### Minnesota Pollution Control A **g e**  **n c**  **y**

**520 Lafayette**  **Road North**  **I St. Paul, Minnesota**  **55155-4194 I**  **651-296-6300**

**800-657-3864 I**  **65 1**  **-282-533 1**  **I W**  **Vfiloi..JX'l**

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**May 1,**  **2015**

**Dr. Susan**  **Hedman Regional**  **Administrator USEPA**  **REGION 5**  **77 West**  **Jackson Boulevard**  **Mail Code:**  **R-19J Chicago,**  **IL 60604-3507** 

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

**Dear Dr.**  **Hedman:**

**The Minnesota**  **Pollution Control**  **Agency (MPCA)**  **hereby submits**  **to the**  **U. S.**  **Environmental Protection**  **Agency (EPA)**  **a request**  **for revision**  **of Minnesota's**  **State Implementation**  **Plan (SIP).** 

**The revision**  **concerns Flint**  **Hills Resources**  **LLC's Pine**  **Bend Refinery**  **(FHR) and**  **Northern States**  **Power Company's**  **Xcel Energy**  **-Inver Hills**  **Generating Plant**  **(Inver Hills),**  **both of**  **which have**  **facility-specific restrictions**  **as part**  **of Minnesota's**  **SIP for**  **sulfur dioxide**  **(S02) in**  **the Pine**  **Bend area**  **of Dakota**  **County. Minnesota's**  **SIP currently**  **includes an**  **Administrative Order**  **(Order) issued**  **to FHR**  **and a**  **joint Title**  **1/Title V**  **permit for**  **Inver Hills,**  **which contain**  **emission limits**  **and other**  **conditions that**  **were found**  **necessary to**  **demonstrate compliance**  **with the**  **National Ambient**  **Air Quality**  **Standards (NAAQS) for**  **S02.**

**The primary**  **purpose of**  **this proposed**  **SIP revision**  **is to**  **add a**  **new process**  **to enable**  **the removal**  **and**
**recovery of**  **more sulfur**  **from fuel**  **produced at**  **FHR. This**  **new process**  **will allow**  **FHR to**  **produce gasoline**  **that meets**  **the EPA's**  **Tier 3**  **gasoline sulfur**  **standard. The**  **SIP revision**  **would also**  **allow changes**  **and updates**  **to monitoring**  **requirements and**  **the facility's**  **flaring policy.**  **Additionally, this**  **SIP revision**  **would incorporate**  **the new**  **and revised**  **Title I**  **SIP conditions**  **for FHR**  **into Permit**  **No. 03700011-012,**  **which will** 

**serve as**  **a joint**  **Title 1/Title**  **V document**  **and replace**  **the existing**  **Order.**

**This SIP**  **revision also**  **removes residual**  **fuel oil**  **as an**  **allowable fuel**  **type from**  **the Inver**  **Hills joint**  **Title 1/Title**  **V permit.**  **There are**  **no SIP-relevant**  **construction changes**  **being made**  **to the**  **Inver Hills**  **facility and**  **therefore this**  **proposed SIP**  **revision does**  **not authorize**  **any new**  **operations or**  **emission units**  **at that**  **facility.**

**This submittal includes Permit**  **No. 03700011-012**  **and supporting**  **technical documentation,**  **including modeling,**  **issued to**  **FHR and**  **Permit No.**  **03700015-004, issued**  **to Inver**  **Hills. It**  **also includes**  **the Revocation**  **of the**  **Ninth Amended Findings**  **and Order**  **issued to**  **Flint Hills,**  **effective on**  **the date**  **that EPA**  **approves the**  **SIP revision.**  **The MPCA**  **hereby requests**  **that EPA**  **incorporate in**  **Minnesota's SIP**  **all the**  **conditions cited**  **as "Title**  **I Condition:**  **40 CFR**  **Section 50.4,**  **S02 SIP;**  **Title I**  **Condition: 40**  **CFR pt.**  **52, subp.**  **Y" in**  **Perming No.**  **03700011-012, replacing**  **the current Title**  **I SIP**  **conditions from**  **the Order**  **(approved into Minnesota's**  **SIP on**  **May 15,**  **2013, 78**  **FR 28501).**  **The MPCA**  **also requests**  **that EPA**  **incorporate into**  **Minnesota's SIP**  **all conditions**  **cited as**  **"Title I**  **Condition: SIP**  **for S02**  **NAAQS, 40**  **CFR pt.**  **50" in**  **Permit No.**  **03700015-003, replacing**  **the current**  **Title I**  **SIP conditions**  **in Permit**  **No. 03700015-003**  **(approved into**  **Minnesota's SIP**  **on December**  **5, 2007,**  **72 FR**  **68508). Dr.**  **Susan Hedman** 

