•

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 ofRochester, 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 ofAir

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 ofMinnesota'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 ofthe new pennit that serves as the joint Title IITitle

V document, the pennit technical support document, a copy ofthe 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 (Saint Marys), which is owned and operated by the 

Mayo Foundation. 

The requested revision involves changes to Saint Marys current operating conditions and 

revisions to the applicable Sulfur Dioxide (SO2) State Implementation Plan (SIP) conditions 

currently listed in the joint Title I/Title V document and incorporated into Minnesota’s SIP. All 

currently existing Title I SIP conditions will continue to apply until this SIP revision is approved 

by the Environmental Protection Agency (EPA). 

This amendment is being proposed in conjunction with a facility modification and total facility 

operating permit amendment (Air Emission Permit No. 10900008-002). The permit and its 

technical support document (TSD) provide information on the proposed changes to Saint Marys 

Hospital’s operations. This document concentrates on the changes that are relevant to the 

facility’s Title I SIP conditions for SO2. 

SIP revision is necessary due to the facility’s location in the Rochester/Olmsted County SO2 

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 Conditions in the Title I/Title V Document 

Saint Marys 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 oil as a backup fuel. 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 (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 SO2 

National Ambient Air Quality Standards (NAAQS), and has been subject to a federally 

enforceable permit incorporated into Minnesota’s SIP as a joint document, containing 

requirements for ensuring the attainment of the National Ambient Air Quality Standards 

(NAAQS) for SO2. The area was officially re-designated to attainment in 2001. 

The most recent SIP action came when EPA approved 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 which 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 system 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 incorporating the most recent, 
2 

and correctly numbered, Air Emission Permit No. 10900008–002 as the joint document for this 

facility. Attachment 4 shows the current SIP included permit, marked up to show the changes in 

the numbering of the subject sources and where the 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 international combustion engine electric 

generator. The new generator is listed as EU012. Installation of the new generator results in a 

potential 6.51 tons per year (tpy) increase of SO2 emissions, and a limited SO2 emission increase 

of 1.52 tpy. The new generator is subject to a requirement to burn only diesel fuel oil with a 

sulfur content of less than 500 ppm by weight. The diesel fuel oil limit decreases to 15 ppmw as 

of October 1, 2010. This diesel fuel oil limit 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 ensure that the addition of the generator is not a 

major modification under federal New Source Review requirements. 

Reduced SO2 Limits 

The existing boilers, cogeneration turbine, and generators are subject to fuel sulfur limits in order 

to comply with the NAAQS requirements. The cogeneration turbine burns 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 burn distillate oil with a sulfur 

content less than 0.41% by weight. In order to add the new generator and ensure that emissions 

from the facility remain low, the existing generators 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. The 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 SO2 emissions from the facility are very low. 

 
3 

Table: Limited PTE and Actual Facility Emissions 

 PM 

tpy 

PM10

tpy 

PM2.5

tpy 

SO2

tpy 

NOx

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 new 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 AERMOD, using meteorological 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 results showed equivalent or decreased ambient impacts from the 

facility at each receptor,1

 even after the installation of the new generator. 

The high-second-high SO2 modeling results for the facility are as follows: 

Table: High-Second-High Ambient SO2 Concentrations from Facility 

Averaging 

Time 

Modeled Concentration (μg/m3

) 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 impacts 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 considered to be equal ambient impacts. 
4 

Attachment 3: Permit No. 10900008-002; Title I SIP conditions only 

Attachment 4: Marked up version of current SIP included permit 

Attachment 5: Modeling 

Attachment 6: Public notice 

Attachment 7: Completeness Review 

This summary was prepared by Catherine Neuschler, Environmental Analysis and Outcomes 

Division of the MPCA.
Attachment 1: Permit No. 10900008-002; joint Title I/Title V document 

 
Am f:MISSIO.\' I't:Rj\.llT NO. 11l91111008-002

j\1:Jj'}I' Amend n"'"1

IS ISSUU)TO

Mayo Foundation

SAINT :'>lARYS HOSPITAl.

t216 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 IConditions do nOt expi,".

Each neW", ,evi,ed eond ition de,igrlated "Title ICondition: 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 fibersfrom 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 SO2 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 provision of the applicable requirement identified 

in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 

and 7017.0100, subp. 2, notwithstanding the conditions of this permit 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 SO2. 

