# • Minnesota Pollution Control Agency

520 lafayette Road North 

### I St. Paul, MN 55155-4194 

### I 651-296-6300 

### I 800-657-3864 

### I 651-282-5332 TTY 

### I www.pca.state.mn.u5

November 23, 2009

Mr. Bharat Mathur Acting Regional Administrator U.S. Environmental Protection Agency Region V, R-19J 77 West Jackson Boulevard Chicago, Illinois 60604 

### RECEIVED 

## NOV 27 

# 2009

,J'A REGIV"" J VII'ILl: ur KtGIONALADMINISTRA'ili

RE: Proposed Amendments to Minnesota's State Implementation Plan for Sulfur Dioxide

Dear Mr. Mathur:

The Minnesota Pollution Control Agency (MPCA) hereby submits to the U.S. Environmental Protection Agency (EPA) a revision to Minnesota's state implementation plan (SIP) for the city of Rochester, Olmsted County, that
was previously in nonattainment with the National Ambient Air Quality Standards (NAAQS) for Sulfur Dioxide (S02)' This revision includes a new joint Title Iffitle V document for Saint Marys Hospital, in the fonn of Air Emission Pennit Number 10900008-002, issued October 14,2009.

The MPCA is requesting that the revised conditions in the joint Title Iffitle V document labeled "Title I Condition: State Implementation Plan for S02" be approved as a revision of Minnesota's SIP, replacing the current SIP conditions, which were approved on March 9, 2001, (66 FR 14087).

This revision makes changes to the operations at Saint Marys, allowing the installation of a new electric generator and reducing fuel sulfur content limits for other units at the facility. This revision also serves to generally update the SIP, so that the most recent approved air emission pennit serves as the joint document.

This submittal also includes a background document, a copy of the new pennit that serves as the joint Title IITitle V document, the pennit technical support document, a copy of the public notice, and other supporting documents.

Please contact Catherine Neuschler, of our staff, at 651-757-2607, if you have any questions regarding this submittal.
Sincerely,

# '?---i2-~ Paul Eger Commissioner

Enclosures

cc: Kathleen D'Agostino, EPA Region 5 (w/enclosures)

St. Paul 

### I Brainerd 

### I Detroit Lakes 

### I Duluth 

### I Mankato 

### I Marshall 

### I Rochester 

### I Willmar 

### I Printed on 100% post-consumer recycled paper

### 1 Background Information for SIP Revision Saint Marys Hospital, Rochester, Minnesota This document provides background information on the changes to be made in the joint Title I/Title V Document for Saint Marys Hospital (Sai nt Marys), which is owned and operated by the Mayo Foundation. The requested revision involves changes to Saint Marys current ope rating conditions and revisions to the applicable Sulfur Dioxide (SO 2 

### ) State Implementation Plan (SIP) conditions currently listed in the joint Title I/Title V docum ent and incorporated into Minnesota’s SIP. All currently existing Title I SIP conditions will conti nue to apply until this SIP revision is approved by the Environmental Protection Agency (EPA). This amendment is being proposed in conjunction with a facility modifica tion and total facility operating permit amendment (Air Emission Permit No. 10900008-002). The permit and its technical support document (TSD) provide inform ation on the proposed changes to Saint Marys Hospital’s operations. This document concentrat es on the changes that are relevant to the facility’s Title I SIP conditions for SO 2 

### . SIP revision is necessary due to the facility ’s location in the Rochester/Olmsted County SO 2 

### maintenance area and the inclusion into Minnesota ’s SIP of Title I conditions from the currently approved joint Title I/Title V document.

1. Reasons for Changes to the Applicable Co nditions in the Title I/Title V Document Saint Marys is a tertiary care hospital which in cludes several buildings located on a 49 acre campus. The primary emission units at the facili ty are three identical boilers which exhaust through a common stack, one cogeneration turbine, and two emergency generators. Each boiler combusts natural gas with distillate oil as a backup fuel. The cogeneration turbine burns only natural gas. One generator burns only distillate o il; the other can burn distillate oil or operate in dual-fuel mode (natural gas with a small amount of distillate oil). The facility was identified as a culpable source in the Rochester area’s non-attainment of the SO 2 

### National Ambient Air Quality Standards (NAAQS ), and has been subject to a federally enforceable permit incorporated into Minneso ta’s SIP as a joint document, containing requirements for ensuring the attainment of the National Ambient Air Quality Standards (NAAQS) for SO 2 

### . The area was officially re-d esignated to attainment in 2001.

The most recent SIP action came when EPA a pproved the Title I Conditions from permit 989– 91–OT–2, Amendment No. 4 into Minnesota’s SIP on March 9, 2001. (66 FR 14087).

The first reason for this SIP revision is due to some confusion over wh ich joint document is referenced in the SIP. The most recently approved joint document is referred to as 989–91–OT– 2, Amendment No. 4, but EPA also refers to this as Air Emission Permit No. 10900008–007. The MPCA has changed its permit numbering syst em since this permit was issued; Air Emission Permit No. 10900008–007 does not show as issued in the new numbering system. Therefore, one purpose of this SIP revision is to generally update the SIP by incorpora ting the most recent,

### 2 and correctly numbered, Air Emission Perm it No. 10900008–002 as the joint document for this facility. Attachment 4 shows the current SIP in cluded permit, marked up to show the changes in the numbering of the subject sources and where th e current provisions have been incorporated into the new joint document or changed. In addition, SIP revision is necessary in order to incorporate changes being made at the facility with this permit amendment. 2. Changes Made

New Electric Generator The facility is installing a 2500 kW reciprocating internationa l combustion engine electric generator. The new generator is listed as EU012. Inst allation of the new ge nerator results in a potential 6.51 tons per y ear (tpy) increase of SO 2 

### emissions, and a limited SO 2 

### emission increase of 1.52 tpy. The new generator is subject to a re quirement to burn only diesel fuel oil with a sulfur content of less than 500 ppm by weight. Th e diesel fuel oil limit decreases to 15 ppmw as of October 1, 2010. This diesel fuel oil lim it is imposed by 40 CFR 80.510, and has also been listed as a SIP condition to ensure that it may not be exceeded even if the federal standard does not go into effect. The new generator is also limited in its hours of operations to less than 2045 hours per year, based on a rolling twelve month sum, in order to en sure that the addition of the generator is not a major modification under federal Ne w Source Review requirements.

Reduced SO 2 

### Limits The existing boilers, cogeneration tu rbine, and generators are subject to fuel sulfur limits in order to comply with the NAAQS requirements. The cogeneration turbine burn s only natural gas, and therefore is not subject to SIP conditions. The boilers must burn only natural gas and low-sulfur distillate fuel, less than 0.5% sulfur by weight; this limit is unchanged from previous SIP submittals. The existing generators have been subject to a requirement to bur n distillate oil with a sulfur content less than 0.41% by weight. In order to add the new genera tor and ensure that emissions from the facility remain low, the existing genera tors are now subject to similar requirements as the new generator; namely, a requirement to burn only diesel fuel oil with a sulfur content of less than 500 ppm by weight. This represents a limit of 0.05% sulfur by weight, considerably lower than the limit currently included in the SIP. Th e diesel fuel oil limit further decreases to 15 ppmw (0.0015% sulfur by weight) as of October 1, 2010, with the same requirements as the new diesel generators. The facility’s limited potential to emit and most recent actual emissions are shown in the table below. This shows that actual SO 2 

### emissions from the facility are very low.

### 3 Table: Limited PTE and Ac tual Facility Emissions

PM tpy PM 10 tpy PM 2.5 tpy SO 2 tpy NO x tpy CO tpy VOC tpy Total Facility Limited Potential Emissions 20.0 18.7 18.7 65.7 546 218 19.6 Total Facility Actual Emissions (2008) 3.15 3.11 NR 1.16 75.5 34.4 1.89


### 3. Modeling

In order to ensure that installation of the ne w generator would not jeopardize air quality and NAAQS attainment, Saint Marys conducted modeling of the facility both with and without the new generator. The modeling was done in AE RMOD, using meteorolog ical data from 1986 – 1990, and included flagpole receptors in downtown Rochester. The high-first-high result for each standard averaging time (1 hour, 3 hour, 24 hour, and annual), were compared for the two scenarios as each receptor. With the addition of the 500 ppm fuel oil sulfur content limit for the two existing generators, the resu lts showed equivalent or decr eased ambient impacts from the facility at each receptor, 1 

### even after the installatio n of the new generator. The high-second-high SO 2 

### modeling results for the facility are as follows: Table: High-Second-High Ambient SO 2 

### Concentrations from Facility Averaging Time Modeled Concentration ( μ g/m 3 ) Background Total Standard 1986 1987 1988 1989 1990 Max Facility Prior to Modification

1-hour 328 318 337 317 336 337 26 363 1300 3-hour 244 253 249 269 250 269 13 282 1300 24-hour 124 134 110 127 132 134 5 139 365 Annual 21 21 20 21 20 21 3 24 60 Facility After Modification

1-hour 301 300 320 303 319 320 26 346 1300 3-hour 237 245 242 262 238 262 13 275 1300 24-hour 109 117 94 121 125 125 5 130 365 Annual 15 15 14 14 13 15 3 18 60 

### The modeling shows that the high-second-high impact s from the facility will decrease due to the changes being proposed in this SIP revision: the installation of the new generator and the decreased fuel oil sulfur limits on the two existing generators. In addition, the impacts are all far below the relevant standard. This assures that ambient air quality will be protected. Attachments to Background Document Attachment 1: Permit No. 10900008-002; joint Title I/Title V document Attachment 2: Permit technical support document

1 For a single receptor, using 1987 meteorological data, at the Minnesota standard only one-hour averaging time, there was an increase in impacts that was less than the significant figures generally used to report the ambient concentrations. This is therefore cons idered to be equal ambient impacts.

### 4 Attachment 3: Permit No. 10900008-002; Title I SIP conditions only Attachment 4: Marked up versi on of current SIP included permit Attachment 5: Modeling Attachment 6: Public notice Attachment 7: Completeness Review

This summary was prepared by Catherine Neus chler, Environmental Analysis and Outcomes Division of the MPCA.

### Attachment 1: Permit No. 10900008-002; joint Title I/Title V documentAm f:MISSIO.\' I't:Rj\.llT NO. 11l91111008-002 j\1:Jj'}I' A mend n"'"1

IS ISSUU)TO
Mayo Foundation

SAINT :'>lARYS HOSPITAl. 