**Page 2**  **May 1,**  **2015**

**A full**  **and accurate**  **electronic copy**  **of all**  **the enclosed**  **materials comprising**  **this SIP**  **submittal is**  **also being**  **submitted to**  **EPA staff.**  **Please contact**  **Amanda Jarrett**  **Smith of**  **our staff**  **at 651-757-2486**  **or amanda.smith@state.mn.us**  **if you**  **have any**  **questions regarding**  **Minnesota's SIP.** 

**Sincer�l,y1**

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**Jo Commissioner** 

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**Enclosures**

**cc: Kathleen**  **D' Agostino,**  **EPA Mary**  **Portanova, EPA**  **Mary Jean**  **Fenske, MPCA Amanda**  **Jarrett Smith,**  **MPCA**Background Information for State Implementation Pla n Revision Flint Hills Resources, Rosemount, MN

This document describes the State Implementation Plan (SIP) revision for Flint Hills Resources Pine Bend Re finery, located in the Rosemount/Pine Bend area of the Twin Citi es Sulfur Dioxide (SO 2 ) maintenance area for the three-hour, 24-hour, and annual SO 2 National Ambient Air Quality Standards (NAAQS). Flint Hi lls Resources (FHR) is currently subject to an Administrative Order (Order) containing SO 2 emission limits in order to ensure that the Pine Ben d area continues to maintain the SO 2 NAAQS.

This SIP re vision is being proposed to incorporate specific cha nges to the facility’s operating conditions and to transfer all of the SIP requirements into the federally enforce able Part 70 permit, which serves as a joint Title I/Tit le V document, subsequently terminating the current Order, approved into the SIP on May 15, 2013 (78 FR 28501). The Order, and all the conditions therein, will continue to apply until this SIP revision is approved by the U.S. Environmental Pr otection Agency (EPA).

This SIP revision is be ing submitted in conjunction with a major modification o f the facility’s operating permit (Air Emission Permit No. 03700011-012). The permit and it s technical support document (TSD) provide information on the proposed changes to FHR ’s operations. This document concentrates on the relevant changes to the fac ility’s Title I SIP conditions for SO 2 .
The proposed SIP revision is referred to as “SIP10” because this is the tenth time that the site -specific SIP requirements for FHR have been amended. The currently effective Ad ministrative Order, approved into the SIP in 2013, is ref erred to as “SIP9.”

1. Reasons for Changes to the Site-Specific SIP Re quirements and Placing them in Joint Title I/Title V Document FHR requested changes to its SIP-included Order and its associated facility permit in order to make certain chang es at the FHR facility. The changes to the Order are as follo ws:

· Installation of a new process to convert gas containingsulfur and nitrogen into a stable, non-hazardous, aqueo us liquid fertilizer, ammonium thiosulfate (ATS), which will result in a new SO 2 emission point.

· Changes to the fuel gas sulfur monitoring requiremen ts for the 45 unit mix drum to add direct monitoring o f fuel gas total sulfur as an additional monitoring option to th e current requirement to monitor at a representative stack for sulfur dioxide emissions. Remove historic requirements for monitoring H 2 S.

· Incorporate new, more restrictive language reflecting F HR’s current flaring policy, which clarifies that flaring is only allowed in the event of unplanned and infrequent e vents (i.e., malfunction).

· Assorted updates that serve to clarify the requirements of the Order by removing completed requirements and placeholders.

· Move all SIP requirements from the Order and into the joint Title I/Title V document.