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

ACTIVITIES 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

Appendix 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. 2
TABLE 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

ATPA 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

Agency within 60 days after the end of the year in which the exceedances occur.

The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of

the facility contact person

b. The annual emissions (actual, plus potential if any part of the project was

analyzed using the hybrid test) for each pollutant for which the preconstruction

projection and significant emissions 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 hdr
TABLE 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.

At 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.

At 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

Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

Minn. R. 7007.1150 through Minn. R. 7007.1500
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/14/09

St Marys

10900008 - 002

Facility Name:

Permit Number:

A-4

Application 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. 7002.0095
TABLE 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.

As 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 hdr
TABLE 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 above
TABLE 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 5
TABLE 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 Plan
TABLE 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 Plan
TABLE 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, 2003
TABLE 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. 7011.3520
TABLE 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

Application 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.

Acceptable 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

All 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

Air 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. 3
TABLE 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.

Acceptable 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

All 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. 3
APPENDIX B – Updated 2009 SO2 Modeling Parameters 

Facility Name: Saint Marys Hospital Permit Number: 10900008-002 Any physical change or change in a method of operation must result in plume dispersion characteristicbetter than the plume dispersion characteristics modeled using the parameters below. Revision of any parameters may require a permit amendment. 

NAD 83 

Easting 

(X) 

NAD 83 

Northing 

(Y) 

Base 

Elevation

Stack 

Height Temperature

Exit 

Velocity

Stack ID EU ID Description (m) (m) (m) (m) (K) (m/s) SV 001 

EU 001 EU 002 EU 003 

Boilers stack 541730.1 4874149.5 326.7 68.0 449.8 20.7 

SV 002 EU 004 Generator 5 541674.4 4874193.5 320.6 11.3 755.4 36.4 SV 003 EU 005 Generator 6 541675.1 4874189.5 320.8 11.3 755.4 42.4 SV 004 EU 006 Turbine 541674.1 4874230.0 319.1 19.7 422.0 22.2 SV 005 EU 012 Generator 7 541694.7 4874222.0 321.0 15.2 724.8 26.7 
Attachment 2: Permit technical support document 

 
Technical 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 hospital 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, and 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 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 SO2. 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). 
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 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. 

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 Emissions 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 

PM10 2.13 0.50 15 NO 

PM2.5 2.13 0.50 10 NO 

NOX 163 38.0 40 NO 

SO2 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 NO 
Technical 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 

PM10

tpy 

PM2.5

tpy 

SO2

tpy 

NOX

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 NOX, CO SO2 PM, PM10, PM2.5, VOC 

Part 70 Permit Program NOX, CO SO2 PM10, PM2.5, 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 Source Review permit regulations. The facility is a 

fossil fuel-fired boilers facility with total heat input 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 permit 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-emergency 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 therefore 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 meet 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. 

SO2 State Implementation Plan (SIP)

The facility was identified as a potentially-culpable source in the Rochester area's non-attainment of the 

SO2 NAAQS. As a result, the facility is subject to fuel usage limitations to restrict total facility SO2

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

SO2 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 conditions, and have been carried forward into this 

permit. The Rochester area was redesignated to attainment in March 2001, and is now a maintenance area 

for SO2. 

Minnesota State Rules

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

Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment 

Subject 

Item 

Applicable Regulations Comments: 

EU 012 

Title I Conditions: SIP for 

SO2 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 NOX

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 

SO2 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 NOX Emission Factor Verification Testing: Testing is required to validate the accuracy of the 

manufacturer’s NOX emission factor. The factor (1.012 g/hp-hr) was used to determine the 

2045 hr/yr operating hours limit and restrict NOX 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 NOX emissions can not exceed 38.0 tpy. 

3.1. Emissions Calculations 

Emissions were calculated using manufacturer’s emissions guarantees for PM, NOX, CO, and VOC, and 

AP-42 ch. 3-4 for all other pollutants. PM was assumed to be all PM2.5, and PM10 was assumed to be all 

PM2.5. 

Revised total facility limited annual emissions (as shown in Table 3) were calculated using Table 1 data 

from the TSD for PER 001, and the additional limited EU 012 emissions, except for SO2. There is no 

change in limited annual SO2 emissions due to the addition of EU 012 to the facility because EU 012 was 

added to GP 002 and GP 002 limits SO2 from the 3 boilers and 3 engines (to 65.56 tpy on a 12-month 

rolling sum basis). 