### t 216**Sc~ond** Streel Somh",o'l Roche,te,. Olm,ted County, Minno'ota 55902

The emi"ion units, control**C'luiprTl~nl** and cmi"ion**~taek~** atlho 'Iationary source**aUlhori~ed** in thi, p<',mit amendmenl arc 

### as dese,ibed in lhe Permit Applications -rable.

This major amelldmenl pe,mit supersede, Air Emission Oremting Permit No. 10900008·001 and ntJlhori7.C5 tho P"n"ilteo 10 opernte and modify Ihe stationary source al tho add,e" li,ted above unless olherwise noted in Table A, The Perminee must comply Wilh all the eOlldil;OllS ortlle permit Afly changes 

### 0' modifH:mion' to tho stalional)' so"ree musl be performed in compliance with Minll, 

### R, 7007,1150 to 7007.1500. Any addition' or chunges to cOllditions**ineorporal~d** into MUII,eSOla'S Slate Implementation Plan ($\1') under 40 CFR 

### § 52.1220, designatcd "Title I: SIP for SOl" mast go lhroullh lhe federal Sll' approval proccs' beforc becoming effcclivo. Tenn, '''cd irl the permit are as ddined III lhe ,tme air pollulion eontrol ru les unless the tenn is explicitly defincd in the per'" it.
Unles, otherwisc indieated. ailiho Minncsota rules ciled as lhe origin "fthe pe,mit terms a,e incorporated illlo the SIP undcr40 CFR 

### § 52 1220 and a, such a.' arc enforceable by U.S. F""ron"'crltal**l'fOt~CI** ion Agency (10 I' A) AdministralO' or**eili~ens** Ullder the Cleon Air Aet. I'er",it Tn'e: Federal: 

### PI. 70/Majo, fur New Source Review; Ti[le J SIP Conditions lbr SO) 0l'e'"lllinl; I'ermil Isslle IJnte: July 23. 2003 Major A",clldnll'1I1 Iss"e Date: October 14, 21109**K~pi1"ll1ion** Dme: July 

### 23,**200~'** - Title 

### I Conditions do nOt expi,". Each neW", ,evi,ed eond ition de,igrlated "Title 

### I Condition: SI 

### P for SO," i, not eITc"<;live or en fo"'cablc Llntil approved by EPA as a SIP revision LJndcrTitle I ofthc Clean Air Act.

,**Th~** l'cmlitlee may eontinue to operale lh is rae ilit) afte, the**e.~pi"'tion** date of the permi[, PC' Ihe prov;,ion under Minn. R, 7007.0450, subp, 3. (Tille V Reissuallce Applicalion wa, rceeiv,'<l Jan""ry 23, 200g.) 

# V Don Smith, P.E.. Manage' Ai, Quality Permit, Seelioll IndusuiaIUiv;,i"n

for )'a,,1 Egcr Commissioner Minne,ola 1'"l1uli"n Cont",l Agcnc}

TDD (for boari".': and 'fX'0<b impaif<d <>nly): (65 I) 282-5332 P"""d 0" re'-J'Cld paper cotrrm"'"8 alle",1 10"/0 fibers from pap" r<<)-ct,d hy con",.",,,

### Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit December 15, 1995, & December 9, 2002 001 Major Amendment March 27, 2009 002

### TABLE OF CONTENTS

Notice to the Permittee

Permit Shield
Facility Description
Amendment Description
Table A: Limits and Other Requirements

Table B: Submittals
Table C: Compliance Schedule – not used in this permit
Appendices Appendix B – Updated 2009 SO 2 

### Modeling Parameters Appendix C – Insignificant Activities

### 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: St. Mary’s is a tertiary care hospital which includes several buildings located on a 49 acre campus. The primary emission units at the facility are three identical boilers which exhaust through a common stack, one cogeneration turbine, and two emergency generators. Each boiler combusts natural gas with distillate fuel as backup. The cogeneration turbine burns only natural gas. One generator burns only distillate oil; the other can burn distillate oil or natural gas (with a small amount of distillate oil; dual fuel). While St. Mary’s is owned and operated by the Mayo Foundation, it is not contiguous with the majority of the Mayo facilities in Rochester, and thus is a separate source under the New Source Review and Part 70 regulations. The facility is an existing major source under New Source Review and a minor HAP source. The facility is located in an area that was previously designated as non-attainment for SO 2 

### . However, the area currently meets the ambient air quality standards, and was officially redesignated as “attainment” on May 8, 2001. The facility has been subject to a federally enforceable permit (No. 989-91-OT-2; part of Minnesota’s state implementation plan, or SIP, for attaining ambient air quality standards) containing requirements contributing to the correction of the non-attainment problem and the ultimate redesignation. The requirements of that permit were incorporated into the title V operating permit No. 10900008-001 as non-expiring Title I conditions. Permit No. 10900008-002 replaces permit No. 109000008-001 and will ultimately replace permit No. 989-91-OT-2 and be incorporated into the SIP (sometime after issuance of permit No. 10900008-002).

PER 002 AMENDMENT DESCRIPTION:

This is a major amendment to an existing major source operating permit. This permit amendment authorizes the Permittee to install a 2500 KW reciprocating internal combustion engine (RICE) electric generator, and reduces the allowable diesel fuel sulfur content for two existing electric generators (EU 004 and EU 005).The new RICE is referred to as EU 012/Generator 7. The RICE is a compression ignition nonemergency 2007-2010 model year diesel engine with a displacement less than 10 liters per cylinder, and certified by the manufacturer to meet part 60, subpart IIII table 1 emission limits.TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 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 SITE-SPECIFIC REQUIREMENTS hdr Parameters Used in Modeling: The stack parameters used in the most recently approved modeling are listed in Appendix B of this permit. Before making any physical changes or changes in the method of operation which may affect parameters listed in Appendix B, the Permittee shall demonstrate to the MPCA that the SO2 plume dispersion characteristics following the physical change or change in method of operation will be equivalent to or better than the SO2 dispersion characteristics modeled using the parameters in Appendix B. The information submitted must include, at a minimum, the locations, heights, and diameters of the stacks, locations and dimensions of nearby buildings, the velocity and temperature of the gasses emitted, and the SO2 emission rates. 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. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

A CTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility in compliance with Minnesota Rules and without obtaining a modification to the SIP as long as the change does not increase from any emission point, the SO2 emission rates (in lb/hr) or overall SO2 emissions or alter equipment or parameters described in A ppendix B, which forms the basis for the SO2 modeling, unless such alteration demonstrates equivalent or better dispersion characteristics. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS" shall be reported semiannually with the Semiannual Deviations Report required by this permit (See Table B). Reporting for these conditions shall occur even if there were no deviations for the reporting period. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

State Implementation Plan Recordkeeping: Retain all records at the stationary source for a period of five years from the date of the required monitoring, sample, measurement, or report that corresponds with a "Title I Condition: SIP for SO2 NAAQS" requirement. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections 601-618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections 601-618 and 40 CFR pt. 82 to determine all the requirements that apply to your facility. 40 CFR pt. 82

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR 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. 2TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-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

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if 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 A gency 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 increase are 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
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

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 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

RECORDKEEPING hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-3

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)

Recordkeeping: 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 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 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

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. 7007.1500TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-4

A pplication for a major permit amendment: If any EU 012 NOx emission factor verification test measures the EU 012 NOx emission factor at 1.040 g/hp-hr or greater, the Permittee shall submit an application for a major amendment. The application shall propose a reduction of the 2045 hr/yr EU 012 operating limit to a level that will limit EU 012 NOx emissions to no greater than 38.0 tons per year. The application shall be submitted no later than 30 days after the Permittee's receipt of the MPCA letter approving the performance test results (i.e. a Notice of Verification). This requirement is repeated under Subject Item EU 012. Title I Condition: To avoid major modification status under 40 CFR Section 52.21(b)(2)(i)

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 report shall 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. 7002.0095TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-5

Subject Item: GP 001 Boilers
Associated Items: EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3

What to do Why to do it EMISSION AND OPERATING LIMITS hdr Fuel Used: The Permittee shall burn only natural gas or very low sulfur oil, as defined in 40 CFR Section 60.41b. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Sulfur Content of Fuel: less than or equal to 0.5 percent by weight (very low sulfur oil, as defined in 40 CFR Section 60.41b) Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j); Minn. R. 7011.0565 Nitrogen Oxides: less than or equal to 0.10 lbs/million Btu heat input using 30-day Rolling Average . This standard applies at all times. 40 CFR Section 60.44b(a); 40 CFR Section 60.46b(a); Minn. R. 7011.0565 Opacity: less than or equal to 20 percent opacity using 6-minute Average , except for one 6-minute period per hour of not more than 27 percent opacity. This standard applies at all times except during periods of startup, shutdown, or malfunction. 40 CFR Section 60.43b(f) and (g); 40 CFR Section 60.46b(a); Minn. R. 7011.0565

MONITORING REQUIREMENTS hdr Sulfur Content of Fuel Oil: The Permittee shall obtain and maintain a fuel supplier receipt from the fuel oil supplier for each shipment of oil received, certifying that the oil meets the definition of very low sulfur oil as defined in 40 CFR Section 60.41b. The Permittee shall ensure that the fuel supplier uses an approved American Society of Testing and Materials (ASTM) method to determine the sulfur content of liquid fuels. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j)(2); Minn. R. 7011.0565

NOx Emissions: The Permittee shall calibrate, maintain, and operate a continuous emission monitoring system (CEMS), and record the output of the system, for measuring NOx emissions discharged to the atmosphere. As allowed by 40 CFR 60.13(g), the Permittee operates one CEMS in the common duct for the three boilers. The CEMS shall be operated and data recorded during all periods of operation of the boilers, except for CEMS breakdowns and repairs. Data is recorded during calibration checks, and zero and span adjustments. The 1-hour average NOx emission rates measured by the CEMS shall be expressed in lb/million Btu heat input, and shall be used to calculate the average emission rates. At least 2 data points must be used to calculate each 1-hour average. [For additional monitoring requirements, see Subject Item MR001.] 40 CFR Section 60.48b(b)(1), (c), and (d); 40 CFR Section 60.13(g); Minn. R. 7011.0565

When NOx emissions data are not obtained because of CEMs breakdowns or repairs, data will be obtained by using standby monitoring systems, Method 7 or 7A, or other approved reference methods to provide data for a minimum of 75% of the operating hours in each steam generating unit operating day, in at least 22 out of 30 successive steam generating unit operating days. 40 CFR Section 60.48b(f); Minn. R. 7011.0565

Opacity: The Permittee shall calibrate, maintain, and operate a continuous monitoring system for measuring the opacity of emissions discharged to the atmosphere, and record the output of the system.