New ATS Process Unit (EU361) The primary reason for this SIP revision involves mod ifications proposed by FHR to meet EPA’s Tier 3 gasoline sulfur standard which becomes effective in 2017. The Tier 3 P rogram will set new vehicle emissions standards and lo wer the sulfur content of gasoline. To accomplish the removal of additional sulfur from gasoline produced at the ref inery, FHR plans to increase the amount of hydrotreating in the 33 and 38 Unit gas-oil hydrotreaters (GOHTs) to remove sul fur from intermediate fuel products. No physical changes are requi red at the GOHTs to accommodate the additional hydrotreating. However, additional sulfur removal via hy drotreating increases the removal of nitrogen, which t axes existing sulfur-management units, including amine systems , the sour water system, and the sulfur-recovery plant

.
FHR proposes to install a process to convert gas containing sulfur and nitrogen into a salable, non-hazardous, aqueo us liquid fertilizer: ammonium thiosulfate. FHR also propo ses to use a more efficient amine solution in the exist ing amine treatment units. FHR plans a sour-water skimmers and tanks i mprovements project to reduce potential process safety risk s. This will improve FHR’s skimming and storage system s for sour water. This project will be funded separatel y and completed independent of the ATS process unit or othe r project-related work.Fuel Gas Sulfur Content Continuous Emissions Monitori ng System As part of the SIP10 action and permit reissuance, an addit ional monitoring option will be added. FHR will be p ermitted to add and maintain a total sulfur continuous emissions mo nitoring system (CEMS) to monitor total sulfur conten t in the 45 unit mix drum fuel gas stream. As part of SIP9, FH R added a CEMS to measure reduced sulfur in the 41 unit mix drum fuel gas stream and a CEMS to measure SO 2 at the 45 unit mix drum. These monitoring systems to gether form a comprehensive monitoring strategy that provides a more robust SO 2 emissions calculation than the current SIPapproved system, which monitors for H 2 S.

The proposed total sulfur CEMS for the 45 unit mix drum will use a technology where the sulfur in the fuel gas is oxidized and measured as SO 2 . The measured SO 2 concentration will provide a basis to calculate SO 2 emissions from the fuel gas fired emission units that are supplied by the 45 uni t mix drum.

In the original SIP Order, hydrogen sulfide (H 2 S) was monitored and used to calculate SO 2 emissions; however, the combination of monitoring approaches approved in SIP9 and proposed in SIP10 will take account of other sulfur compounds beyond H 2 S to provide a more accurate emissions calculation. We a re also requesting the removal from the SIP historic references to monitoring H 2 S, which will be redundant and thus no longer needed once the new monitoring strategy is SIP-approved. H 2 S monitoring will remain in the joint Title I/Title V document, but not as a SIP requirement, since H 2 S monitoring continues to be required in the Title V per mit for compliance demonstration under New Source Performance Standards for petroleum refineries (J and Ja)

.
Note that the proposed changes to the monitoring system are unrelated to the addition of the ATS unit.

Hydrocarbon Flare System We are requesting to update the existing flare language in the SO 2 maintenance SIP to include more restrictive language that is consistent with FHR’s actual operation and management of its hydrocarbon flare systems. The proposed language confirms that the flares are intended only to be used during unplanned and infrequent events (i.e., malfunctions) and that gases resulting from refinery oper ation, including gases from scheduled startups and shutd owns of refinery process units, are not flared except durin g unplanned and infrequent events.

Other Updates Finally, the update generally serves to clarify the req uirements of the SIP by removing references to or p laceholders for requirements that have previously been removed from the Order and by also clarifying or removing completed requirements.

This SIP action proposes to remove Boiler B-10 (EU33 7) from the SIP. Boiler B-10 was added to the SIP as part of SIP8. FHR subsequently decided not to continue with this proj ect and the boiler was never installed.

Incorporation of Title I SIP Conditions into Operatin g Permit In 1997 MPCA and EPA came to an agreement about placing permanent “Title I Con ditions” on sources through the issuance of state and federal permits. Prior to that agree ment, facilities deemed culpable sources for non-attainm ent of the NAAQS operated with requirements imposed on them b oth by State or Part 70 permits and by permanent Orders approved into the SIP and delineating those requirements necessary to obtain the relevant NAAQS in a specific ar ea. MPCA and EPA agreed to streamline these requirements byplacing all SIP conditions in the permit. In the con text of the SIP, the relevant permit acts as a joint Title I/Title V do cument and contains all applicable requirements for each s ource, including SIP requirements.