3.2 SO2 SIP Modeling

The facility is located in Rochester, Minnesota which is a SIP maintenance area for SO2. Revised SO2

modeling was submitted for this permit action. Table 6 shows the results of that modeling. 

Table 6. SO2 Modeling Results 

Averaging 

Period 

SO2 standard 

ug/m3

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 per 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 responsibility of the owner or operator of a facility to have 

sufficient knowledge of the facility to certify that the 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 requirements for those emission units for which the 

monitoring required by the applicable requirement 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 and contains adequate 

periodic monitoring requirements. 

The 2045 hours limit is derived from hourly lb/hr 

NOX calculated with the manufacturer’s NOX

emission factor, and 38 tpy of NOX 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 SO2 SIP 

Limit; meets SO2

< 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 SO2 limit. When 

combusting 500 ppmw sulfur oil, SO2 emissions 

are approximately 0.05 lb/mmBtu, and when 

combusting 15 ppmw, SO2 emissions are 

approximately 0.0015 lb/mmBtu 
Technical 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 installed 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 determination and subjecting the 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 fuel supplier certification letter stating diesel fuel 

sulfur content will not exceed 500 ppmw through May 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 Foundation, 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 violation 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 (SO2 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 only 

 
Am f:MISSIO.\' I't:Rj\.llT NO. 11l91111008-002

j\1:Jj'}I' Amend n"'"1

IS ISSUU)TO

Mayo Foundation

SAINT :'>lARYS HOSPITAl.

t216 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 IConditions do nOt expi,".

Each neW", ,evi,ed eond ition de,igrlated "Title ICondition: 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 fibersfrom 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 SO2 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 provision of the applicable requirement identified 

in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 

and 7017.0100, subp. 2, notwithstanding the conditions of this permit 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 SO2. 

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

ACTIVITIES 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

Appendix 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 hdr
TABLE 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 hdr
TABLE 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 Plan
TABLE 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 Plan
TABLE 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 hdr
APPENDIX B – Updated 2009 SO2 Modeling Parameters 

Facility Name: Saint Marys Hospital Permit Number: 10900008-002 Any physical change or change in a method of operation must result in plume dispersion characteristicbetter than the plume dispersion characteristics modeled using the parameters below. Revision of any parameters may require a permit amendment. 

NAD 83 

Easting 

(X) 

NAD 83 

Northing 

(Y) 

Base 

Elevation

Stack 

Height Temperature

Exit 

Velocity

Stack ID EU ID Description (m) (m) (m) (m) (K) (m/s) SV 001 

EU 001 EU 002 EU 003 

Boilers stack 541730.1 4874149.5 326.7 68.0 449.8 20.7 

SV 002 EU 004 Generator 5 541674.4 4874193.5 320.6 11.3 755.4 36.4 SV 003 EU 005 Generator 6 541675.1 4874189.5 320.8 11.3 755.4 42.4 SV 004 EU 006 Turbine 541674.1 4874230.0 319.1 19.7 422.0 22.2 SV 005 EU 012 Generator 7 541694.7 4874222.0 321.0 15.2 724.8 26.7 
Attachment 4: Marked up version 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 I00 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. I0900008~(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 ofthe 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

combusts 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.

"

-

-
123

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 offuel 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 ofthe fuel oil

in percent by weight in accordance with ASTM method D 1552 or

with the current ASTM method. The percent sulfur ofthe 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

ofthe fuel oil using the following equation:

Average % Sulfur =«Last Average % Sulfur * Last Volume) + (%

Sulfur ofthe Oil Delivery * Volume ofthe Oil Delivery))/ Volume

Where:

Volume = Last Volume - L Volume Oil Burned + L Volume of Oil

Delivered

% Sulfur Each Oil Shipment = The sulfur content ofthe fuel from

the fuel supplier receipt. The fuel supplier receipt shall certify the

maximum sulfur weight percent ofthe 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 offuel 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 ofthe fuel oil in percent by weight in

accordance with ASTM method D 1552 or with the current

ASTM method. The percent sulfur ofthe sample shall be

used to determine the average percent sulfur in the equation

below (till in as Last Average % Sulfur).

b) Before the end ofthe 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 ofthe fuel oil using the lallowing

equation:

Average % Sulfur =((Last Average % Sulfur * Last Volume)

+ (% Sulfur of the Oil Delivery * Volume ofthe Oil

Delivery»)! Volume

Where:

Volume = Last Volume· L Volume Oil Burned + L Volume

of Oil Delivered

% Sulfur Each Oil Shipment = The sulfur content ofthe 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 SO2. 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 PM10 PM2.5 SO2 NOX 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 PM10 = PM smaller than 10 microns 

 PM2.5 = PM smaller than 2.5 microns SO2 = Sulfur Dioxide 

 NOX = 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 SO2. 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 support 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 Office, 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 Completeness of Plan Submittals, published at 40 CFR 

pt. 51, Appendix V (2001), requires states to provide the basic documents that show that the 

State has properly followed the 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 Region V Administrator, Bharat Mathur. The 

office of the Commissioner of the MPCA is statutorily created at Minnesota Statute § 116.03, 

subd. 1 (a) (2000). The Commissioner is appointed 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 federal 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 requirements of such federal law or such rules and regulations 

promulgated thereunder to facilitate application for, 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 final 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 conditions, labeled “Title I Condition: SIP for 

SO2 NAAQS.” This Air Emission Permit became effective as soon as it was signed. All Title I 

conditions are non-expiring. 

3) Legal Authority Documentation: 

“Evidence that the State has the necessary legal authority under State law to adopt and 

implement the plan.” 

This SIP revision request is an update to MPCA’s Olmsted County SO2 SIP revision and 

redesignation request submitted to the EPA 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, modify or revoke permits, as well as to enforce 

those permits. 

On May 2, 1995, EPA approved MPCA’s revised operating permit program as a SIP revision (60 

FR 21447). MPCA submitted the operating permit program 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 Administrative 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 EPA 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 procedural requirements of the State’s laws and 

constitution in conducting and completing 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 proposed 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 located 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 hearing(s) were held in accordance with the information provided in 

the public notice and the State’s laws and constitution, if applicable.” 

The public notice states: “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 Office, 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.” 
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 joint 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 identification of "subject item" and "associated 

items" permitted. 

MPCA Response 1. 

MPCA was aware that there is substantial confusion over the numbering of this permit. For 

instance, Permit 10900008-007 does not show as issued 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 SIP, the MPCA has added Attachment 4 to the 

SIP revision. Attachment 4 consists 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 million) by weight. It is unclear how MPCA is to 

determine compliance with sulfur content in diesel fuel in terms of ppm (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 SO2 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 SO2 limit also decrease to 15 ppm as of 

October 1, 2010? 

MPCA Response 2. 

MPCA has added an explanation to the background document that 500 ppmw is equivalent to 

0.05% sulfur by weight. This limit is being applied to new generators, and to older generators 

where it is considerably lower than the current 0.41% sulfur by weight restriction. The engines 

at the facility are required to use fuel that meets 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 producing 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 sulfur limit to the joint document for the existing generators. 

In terms of demonstrating compliance with the sulfur content of the diesel fuel, the MPCA has 

added a requirement to the joint document that the facility received and retain a fuel certification 

from the fuel supplier. 

B. Technical Support: 

1) Pollutants Regulated: 

“Identification of all regulated pollutants affect by the plan.” 

The regulated pollutant subject to this SIP revision request is SO2. 

2) Source Identification 

“Identification of the locations of affected sources including the EPA attainment/nonattainment 

designation of the locations and the state of the Attainment Plan for the affected area(s).” 

The affected source within the former Olmsted SO2 nonattainment area is the St Marys Hospital. 

Further information on the facility is included in the attached modeling and Technical Support 

Documents. 

3) Emissions Quantification: 

“Quantification of the changes in the plan; allowable emissions from the affected sources; 

estimates of changes in current actual emissions from affected sources or, where appropriate, 

quantification of the changes in actual emissions through calculations of the differences between 

certain baseline levels and allowable emissions anticipated as a result of the revision.” 

The changes allowed in this SIP revision impacts 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 SO2. However, added limits on the existing 

generators will decrease the facility’s potential emissions. Further information can be found in 

the Technical Support Document, Attachment 2. 