A s allowed by 40 CFR 60.13(g), the Permittee operates one COMS in the common duct for the three boilers. [For additional monitoring requirements, see Subject Item MR003.] 40 CFR Section 60.48b(a); 40 CFR Section 60.13(g); Minn. R. 7011.0565

PERFORMANCE TESTING REQUIREMENTS hdr Upon request, the Permittee shall use a 30-day performance test to determine compliance with the NOx standard. During periods when performance tests are not requested, NOx emission data collected via the CEM shall be used to calculate a 30-day rolling average emission rate on a daily basis and used to prepare excess emission reports, but will not be used to determine compliance with the NOx emission standard. A new 30-day rolling average emission rate is calculated each steam generating unit operating day as the average of all of the hourly NOx emission data for the preceding 30 steam generating unit operating days. 40 CFR Section 60.46b(e)(4); Minn. R. 7011.0565

RECORDKEEPING AND REPORTING REQUIREMENTS hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-6

The Permittee shall record and maintain records of the amounts of each fuel combusted each day and calculate the annual capacity factor individually for distillate oil and natural gas. The annual capacity factor is determined on a 12-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. 40 CFR Section 60.49b(d); Minn. R. 7011.0565

The Permittee shall maintain records of opacity. 40 CFR Section 60.49b(f); Minn. R. 7011.0565 The Permittee shall maintain records of the following information for each steam generating unit operating day: (1) Calendar date. (2) The average hourly NOx emission rates (expressed as NO2), in lb/million Btu heat input. (3) The 30-day average NOx emission rates calculated at the end of each steam generating unit operating day. (4) Identification of the steam generating unit operating days when the calculated 30-day average NOx emission rates are in excess of the NOx emission standard, including the reasons for the excess emissions and a description of corrective actions taken. (5) Identification of the steam generating unit operation days for which data have not been obtained including reasons for not obtaining sufficient data and a description of corrective actions taken. (6) Identification of the times when emission data have been excluded from the calculation of average emission rates and the reasons for excluding data. 40 CFR Section 60.49b(g); Minn. R. 7011.0565

(7) Identification of "F" factor used for calculations, method of determination, and type of fuel combusted. (8) Identification of the times when the pollutant concentration exceeded full span of the CEMS. (9) Description of any modifications to the CEMS that could affect the ability of the CEMS to comply with Performance Specification 2 or 3. continued from aboveTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-7

Subject Item: GP 002 Boilers and Generators
Associated Items: EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3
EU 004 Generator 5
EU 005 Generator 6 EU 012 Generator 7 (Non-emergency CI; <10 liter/cyl; 2500 kW)

What to do Why to do it EMISSION LIMITS hdr Sulfur Dioxide: less than or equal to 65.56 tons/year using 12-month Rolling Sum calculated monthly, as described below. Title I Condition: To avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000 (limit originally set 3/27/91) MONITORING AND RECORDKEEPING hdr Daily recordkeeping: Each day, record the total quantity of each type of fuel burned, and the sulfur content by weight of fuel oil in the tank from which oil is drawn on that day. Title I Condition: To avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Monthly Recordkeeping: SO2 Emissions By the 15th day of each month, calculate and record the following: a. The total quantity of natural gas used in the GP002 units during the previous month (G), in million cubic feet b. The total quantity of sulfur contained in distillate oil used in the GP002 units during the month (S), in pounds, calculated by multiplying the gallons of oil with sulfur content "x" by "x" and the density of the oil (pounds/gallon), plus the gallons of oil with sulfur content "y" by "y" and the density of the oil, etc. c. The SO2 emissions for the previous months (E), in tons, using the following equation: E = 0.001 S + 0.0003 G, where: 0.001 = [(2 pounds of SO2/pound of sulfur) x (1 ton/2000 pounds)] and 0.0003 = [(0.6 pounds of SO2/million cubic feet of natural gas) x (1 ton/2000 pounds)] The 12-month rolling sum is calculated by summing the values of "E" calculated for the previous 12 months. Minn. R. 7007.0800, subp. 4 and 5TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-8

Subject Item: EU 004 Generator 5
Associated Items: GP 002 Boilers and Generators
SV 002 No. 5 Generator Stack

What to do Why to do it Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained Minn. R. 7011.2300, subp. 1
Sulfur Content of Fuel: less than or equal to 500 parts per million by weight as specified at 40 CFR Section 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel. This requirement is effective from the date of issuance of permit No. 10900008-002 through September 20, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2
Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 004 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation PlanTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-9

Subject Item: EU 005 Generator 6
Associated Items: GP 002 Boilers and Generators
SV 003 No. 6 Generator Stack

What to do Why to do it Fuel: The Permittee shall burn only natural gas or diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Sulfur Content of Fuel: less than or equal to 500 parts per million by weight as specified at 40 CFR Section 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel. This requirement is effective from the date of issuance of permit No. 10900008-002 through September 30, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2
Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained Minn. R. 7011.2300, subp. 1
Operating Hours: less than or equal to 1040 hours/year using 12-month Rolling Sum Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000. Recordkeeping - Hours of Operation: By the 15th day of each month, calculate and record the hours the generator was operated during the previous month, and the total hours operated during the previous 12 months. Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000. Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 005 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation PlanTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-10

Subject Item: EU 006 Turbine Engine
Associated Items: SV 004 Cogeneration Turbine Stack

What to do Why to do it EMISSION LIMITS AND OPERATING REQUIREMENTS hdr Nitrogen Oxides: less than or equal to 190 parts per million at 15% O2, on a dry basis 40 CFR Section 60.332(a)(2); Minn. R. 7011.2350
Sulfur Content of Fuel: less than or equal to 0.8 percent by weight 40 CFR Section 60.333(b); Minn. R. 7011.2350
MONITORING REQUIREMENTS hdr Custom Sulfur Monitoring Schedule: (A) Sulfur monitoring shall be conducted twice monthly (bi-weekly) for six (6) months. If the monitoring shows little variability in the fuel sulfur content, and indicates consistent compliance with 40 CFR Section 60.333(b), then sulfur monitoring shall be conducted once per calendar quarter. (B) Conduct fuel sulfur content monitoring once per quarer for six (6) quarters. If quarterly monitoring shows little variability in the fuel sulfur content, and indicates consistent compliance with the 40 CFR Section 60.333(b), the fuel sulfur content monitoring frequency may be reduced to a semi-annual basis (first and third quarters of the calendar year). 40 CFR Section 60.334(b)(2); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987; EPA approval memo dated May 2, 2003

Determination of Sulfur Content: ASTM D 1072-80 or 90 (Reapproved 1994), D 3031-81, D 4084-82 or 94, or D 3246-81, 92, or 96 shall be used to determine the sulfur content of gaseous fuels. Upon written approval of U.S. EPA, the following alternative method may be used to determine the sulfur content of pipeline natural gas: Gas Processors Association (GPA) Standard Method 2377-86, "Test for Hydrogen Sulfide and Carbon Dioxide in Natural Gas Using Length of Stain Tubes." The Permittee will use two length of stain tubes for each sample: one to detect hydrogen sulfide and one to detect mercaptans. 40 CFR Section 60.335(d); Minn. R. 7011.2350

Custom Nitrogen Monitoring Schedule: The requirement to monitor the nitrogen content of the fuel is waived, provided only pipeline quality natural gas is combusted in the turbine. 40 CFR Section 60.334(b)(2); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987; EPA approval letter dated May 2, 2003 The Permittee shall comply with the above monitoring requirements until such time as EPA promulgates revisions to the monitoring requirements in 40 CFR Part 60 Subpart GG. At that time, the Permittee may choose to comply with the monitoring requirements of the revised rule, provided the revised rule allows that choice. 40 CFR Sectio 60, Subpart GG; Minn. R. 7011.2350; Minn. R. 7007.0800, subp. 4

REPORTING REQUIREMENTS hdr Notification of Noncompliance: Should any sulfur analysis indicate noncompliance with 40 CFR Section 60.333(b), as described in 40 CFR Section 60.334(c)(2), the Permittee shall notify the MPCA of such excess emissions and the custom fuel monitoring schedule shall be re-examined by the Administrator. Sulfur monitoring shall be conducted weekly during the interim period when the custom fuel monitoring schedule is being re-examined. 40 CFR Section 60.334(b)(2); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987; EPA approval letter dated May 2, 2003

Reporting: If there is a change in fuel supply, the Permittee shall notify the MPCA of such change for re-examination of the custom fuel monitoring schedule. A substantial change in fuel quality shall be considered as a change in fuel supply. Sulfur monitoring shall be conducted weekly during the interim period when the custom fuel monitoring schedule is being re-examined. 40 CFR Section 60.334(b)(2); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987; EPA approval letter dated May 2, 2003TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-11

Subject Item: EU 012 Generator 7 (Non-emergency CI; <10 liter/cyl; 2500 kW)
Associated Items: GP 002 Boilers and Generators
SV 005 No. 7 Generator Stack

What to do Why to do it LIMITS AND OPERATING RESTRICTIONS hdr Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Fuel Requirements - Beginning October 1, 2007, the Permittee must use diesel fuel in EU 012 that meets the following requirements of 40 CFR Section 80.510(a): (1) Sulfur content maximum 500 ppm; and, (2) Cetane index minimum of 40 or aromatic content maximum of 35% by volume. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Sections 60.4207(a) and 80.510(a); Minn. R. 7011.3520

Fuel Requirements - Beginning October 1, 2010, the Permittee must use diesel fuel in EU 012 that meets the following requirements of 40 CFR Section 80.510(b) for nonroad diesel fuel: (1) Sulfur content maximum 15 ppm (for nonroad diesel); and, (2) Cetane index minimum of 40 or aromatic content maximum of 35% by volume. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Sections 60.4207(b) and 80.510(b); Minn. R. 7011.3520

The provisions of pt. 60, subp. IIII apply to the Permittee for operation of EU 012 because EU 012 was manufactured after April 1, 2006, and the Permittee commenced construction of EU 012 after July 11, 2005. For the purposes of pt. 60, subp. IIII, the date that construction commences is the date EU 012 is ordered by the Permittee. 40 CFR Section 60.4200(a)(2)(i); Minn. R. 7011.3520

The Permittee must install an EU 012 engine that meets the requirements for 2007 model year engines. 40 CFR Section 60.4208(a); Minn. R. 7011.3520
Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained Minn. R. 7011.2300, subp. 1
Operating Hours: less than or equal to 2045 hours/year using 12-month Rolling Sum calculated monthly by the last day of each month. This limit may be revised based on results from emission factor testing required by this permit. During the initial 12 months of operation, the applicable operating hours limit as of month 'n' shall be the following:
month 1 = 400 hrs month 2 = 650 hrs month 3 = 870 hrs month 4 = 1080 hrs month 5 = 1260 hrs month 6 = 1420 hrs month 7 = 1560 hrs month 8 = 1690 hrs month 9 = 1810 hrs month 10 = 1920 hrs month 11 = 2000 hrs month 12 = 2045 hrs Title I Condition: To avoid major modification status under 40 CFR Section 52.21(b)(2)(i)

MONITORING AND RECORDKEEPING REQUIREMENTS hdr Recordkeeping - Operating Hours: by the last day of each calendar month, the Permittee shall: 1. record the EU 012 operating hours during the provious calendar month; and 2. calculate and record EU 012 operating hours during the previous 12-month period by summing the monthly operating hours records for the previous 12 months. Title I Condition: To avoid major modification status under 40 CFR Section 52.21(b)(2)(i); Minn. R. 7007.0800, subp. 4 and 5

Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 012 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

PART 60 SUBPART IIII REQUIREMENTS hdr The Permittee must comply with the emission standards in Section 60.4201(b) and table 1 of subp. IIII when operating EU 012. 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520 Hyrocarbons: less than or equal to 1.3 grams/kilowatt-hour 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-12

Nitrogen Oxides: less than or equal to 9.2 grams/kilowatt-hour 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520 Carbon Monoxide: less than or equal to 11.4 grams/kilowatt-hour 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520 Total Particulate Matter: less than or equal to 0.54 grams/kilowatt-hour 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520 The Permittee shall operate and maintain EU 012 so that it achieves the emission standards as required in Section 60.4204 over the entire life of EU 012. The operation and maintenance shall be conducted according to the manufacturer's written instructions or procedures developed by the Permittee that are approved by the engine manufacturer. 40 CFR Section 60.4206; Minn. R. 7011.3520

Pt. 60, Subp. IIII Compliance Requirements

The Permittee shall: 1. comply with the emission standards specified in subpart III; 2. operate and maintain EU 012 according to the manufacturer's written instructions or procedures developed by the Permittee that are approved by the engine manufacturer; 3. only change those settings that are permitted by the manufacturer; 4. meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable. The Permittee shall purchase an engine certified to the emission standards in Section 60.4204(b) as applicable, 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(a) and (c); Minn. R. 7011.3520