In order for permit requirements to be eligible forinclusion in the SIP, they had to be permanent. For thi s reason, Minnesota’s permit rule created the term “Title I Condition” as defined in Minn. R. 7007.0100 subp. 25. Item B of this subpart specifically addresses SIPs:

Title I SIP condition definition: (Minn. R. 7007.0100, subp. 25, item B)Any condition based on a source specific determination of ambient impacts imposed for the purpose of

achieving or maintaining attainment with the national ambient air quality standard and which was part of a state implementation plan approved by the EPA or sub mitted to the EPA and pending approval under section 10 of the act.

Any permit term designated in the permit as a Title I Co ndition does not expire, even though other parts of th e Part 70 permit may expire in five years (Minn. R. 7007.1050, subp. 4). Also, as required by Minn. R. 7007.0450, su bp. 2, not only do Title I conditions remain in effect regardless of p ermit expiration, but these conditions must be reinstate d in the reissued permit.

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 i n the SIP in part so that permits issued under the prog ram could be considered federally enforceable vehicles for impo sing emissions limitations on culpable sources located in nonattainment areas.

All conditions necessary for maintaining the NAAQS and in cluded in the SIP are designated in Minnesota’s permits as

“ Title I Condition: 40 CFR Section 50.4, SO2 SIP; Titl e I Condition: 40 CFR pt. 52, subp. Y ,” making it clear that the term is part of the SIP. In SIP submittals, Minnesota requests t hat only those requirements with the term “ Title I Condition: 40 CFR Section 50.4, SO2 SIP; Title I Condition: 40 CFR p t. 52, subp. Y ” be included into the SIP. Consistent with past procedures of revising the SIP when changes were made to the Order, any changes to these “ Title I Condition: 40 CFR Section 50.4, SO2 SIP; Title I Condition: 40 CFR pt. 52, subp. Y ” conditions will require a major permit amendment and a SIP revision, with all the associated EPA review and pub lic participation requirements.

In a letter dated July 3, 1997, EPA found MPCA’s appro ach to issuing permits that contain SIP conditions to be acceptable under both Title I and V of the Clean Air Act. MPCA then began moving SIP conditions into permits as they are opened.

2. Changes to the Permit As noted previously, this SIP revision removes the O rder for FHR and places all applicable requirements in t he joint Title I/Title V document. Therefore, all continuing require ments from the Order are listed in the joint document an d designated “ Title I Condition: 40 CFR Section 50.4, SO2 SIP; Title I Condition: 40 CFR pt. 52, subp. Y .” Attachment 6 is a table which serves to outline where each of the Order’s requirements can be found in the Title I/Title V joint document. Any changes to the language have also been noted in this table. If no change is noted, then the language in the j oint document is identical to that in the Order. A state revo cation of the Order can be found in Attachment 7.

3. Emission Changes Table 1 shows the SO 2 emission changes from SIP9 to SIP10 for each NAAQS averaging time. SIP10 adds a new SO 2
source
–the ATS Process Unit

– however, the overall modeled emissions from the faci lity are reduced from SIP9. This is primarily due to the removal of the Merox unit and the reduction of several generators to insignificant activity (addressed in SIP9). See Attachment 3 for more detail

.
Table 1: Emission Changes for Each Averaging Time

1 Hour SIP Emission Rate 3 Hour SIP Emission Rate 24 Hour SIP Emission Rate Annual SIP Emission Rate (g/s) (lb/hr) (g/s) (lb/hr) (g/s) (lb/hr) (g/s) (lb/hr)
SIP9 152.4568 1209.975 152.3608 1209.213 134.7588 1069.514 108.1188 840.7426
SIP10 143.5938 1139.633 143.4978 1138.871 125.8958 999.173 99.7678 780.524 change -8.863 -70.3413 -8.863 -70.3413 -8.863 -70.3413 -8.351 -60.2185 % change -6% -6% -6% -6% -7% -7% -8% -7%4. Modeling Data The tables below show the ambient SO 2 concentrations predicted by AERMOD (v14134) modeling . These results include both FHR and nearby sources. The SIP10 modeled NAAQS r esults summarized in Table 2 demonstrate that the propose d updates to the facility do not cause an exceedance of the m odeled SO 2 standards.

