short Term Emergency and Testing) Operating hours limit:

The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Documentation of all STET operation shall be maintained. The boiler must meet emission limits during STET operation. Minn. R. 7007.0800, subp. 2

STET Operation Definition that applies to Boilers that Meet or do Not Meet the A lternative Operating Condition for Performance Testing:

If performance test results measure emissions at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test.

If performance test results measure emissions at greater than 80% any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test.

In no case will STET operation be higher than allowed by an existing permit condition. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-25

A CID RAIN PROGRAM REQUIREMENTS hdr

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Sections 72.9(c)(1)(ii) & 72.9(g)(4)

NOx Averaging Plan:

Beginning January 1, 2002, either:

Maintain an annual average NOx emission rate of 0.40 lbs/mmBtu and limit the annual heat input to less than or equal to 5,600,000 mmBtu per year.

OR

Maintain a Btu-weighted annual average emission rate in lbs/mmBtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or 76.7. Units covered in the plan are:

Plant Boiler ID#

Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 40 CFR Section 76.11

Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created:

1. The certificate of representation; 2. All emissions monitoring information; 3. Copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program; 4. Copies of all documents used to complete an acid rain permit application. 40 CFR Section 72.9(f)(l)

A pply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). 40 CFR Section 72.30(c)

Certify Acid Rain Program Submittals.

Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section 72.21. 40 CFR Section 72.21

Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, 2002. A llowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. 40 CFR Sections 72.9(c)(1)(i) & 72.9(g)(4)

The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section 75.10. 40 CFR Section 75.10

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-26

Subject Item: EU 004 Heating Boiler - 34 mmBtu/hr

Associated Items: SV 004 Heating Boiler stack

What to do Why to do it Heat Input: less than or equal to 29,784 million Btu/year using 12-month Rolling Sum Title I Condition: Limit to restrict annual capacity factor to qualify as a limited use boiler under 40 CFR Section 63.7575 Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Opacity: less than or equal to 20 percent opacity except that a maximum of 60 percent opacity shall be permissible for four minutes in any 60-minute period and that a maximum of 40 percent opacity shall be permissible for four additional minutes in any 60-minutes period. Minn. R. 7011.0510, subp. 2

Fuel type limited to distillate fuel oil. Minn. R. 7007.0800, subp. 2

Heat Input Monitoring and Recordkeeping: By the last day of each month calculate and record:

1. EU 004 monthly fuel usage and (convert to) monthly heat input for the previous calendar month; 2. EU 004 heat input for the previous 12-month period by summing the monthly heat inputs for the previous 12 months. Title I Condition: Recordkeeping for annual capacity factor to qualify as a limited use boiler under 40 CFR Section 63.7575; Minn. R. 7007.0800, subps. 4 & 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-27

Subject Item: EU 005 Cold Start Generator

Associated Items: SV 005 Cold Start Generator stack

What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2

Fuel type limited to distillate fuel oil. Minn. R. 7007.0800, subp. 2

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-28

Subject Item: EU 006 Ash Collection Baghouse

Associated Items: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 006 Ash Collection Baghouse stack

What to do Why to do it Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0710, subp. 1(A)

Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0710, subp. 1(B)

The Permittee shall operate and maintain CE 004 so that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 The Permittee shall operate and maintain CE 004 so that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 The Permittee shall operate and maintain CE 004 at all times that any emission unit controlled by the fabric filter is in operation. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 & 14 Visible Emissions: The Permittee shall check the stack/vent for CE 004 for any visible emissions once each week of operation.

A ll observations shall be made during daylight hours. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

Recordkeeping of Visible Emissions: The Permittee shall record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5 Periodic Inspections: The Permittee shall inspect the fabric filter components once per calendar quarter or as required by the manufacturer. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5, & 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

1. Visible emissions are observed; 2. During an inspection, the fabric filter or any of its components are found to need repair.

Corrective actions shall eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O&M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, & 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 10/19/09
Minnesota Power - Tac Harbor Energy Ctr

03100001 - 008 Facility Name:

Permit Number: A-29

Subject Item: EU 011 Crusher and Related Transfer Points

Associated Items: CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 011 Crusher Baghouse

What to do Why to do it
LIMITS hdr

Opacity: less than or equal to 20 percent opacity 40 CFR Section 60.252(c); Minn. R. 7011.1105(G) The Permittee shall operate and maintain CE 019 so that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2, 4, & 5

The Permittee shall operate and maintain CE 019 so that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2, 4, & 5

MONITORING AND RECORDKEEPING hdr

The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. Minn. R. 7007.0800, subps. 4 & 5

Recordkeeping of Visible Emissions: The Permittee shall record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Minn. R. 7007.0800, subps. 4 & 5

CE 019 shall operate all listed control equipment located at the stationary source whenever operating the coal crusher and/or associated conveyers. Minn. R. 7007.0800, subps. 4 & 5

Periodic Inspections: The Permittee shall inspect the fabric filter components once per calendar quarter or as required by the manufacturer. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5, & 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:

1. Visible emissions are observed; 2. During an inspection, the fabric filter or any of its components are found to need repair.

Corrective actions shall eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O&M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, & 14

Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. 40 CFR Section 60.7(a)(4); Minn. R. 7019.0100, subp. 1

## TABLE B: SUBMITTALS
Facility Name: Minnesota Power - Tac Harbor Energy Ctr

Permit Number: 03100001 - 008 10/19/09 B-1

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by part s 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separatel y list one-time only and recurrent submittal requirements.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

## TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS
Facility Name: Minnesota Power - Tac Harbor Energy Ctr

Permit Number: 03100001 - 008 10/19/09 B-2

What to send When to send Portion of Facility Affected
A pplication for Permit Reissuance due 180 days before expiration of Existing Permit Total Facility

Submittal of Permit Application due 90 days after achieving normal operation of combined calcium bromide and activated carbon injection systems, conduct performance test for EU 002 mercury emissions. Within 90 days of performance test completion, submit permit application. The application shall contain the appropriate forms for a major amendment to this permit to add an EU 002 mercury emission limit and/or control efficiency, mercury control monitoring parameter ranges, and minimum parameter values for the parameters as described in the Mercury Control Requirements section of the permit.