Recordkeeping: Keep records of the following: (i) All notifications submitted to comply with part 60, subpart IIII and all documentation supporting any notification; (ii) Maintenance conducted on EU 012; (iii) Documentation from the manufacturer that EU 012 is certified to meet applicable emission standards in table 1 of part 60, subp. IIII. 40 CFR Section 60.4214(a)(2); Minn. R. 7011.3520

PART 63 SUBPART ZZZZ REQUIREMENTS hdr EU 012 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, and the facility is an area source as defined at 40 CFR Section 63.2. The Permittee shall meet the requirements of subp. ZZZZ by meeting the requirements of pt. 60, subp. IIII. No further requirements of subp. ZZZZ apply to EU 012. 40 CFR Section 63.6590

PERFORMANCE TEST REQUIREMENTS hdr Initial Performance Test: due 365 days after Initial Startup of EU 012 to verify the NOx emission factor (this is not a test for compliance determination). The NOx emission factor is 1.012E-02 grams per horsepower-hr (g/hp-hr). Minn. R. 7017.2020, subp. 1

A pplication for a major permit amendment: If any EU 012 NOx emission factor verification test measures the EU 012 NOx emission factor at 1.040 g/hp-hr or greater, the Permittee shall submit an application for a major amendment. The application shall propose a reduction of the 2045 hr/yr EU 012 operating limit to a level that will limit EU 012 NOx emissions to no greater than 38.0 tons per year. The application shall be submitted no later than 30 days after the Permittee's receipt of the MPCA letter approving the performance test results (i.e. a Notice of Verification). This requirement is repeated under Subject Item Total Facility. Title I Condition: To avoid major modification status under 40 CFR Section 52.21(b)(2)(i)TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-13

Subject Item: MR 001 NOx Monitor
Associated Items: CM 001
EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3

What to do Why to do it 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), Minn. R. 7017.1090, subp. 1; Minn. R. 7007.0800, subp. 4

A ll CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. The Permittee shall reduce all CEMS data to 1-hour averages. One hour averages shall be computed from four or more data points equally spaced over each 1-hour period. Data recorded during periods of CEMS breakdown, repair, calibration checks, and zero and span adjustments shall not be included in the data average. 40 CFR Section 60.13(e)(2); 40 CFR Section 60.13(h); Minn. R. 7017.1140; Minn. R. 7017.1160; Minn. R. 7007.0800, subp. 4

QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40CFR 60, App. F, section 3. Minn. R. 7017.1170, subp. 2; Minn. R. 7007.0800, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test, except as noted in Minn. R. 7017.1170, subp. 5. Follow the procedures in 40 CFR Section 60, Appendix F. Minn. R. 7017.1170, subp. 5; Minn. R. 7007.0800, subp. 4
Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA)) . Notification may be made by fax, mail, electronic mail, or hand delivered. This is state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. 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 annual CEMS RATA was conducted. This is state-only requirement and is not enforceable by EPA or citizens under the Clean A ir Act. Minn. R. 7017.1180, subp. 3

CEMS Daily Calibration Drift (CD) Test: The Permittee shall automatically check the zero (or low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily in accordance with a written procedure. The zero and span must, as a minimum, be adjusted whenever either the 24-hour zero drift or the 24-hour span drift exceeds two times the limit from Appendix B of 40 CFR 60. 40 CFR Section 60.13(d)(1); Minn. R. 7017.1170, subp. 3; Minn. R. 7007.0800, subp. 4

CEMS Cylinder Gas Audit (CGA): due before end of each calendar half-year following CEM Certification Test, using a form approved by the commissioner, except that a CGA is not required during any half-year in which a RATA is performed. Minn. R. 7017.1170, subp. 4; Minn. R. 7007.0800, subp. 4

Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following Cylinder Gas Audit (CGA). This is state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. Minn. R. 7017.1180, subp.1

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 60.7(f); Minn. R. 7017.1130; Minn. R. 7007.0800, subp. 4
Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; 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)TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-14

CEMS Recertification Test: Recertification of a previously certified CEMS is required if the monitor undergoes a change invalidating its certification. Any of the following changes to a certified CEMS invalidates the certification status of the monitoring system: A . replacement of the analyzer; B. change in location or orientation of the sampling probe or site; C. modification to the flue gas handling system which changes its flow characteristics; or D. a change that in the commissioner's judgement siginficantly affects the ability of the stem to measure or record the pollutant concentration, or volumetric gas flow. 40 CFR Section 60.13(b); Minn. R. 7017.1050, subp. 1; Minn. R. 7007.0800, subp. 4

CEMS Recertification Test Pretest Meeting: due 7 days before CEMS Recertification Test. This is a state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. Minn. R. 7017.1060, subp. 3

CEMS Recertification Test Plan: due 30 days before CEMS Recertification Test. 40 CFR Section 60.7(a)(5); Minn. R. 7017.1060, subp. 1 & 2 CEMS Recertification Test Report: due 45 days after CEMS Recertification Test Minn. R. 7017.1080, subp. 1, 2, & 4; 40CFR 60.13(c)(2) CEMS Recertification Test Report - Microfiche Copy: due 105 days after CEMS Recertification Test. This is a state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. Minn. R. 7017.1080, subp. 3TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-15

Subject Item: MR 002 O2 Monitor
Associated Items: CM 001
EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3

What to do Why to do it Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; 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)TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-16

Subject Item: MR 003 Opacity Monitor
Associated Items: CM 001
EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3

What to do Why to do it 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. 40 CFR Section 60.13(e); Minn. R. 7017.1090, subp. 1

The Permittee must at a minimum follow the following procedures for a COMS. Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition using a certified neutral density filter or other related technique to produce a known obstruction of the light beam. Such procedures must provide a system check of all active analyzer internal optics with power or curvature, all active electronic circuitry including the light source and photo-detector assembly, and electronic or elecro-mechanical systems and hardware and/or software used during normal measurement operation. 40 CFR Section 60.13(d)(2)

QA Plan Required: Develop and implement a written quality assurance plan which covers each COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain the written procedures listed in Minn. R. 7017.1210, subp. 1. Minn. R. 7017.1210; Minn. R. 7007.0800, subp. 4

COMS Daily Calibration Drift (CD) Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero (low-level) and upscale (high-level) calibration drifts at least once daily. The optical surfaces exposed to effluent gases must be cleaned before performing the drift adjustments, except for systems using automatic zero adjustments. The optical surfaces must be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity. 40 CFR Section 60.13(d)(2); Minn. R. 7017.1210, subp. 2; Minn. R. 7007.0800, subp. 4

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. Filter values used shall correspond to approximately 10%, 25%, and 50% opacity. Refer to Minn. R. 7017.1210 for full instructions. Minn. R. 7017.1210, subp. 3; Minn. R. 7007.0800, subp. 4

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. The Permittee shall reduce all COMS data to 6-minute averages. Six minute averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. Data reduction shall be done in accodance with the procedures outlined in Minn. R. 7011.7017.1200, subp. 3 Data recorded during periods of COMS breakdown, repair, calibration checks, and zero and span adjustments shall not be included in the data average. 40 CFR Section 60.13(e)(1); 40 CFR Section 60.13(h); Minn. R. 7017.1200, subp. 1, 2 & 3; Minn. R. 7007.0800, 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; Minn. R. 7007.0800, subp. 4

Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; 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)TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-17

COMS Recertification Test: Recertification of a previously certified COMS is required if the monitor undergoes a change invalidating its certification. Any of the following changes to a certified COMS invalidates the certification status of the monitoring system: A . replacement of the analyzer; B. change in location or orientation of the sampling probe or site; C. modification to the flue gas handling system which changes its flow characteristics; or D. a change that in the commissioner's judgement siginficantly affects the ability of the stem to measure or record the pollutant concentration, volumetric gas flow, or opacity. 40 CFR Section 60.13(b); Minn. R. 7017.1050, subp. 1; Minn. R. 7007.0800, subp. 4

COMS Recertification Test Plan: due 30 days before COMS Recertification Test. This is a state-only requirement and is not enforceable by the EPA or citizens under the Clean Air Act. Minn. R. 7017.1060, subp. 1 & 2

COMS Recertification Test Pretest Meeting: due 7 days before COMS Recertification Test. This is state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. Minn. R. 7017.1060, subp. 3

COMS Recertification Test Report: due 45 days after COMS Recertification Test. This is a state-only requirement and is not enforceable by EPA or citizens under the Clean Air Act. Minn. R. 7017.1080, subp. 1, 2 & 4

COMS Recertification Test Report - Microfiche Copy: due 105 days after COMS Recertification Test. This is a state-only requirement and is not enforceable by EPA or Citizens under the Clean Air Act. Minn. R. 7017.1080, subp. 3APPENDIX B – Updated 2009 SO2Modeling ParametersFacility Name: Saint Marys HospitalPermit Number: 10900008-002Any physical change or change in a method of operation must resultin plume dispersion characteristics equivalent to orbetter than the plume dispersion characteristics modeled using the parameters below. Revision of any of theseparameters may require a permit amendment.NAD 83Easting(X)NAD 83Northing(Y)BaseElevationStackHeight TemperatureExitVelocityStackDiameterShortTerm SO2EmissionRateStackID EU ID Description (m) (m) (m) (m) (K) (m/s) (m) (g/s)SV 001EU 001EU 002EU 003Boilersstack541730.1 4874149.5 326.7 68.0 449.8 20.7 1.77 20.700SV 002 EU 004 Generator 5 541674.4 4874193.5 320.6 11.3 755.4 36.4 0.71 0.140SV 003 EU 005 Generator 6 541675.1 4874189.5 320.8 11.3 755.4 42.4 0.71 0.151SV 004 EU 006 Turbine 541674.1 4874230.0 319.1 19.7 422.0 22.2 1.19 0.004SV 005 EU 012 Generator 7 541694.7 4874222.0 321.0 15.2 724.8 26.7 0.68 0.187

### Attachment 2: Permit technical support documentTechnical Support Document, Permit No. 10900008-002 DQ #2526 Page 1 of 7 Date: 10/27/2009 

### TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 10900008-002
This technical support document (TSD) is intended for all parties interested in the draft/proposed 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 draft/proposed permit. 1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address Applicant/Address Stationary Source/Address (SIC Code: 8062) Mayo Foundation 200 First Street SW Rochester, Minnesota 55905 Saint Marys Hospital 1216 Second Street SW Rochester, Olmsted County, Minnesota Contact: Deedra DeLisa Phone: 507-293-3382 1.2 Facility Description Saint Marys Hospital (facility) is a tertiary care hosp ital that includes several buildings located on a 49 acre campus. The primary emission units at the facility are three identical boilers which exhaust through a common stack, one cogeneration turbine generator, a nd two emergency reciprocating internal combustion engine (RICE) generators. Each boiler combusts natural gas with distillate fuel as backup. The cogeneration turbine burns only natural gas. One generator burns only distillate oil; the other can burn distillate oil or operate in dual fuel mode (95 percent natural gas and 5 percent diesel fuel). The facility is owned and operated by the Mayo Foundation, but is not contiguous with the majority of the Mayo facilities in Rochester, and thus is a sep arate source under the New Source Review and Part 70 regulations. The facility is an existing major sour ce under New Source Review and a minor HAP source. The facility is located in an area that was previously designated as non-attainment for SO 2 