Table 2: SO 2SIP10 Modeling Results Summary Pollutant Avg. Period NAAQS (ug/m 3 ) Total Modeled Conc. (ug/m 3 )

(Includes background & nearby sources) Percent of Standard (%)

SO 2 3-hr 1300 539 41.5%

24-hr 365 177 48.5% Annual 80 22 27.5%

Though this maintenance plan SIP revision addresses the 3-hour, 24-hour, and annual SO 2 standards, section 110(l) of the CAA requires that a SIP revision not interfere with any applicable requirement concerning attainment or any oth er applicable requirement of the Act. For this reason, th e SIP must also demonstrate that the proposed actions do not interfere with the 1-hour SO 2 NAAQS, even though the area has not yet been designate d under this standard. As agreed upon with the EPA, the 2010 1-hour primary NAAQS is add ressed by a demonstration that the 1-hour Significant Imp act Level (SIL) is met with Permit 03700011-012. Table 3 shows the 1 hour high 1 sthigh SO 2 project-only modeled results compared to the 1 hour SO 2 SIL. The emissions increases resulting from the Tie r 3 project are less than the SIL, demonstrating that its impacts are insignificant.

Table 3: Tier 3 Clean Fuels Project SO 2SIL Modeling Results Summary Pollutant Avg. Period SIL (ug/m 3 ) Total Modeled Conc. (ug/m 3 ) Percent of Standard (%) SO 2 1-hr 7.83 (SIL) 4.63 59.1%

In addition, Table 4shows the most recent quality-assur ed ambient air monitoring data from the four monitors loc ated around the FHR site. This data shows attainment of all the current SO2 NAAQS, including the 1-hour standard.

Table 4: SO 2Monitoring Data around the FHR Facility
Monitor FHR 420 FHR 423 FHR 442 FHR 443

Standard Years Design

Value Percent of Standard Design

Value Percent

of Standard Design

Value Percent of

Standard Design

Value Percent of

Standard
1-hour (75ppb) 2011

-

2013 14 19% 8 11% 3 4% 2 3%
24-hour (140 ppb) 2013 4 3% 3 2% 1 1% 1 1% 3-hour (500ppb) 2013 10.0 2% 5.6 1% 21.3 4% 2.0 0% Annual (30ppb) 2013 0.7 2% 0.6 2% 0.6 2% 0.4 1%

The combination of monitoring and the SIL analysis indicate s that the emissions increases from the Tier 3 project will not jeopardize continued attainment of the NAAQS.Attachments Attachment 1: Air Emission Permit No. 03700011-012, Issu ed to FHR, Including Modeling Exhibit Attachment 2: Technical Support Document for Related Permit A ction Attachment 3: Air Quality Dispersion Modeling Reports (AQ DM-06 and AQDM-07) Attachment 4: Markup Version of Air Emission Permit No. 0 3700011-012 Attachment 5: Markup Version of Current SIP-Approved Adm inistrative Order Attachment 6: Table of Administrative Order Requirements’ New Locations in Air Emission Permit No. 03700011-01 2 Attachment 7: Administrative Order Revocation Attachment 8: Public Notice Attachment 9: Completeness Review

This summary was prepared by Amanda Jarrett Smith, Environmental Analysis and Outcomes Division of the MPCA.Background Information for SIP Revision Xcel Energy, Inver Hills Facility, Saint Paul, Minne sota

This document describes the State Implementation Plan (SIP) revision for Northern States Power Company’s Xcel Energy

– Inver Hills Generating Plant (Inver Hills), located in the Rosemount/Pine Bend area of the Twin Cities Sulf ur Dioxide (SO 2 ) maintenance area for the three-hour, 24-hour, and annual SO 2 National Ambient Air Quality Standards (NAAQS). Inver Hills is subject to a joint Title I/Title V docume nt containing SO 2 emission limits in order to ensure that the Pine Bend area continues to maintain the SO 2 NAAQS.