A n extension was given due to the difficulties with quantifing control perameters for proper murcury removal. Total Facility

## TABLE B: RECURRENT SUBMITTALS
Facility Name: Minnesota Power - Tac Harbor Energy Ctr

Permit Number: 03100001 - 008 10/19/09 B-3

What to send When to send Portion of Facility Affected Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter starting 05/19/1997 (Submit Deviations Reporting Form DRF-1 as amended). The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. SV001

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter starting 05/19/1997 (Submit Deviations Reporting Form DRF-1 as amended). The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. SV002

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter starting 05/19/1997 (Submit Deviations Reporting Form DRF-1 as amended). The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. SV003

Semiannual Deviations Report due 30 days after end of each calendar half-year starting 05/19/1997 . The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Total Facility

Compliance Certification due 30 days after end of each calendar year starting 05/19/1997 (for the previous calendar year). Submit the certification on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This certification covers all deviations experienced during the calendar year. Total Facility

# APPENDIX MATERIAL Facility Name: Minnesota Power - Taconite Harbor Energy Permit Number: 03100001-008 

# Phase II NOx Compliance Plan

For more information, see instructions and refer to 40 CFR 76.9

This submission is: New(Renewal) Revised

Step 1 Indicate plant name, State, and ORIS code from NADB, if applicable Taconite Harbor Energy Center

Plant Name MN

State 10075

ORIS Code

Step 2 Identify each affected Group 1 and Group 2 boiler using the boiler ID# from NADB, if applicable. Indicate boiler type: “CB” for cell burner, “CY” for cyclone, “DBW” for dry botton wall-fired, “T” for tanget ially fired, “V” for vertically fired, and “WB” for wet bottom. Indicate the compliance option selected for each unit



## ID# 1 ID# 2 ID# 3 ID# ID# ID#

Type T Type T Type T Type Type Type

( a) Standard annual average emission limitation of 0.50 lb/mmBtu (for Phase I dry bottom wall-fired boilers) (b) Standard annual average emission limitation of 0.45 lb/mmBtu (for Phase I tangentially fired boilers) (c) EPA-approved early election plan under 40 CFR 76.8 through 12/31/07 (also indicate above emission limit specified in plan) (d) Standard annual average emission limitation of 0.46 lb/mmBtu (for Phase II dry bottom wall-fired boilers) (e) Standard annual average emission limitation of 0.40 lb/mmBtu (for Phase II tangentially fired boilers) (f) Standard annual average emission limitation of 0.68 lb/mmBtu (for cell burner boilers) 

## X

### (g) Standard annual average emission limitation of 0.86 lb/mmBtu (for cyclone boilers) (h) Standard annual average emission limitation of 0.80 lb/mmBtu (for vertically fired boilers) (i) Standard annual average emission limitation of 0.84 lb/mmBtu (for wet bottom boilers) (j) NOx Averaging Plan (include NOx Averaging form) 

## X X X

(k) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(A) (check the standard emission limitation box above for most stringent limitation applicable to any unit utilizing stack (l) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(B) with NOx Averaging (check the NOx Averaging Plan box and include NOx Averaging form) (m) EPA-approved common stack apportionment method pursuant to 40 CFR 75.17 (a)(2)(i)(C), (a)(2)(iii)(B), or (b)(2) (n) AEL (include Phase II AEL Demonstration Period, Final AEL Petition, or AEL Renewal form as appropriate) (o) Petition for AEL demonstration period or final AEL under review by U.S. EPA or demonstration period ongoing (p) Repowering extension plan approved or under reviewStandard Requirements

General. This source is subject to the standard requirements in 40 CFR 72.9 (consistent with 40 CFR 76.8(e)(1)(i)). These requirements are listed in th is source's Acid Rain Permit.

Special Provisions for Early Election Units

Nitrogen Oxides. A unit that is governed by an approved early election plan shall be s ubject to an emissions limitation for NO x as provided under 40 CFR 76.8(a)(2) except as provided under 40 CFR 76.8(e)(3)(iii).

Liability. The owners and operators of a unit governed by an approved early election plan shall be liable for any violation of the plan or 40 CFR 76.8 at that unit. T he owners and operators shall be liable, beginning January 1, 2000, for fulfilling the obligations specified in 40 CFR Part 77.

Termination. An approved early election plan shall be in effe ct only until the earlier of January 1, 2008 or January 1 of the calendar year for which a termination of the pl an takes effect. If the designated representative of the unit under an approved early election plan fails to demonstrate compliance with the applicable emissions limitation under 40 CFR 76.5 for any year during the period beginning J anuary 1 of the first year the early election takes effect and ending December 31, 2007, the permitting authority will terminate the plan. The termination will take effect beginning January 1 of the year after the year for wh ich there is a failure to demonstrate compliance, and the designated representative may not submit a new early el ection plan. The designated r epresentative of the unit under an approved early election plan may terminate the pl an any year prior to 2008 but may not submit a new early election plan. In order to terminate the plan, the designated representative must submit a notice under 40 CFR 72.40(d) by January 1 of the year for which the term ination is to take effec t. If an early election plan is terminated any year prior to 2000, the unit shall meet, begi nning January 1, 2000, the applicabl e emissions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7. If an early election plan is terminated on or after 2000, the unit shall meet, beginning on the effective date of the termination, the applicable em issions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7.

# Phase II NOx Averaging Plan

For more information, see instructions and refer to 40 CFR 76.11

This submission is: New (Renewal) Revised

(b) (c) Alt. Annual (a) Contemp. Heat Emission Emission Input Step 1 Plant Name State ID# Limitation Limitation Limit Identify the units participating in this averaging plan by plant name, State, and boiler ID# from NADB. In column (a), fill in each unit’s applicable emission limitation from 40 CFR 76.5, 76.6, or 76.7. In column (b), assign an alternative contemporaneous annual emissions limitation in lb/mmBtu to each unit. In column (c), assign an annual heat input limitation in mmBtu to each unit. Continue to page 3 if necessary. 