### . However, the area currently meets the ambient air quality standards, and was officially redesignated as “attainment” on May 8, 2001. The facility has been subject to a fede rally enforceable permit (No. 989-91-OT-2; part of Minnesota’s state implementation plan, or SIP, for attaining ambient air quality standards) containing requirements contributing to the correction of the non- attainment problem and the ultimate redesignation. The requirements of that permit were incorpor ated into the title V operating permit No. 10900008-001 as non-expiring Title I conditions. Permit No . 10900008-002 replaces permit No. 109000008-001 and will ultimately replace permit No. 989-91-OT-2 and be incor porated into the SIP (sometime after issuance of permit No. 10900008-002).Technical Support Document, Permit No. 10900008-002 DQ #2526 Page 2 of 7 Date: 10/27/2009 

### 1.3 Description of the Activities Allowed by this Permit Action This is a major amendment to an existing majo r source operating permit. This permit amendment authorizes the Permittee to install a 2500 KW reciprocating internal combustion engine (RICE) electric generator, and reduces the allowable diesel fuel sulf ur content for two existing electric generators. The new RICE is referred to as EU 012/Generator 7. The RICE is a compression ignition non-emergency 2007-2010 model year diesel engine with a displacement less than 10 liters per cylinder, and certified by the manufacturer to meet part 60, subpart IIII table 1 emission limits. 1.4. Facility Emissions: Table 2. Title I Emi ssions Increase Summary

Pollutant Emissions Increase from the Modification (tpy) Limited Emissions Increase from the Modification (tpy) PSD/112(g) Significant Thresholds for major sources (tpy) NSR/ 112(g) Review Required? PM 2.13 0.50 25 NO PM 10 

### 2.13 0.50 15 NO PM 2.5 

### 2.13 0.50 10 NO NO X 

### 163 38.0 40 NO SO 2 

### 6.51 1.52 40 NO CO 14.5 3.39 100 NO Ozone (VOC) 4.61 1.08 40 NO Lead NA NA 0.6 NO Single and Total HAPs 0.08/0.17 0.02/0.04 10/25 NOTechnical Support Document, Permit No. 10900008-002 DQ #2526 Page 3 of 7 Date: 10/27/2009 

### Table 3. Total Facility Potential to Emit Summary
PM tpy PM 10 

### tpy PM 2.5 

### tpy SO 2 

### tpy NO X 

### tpy CO tpy VOC tpy Single HAP

tpy All HAPs

tpy Total Facility Limited Potential Emissions 20.0 18.7 18.7 65.7 546 218 19.6 2.7 3.14

Total Facility Actual Emissions (2008) 3.15 3.11 NR 1.16 75.5 34.4 1.89 HAPs not reported in emission inventory
Table 4. Facility Classification Classification Major/Affected Source Synthetic Minor Minor

PSD NO X 

### , CO SO 2 

### PM, PM 10 

### , PM 2.5 

### , VOC Part 70 Permit Program NO X 

### , CO SO 2 

### PM 10 

### , PM 2.5 

### , VOC Part 63 NESHAP Single and Total HAP
2. Regulatory and/or Statutory Basis

New Source Review The facility is an existing major source under New S ource Review permit regulations. The facility is a fossil fuel-fired boilers facility with total heat i nput exceeding 250 mmBtu/hr and therefore is subject to the 100 ton per year major source definition at 40 CFR § 52.21(b)(1)(i)(a). This permit amendment does not change this status. Part 70 Permit Program The facility is a major source under the Part 70 pe rmit program and this permit amendment does not change this status.
New Source Performance Standards (NSPS) The new generator EU 012 is a 2500 kilowatt non-emer gency compression ignition diesel engine subject to pt. 60, subp. IIII for 2007 model year engines with displacement less than 10 liters per cylinder.
National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is an area source under pt. 63, and th erefore EU 012 is subject to pt. 63, subp. ZZZZ. However, as stated in subp. ZZZZ, EU 012 shall comply with subp. ZZZZ through meeting the requirements of pt. 60, subp. IIII. Compliance Assurance Monitoring (CAM) The new engine will not use add-on controls to m eet applicable limits and therefore, CAM does not apply.Technical Support Document, Permit No. 10900008-002 DQ #2526 Page 4 of 7 Date: 10/27/2009 

### Environmental Review & AERA Emission increases authorized by this permit amendment do not trigger environmental review or an Air Emissions Risk Analysis. SO 2 

### State Implementation Plan (SIP) The facility was identified as a potentially-culpable s ource in the Rochester area's non-attainment of the SO 2 

### NAAQS. As a result, the facility is subject to fu el usage limitations to restrict total facility SO 2 

### emissions. These restrictions have been submitted as part of Minnesota’s State Implementation Plan for SO 2 

### through Amendment No. 4 to Air Emission Permit No. 989-91-OT-2, which was issued on February 28, 1997. These restrictions are non-expiring Title I cond itions, and have been carried forward into this permit. The Rochester area was redesignated to attain ment in March 2001, and is now a maintenance area for SO 2 

### . Minnesota State Rules

• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 5. Regulatory Overview of Units Aff ected by the Modification/Permit Amendment Subject Item Applicable Regulations Comments:

EU 012 Title I Conditions: SIP for SO 2 

### NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2

Title I Condition: To avoid major modification status under 40 CFR § 52.21(b)(2)(i)

40 CFR pt. 60, subp. IIII

40 CFR pt. 63, subp. ZZZZ Diesel fuel shall meet the 500 ppm sulfur limit requirement at 40 CFR § 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel.

2045 hours/year operating hours limit to restrict NO X 

### emissions increase to 38.0 tpy, and associated recordkeeping

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

EU 004 and EU 005 Title I Conditions: SIP for SO 2 

### NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Diesel fuel shall meet the 500 ppm sulfur limit requirement at 40 CFR § 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel.Technical Support Document, Permit No. 10900008-002 DQ #2526 Page 5 of 7 Date: 10/27/2009 

### 3. Technical Information EU 012 NO X 

### Emission Factor Verification Testing : Testing is required to validate the accuracy of the manufacturer’s NO X 

### emission factor. The factor (1.012 g/hp-hr) was used to determine the 2045 hr/yr operating hours limit and restrict NO X 

### to 38.0 tpy. If a test result is greater than 1.040E-02 g/hp-hr, the Permittee is required to submit a major amendment permit application to revise the 2045 hr/yr operating limit to ensure the limited NO X 

### emissions can not exceed 38.0 tpy.

3.1. Emissions Calculations Emissions were calculated using manufacturer’s emissions guarantees for PM, NO X 

### , CO, and VOC, and AP-42 ch. 3-4 for all other pollutants. PM was assumed to be all PM 2.5 

### , and PM 10 

### was assumed to be all PM 2.5 

### . Revised total facility limited annual emissions (as show n in Table 3) were calculated using Table 1 data from the TSD for PER 001, and the additional limited EU 012 emissions, except for SO 2 

### . There is no change in limited annual SO 2 

### emissions due to the addition of EU 012 to the facility because EU 012 was added to GP 002 and GP 002 limits SO 2 

### from the 3 boilers and 3 engines (to 65.56 tpy on a 12-month rolling sum basis).

3.2 SO 2 

### SIP Modeling The facility is located in Rochester, Minneso ta which is a SIP maintenance area for SO 2 

### . Revised SO 2 

### modeling was submitted for this permit action. Ta ble 6 shows the results of that modeling.

Table 6. SO 2 

### Modeling Results Averaging Period SO 2 

### standard ug/m 3 

### Predicted impact w/background Percent of standard

1-hr 1300 343.8 26% 3-hr 1300 275.0 21% 24-hr 365 130.3 36% annual 60 18.2 30% Note that SV 001 contains three separate flues (one pe r boiler). The diameter of each flue is 3.35 feet. The effective diameter is 5.81 feet (1.77 m) when the three flues are modeled as a single source. Finally, modeling is a SIP requirement, and as a result triggers for remodeling are determined by the SIP (requirements in the total facility part of the permit) and not the current criteria pollutant modeling policy from December 17, 2008.

3.3 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.Technical Support Document, Permit No. 10900008-002 DQ #2526 Page 6 of 7 Date: 10/27/2009 

### 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. The table below summarizes the periodic monitoring re quirements for those emission units for which the monitoring required by the applicable re quirement is nonexistent or inadequate. Table 7. Periodic Monitoring Subject

Item Requirement (rule basis) Additional Monitoring Discussion

EU 012 Opacity < 20% (Minn. R. 7017.2300, subp. 1) Part 60 subp. IIII

< 2045 hrs/yr on a 12-month rolling sum (Title I Condition: to avoid significant NOx emissions increase) None

None

Monthly and 12- month rolling sum operating hours records; emission factor verification through performance testing Opacity is typically not an issue if the equipment is operated properly on very low sulfur (500 ppm) diesel fuel.

Standard is post-1990 a nd contains adequate periodic monitoring requirements. The 2045 hours limit is derived from hourly lb/hr NO X 

### calculated with the manufacturer’s NO X 

### emission factor, and 38 tpy of NO X 

### emissions. Testing for factor validation is necessary to ensure emissions can not exceed 38 tpy even if operating hours do not exceed 2045 hr/yr. If test results exceed the 1.040E-02 g/hp-hr threshold, the Permittee is required to submit an application for a major amendment to revise the hours limit accordingly.
EU 004, EU 005, & EU 012 Title I SO 2 

### SIP Limit; meets SO 2 

### < 0.5 lb/mmBtu (Minn. R. 7011.2300, subp. 2) Certification letter from fuel supplier Diesel fuel sulfur limit of 500 ppm (which will decrease to 15 ppmw in 2010) ensures compliance with this SO 2 

### limit. When combusting 500 ppmw sulfur oil, SO 2 

### emissions are approximately 0.05 lb/mmBtu, and when combusting 15 ppmw, SO 2 

### emissions are approximately 0.0015 lb/mmBtuTechnical Support Document, Permit No. 10900008-002 DQ #2526 Page 7 of 7 Date: 10/27/2009 

### 3.4 Insignificant Activities No additional insignificant activities will be in stalled as part of this permit action. 3.5 Comments Received Public Notice Period: August 23 – September 21, 2009 EPA 45-day Review Period: August 23 – October 6, 2009 No comments were received during the public comment period. EPA SIP staff provided comments regarding diesel fuel sulfur content compliance dete rmination and subjecting th e existing two generators to the 15 ppmw sulfur limit. In response to the comments, a Title I SIP requirement was added to EU 004, EU 005, and EU 012 for obtaining and maintaining a fu el supplier certification letter stating diesel fuel sulfur content will not exceed 500 ppmw through Ma y 31, 2010, and will not exceed 15 ppmw after May 31, 2010. A Title I SIP requirement was also added to EU 004 and EU 005 to limit allowable diesel fuel sulfur content to 15 ppmw after May 31, 2010. 4. Conclusion Based on the information provided by Mayo Foundati on, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 10900008-002, and this TSD, will not cause or contribute to a violati on of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Marshall Cole (permit writer/engineer) Jennifer Lovett (enforcement) Marc Severin (stack testing) Toni Volkmeier (peer reviewer) Melissa Sheffer (modeling) Catherine Neuschler (SO 2 

### SIP)
AQ File No. 989; DQ No. 2526

Attachments: 1. Emission Calculations 2. Facility Description and CD-01 Forms 3. SAM spreadsheet 4. SIP permit No. 989-91-OT-2

### Attachment 3: Permit No. 10900008-002; Title I SIP conditions onlyAm f:MISSIO.\' I't:Rj\.llT NO. 11l91111008-002 j\1:Jj'}I' A mend n"'"1

IS ISSUU)TO
Mayo Foundation

SAINT :'>lARYS HOSPITAl. 