This SIP revision is being proposed in conjunction w ith the reissuance of a Title V/Part 70 total facilit y operating permit (Air Emission Permit No. 03700015-004). The permit a nd its technical support document (TSD) provide inform ation on the proposed minor changes to Inver Hills’ operations , none of which are SIP-applicable. This document concen trates on the changes to the permit that are releva nt to the facility’s Title I SIP conditions for SO 2 .
The proposed SIP revision is referred to as “SIP 3 ” because this is the third time that the site-specific SIP requirements for Inver Hills have been amended , including Inver Hills’ initial inclusion in t he SIP. The currently effective joint Title I/Title V d ocument, approved into the SIP on December 5, 2007, is referred to as “SIP2.”

1. Reasons for changes to the applicable condition s in the Title I/Title V document Inver Hills has requested the following changes to i ts SIP-included joint Title I/Title V document:

· Residual fuel oil has been removed as an allowable fuel ty pe in accordance with the revised SIP

· Removed SIP limits that were terminated on the date the EPA approved the revision to SIP2

There are no SIP-relevant construction changes being mad e to the facility and therefore this proposed SIP rev ision does not authorize any new operations or emission units.

Sulfur content of fuel and compliance demonstration The maximum sulfur content of the fuel that is now prov ided to Inver Hills from its supplier is .0015 perc ent by weight. The facility has requested that this be reflected in its j oint Title I/Title V document. Method A and B of demon strating compliance with this new, lower standard will also be upd ated to reflect the change.

Language removal Permit No. 03700015-003 included SIP-applicable change s to allowable fuel sulfur content. These changes were approved by EPA on December 5, 2007 as part of SIP2. R eferences to terminated limits and transitional language ar e to be removed from the SIP.

2. Changes to the Permit

Sulfur content of fuel and compliance demonstration Permit 03700015-004 will require a lower sulfur conte nt in liquid fuel used at Inver Hills. GP 001 Electr ic Generating Combustion Turbines is being modified to require a s ulfur content of less than or equal to .005 percent byweight for all fuels. Language is included to indicate that the old lim it of .48 percent by weight will be terminated and th e new limit of .005 percent by weight will become effective upon E PA approval of SIP3.

GP 001 is also being modified to update the compliance d emonstration necessary for the lower sulfur standard. Me thod A will be changed from .48 percent by weight to .005 percent by weight and Method B will be changed from .10 percent by weight to .0015 percent by weight. Inver Hills h as a guarantee from its fuel supplier, Flint Hills Resou rces, to provide fuel oil containing no more than .0015 percent sulfur b y weight. Language is included to indicate that the old me thods will be terminated and the new methods will become effe ctive upon EPA approval of SIP3.Language removal Permit No. 03700015-003 included SIP-applicable change s to allowable fuel sulfur content. This SIP action (SI P3) removes the limits that were terminated upon the approval of that SIP revision (SIP2) on December 5, 2007. It also removes language stating that the new conditions would be come effective on the date of approval of SIP2. Relevant conditions can be found in Subject Item GP 001 Electric Generating Combustion Turbines of Permit 03700015-00 3.

3. Modeling and NAAQS Attainment Because the revision to the SIP conditions simply red uces the allowable sulfur content of liquid fuels used at Inver Hills, air dispersion modeling was not conducted.

Modeled attainment of the area with the SO 2 NAAQS continues to be demonstrated. Included in the s ame EPA submittal is a SIP modification (SIP10) for Flint Hills Resources (FHR), which is also included in the Pine Be nd Maintenance Area. The SO 2 levels modeled in the FHR SIP10 submittal are included in Table 1. This modeling includes nearby sources, of which Inver Hills is one.

Table 1: SO 2Modeling Results Summary for FHR SIP10 Pollutant Avg. Period NAAQS (ug/m 3 ) Total Modeled Conc. (ug/m 3 )

(Includes background & nearby sources) Percent of Standard (%)

SO 2 3-hr 1300 539 41.5%

24-hr 365 177 48.5% Annual 80 22 27.5%

For more detail, see the FHR SIP modification and related attachments. Because this SIP revision reduces the allow able sulfur content of liquid fuels used at Inver Hills, this SIP modification will not jeopardize continued attain ment of the NAAQS.

Attachments Attachment 1: Permit No. 03700015-004 issued to Inver Hi lls (SIP3 relevant) and related technical support docum ent Attachment 2: Permit No. 03700015-003 issued to Inver Hi lls (SIP2 relevant) Attachment 3: Permit No. 03700015-003 red-line version Attachment 4: Public Notice Attachment 5: Completeness Review