## Boswell MN 1 0.46 0.45 3,500,000
Boswell MN 2 0.46 0.45 3,500,000
Boswell MN 3 0.40 0.39 19,000,000
Boswell MN 4 0.40 0.35 33,000,000
Laskin MN 1 0.40 0.50 4,600,000
Laskin MN 2 0.40 0.50 4,600,000
Taconite Harbor MN 1 0.40 0.45 5,600,000
Taconite Harbor MN 2 0.40 0.45 5,600,000
Taconite Harbor MN 3 0.40 0.45 5,600,000 X

## Step 2

Use the formula to enter the Btu-weighted annual em ission rate averaged over the units if they are operated in accordance with the proposed averaging plan and the Btu-weighted annual averge emission rate for the same units if they are operate d in compliance with 40 CFR 76.5, 76.6, or 76.7. The former must be less than or equal to the latter.

Btu-weighted annual emission rate Btu-weighted annual average averaged over the units if they are emission rate for same units operated in accordance with the operated in compliance with proposed averaging plan 40 CFR 76.5, 76.6, or 76.7



# n n Σ (R Li 

# x HI i 

# ) Σ [R li 

# x HI i 

# ] i=l i=l

________________ <

__________________ n n Σ HI i 

# Σ HI i 

# i=l i=l

Where, R Li 

# = Alternative contemporaneous annual emission limitation unit i, in lb/mmBtu, as specified in column (b) of Step 1: R li 

# = Applicable emission lim itation for unit i, in lb/mmBtu, as specified in column (a) of Step 1:

HI i 

# = Annual heat input for unit i, in mmBtu, as specified in column (c) of Step 1: n = Number of units in the averaging plan

This plan is effective for calendar year 2008 through calendar year 2012 unless notification to term inate the plan is given.

Treat this plan as identical plans, eac h effective for one calendar year for the following calendar years ______, ______, ______, ______, and ______ unless notification to terminate one or more of these plans is given. 0.40 0.40

X

## Special Provisions

Emission Limitations

Each affected unit in an approved averaging plan is in comp liance with the Acid Rain emission limitation for NO x 

### under the plan only if the fo llowing requirements are met: (i) For each unit, the unit's actual annual average emission rate for the calendar year, in lb/mmBtu, is less than or equal to its alternative cont emporaneous annual emission limitati on in the averaging plan, and (a) For each unit with an alternative contemporaneous emi ssion limitation less stringent than the applicable emission limitation in 40 CFR 76.5, 76. 6, or 76.7, the actual annual heat input for the calendar year does not exceed the annual heat input limit in the averaging plan, (b) For each unit with an alternative contemporaneous emi ssion limitation more stringent than the applicable emission limitation in 40 CFR 76.5, 76.6, or 76.7, the actual annual heat input for the calendar year is not less than the annual heat input limit in t he averaging plan, or (ii) If one or more of the units does not meet the requirements of (i ), the designated r epresentative shall demonstrate, in accordance with 40 CFR 76.11(d)(1)(ii)(A) and (B), that t he actual Btu-weighted annual av erage emission rate for the units in the plan is less than or equal to the Btu-wei ghted annual average rate for the same units had they each been operated, during the same period of time, in compliance with the applicable emission limitat ions in 40 CFR 76.5, 76.6, or 76.7. (iii) If there is a successful group showing of complianc e under 40 CFR 76.11(d)(1)(ii)(A) and (B) for a calendar year, then all units in the averaging plan shall be deemed to be in compliance for that year with their alternative contemporaneous emission lim itations and annual heat i nput limits under (i).

Liability

The owners and operators of a unit gover ned by an approved averaging plan shall be liable for any violation of the plan or this section at that unit or any other unit in the plan, including liability for fulfilling the obligations specified i n part 77 of this chapter and se ctions 113 and 411 of the Act.

Termination

The designated representativ e may submit a notification to te rminate an approved averaging plan, in accordance with 40 CFR 72.40(d), no later than October 1 of the calendar year for which the plan is to be terminated.

# Acid Rain Permit Application

For more information, see instruct ions and refer to 40 CFR 72.30 and 72.31

This submission is New Revised

Taconite Harbor Energy Center

Plant Name 

## MN

State 

## 10075

ORIS Code



## a b c d Boiler ID# Unit Will Hold Allowances in Accordance with 40 CFR 72.9(c)(1) New Units Commence Operation Date New Units Monitor Certification Deadline

1 X Yes 2 X Yes 3 X Yes Yes Yes Yes Yes Yes Yes Yes Yes XPermit Requirements.

(1) The designated representative of each affected s ource and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (i ncluding a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental informati on that the permitting authority determines is necessary in order to review an Acid Rain permit applicat ion and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Ra in permit application or a super seding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit.

Monitoring Requirements.

(1) The owners and operators and, to the extent applicable, desi gnated representative of each affected source and each affected unit at the source shall comply with the moni toring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitat ions and emissions reduction requi rements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other em issions characteristics at the unit under other applicable requirements of the Act and other provisions of the operati ng permit for the source.

Sulfur Dioxide Requirements.

(1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadli ne, in the unit's compliance s ubaccount (after deductions under 40 CFR 73.34(c)), or in the compliance subaccount of another affe cted unit at the same source to the extent provided in 40 CFR 73.35(b)(3), not less than the total annual emissions of sulf ur dioxide for the previous calendar year from the unit; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Ra in emissions limitations for sulf ur dioxide shall constitute a s eparate violation of the Act. (3) An affected unit shall be subject to the requirement s under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted fr om, or transferred among Allowance Tracki ng System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply wi th the requirements under paragraph (1)(i) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Ra in Program is a limited authorizat ion to emit sulfur dioxide i n accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no pr ovision of law shall be construed to limit the authority o f the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right.

Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides.

Excess Emissions Requirements.

(1) The designated representative of an affected unit that has ex cess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall: (i) Pay without demand the penalty required, and pay upon dem and the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77.

Recordkeeping and Reporting Requirements.