### t 216**Sc~ond** Streel Somhwo'l Roche,te,. Olm,ted County, Minno,ota 55902

The emi"ion units, control**C'luiprTl~nl** and cmi"ion**~taek~** atlho 'Iationary source**aUlhori~ed** in thi, p<',mit amendmenl arc 

### as dese,ibed in lhe Permit Applications -rable.

This major amelldmenl pe,mit supersedes Air Emission Oremting Permit No. 10900008·001 and ntJlhori7.C5 tho P"n"ilteo 10 opernte and modify Ihe stationary source at tho add,es, li,ted above unless otherwise Jloted in Table A, The Perminee must comply with all the eOlldil;OllS ortlle permit Afly changes 

### 0' modifH:mion, to tho stalional)' so"ree must be performed in compliance with Minll, 

### R, 7007,1150 to 7007.1500. Any addition, or chunges to cOllditions**ineorporal~d** into MUII,esota's Slate Implementation Plan ($\1') under 40 CFR 

### § 52.1220, designatcd "Title I: SIP for SOl" mast go lhroullh the fedcral Sll' approval proccs, beforc becoming effcclivo. Tenn, '''cd irl the permit are as ddined III the ,tme air pollulion eontrol ru les unless the tenn is explicitly defincd in the per", it.

Unles, otherwisc indieated. ailiho Minncsota rules cited as the origin "fthe pe,mit terms a,e incorporatcd illlo the SIP undcr40 CFR 

### § 52 1220 and a, such a.' arc enforceable by U.S. F""ron"'crltal**l'fOt~CI** ion Agency (10 I' A) AdministralO' or**eili~ens** Ullder the Cleon Air Aet. I'er",it Tn'c: Federal: 

### PI. 70/Majo, fur New Source Review; Ti[le J SIP Conditions lbr SO) 0l'e'"lltinl; I'ermit Issllc IJntc: July 23. 2003 Major A",""dnll'lIt Issuc Date: October 14, 21109**K~pi1"ll1ion** Dme: July 

### 23,**200~'** - Title 

### I Conditions do nOt expi,". Each neW", ,evi,ed eond ition de,igrlated "Title 

### I Condition: SI 

### P for SO," i, not eITc"<;tive or en fo",cablc Llntil approved by EPA as a SIP revision LJn<lcrTitle I ofthc Clean Air Act.

,**Th~** l'cmlitlee may eontinue to operate th is rae ilit) afte, the**e.~pi"'tion** dato of the permi[, PC' Ihe prov;,ion under Minn. R, 7007.0450, subp, 3. (Tille V Reissuallce Applicalion wa, rceeivc'<! Jan""ry 23, 200g.) 

# V Don Smith, P.E.. Manage, Ai, Quality Permit, Seelioll IndusuiaIUiv;si"Jl

for 1'aul Egcr Commissioner Minne,ola 1'"l1uli"n Cont",l Agcnc}

TDD (for boari".': and 'fX'0<b impaif<d <>nly): (65 I) 282-5332 P"""d 0" re'-J'Cld paper cotrrm"'"8 alle",t 10"/0 fibers from pap" r<<)'Ct,,, hy con",.",,,

### Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit December 15, 1995, & December 9, 2002 001 Major Amendment March 27, 2009 002

### TABLE OF CONTENTS

Notice to the Permittee

Permit Shield
Facility Description
Amendment Description
Table A: Limits and Other Requirements

Table B: Submittals
Table C: Compliance Schedule – not used in this permit
Appendices Appendix B – Updated 2009 SO 2 

### Modeling Parameters Appendix C – Insignificant Activities

### 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: St. Mary’s is a tertiary care hospital which includes several buildings located on a 49 acre campus. The primary emission units at the facility are three identical boilers which exhaust through a common stack, one cogeneration turbine, and two emergency generators. Each boiler combusts natural gas with distillate fuel as backup. The cogeneration turbine burns only natural gas. One generator burns only distillate oil; the other can burn distillate oil or natural gas (with a small amount of distillate oil; dual fuel). While St. Mary’s is owned and operated by the Mayo Foundation, it is not contiguous with the majority of the Mayo facilities in Rochester, and thus is a separate source under the New Source Review and Part 70 regulations. The facility is an existing major source under New Source Review and a minor HAP source. The facility is located in an area that was previously designated as non-attainment for SO 2 

### . However, the area currently meets the ambient air quality standards, and was officially redesignated as “attainment” on May 8, 2001. The facility has been subject to a federally enforceable permit (No. 989-91-OT-2; part of Minnesota’s state implementation plan, or SIP, for attaining ambient air quality standards) containing requirements contributing to the correction of the non-attainment problem and the ultimate redesignation. The requirements of that permit were incorporated into the title V operating permit No. 10900008-001 as non-expiring Title I conditions. Permit No. 10900008-002 replaces permit No. 109000008-001 and will ultimately replace permit No. 989-91-OT-2 and be incorporated into the SIP (sometime after issuance of permit No. 10900008-002).

PER 002 AMENDMENT DESCRIPTION:

This is a major amendment to an existing major source operating permit. This permit amendment authorizes the Permittee to install a 2500 KW reciprocating internal combustion engine (RICE) electric generator, and reduces the allowable diesel fuel sulfur content for two existing electric generators (EU 004 and EU 005).The new RICE is referred to as EU 012/Generator 7. The RICE is a compression ignition nonemergency 2007-2010 model year diesel engine with a displacement less than 10 liters per cylinder, and certified by the manufacturer to meet part 60, subpart IIII table 1 emission limits.TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 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 column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you 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 total facility requirements.

Subject Item: Total Facility

What to do Why to do it SITE-SPECIFIC REQUIREMENTS hdr Parameters Used in Modeling: The stack parameters used in the most recently approved modeling are listed in Appendix B of this permit. Before making any physical changes or changes in the method of operation which may affect parameters listed in Appendix B, the Permittee shall demonstrate to the MPCA that the SO2 plume dispersion characteristics following the physical change or change in method of operation will be equivalent to or better than the SO2 dispersion characteristics modeled using the parameters in Appendix B. The information submitted must include, at a minimum, the locations, heights, and diameters of the stacks, locations and dimensions of nearby buildings, the velocity and temperature of the gasses emitted, and the SO2 emission rates. 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. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

A CTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility in compliance with Minnesota Rules and without obtaining a modification to the SIP as long as the change does not increase from any emission point, the SO2 emission rates (in lb/hr) or overall SO2 emissions or alter equipment or parameters described in A ppendix B, which forms the basis for the SO2 modeling, unless such alteration demonstrates equivalent or better dispersion characteristics. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS" shall be reported semiannually with the Semiannual Deviations Report required by this permit (See Table B). Reporting for these conditions shall occur even if there were no deviations for the reporting period. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

State Implementation Plan Recordkeeping: Retain all records at the stationary source for a period of five years from the date of the required monitoring, sample, measurement, or report that corresponds with a "Title I Condition: SIP for SO2 NAAQS" requirement. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-5

Subject Item: GP 001 Boilers
Associated Items: EU 001 Boiler 1
EU 002 Boiler 2
EU 003 Boiler 3

What to do Why to do it EMISSION AND OPERATING LIMITS hdr Fuel Used: The Permittee shall burn only natural gas or very low sulfur oil, as defined in 40 CFR Section 60.41b. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Sulfur Content of Fuel: less than or equal to 0.5 percent by weight (very low sulfur oil, as defined in 40 CFR Section 60.41b) Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j); Minn. R. 7011.0565

MONITORING REQUIREMENTS hdr Sulfur Content of Fuel Oil: The Permittee shall obtain and maintain a fuel supplier receipt from the fuel oil supplier for each shipment of oil received, certifying that the oil meets the definition of very low sulfur oil as defined in 40 CFR Section 60.41b. The Permittee shall ensure that the fuel supplier uses an approved American Society of Testing and Materials (ASTM) method to determine the sulfur content of liquid fuels. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j)(2); Minn. R. 7011.0565

PERFORMANCE TESTING REQUIREMENTS hdr

RECORDKEEPING AND REPORTING REQUIREMENTS hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-8

Subject Item: EU 004 Generator 5
Associated Items: GP 002 Boilers and Generators
SV 002 No. 5 Generator Stack

What to do Why to do it Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

Sulfur Content of Fuel: less than or equal to 500 parts per million by weight as specified at 40 CFR Section 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel. This requirement is effective from the date of issuance of permit No. 10900008-002 through September 20, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2
Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 004 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation PlanTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-9

Subject Item: EU 005 Generator 6
Associated Items: GP 002 Boilers and Generators
SV 003 No. 6 Generator Stack

What to do Why to do it Fuel: The Permittee shall burn only natural gas or diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Sulfur Content of Fuel: less than or equal to 500 parts per million by weight as specified at 40 CFR Section 80.510(a)(1) for nonroad, locomotive, and marine (NRLM) diesel fuel. This requirement is effective from the date of issuance of permit No. 10900008-002 through September 30, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2
Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2

Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 005 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation PlanTABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09 St Marys
10900008 - 002 Facility Name: Permit Number: A-11

Subject Item: EU 012 Generator 7 (Non-emergency CI; <10 liter/cyl; 2500 kW)
Associated Items: GP 002 Boilers and Generators
SV 005 No. 7 Generator Stack

What to do Why to do it LIMITS AND OPERATING RESTRICTIONS hdr Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Fuel Requirements - Beginning October 1, 2007, the Permittee must use diesel fuel in EU 012 that meets the following requirements of 40 CFR Section 80.510(a): (1) Sulfur content maximum 500 ppm; and, (2) Cetane index minimum of 40 or aromatic content maximum of 35% by volume. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Sections 60.4207(a) and 80.510(a); Minn. R. 7011.3520

Fuel Requirements - Beginning October 1, 2010, the Permittee must use diesel fuel in EU 012 that meets the following requirements of 40 CFR Section 80.510(b) for nonroad diesel fuel: (1) Sulfur content maximum 15 ppm (for nonroad diesel); and, (2) Cetane index minimum of 40 or aromatic content maximum of 35% by volume. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Sections 60.4207(b) and 80.510(b); Minn. R. 7011.3520

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 012 will not contain more than 0.05 percent by weight sulfur (500 ppmw) through May 31, 2010, and no more than 0.0015 percent by weight sulfur (15 ppmw) after May 31, 2010. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan

PART 60 SUBPART IIII REQUIREMENTS hdrAPPENDIX B – Updated 2009 SO2Modeling ParametersFacility Name: Saint Marys HospitalPermit Number: 10900008-002Any physical change or change in a method of operation must resultin plume dispersion characteristics equivalent to orbetter than the plume dispersion characteristics modeled using the parameters below. Revision of any of theseparameters may require a permit amendment.NAD 83Easting(X)NAD 83Northing(Y)BaseElevationStackHeight TemperatureExitVelocityStackDiameterShortTerm SO2EmissionRateStackID EU ID Description (m) (m) (m) (m) (K) (m/s) (m) (g/s)SV 001EU 001EU 002EU 003Boilersstack541730.1 4874149.5 326.7 68.0 449.8 20.7 1.77 20.700SV 002 EU 004 Generator 5 541674.4 4874193.5 320.6 11.3 755.4 36.4 0.71 0.140SV 003 EU 005 Generator 6 541675.1 4874189.5 320.8 11.3 755.4 42.4 0.71 0.151SV 004 EU 006 Turbine 541674.1 4874230.0 319.1 19.7 422.0 22.2 1.19 0.004SV 005 EU 012 Generator 7 541694.7 4874222.0 321.0 15.2 724.8 26.7 0.68 0.187

### Attachment 4: Marked up versio n of current SIP included permit

### AIR EMISSION PERMIT NO. (10900008-0071 [989-91-0T-2, AMENDMENT No.4]

IS ISSUED TO

ST. MARY'S HOSPITAL

1216 Southwest 2nd Street Rochester. Minnesota 55902

The emission units, control equipment, and emission stacks at the stationary source authorized in this permit are as described in the following permit applications:

Total facility permit application received December 15, 1995.