4) NAAQS Protections: 

“The State’s demonstration that the NAAQS, prevention of significant deterioration increments, 

reasonable further progress demonstration, and visibility, 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 NAAQS will remain the same or decrease. 
" , • J I!] t; ~..: ~. - !:; d~ ... ~~~ t:·] . ~"' fil: 

"j' l .J;,,1, i1 I'h l!' 1 

III . ,'dlj'1- .", J,! •

'1'1 "I··' - I" I ,/; <~. ; 

:!!~~ . -ll - 'S.,!!~ 

'J,l I J.111,1. I 51. ·IF" 

j 0 J! i -"J .'" ,-, • I 

... .., J . .~.; 1 e eJ' J '

,I !j:! l Jil ,jAJl ! 1!~ jj! I 

" -I' j" ,ii'l' , ·1' ,"' 

tl i', ,",'. 'i. i l, J.~ ! 

!! 11 1 ,1111" <1' 'I'! ,

<J< S·;:; _ I." _

fO 1.11 ! I•. '1"1 1 jlj :-1 I 

it. -ll~!1 ,;,"j~~~'Ol~ ~.a .::l"; I

... '" ,/I '~Jte,.z--'S - "'~ .... 

1i Idll ,~ if; 14m }h ~!!.!, 

I Ill!l I .•" 1.1 tIll" 1,111 "1 II!I !; 

;:; .!ieJ~~ '0 -J ;~H.r~./li'j! j f. .!1..<~ ~

I jil" l I! 1'!~Jil1 1 ' !j:l i.PI ! j

• ll;'}"l i -jl l·I.lo·lllli I 'I';' l-~I!' I I

, , .. " • --;'1'--' li' ~':l 

: ~~~ 't 11 !!~ll-~~~ll A ~./l.~1 !iil ~
Jl.UITb9. 2001 (66 FR 14OI!7), ..."""_ Boflb.u,,""'iu.J _ .... MPC... '. qal

OUl!>o<ily OJ """";1 SIP .....- ood OJ -.moo:lily Of=- permi", .. ""II .. OJ ..,force

_p<mlitL

00 M.~ 2, 199~, EP... appro..... MPC...·• __ ~tinI pemu' 11"'I'"'" ... SIP r<>i';"" 11;(1

FR ll4(7). MPCA llUbmitl«l tl>< "I'<fotin& penIIiI prop.lIl for ind"."", in th< SIP ;n I"rt OD

,I""p=rito __"'" _ cooid be <ODIi<k~ -'Uy"'-" ¥e'''Io. for

tmi_ limilotioM OIl <1111",,10 ooorC<'llo<ot«l iII ....."' __

EP... '''00<1"..,., 1",-1 MPC'" ""' th< oothoriIy .. _ penni"..-ith -,,;.-inf; Tot!< I SIP

OOl>li....ill .. '<1110« ""mini_.. Onl<n has b=o r...u.,- doown<no<d in., "",;1 4,

19\171<t1<r &om MicM<1 Sondu,q oftho MPC... ., !>ovid K"" ofEPA J,' Jut)' J, 1997

..- &om !>ovid K""off.P'" il<p", l .,M.,h.<I ~ofth<MPCA...:Ii..l"", Il,

2006 _ from loy Il<>rt= .rEPA R~ l ., r:-vid n.o.-, ofth< MPC.... C.....f_

Jenen ""•.• bern ..bIIl,""..-ith 5IP~,

'Evida>« ..... tho ..... fullooo-«1.11 of"'" "'l"i=Dont& ofth< S",,',l&w. 011<I

ronotinllioo in .... "'" odoptionf..-_ oftb< pt&n..

MPCA oompliod ,..;t!l 011 "' for i , th< penoit .. ""II .. th< SIP

""moo.

l) Public Noti«:

''Evi<lmo>o """ I"'bli< _ wool"'"" .ftho '"""" «-io>mt with tl>< 1""'''''''''''

approvo:l by"'" EPA. ind"di"ll ""' dol< of"" pIDI;.;.a"" of"'" _.'

Th< public ""' for th< penni''''' """","«d SIP =;';"" "... po>bli!bo:lill ""__or

l'>rII<ulloti A"I""' 22. 2009. "ith th< pub!" """"""'" p<riod """"""'".. iuly J I, 2009

an;I <TWlioI "" S<po<m~ 21, 2009. llorin& "" publ" ........... p<riod. 'oop)' of"'" I"nai' 011<I

SIP"";';"" _,.... mod< .",'bbl< "' "'" MPCA oIl'o« Io<uo:l in Sl Pool 00<l OIl 'ho

MPC... '. """"'i... A ""I'Y .ft!>< publi< ..,.;0" i< .""bed. (A'''''''''''''' 6),