(1) Unless otherwise provided, the owners and operators of the s ource and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i) The certificate of representation for the designated representative for the s ource and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submissi on of a new certificate of representation changing the designated representative;(ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provids for a 3-year period for reco rdkeeping, the 3-year period shall apply; (iii) Copies of all reports, complianc e certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Pr ogram, including those under 40 CFR part 72 subpart I and 40 CFR part 75.

Liability.

(1) Any person who knowingly viol ates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be s ubject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pur suant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any viol ation of the requirements of the Acid Rain Program that occurs prior to the date th at the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a pr ovision applicable to the designat ed representative of an affected source) shall also apply to the ow ners and operators of such source and of the affected units at the

source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a prov ision applicable to the designated representative of an affected unit) shall also apply to the ow ners and operators of such unit. Ex cept as provided under 40 CFR 72.44 (Phase II repowering extens ion plans) and 40 CFR 76.11 (NO x averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit sha ll not be liable for any violation by any other affected un it of which they are not owners or operators or the designated representative and that is loca ted at a source of which they are not owners or operators or the designated representative. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act.

Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72. 7 or 72.8 shall be construed as: (1) Except as expressly provided in titl e IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from co mpliance with any other provision of th e Act, including the provisions of title I of the Act relating to applicable Na tional Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold; provided, that the number of a llowances held by the unit shall not affec t the source's obligation to comply wi th any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating el ectric utility rates and charges, affecting any State law rega rding such State regulation, or limiting such State regulat ion, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authorit y of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established.

## Technical Support Document, Permit Action Number: 03100001-008 Page 1 of 5 Date: 11/16/2009 

# TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 03100001-008

This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set fort h by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit.

1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address
Applicant/Address Stationary Source/Address (SIC Code: 4911 ) Minnesota Power 30 West Superior St. Duluth, MN 55802 

# Taconite Harbor Energy Center 8124 W Highway 61 Schroeder Cook County Contact: Krogh, Brandon Phone: 218-723-3954
1.2 Facility Description

Minnesota Power’s Taconite Harbor Energy Center c onsists of three 745 MMBtu coal-fired units located in Schroeder, MN. The units have ta ngentially fired boilers that are permitted to burn both bituminous and sub-bituminous coals. Coal for the boilers is stored in an outdoor storage pile. The plant currently uses Montana Powder River Basin (PRB) sub-bituminous coal.



# 1.3 Description of the Activities Allowed by this Permit Action

No physical changes will occur as part of this permit amendment. The permit amendment is primarily a revision to the State-Only (Non Title-I) emission limits of SO 2 

# and NOx for EU002.

In 2006, Minnesota Power installed Mobotec’s multi pollution control technologies as a pilot test project on Taconite Harbor Unit 2 boiler to reduce SO 2 

# , NO x 

# , and Mercury. There was a possibility of a significant increase in PM and PM 10 

# emissions due to the injection of lime based alkali into the boiler for SO 2 

# control. There were various permit conditions put in the permit to avoid a significant increase of PM and PM 10 

# under PSD. This permit amendment revises the state-only emissions limits due to uncertainties surrounding the control devices and technologies involved. It has proven necessary to operate the control system at a reduced hydrate injection rate in order to reliably meet the PM and PM 10 

# limits. These reduced injection rates has caused the facility to be unable to achieve the level of SO 2 

# expected by the pilot project. Likewise, the

## Technical Support Document, Permit Action Number: 03100001-008 Page 2 of 5 Date: 11/16/2009 

# actual efficiency of the NOx reduction system is slightly less then anticipated. The revised emissions limits are 0.45 lbs/MMBtu SO 2 

# and 0.17 lbs/MMBtu NO x 

# . This permit amendment allows the facility to discontinue use of molten sulfur ejection as an ESP conditioning agent. Molten sulfur has been shown to have an inverse relationship with mercury removal. Stack tests have also shown that the facility can meet particulate limits without the use of SO 3 

# injection.

This permit amendment gives an extension for the submittal of the Mercury Removal Control Plan. Due to ongoing issues with the mercury capture reagent and interactions between other portions of the control systems, the facility requires an extension. This time will be used to tune and retest the control equipment. This extension has been reviewed and approved by Anne Jackson.

This permit amendment removes requirement and citations that no longer apply. On February 8, 2008, CAMR was vacated by the U.S. Court of appeals for the D.C. Circuit.

This Permit also rolls in two Reopenings and an administrative amendment.

1.4. Facility Emissions: Table 2. Title I Emissions Increase Summary

Pollutant Emissions Increase from the Modification (tpy) PSD/112(g) Significant Thresholds for major

sources

(tpy) NSR/ 112(g) Review Required?

(Yes/No)
PM 23.5 25 No
PM 10 

# 12.1 15 No
PM 2.5 

# NA 10 No
NO x 

# -589 40 No
SO 2 

# -646 40 No
CO 0 100 No Ozone (VOC) 0 40 No
Lead 0 0.6 No

Table 3. Facility Classification

Classification Major/Affected Source Synthetic Minor Minor PSD PM, PM 10 

## , SO x 

## , NO x 

## , CO VOC Part 70 Permit Program PM 10 

## , SO x 

## , NO x 

## , CO VOC Part 63 NESHAP Single & Total HAPs

## Technical Support Document, Permit Action Number: 03100001-008 Page 3 of 5 Date: 11/16/2009 

# 2. Regulatory and/or Statutory Basis

New Source Review The facility is an existing major source under New Source Review regulations. Table 2 is the summary of the revised Past-Actual to Future-Projected analysis. Part 70 Permit Program
The facility is a major source under the Part 70 permit program. 

# New Source Performance Standards (NSPS)
The facility is subject to 40 CFR Part 60 Subpart Y St andard of Performance for Coal Preparation Plants. 

# National Emission Standards for Hazardous Air Pollutants (NESHAP)
The facility is an existing major source of HAPs but this permit action does not change HAP emissions nor does it trigger a NESHAP standard. 