This major permit amendment incorporates the Title I conditions and compliance demonstration requirements into the facility's operating permit. These Title I State Implementation Plan (SIP) conditions consist of emission limits necessary to demonstrate compliance 

### with national and state ambient standards for sulfur dioxide. The Permittee must comply with all the conditions of the permit and with all general conditions listed in Minn. R. 7007.0800. suhp, 16. and all standard permit requirements listed in 40 CFR 

### § 70.6(a). Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms lIsed in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Issue Date: February 28, 1997 Expiration: Pursuant to Minn. R. 7007.0350. subp. 2. if a stationary SOurCl' is operating under an air**~mission** permit issued by the Minnesota Pollution Control Agency (MPe/\) under Minn. 

### Roo 7001.1200 to 7001.1220. and if the Permittee submits a complete applicat iOIl for reissuance by \larch 

### IS. 1995, under Minn. R. 7007.0 I 00 to 7007.1850. the permit shall he considered not to e'\pire until a new permit is issued.

Michael 

### J. Sandusky Acting Division Manager Air Quality Division

for Peder J. Larson Commissioner Minnesota Pollution COlltrol Agency

TOO '(for hearing and speech impaired only): (612)282-5332 Pril/ted Oil recycled paper containlllg at least IO%fibersfrom paper recycled by CP'ltllfllt'rJ

### Notice to Permittee

Facilit)· Description

Deletions to Permit 989-91-0T-2 Air Emissions Permit No. I**0900008~(J7** 

### Amendment No 4 Page 2 of 11



### TABLE OF CONTENTS 

# -

Additions to Permit 989-91-0T-2



# -

### Air Emissions Permit No.1 0900008-007 Amendment No 4 Page 3 of 11


### NOTICE TO THE PERMITTEE

Your stationary source may be subject to the requirements of the MPCA solid waste, hazardous waste, and water quality programs. If you wish to obtain infonnation on these programs, including information on obtaining any required pennits, please contact the MPCA general information number at:

Metro Area

Outside Metro Area

TTY ( 612)296-6300

1-800-657-3864

(612)282-5332

The rules governing these programs are contained in Minnesota Rules (Minn. R.) chapters (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 lelephone numbers and address listed above.

### Air Emissions Permit No.1 0900008-007 Amendment No 4 Page 4 

### of 11


### FACILITY DESCRIPTION

S1. Mary's Hospital is a tertiary care hospital which includes several buildings located on a 49

acre campus. The primary emission units at the facility are three identical boilers which exhaust through a common stack, one cogeneration turbine, and two emergency generators. The design heat input of each boiler is 107.05 MMBtu/hr while combusting natural gas. Each boiler

com busts natural gas with distillate fuel oil as back up. The cogeneration turbine burns only :-. natural gas. One emergency generator burns natural gas with distillate fuel oil as back up. The other generator burns only distillate fuel oil. The boilers were installed in 1992, the cogeneration turbine in 1996, and the emergency generators in 1984 and 1978. "



# -

-1

2

3

4

5

## Page: 5

Number: 1 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:19:46 AM Now EU001, Boiler 1. Page A-5. Number: 2 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:20:04 AM Now EU002, Boiler 2. Page A-5. Number: 3 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:20:20 AM Now EU003, Boiler 3, page A-5. Number: 4 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:23:50 AM Now SV001 Number: 5 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:22:20 AM All conditions on this page have been maintained. The emission units are now GP001. Conditions on Page A-5.1

2

3

## Page: 6

Number: 1 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:24:49 AM Now EU004, Generator 5. Number: 2 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:25:06 AM Now SV002 Number: 3 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:25:46 AM Condition has been changed to limit fuel oil sulfur content to 500 ppm. Page A-8.

### Air Emissions Permit No. 10900008-007 Amendment No 4 Page 8 of 11 The following steps shall be taken:

a) The Permittee shall sample fuel oil from the tank(s) prior to the initial delivery of fuel oil when using this method. Sampling of each tank shall be conducted at least once a calendar year for any calendar year in which this method is used. The Permittee shall analyze the oil sample to determine the sulfur content of the fuel oil in percent by weight in accordance with ASTM method D 1552 or with the current ASTM method. The percent sulfur of the sample shall be used to determine the average percent sulfur in the equation below (fill in as Last Average % 

### Sulfur).

b) Be tore the end of the following business day after each fuel delivery to a tank which supplies fuel oil to the emergency generators, the Permittee shall calculate the maximum percent sulfur of the fuel oil using the following equation:

Average 

### % Sulfur 

## = «Last Average 

### % Sulfur 

## * Last Volume) 

### + (% Sulfur of the Oil Delivery 

## * Volume of the Oil Delivery))/ Volume

Where:

Volume 

### = Last Volume

- L 

### Volume Oil Burned 

### + L 

### Volume of Oil Delivered

% 

### Sulfur Each Oil Shipment 

## = The sulfur content of the fuel from the fuel supplier receipt. The fuel supplier receipt shall certify the maximum sulfur weight percent of the fuel oil shipment as determined by ASTM method D 1552 or in accordance with the current ASTM method. The Permittee shall obtain and maintain receipts from the fuel supplier.1

2

3

## Page: 8

Number: 1 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:28:21 AM Now EU005, Generator 6. Number: 2 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:28:52 AM Now SV003. Number: 3 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:29:32 AM Condition has been changed to limit fuel oil sulfur content to 500 ppm. Page A-9.Air Emissions Permit No. 10900008·007 Amendment No 4 Page 

### 10 of 

### 11

-
Method 2. The Permittee shall calculate and record the sulfur content of the fuel oil in each tank which supplies fuel to the emergency generators after each delivery of fuel oil to the tank. The following steps shall be taken:

. a) The Permittee shall sample fuel oil from ·the tank(s) prior to the initial delivery offuel oil using this method. Sampling of each tank shall be conducted at least once a calendar year for any calendar year in which this method is used. The Permittee shall analyze the oil sample to detennine the sulfur content of the fuel oil in percent by weight in accordance with ASTM method D 1552 or with the current ASTM method. The percent sulfur of the sample shall be used to determine the average percent sulfur in the equation below 

### (till in as Last Average 

### % Sulfur).

b) Before the end of the following business day after each fuel deliv&ry to a tank which supplies fuel oil to the emergency generators, the Permittee shall calculate the maximum percent sulfur of the fuel oil using the lallowing equation:

Average % Sulfur 

## = ((Last Average % Sulfur 

## * Last Volume)
+ (% Sulfur of the Oil Delivery 

## * Volume of the Oil Delivery»)! Volume

Where:

Volume 

### = Last Volume· 

### L Volume Oil Burned 

### + L Volume of Oil Delivered

% Sulfur Each Oil Shipment 

## = The sulfur content of the fuel from the fuel supplier receipt. The fuel supplier receipt shall certify the maximum sulfur weight percent of the fuel oil shipment as determined by ASTM method D 1552 or in accordance with the current ASTM method. The Permittee shall obtain and maintain receipts from the fuel supplier.1

2

## Page: 10

Number: 1 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:30:04 AM Page A-1 Number: 2 Author: cneusch Subject: Sticky Note Date: 9/30/2009 10:30:23 AM Page A-1

### Attachment 5: Modeling

### Attachment 6: Public notice

### MINNESOTA POLLUTION CONTROL AGENCY PUBLIC NOTICE ON DRAFT/PROPOSED AIR EMISSION FACILITY PERMIT

NOTICE IS HEREBY GIVEN , that the Commissioner of the Minnesota Pollution Control Agency (MPCA) proposes to issue Air Emission Permit No. 10900008-002, to Mayo Foundation for the Saint Marys Hospital facility located at 1216 Second Street Southwest, Rochester, Olmsted County, Minnesota. In addition, NOTICE IS HEREBY GIVEN that the Commissioner has determined that the State Implementation Plan (SIP) conditions for this facility should be amended. This permit incorporates Title I requirements for Saint Marys which are included in Minnesota’s SIP and are necessary to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) for SO 2 

### . Title I conditions from Air Emission Permit No. 989-91-OT-2, Amendment No. 4 are already included in Minnesota’s SIP. Under its Title I authority, the MPCA is revising the SIP conditions and will be formally requesting that the U.S. Environmental Protection Agency (EPA) amend Minnesota’s SIP to include the new and revised Title I SIP conditions from Air Emission Permit No. 10900008-002, which will serve as a joint Title I SIP/Title V document. These Title I Conditions do not expire. 1) Proposed Permit The permit action is for modification and operation of the facility. The permit action is major amendment; therefore, the draft/proposed permit has been placed on public notice. The MPCA is seeking the U.S. Environmental Protection Agency’s (EPA) concurrent review of this draft/proposed permit and the EPA’s 45-day review period will begin with the 30-day public review period. This permit amendment authorizes the installation of a 2500 kilowatt electric generator and reduces the allowable diesel fuel sulfur content for two existing electric generators. A summary of the Limited Potential to Emit (PTE) in tons per year is as follows:

Pollutant PM PM 10 

### PM 2.5 

### SO 2 

### NO X 

### CO VOC Total HAP PTE from new generator 0.50 0.50 0.50 1.52 38.0 3.39 1.08 0.04
Total Facility PTE 20.0 18.7 18.7 65.7 546 218 19.6 3.14 PM = Particulate Matter PM 10 

### = PM smaller than 10 microns PM 2.5 

### = PM smaller than 2.5 microns SO 2 

### = Sulfur Dioxide NO X 

### = Nitrogen Oxides VOCs = Volatile Organic Compounds CO = Carbon Monoxide HAP = Hazardous Air Pollutant
The Permittee is not required to submit a pollution prevention progress report pursuant to Minn. Stat. § 115D.08.