"Can/i<aboo ""', publ;" ~.}"""" held in ooeo<dmo< "i'" ""inf_provOlod ill

th< bl" ..,.;0" md t!>< SI&",', loW> .... """"i..,;"", if"I'Pti<ob...•

Th< bIk _ """'.: 'A publi< ioformaIioot ....tinl will ooly bo kid ifon< is uqu<oIo:l

durin;I "" 1"'06< 00Il>I>l<01 p<riod, IfIU<" 0-.is '"'1..-. it"';l1 be hold fmm HlO I""'"

4:00 1""" w_~, 2J, 2009, .. "'" MPCA 51. Pul 01500:. 520 Laf.y<U< Rood

Nonb. Mu.-:.u, T. fond "'" if0..."1i< .....in;I will be bold. «IICad><rioo !-Ieu.d.lo:>- ..

611·717·2607, aft" tl>< elMo of"" public ""'"""'" period. Th< b1i< ;0["""""",, moo:tffiI w;1I

1'1<,,* .._ ..... re«i,', ""Olic iIIpoot, ood ........ qu<slions.-. _ tb< prop<>o«l p<noil

...:I SIP on;";"""
-c"""""'"'" of..., pubI;" co"""""" anlS_·. "..,...... _."

no: MI'C" <tid _....,.;,.., ""Y I"Ooc"""""" during do< 1"bI;" nob« poriod lbr..., SIP

......mo.. "0"""', tho MI'C" <tid =<i,.., "'"'"__HA R.p.n l. oncononcn" ON! MI'C"'. """""'" folio".

foP" Coonm<nt L

EPA ............... of..., onIp<nnil~_ liP" ....,._ ...,..,~p=nit

~I(;J9(IO)OO8--OO, InIQ ..., SIP....._._ble ",....,h TOIl< 1 SIP coowi_ "".<tIy .. _ in p<nnh ~,09(l(IOXli.-Ol», liP" """ ..n 1"" Ibot _ oJl of.... Till< 1 SIP"""I6bon'

"I'I'f'l""'l in M>r1;b lOOl (t<fenod ....join1 ~t09SQ·Ql.()T·2.AtI><II'Im<m No.'. Air

Permi, No. lO9OOOOklO1j .., vi.i\>ly ..-. in p<nnil.I(;J9(IO)OO8-<lOZ, <boo ioo<l _

oftbo pamir.n<! """ w,g..g< odtlnd, anl ...... i<lmOf'nbon n,"""bje<t item" ....,.,;,,!Od

i....." """'"......

MI'CA R,_,.

MI'C" ............ tho, ","",;, ..w.m41 cooliozO;>nm...-"" nfth;, ponnil. F..

""""',. Permi. 109(v:Xl(il.(l(l7 __"""" .. """'" in .... MPC" '. pamftliac 'Y*'"- In

O<d<t '" <Iori~ .... 'horI&« .... , ..010 EPA '" _" "" Ti1l< I SIP coowi""",,, i• ...,"""..... <I0<:Il_ '" _ CII"",'1y approv«I ioIo .... SIP..... MI'CA .... _ ,,__"'...,

SIP r..i.- A __, _ """,im ofa marko<I up _Don oflll< currmtly..,b><lod SIP ,.....m.

Ibowina ..ller< coowi;'iono 110,.., Ilo<o1 p10ced in til< "''' joim <lo<u......ntl o.-ribioi OIlY

c....... in """,beri.. of"",iom. oniIo.

EPA Commonll,

ClIaftI<o ..- ""'1 ......... ,Icc";'; sm<'l'.... on<! """ ""'y....... d.".1 fi,.<!..-w. • ..Ifu, t:<>Ill<II' of!<so IlIan $00 ppm (por1 per "';100.) by ; It ;, ""''''' _ MI'CA ....

oIe<eunine COO"4'lion<, """ ..lfuJ conI<II1 ill dieo<l fud in of""", (by b"h""'" ""'" ",1.0.. "'._,by Y(>lUlll< of <:o<>:enlnlion of ooIid .. liqoid No< q.i _ MPCA

"la1<s m"j, in ....... of% ..Ifur by,..;po .. lirrU,__ill """" of ppm of..Ifur bJ

....,iljlt. anol io IlIis -"Ml'CA ..ill ..........ph.. tbi> "Ioliortohip ("""" oqui,,""'y)••nd

_ .."'_.."'" ....""illinlso, I;";. is _D&ll-i.... _ketlq"" SIP. A"" oil>;<

tllo...., """'jleI'>C)' ,.,........... to IIe ..bje<t to oimil&r _imneDls.. tII< .....