# Compliance Assurance Monitoring (CAM) CAM does not apply to the modification allowed in this permit amendment.

3. Technical Information

New Source Review Calculations 

# Attachment 1 to this TSD contains a spreadsheet detailing the Title-I emissions calculations. There was sufficient data to determine the baseline actual emissions as defined at §52.21(b)(48)(i). The Permitee has two options for demonstrating the PM and PM 10 

# emission increases are not significant under §52.21. Two options are available because the first option has reduced recordkeeping compared to the second option. PM and PM 10 

# emission factor performance tests are required regardless of the option selected. Option 1 requires the Permitee to conduct the monitoring, recordkeeping and reporting requirements described at § 52.21(r)(6), if the PM and PM 10 

# performance tests demonstrate that PM and PM 10 

# emissions do not exceed the Title I 0.039 lb/mmBtu and 0.120 lb/mmBtu emission factors in the permit for PM and PM 10 

# , respectively. The Title I emission factors are based on guarantees by the contractor that has converted the ESP from hot-side to cold-side.

If the Permittee can demonstrate that the PM and PM 10 

# do not exceed these emission factors, the Permittee will not be subject to a 12-month rolling sum limit necessary to avoid significant emissions increases for PM and PM 10 

# . Instead, the Permittee will be subject to the annual emissions monitoring requirements at § 52.21(r)(6)(c)(iii) for a ten year period, and annual reporting (due within 60 days after the end of the calendar year) of the unit’s annual emissions for the previous calendar year as required by § 52.21(r)(6)(c)(iv). Option 2 applies if the Permittee can not demonstrate that the PM and PM 10 

# emission factors do not exceed 0.039 lb/mmBtu and 0.120 lb/mmBtu for PM and PM 10 

# , respectively, or if the Permittee desires to be subject to the 12-month rolling sum limit regardless. The factors are based on guarantees from the control equipment vender the With this option, the Permittee will

## Technical Support Document, Permit Action Number: 03100001-008 Page 4 of 5 Date: 11/16/2009 

# be subject to Title I 106 tpy and 327 tpy (12-month rolling sum basis) PM and PM 10 

# limits, respectively, to restrict the emissions increase from the modification to less than the 25 tpy and 15 tpy significant levels for PM and PM 10 

# , respectively. In addition, the Permittee will be subject to on-going monitoring, recordkeeping, and reporting requirements. If the Permittee is only able to meet option 1 requirements for one pollutant, the Permittee may follow option 1 for that pollutant while following option 2 for the other pollutant. The Permittee initially proposed a permit condition stating the Permittee may conduct a PSD analysis if it could not meet the option 1 PM and/or PM 10 

# emissions factor requirement(s) to avoid concerns about potential sham permitting if the post-modification future actual annual PM and/or PM 10 

# increase exceeds the PSD significant level(s). However, based on discussions with EPA Region V staff in St. Paul on May 18, 2006, EPA indicated sham permitting would not be an issue if the future PM and/or PM 10 

# emissions increase is significant (providing the facility post-modification PM and/or PM 10 

# emissions increase doesn’t exceed the significant level until the Permittee obtains a PSD major modification permit authorizing the increase). This is because the Permittee has attempted to the best of its ability to accurately determine future actual emissions, the non-major permit amendment limits the increases to less than significant levels, and there is inherent uncertainty in the PM and PM 10 

# emission changes that will occur when retrofitting old boilers with new emissions control technology.

3.1 Emissions Increase Analysis

Attachment 1 to this TSD contains the Title I net emissions increase calculations for this modification. This demonstrates that this m odification is not a major modification for PSD. Attachment 1 contains the non-Title I calculations for this modification which demonstrate that the modification is a major amendment under Minn. R. 7007.1500.

3.2 Periodic Monitoring This permit amendment does not change any monitoring in the permit. In accordance with the Clean Air Act, it is the responsibility of the owne r or operator of a facility to have sufficient knowledge of the facility to certify that the f acility is in compliance with all applicable requirements.

3.3 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.5 Comments Received Public Notice Period: August 21, 2009 - September 21, 2009

## Technical Support Document, Permit Action Number: 03100001-008 Page 5 of 5 Date: 11/16/2009 

# EPA 45-day Review Period: August 21, 2009 – October 6, 2009 Comments were not received from the public during the public notice period.

4. Conclusion Based on the information provided by Minnesota Power, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03100001-008 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Benjamin Klismith (permit writer/engineer) Steve Palzkill (enforcement) Andy Place (stack testing) Chris Buntjer (peer reviewer)