### Page 2



### 2) Proposed SIP Changes This permit incorporates revised Title I requirements for Saint Marys that are currently included in a joint Title I/Title V document (Air Emission Permit No. 1 No. 989-91-OT-2, Amendment No. 4) issued to Saint Marys and incorporated into Minnesota’s SIP. This SIP revision is intended to update the facility in the SIP and incorporate new and revised Title I conditions. This SIP revision adds requirements and allows for the installation of a new electric generator. Saint Marys is located in a maintenance area for SO 2 

### . The MPCA believes that the changes proposed in this notice will not have an adverse impact on compliance with the NAAQS for this pollutant.
3) Public Participation The preliminary determination to issue the air emission permit and submit the SIP revision is tentative. There are four formal procedures for public participation in the MPCA’s consideration of the permit application. Interested persons may (1) submit written comments on the proposed permit; (2) request that the MPCA hold a public information meeting; (3) request the MPCA hold a contested case hearing; and/or (4) submit a petition to the Commissioner requesting that the MPCA Citizens’ Board (Board) consider the permit matter. The decision whether to issue the permit and submit the SIP revision, and if so, under what terms, will be presented to the Board for decision if: (1) the Commissioner grants the petition requesting the matter be presented to the Board; (2) an Board member requests to hear the matter prior to the time the Commissioner makes a final decision on the permit; or (3) a request for a contested case hearing is pending. Otherwise, the Commissioner will make the decision. Persons who submit comments or petitions to the MPCA must state (1) their interest in the permit application or the draft permit and proposed SIP revision; (2) the action they wish the MPCA to take, including specific references to the section of the draft permit and proposed SIP revision they believe should be changed; and (3) the reasons supporting their position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position. As described in Minn. R. 7000.1800, persons who submit requests for a contested case hearing must also state the issues they propose to address in a contested case hearing, the specific relief requested or resolution of the matter, and the reasons (which may be in the form of proposed findings) supporting an MPCA decision to hold a contested case hearing. Failure to comply with these rules exactly may result in a denial of the request. The decision whether to hold a contested case hearing will be made under Minn. R. 7000.1900. Most public libraries throughout the state have copies of the current Minnesota Rules. They are also available on the Internet at www.revisor.leg.state.mn.us. The public comment period commences August 23, 2009, and terminates September 21, 2009. Comments must be received in writing at the MPCA by 4:30 p.m. on September 21, 2009. Evidence of timely receipt includes a date/time stamp imprinted on the first page of the written comments by the first floor information and reception area of the MPCA, by the Industrial Division support staff, or by the Rochester office s upport staff, or receipt by facsimile at either the St. Paul or Rochester office.

### Page 3



### A public information meeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 pm to 4:00 pm on Wednesday, September 23, 2009, at the MPCA St. Paul Offi ce, 520 Lafayette Road North, Minnesota. To find out if a public meeting will be held, please call Catherine Neuschler at 651-757-2607, after the close of the public comment period. The public information meeting will provide information, receive public input, and answer questions about both the proposed permit and SIP revision. Comments, requests and petitions should be sent to: Permit SIP Revision Marshall Cole Catherine Neuschler Air Quality Permits Section Minnesota Pollution Control Agency Minnesota Pollution Control Agency EAO Division 18 Wood Lake Drive Southeast 520 Lafayette Road North Rochester, MN 55904 St. Paul, MN 55155 507-206-2653 -- Voice 651-757-2607 - Voice 507-280-5513 – Fax 651-297-8324 - Fax

A copy of the draft/proposed permit will available on the MPCA’s website at http://www.pca.state.mn.us/news/data/index.cfm?PN=1, or will also be mailed to any interested person upon the MPCA's receipt of a written request. Information on the SIP revision will be available on the MPCA’s website at http://www.pca.state.mn.us/air/sip.html. Additional materials relating to the issuance of this permit are available for inspection by appointment at the Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155, phone 651-757-2081, and at 18 Wood Lake Drive Southeast, Rochester, Minnesota 55904, phone 507-285-7343, between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday. All MPCA offices may be reached by calling 1-800-657-3864. DATED: August 19, 2009

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

### Attachment 7: Completeness Review A. Administrative Materials (40 CFR pt. 51, Appendix V, Part 2.1) The EPA’s Criteria for Determining the Comple teness of Plan Submittals, published at 40 CFR pt. 51, Appendix V (2001), requires st ates to provide the basic documents that show that the State has properly followed th e administrative requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with these requirements, are discussed here:
1) Formal Letter of Submittal:

“A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof.” Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Paul Eger, to the Acting EPA Re gion V Administrator, Bharat Mathur. The office of the Commissioner of the MPCA is st atutorily created at Minnesota Statute § 116.03, subd. 1 (a) (2000). The Commissioner is appoin ted by the Governor, and the duties of the position include acting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federa l law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the Commissioner. The Commissioner shall comply with any and all re quirements of such federal law or such rules and regulations promulgated thereunder to facilitate application fo r, receipt, and disbursement of such funds.” Minn. Stat. § 116.03 subd. 3 (2000). 2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form “Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter ‘document’) in final form. That evidence shall include the date of adoption or fi nal issuance as well as the effective date of the plan, if different from the adoption/issuance date.” Attachment 1 contains the joint Title I/Title V document, which consists of Air Emission Permit No. 10900008-002, which includes relevant SIP condi tions, labeled “Title I Condition: SIP for SO2 NAAQS.” This Air Emission Permit became e ffective as soon as it was signed. All Title I conditions are non-expiring. 3) Legal Authority Documentation: “Evidence that the State has the necessary le gal authority under St ate law to adopt and implement the plan.” This SIP revision request is an update to MPCA’s Olmsted County SO 2 

### SIP revision and redesignation request submitted to the EP A on November 4, 1998 and approved by EPA on

### March 9, 2001 (66 FR 14087). Attachment B of that submittal documents MPCA’s legal authority to submit SIP revisions and to issue, m odify or revoke permits, as well as to enforce those permits. On May 2, 1995, EPA approved MPCA’s revised ope rating permit program as a SIP revision (60 FR 21447). MPCA submitted the operating permit progr am for inclusion in the SIP in part so that permits issued under the program could be considered federally enforceable vehicles for imposing emissions limitations on culpable sources located in nonattainment areas. EPA’s conclusion that MPCA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace Admi nistrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EP A Region 5 to Michael Sandusky of the MPCA and in a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have been submitted with previous SIP revisions. 4) Compliance with State Procedures: “Evidence that the state followed all of the pr ocedural requirements of the State’s laws and constitution in conducting and completi ng the adoption/issuance of the plan.” MPCA complied with all relevant state procedures for issuing the permit as well as the SIP revision.
5) Public Notice: “Evidence that public notice was given of the pr oposed change consistent with the procedures approved by the EPA, including the date of the publication of the notice.” The public notice for the permit and associated SIP revision was published in the Rochester PostBulletin on August 22, 2009, with the public comment period commencing on July 31, 2009 and ending on September 21, 2009. During the public comment period, a copy of the permit and SIP revision request was made available at the MPCA office lo cated in St. Paul and on the MPCA’s website. A copy of the public notice is attached. (Attachment 6). 6) Public Hearing Certification “Certification that public hearin g(s) were held in accordance w ith the information provided in the public notice and the State’s laws and constitution, if applicable.” The public notice states: “A public information m eeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 pm to 4:00 pm on Wednesday, September 23, 2009, at the MPCA St. Paul Office, 520 Lafayette Road North, Minnesota. To find out if a public meetin g will be held, please call Catherine Neuschler at 651-757-2607, after the close of th e public comment period. The public information meeting will provide information, receive public input, and an swer questions about both the proposed permit and SIP revision.”

### No public meeting was requested. 7) Public Comments and State Response: “Compilation of the public comments and State’s response thereto.” The MPCA did not receive any public comments during the public notice period for the SIP revision. However, the MPCA did receive some comments from EPA Region 5. These comments and MPCA’s response follow.

EPA Comment 1. EPA was unaware of the new permit numbering system. EPA does not have approved permit #10900008-001 into the SIP, and therefore, unable to match Title 1 SIP conditions exactly to those in permit #10900008-002. EPA can tell you that not all of the Title 1 SIP conditions approved in March 2001 [referred to as jo int document #989-91-OT-2,Amendment No.4, Air Permit No. 10900008-007] are visibly noted in permit #10900008-002, due to the revised format of the permit and new language added, and new id entification of "subject item" and "associated items" permitted.
MPCA Response 1. MPCA was aware that there is substantial conf usion over the numbering of this permit. For instance, Permit 10900008-007 does not show as issu ed in the MPCA’s permitting system. In order to clarify the changes and enable EPA to match the Title I SIP conditions in the new joint document to those currently approved into the SI P, the MPCA has added Attachment 4 to the SIP revision. Attachment 4 cons ists of a marked up version of the currently included SIP permit, showing where conditions have been placed in the new joint document and describing any changes in numbering of emission units.

EPA Comment 2. Changes made include new electric generator, and requirement to only burn diesel fuel with a sulfur content of less than 500 ppm (part per milli on) by weight. It is unclear how MPCA is to determine compliance with sulfur content in dies el fuel in terms of pp m (by which these units relate to a percent by volume of concentration of solid or liquid ). Not quite sure how MPCA relates limit in terms of % sulfur by weight to limit expressed in terms of ppm of sulfur by weight, and in this respect, MPCA will need to explain this relationship (show equivalency), and show whether or not the existing SO 2 

### limit is strengthening or weakening the SIP. Also, since the two existing emergency generators are to be subject to similar requirements as the new generator, namely, to burn only diesel fuel oil - will the SO 2 

### limit also decrease to 15 ppm as of October 1, 2010?
MPCA Response 2. MPCA has added an explanation to the backgr ound document that 500 ppmw is equivalent to 0.05% sulfur by weight. This limit is being applie d to new generators, an d to older generators where it is considerably lower th an the current 0.41% sulfur by we ight restriction. The engines at the facility are required to use fuel that m eets the nonroad diesel fuel certifications. Under EPA’s Part 80 regulations ( 80.510(a) and (b)), refineries (except under very specific

### circumstances) cannot produce such diesel fuel with a sulfur content in excess of 500 ppmw. After June 1, 2010, they will be prohibited from produc ing fuel with a sulfur content in excess of 15 ppmw, which is 0.0015% sulfur by weight. After reviewing EPA’s comment, the MPCA has added this decreased ppmw sulf ur limit to the joint document for the existing generators. In terms of demonstrating complia nce with the sulfur content of the diesel fuel, the MPCA has added a requirement to the joint document that the f acility received and reta in a fuel certification from the fuel supplier. B. Technical Support:
1) Pollutants Regulated: “Identification of all regulated po llutants affect by the plan.” The regulated pollutant subject to this SIP revision request is SO 2 

### . 2) Source Identification

“Identification of the locations of affected so urces including the EPA attainment/nonattainment designation of the locations and the state of the Attainment Pl an for the affected area(s).”

The affected source within the former Olmsted SO 2 

### nonattainment area is the St Marys Hospital. Further information on the facility is included in the attached modeli ng and Technical Support Documents.
3) Emissions Quantification: “Quantification of the changes in the plan; allowable emission s from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of the cha nges in actual emissions through calcul ations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.” The changes allowed in this SIP revision im pacts emissions, as shown in the background document and permit technical support document. The addition of the new generators results in a limited emissions increase of 1.52 tpy of SO 2 

### . However, added limits on the existing generators will decrease the faci lity’s potential emissions. Furt her information can be found in the Technical Support Document, Attachment 2.
4) NAAQS Protections:

“The State’s demonstration that the NAAQS, prevention of signifi cant deterioration increments, reasonable further progress demonstration, and visibi lity, as applicable, are protected if the plan is approved and implemented.” Modeling of the proposed changes at the facility show that the NAAQS will be maintained, and that the facility impact on the NAAQ S will remain the same or decrease.

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