_","" !y. "'''''''' ~dio<d lIIel,,;l" will tile so,limi,.,.. .. I~ ppm .. "

Claol>e< I •:lO I0'1

MPCA~2.

MI'CA >ddN .."",!&tIII_ .. tile ,,",I<ground doc.""'" lbo' SOO ppm-... io .......1<0 ..

0.0'% lfUT by ....,;llht· n.;.fuM;, b<ina &ppIied '""'... _ ............ _ 1lCll'......

....... I'" ~"""'"110M tile t:II!lWlI 0..,% ",Ifu. by ...wu "ilrictioo. Tn< er>&iDes

at tile ~ili'y an '"'l"il<oJ "' ... fIoel dII1 ........... _ m-)tl>el cmiJlcationo. Unoler

F-PA'. Port l!O r<pIo.,,- (10,11«.) ond (b)~ ..,_(<X«P' tlnol<l V<r)' ",""iii<:
d.<um.IIn«o)"""'" pro<Ioc< lUCb dicoel /WI willi. oulflor COIII<m in .."".. of~ _. AlIe< j"", 1,1<JIO,1h<y will be probibiled from prod\>ci!t& fuel ,,·iIlI ...!fII, roI'I<rII ill <>_ <if

U 1'PIIl", "biob is O,OOlffi ",lfIor by ....il!", AfI<r =i<o<inI EPA', e<>rrIl"<ll~ .... MPCA hu _ Ulis do=u<4 ppm'" ..lfIor Iimi1IO tbojoino doo<Inro<n< k>< "" .. __

In _ <if-.._..; """"ion« wi", """,1Iu.""'*'"<if.... d;""'1 rod, .... MPCA 110.

""""". "'IUll<m<n, ......p .. !hal .... f"';'<Y «<;<WN and ........ f"d oer,;_

_ """""I~"'-

II. T",hm<aI

I) PoII._ ~ted

-!&obl",tiool of all __poI\uwIlI.fIec1 by .... pllo.-

-Idonbfocaboa or.... 10<0_ orill<aod -=o""'1udinli .... EJ'A .,~tlI;nm<ol

<looripbon orlht Io<obono and .......'" of....A"- Plm lOt .....frt<tt.l .m(,~-

Toe .lk<ltd ""'"'" willri!l .... fonner Olmalod so, .........imnenl_ is .... SI Mory. H"'9ital,

fortbot in_tion on .... fo<ilily iI included in t!>< attIo<l>e<I t»Odeliq and T",bn.,,1 ~_.

"Qo.onIir><ation or.... 'ban£es in plan: .11o~' from tb<.-.oo JOUtCe"

.......... of'hon&e' in , ....... 0< from.rfe<ltd """""" ot, ~hete """"","''',

.,.....o:ifocabon of"'" Cbanlld in ",..I ..-Ihroul!> <ale._ of the <Ii~ bctw.... =tain _~.. I<>~1s and allow.bIe emi.._ alKi<iplted ... .....noftlo< rovioion:'

Tho chlJ1ae••1_;" 1IIi, SlP ,evUion iInpocta ....__.. _~ in tlo< bo<~

documelll and pennit te<hnical ..ppon doc"""",,, Tho od<liliotl oft!>< .....--......iIa ..

• limted _ ineT<o.. of 1.S11p)' ofso,. I\owevc<, _ lirnilo on t!>< "i.;";

__"al <It<..... !be fociIity". poI<t'ltial emioaiono, F...........forma""" coo be fwr>l in

.... Technical Sopp<><t D<I<""""', A__2.

4)NAAOSI'roto<liom:

"The Sta"",_liontN.t .... NMOS,,,,,venOoon <if~pificaro; oItteriototioo ""'''''''''''' .....-fIudlet pt<IifOOIdemon_tion. anoJ ,isibilny, .. oppIic...... 01'< _tt.l if.... pi...

ilI.ppt'<I'ed and impl<ment<4:.

MOOeI'" or". propoo«I <~...... r.cUny _1haI NMOS...-ill b< m';"";n«\, ond

......... 6o<iIi<y",-t on .... NMOS will r<mo;n "" ot~,