AQ File No. 48A; DQ 2243, 2471, 2280

Attachments: 1. Emissions Increase Calculation Spreadsheets 2. Facility Description and CD-01 FormsOMB 2060-0631 Part I Question 14aMinnesota Power Taconite Harbor Energy Center (10075)Materials listed in the permitTaconite Harbor "Other" Material Permitted to burn Actually burn Quantity / yearUsed oilNA No -Facilty-wide quantityUsed oil sorbentsNA Yes 1,369 galFacilty-wide quantityPropaneNAYes 396 gal Facilty-wide quantityBoiler cleaning agentsNANo -NA=No limit listed specifically in permitUnit 1, Unit 2, andUnit 3If "other" was checked in questions 10 or 11 above indicating that any non-fossil fuel or other material (including, but not limited to,plastics, treated wood, rubber belting or gaskets, whole tires, tire-derived fuel, boiler cleaning solutions, animal wastes, etc.) is eitherutilized or permitted to be used, please indicate below what materials are combusted in the boiler and in what quantities (specify whetherthis quantity is on a weight percentage or heat [Btu] basis). Also indicate (yes/no) whether you are permitted to burn non-fossil fuel(s) orother material(s) even if you do not actually burn them.OMB 2060-0631 Part I, Question 15:Identification (or designation) of all coal- and oil-fired steam generating units (boilers) (as defined by Clean Air Act section 112(2)(8)) located at this facility)Minnesota Power Taconite Harbor Energy Center (10075)Facility NameSubpart EIA Plant CodeQ 15.01 Boiler IDUnit 1 Unit 2 Unit 3Q 15.02 Original design fuel (i.e. coal rank or type of oil)Midwest bituminous2Midwest bituminous2Midwest bituminous2Q 15.03Design heat input (mmBtu/hr)1762 762 756Q 15.04Present maximum heat input, (mmBtu/hr)3847 913 908Q 15.05 MWe gross capacity summer 83 79.2 80Q 15.06 MWe Net capacity summer 78 74 76Q 15.07 Original design gross efficiency (%, HHV) 88.9 (12,535btu/lb) 88.9 (12,535btu/lb) 88.9 (12,535btu/lb)Q 15.08Present operating gross efficiency (%, HHV)4NA NA NAQ 15.09Design steam pressure (psig)11450 1450 1450Q 15.10 Operating steam pressure (psig) 1450 1450 1450Q 15.11Design steam temperature (°F)11000 1000 1000Q 15.12 Operating steam temperature (°F) 1000 1000 1000Q 15.13Design steam reheat temperature (°F)11000 1000 1000Q 15.14 Operating steam reheat temperature (°F) 1000 1000 1000Q 15.15 FuelQ 15.16 Hours/year operated 7794.44 7402.85 8081.53Q 15.17 Average annual capacity factor for the past 3 years 71.98 70.7 75.56Q 15.18 Applicable NSPSQ 15.19 Estimated year of retirement Minnesota Power has no scheduled or planned retirement dates for any of our units1Original design values based on boiler acquisition contracts and/or heat balance drawings. Design heat input value does not represent maximum capacity at the time of unit commissioning.2Units were built for midwest bituminous but currently subbitminous PRB coal is being burned3Current heat input data from Title V permit application does not represent maximum heat input capacity.4We do not measure or calculate boiler efficiency on the units at this facility.TACONITE HARBOR1007540 CFR Part 60 Subpart Y>99% coal, <1%otherOMB 2060-0631 Part I, Question 16: Emission Control TechnologyMinnesota Power Taconite Harbor Energy Center (10075)Designate the order of the emission controls -- 1 for first control following the boiler, 2 for second control following the boiler, etc.Plant IDBoilerIDType NOx ControlIn-serviceDateSO2 ControlIn-serviceDatePM ControlIn-serviceDateOther ControlIn-serviceDateTac Harbor 1 Tangentially-fired 1 - ROFA / SNCR 2008 2 - Boiler alkali injection 2008 3 - ESP conversion hot-side to cold-side 2008 None-10075 2 Tangentially-fired 1 - ROFA / SNCR 2007 2 - Boiler alkali injection 2007 4 - ESP conversion hot-side to cold-side 2007 3 - CaBr2injection for Hg 20093 Tangentially-fired Good combustion practices - Low sulfur coal - 1 - Hot side ESP 1974 None -OMB 2060-0631 Part I Question 22: Guaranteed Emission RateMinnesota Power Taconite Harbor Energy Center (10075)PMPM10PM2.5SO2HCl and/orHFHCN Metal HAP Hg COOtherorganics(specify)Otherpollutant(specify)1 0.03 lb/mmBtu0.24lb/mmBtu2 0.03 lb/mmBtu0.24lb/mmBtu3Mostrecent guaranteed emission rate for each pollutant for which there is a permitted emission limitTaconiteHarbor(10075)Plant ID Boiler IDOMB 2060-063 Part II Questions 2-3Minnesota Power Taconite Harbor Energy Center (10075)Coal Shipments - Taconite Harbor Energy CenterTrain ID Tons Boiler ID# State County Coal SeamFuel ShipMethod Sulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel OtherDKMSUM301 14,821.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.410 4.520 9,175N/A N/A N/A N/A N/ADKMSUM302 13,255.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.420 4.680 9,226N/A N/A N/A N/A N/ADKMSUM303 14,813.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.380 4.570 9,315N/A N/A N/A N/A N/ADKMSUM304 14,785.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.390 4.790 9,278N/A N/A N/A N/A N/ADKMSUM305 14,815.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.400 4.660 9,353N/A N/A N/A N/A N/ADKMSUM306 14,823.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.440 4.660 9,390N/A N/A N/A N/A N/ADKMSUM307 14,825.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.320 3.590 9,356N/A N/A N/A N/A N/ADKMSUM308 14,875.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.290 3.930 9,251N/A N/A N/A N/A N/ADKMSUM309 13,858.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.440 4.420 9,422N/A N/A N/A N/A N/ADKMSUM310 14,823.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.420 4.180 9,507N/A N/A N/A N/A N/ADKMSUM311 13,866.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.400 4.140 9,454N/A N/A N/A N/A N/ADKMSUM312 13,860.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.430 4.290 9,562N/A N/A N/A N/A N/ADKMSUM313 14,920.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.400 3.950 9,611N/A N/A N/A N/A N/ADKMSUM314 13,475.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.400 4.070 9,487N/A N/A N/A N/A N/ADKMSUM315 14,792.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.390 4.240 9,404N/A N/A N/A N/A N/ADKMSUM316 14,185.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.390 3.890 9,602N/A N/A N/A N/A N/ADKMSUM317 14,099.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.430 4.060 9,612N/A N/A N/A N/A N/ADKMSUM318 14,196.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.380 3.850 9,614N/A N/A N/A N/A N/ADKMSUM319 13,858.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.260 3.210 9,556N/A N/A N/A N/A N/ADKMSUM320 13,860.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.310 3.510 9,421N/A N/A N/A N/A N/ADKMSUM321 14,701.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.380 4.280 9,561N/A N/A N/A N/A N/ADKMSUM322 14,825.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.340 4.190 9,526N/A N/A N/A N/A N/ADKMSUM323 14,858.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.270 3.750 9,417N/A N/A N/A N/A N/ADKMSUM324 14,820.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.330 3.860 9,492N/A N/A N/A N/A N/ADKMSUM325 14,813.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.310 3.930 9,338N/A N/A N/A N/A N/ADKMSUM326 14,839.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.290 3.480 9,303N/A N/A N/A N/A N/ADKMSUM327 14,572.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.360 4.620 9,332N/A N/A N/A N/A N/ADKMSUM328 14,365.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.360 4.020 9,631N/A N/A N/A N/A N/ADKMSUM329 14,840.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.320 4.530 9,373N/A N/A N/A N/A N/ADKMSUM330 14,827.000 1,2,3MT Big HornDietz 1 and Dietz 2RR0.380 4.420 9,431N/A N/A N/A N/A N/ASCMSUM601 13,433.925 1,2,3MT Big Horn Anderson Dietz RR0.310 4.400 9,575N/A N/A N/A N/A N/ASCMSUM602 13,356.450 1,2,3MT Big Horn Anderson Dietz RR0.290 5.570 9,290N/A N/A N/A N/A N/ASCMSUM603 13,904.350 1,2,3MT Big Horn Anderson Dietz RR0.300 3.860 9,327N/A N/A N/A N/A N/ASCMSUM605 13,991.600 1,2,3MT Big Horn Anderson Dietz RR0.380 4.830 9,348N/A N/A N/A N/A N/ASCMSUM606 14,860.275 1,2,3MT Big Horn Anderson Dietz RR0.330 4.000 9,332N/A N/A N/A N/A N/ASCMSUM607 15,108.550 1,2,3MT Big Horn Anderson Dietz RR0.330 4.480 9,380N/A N/A N/A N/A N/ASCMSUM608 14,975.125 1,2,3MT Big Horn Anderson Dietz RR0.270 4.510 9,440N/A N/A N/A N/A N/ABTMSUM101 14,765.150 1,2,3WY Campbell N/A RR0.280 4.710 8,974N/A N/A N/A N/A N/AN:\Projects\0210426-EPA_SPPD_(Opt3)\0210426.003.001-EGU_MACT\Data_and_Tools\2010_ICR_Collected_Data\Original\Archive\Allete_Hard_Copy\THEC OMB 2060-0631Parts I & II.xlsBTMSUM103 14,347.000 1,2,3WY Campbell N/A RR0.260 5.040 8,787N/A N/A N/A N/A N/ABTMSUM104 14,274.050 1,2,3WY Campbell N/A RR0.320 5.960 8,692N/A N/A N/A N/A N/ABTMSUM102 13,937.350 1,2,3WY Campbell N/A RR0.230 5.160 8,803N/A N/A N/A N/A N/ABTMSUM105 14,660.450 1,2,3WY Campbell N/A RR0.300 4.780 8,959N/A N/A N/A N/A N/ABTMSUM106 14,888.950 1,2,3WY Campbell N/A RR0.250 4.410 8,961N/A N/A N/A N/A N/ABTMSUM107 14,062.400 1,2,3WY Campbell N/A RR0.230 4.420 8,908N/A N/A N/A N/A N/ABTMSUM108 14,839.300 1,2,3WY Campbell N/A RR0.250 4.620 8,866N/A N/A N/A N/A N/AWTMSUM101 14,579.700 1,2,3WY Campbell N/A RR0.300 4.880 8,777N/A N/A N/A N/A N/AWTMSUM102 14,952.500 1,2,3WY Campbell N/A RR0.300 5.380 8,873N/A N/A N/A N/A N/ABTMSUM109 14,951.500 1,2,3WY Campbell N/A RR0.280 4.790 8,910N/A N/A N/A N/A N/ABTMSUM110 14,955.950 1,2,3WY Campbell N/A RR0.250 5.420 8,837N/A N/A N/A N/A N/AOil Shipments - Taconite Harbor Energy CenterOMB 2060-063 Part II Question 3ID Gallons Boiler ID# State County Coal SeamFuel ShipMethod Sulfur Ash Btu/Lb Mercury Chlorine Fluorine Nickel OtherCOMO333621 7,514.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO106886 7,502.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO106880 7,503.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO107530 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO107483 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO337873 7,509.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO337875 5,862.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO338246 7,506.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO114086 7,505.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO114507 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO60171 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO63745 7,514.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO343654 7,506.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO343979 7,513.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO345852 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO346400 7,507.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO347019 7,513.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO347353 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO347399 7,502.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO347708 7,513.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/ACOMO349056 7,500.00 1,2,3MN N/AN/ATR0.200 0.100 ######N/A N/A N/A N/A N/AFuel SourceN:\Projects\0210426-EPA_SPPD_(Opt3)\0210426.003.001-EGU_MACT\Data_and_Tools\2010_ICR_Collected_Data\Original\Archive\Allete_Hard_Copy\THEC OMB 2060-0631Parts I & II.xlsOMB 2060-0631 Part II, Question 8a, 8b, 8fMinnesota Power Taconite Harbor Energy Center (10075)Boiler ID(as listed in Part I question15)Question 8aEmission test report,parametric monitoring data,or other data or monitoringQuestion 8bDate of testingQuestion 8bType of testingQuestion 8bConstituentsQuestion 8fDid the unit's controlconfiguration differ forthat shown in Part I,questions 16 at the timeof the test? Boiler IDNOxControlSO2ControlPMControlOtherControlBoiler 1 Evergreen Air Services, IncPM Testing5/31/2005 stack PM yesnone noneHot SideESPnoneBoiler 2 Evergreen Air Services, IncPM Testing5/25/2005 stack PM yesnone noneHot SideESPnoneBoiler 3 Evergreen Air Services, IncPM Testing5/27/2005 stack PM noBoiler 2 GE EnergyPM & PM10 Testing7/8-10/2008 stack PM & PM10 noBoiler 2 Reaction EngineeringInternationalMercury control testing9/21/2008 to 11/21/2008 stack mercury noBoiler 2 GE EnergyPM & PM10 Testing12/2-4/2008 stack PM & PM10 noBoiler 3 Platt Environmental Services,IncMercury Testing7/1/2008 stack mercury noBoiler 2 Platt Environmental Services,IncMercury Testing7/15/2008 stack mercury noBoiler 2 GE EnergyAmmonia Emission Study7/7/2008 stack NH3 (Ammonia) noBoiler 1 GE EnergyESP PECO PM PerformanceTest2/18/2009 stack PM noBoiler 1 GE EnergyESP PM Engineering Test2/18-19/2009 stack PM noOMB 2060-0631 Part II, Question 12 Minnesota Power Taconite Harbor Energy Center (10075)

Boiler ID Test Date PM* SO2 HCL/HF/HCN Metal HAP Hg* CO Other organic Unit Load (MW) Net MWH NET) Moisture (%) Flow (dscfm or Nm3/hr) Flue gas oxygen (%, dry) Flue gas CO2 (%, dry) Flue gas temp (oF) Flue gas pressure (atm) Standard temp (F) Standard pressure (atm)

Boiler 1 5/31/2005 Boiler 1 = 0.031 lb/mmBtu 75.4 9.94 210301 dscfm 6.27 13.5 300 29.34 68 29.92 Boiler 2 5/25/2005 Boiler 2 = 0.031 lb/mmBtu 74.5 10.41 212157 dscfm 6.2 12.23 317.1 29.08 68 29.92 Boiler 3 5/27/2005 Boiler 3 = 0.027 lb/mmBtu 72.3 10.01 197168 dscfm 6.2 13 306.4 28.94 68 28.92

Boiler 2 7/8/2008 to 7/10/2008 Test 1-3 filterable PM = 0.020 lb/mmBTU total PM10 =0.037 lb/mmBTU Test 4-6 filterable PM = 0.026 lb/mmBTU total PM10 =0.035 lb/mmBTU Test 7-9 filterable PM10 = 0.027 lb/mmBTU total PM =0.035 lb/mmBTU Test 10-1 Test 1-3 = 11.4 Test 4-6 = 12.0 Test 7-9 = 12.2 Test 10-12 = 12.1 Test 1-3 = 183336 dscfm Test 4-6 = 184943 dscfm Test 7-9 = 180534 dscfm Test 10-12 = 182534 dscfm Test 1-3 = 6.2 %vol Test 4-6 = 5.3 %vol Test 7-9 = 5.6 %vol Test 7-9 = 5.6 %vol Test 1-3 = 12.8 %vol Test 4-6 = 13.6 %vol Test 7-9 = 13.3 %vol Test 10-12 = 13.6 %vol Test 1-3 = 362.0 oF Test 4-6 = 366.0 oF Test 7-9 = 373.4 oF Test 10-12 = 365.2 oF Test 1-3 = 29.38 Test 4-6 = 29.39 Test 7-9 = 29.39 Test 10-12 = 29.64 Test 1-3 = 68 Test 4-6 = 68 Test 7-9 = 68 Test 10-12 = 68 Test 1-3 = 29.92 Test 4-6 = 29.92 Test 7-9 = 29.92 Test 10-12 = 29.92

Boiler 2 9/21/2008 to 11/21/2008 Mercury control testing by carbon trap sampling

Boiler 2 12/2/2008 to 12/4/2008 Test 1-3 filterable PM = 0.024 lb/mmBTU total PM10 =0.030 lb/mmBTU Test 4-6 filterable PM = 0.027 lb/mmBTU total PM10 =0.037 lb/mmBTU Test 7-9 filterable PM10 = 0.033 lb/mmBTU total PM =0.041 lb/mmBTU Test 1-3 = 10.5 Test 4-6 = 10.3 Test 7-9 = 10.5 Test 1-3 = 190024 dscfm Test 4-6 = 193390 dscfm Test 7-9 = 186760 dscfm Test 1-3 = 6.0 %vol Test 4-6 = 5.9 %vol Test 7-9 = 5.9 %vol Test 1-3 = 13.0 %vol Test 4-6 = 12.9 %vol Test 7-9 = 13.0 %vol Test 1-3 = 353.5 oF Test 4-6 = 347.0 oF Test 7-9 = 347.2 oF Test 1-3 = 28.50 Test 4-6 = 28.73 Test 7-9 = 28.98 Test 1-3 = 68 Test 4-6 = 68 Test 7-9 = 68 Test 1-3 = 29.92 Test 4-6 = 29.92 Test 7-9 = 29.92

Boiler 3 7/1/2008 Total Hg = 0.49 ppb 69.5 9.0 5.8 28.71 68 29.92

Boiler 2 7/15/2008 Total Hg w/o SO3 Injection = 0.21 ppb Total Hg w/ SO3 Injection = 0.19 ppb w/o SO3 injection = 69.6 mw w/ SO3 injection = 69.0 mw w/o SO3 injection = 10.9 w/ SO3 injection = 9.3 w/o SO3 injection = 191,624 dscfm w/ SO3 injection = 187,077 dscfm w/o SO3 injection = 8.00 w/ SO3 injection = 7.50 w/o SO3 injection = 12.00 w/ SO3 injection = 13.00 w/o SO3 injection = 360.6 w/ SO3 injection = 364.7 w/o SO3 injection = 28.91 w/ SO3 injection = 28.91 w/o SO3 injection = 68 w/ SO3 injection = 68 w/o SO3 injection = 29.92 w/ SO3 injection = 29.92

Boiler 2 7/7/2008

Boiler 1 2/18/2009 22.98 lb/hr 0.0298 lb/mmBtu 75.4 11.1 170,855 dscfm 6.0 13.7 353.3 28.71 68 29.92

Boiler 1 2/18-19/2009 SO3 off ESP Voltage ~ 120 kw = 18.86 lb/hr SO3 off ESP Voltage ~ 120 kw = 0.0247 lb/mmBtu SO3 off 1 ESP Field off = 24.04 lb/hr SO3 off 1 ESP Field off = 0.0308 lb/mmBtu SO3 off ESP Voltage ~ 120 kw = 75.4 SO3 off 1 ESP Field off = 75.4 SO3 off ESP Voltage ~ 120 kw = 172,181 dscfm SO3 off 1 ESP Field off = 175,258 dscfm SO3 off ESP Voltage ~ 120 kw = 5.9 SO3 off 1 ESP Field off = 5.9 SO3 off ESP Voltage ~ 120 kw = 13.6 SO3 off 1 ESP Field off = 13.8 SO3 off ESP Voltage ~ 120 kw = 366.2 SO3 off 1 ESP Field off = 360.0 SO3 off ESP Voltage ~ 120 kw = 28.71 SO3 off 1 ESP Field off = 28.96 SO3 off ESP Voltage ~ 120 kw = 68 SO3 off 1 ESP Field off = 68 SO3 off ESP Voltage ~ 120 kw = 29.92 SO3 off 1 ESP Field off = 29.92

* Averaging Time = 3 - 1 hour rounds