air emission permit no. 16100033-001 is issued to

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

AIR EMISSION PERMIT NO. 16100033-001

IS ISSUED TO

Simon Industries

Simon Entergy LLC - Waterville Facility Highway 13 & 270th Street West

Waseca, Waseca County, MN 56093 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit May 16, 2002 This permit authorizes the permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70 with Limits to Avoid NSR Construction and Operation Issue Date: October 3, 2002 Operating Conditions Issue Date: November 26, 2002 Expiration: Title I Conditions do not expire. Ann M. Foss

Major Facilities Section Manager Majors and Remediation Division

for Karen A. Studders Commissioner Minnesota Pollution Control Agency

Air Emission Permit No. 16100033-001

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule – not used in this permit Appendices: Attached and Referenced in Table A


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: This permit authorizes construction and operation of a facility composed of a natural gas-fired combustion turbine generator, a heat recovery steam generator (HRSG) with duct burner, a steam turbine generator, a gas-fired auxiliary boiler, and a diesel-fired starting engine. The turbine will be able to operate in simple cycle (without the HRSG), or in combined cycle with the HRSG. The turbine will be equipped with inlet cooling to maximize electrical production during warm weather. Net electrical production capacity in simple cycle operation is 26.6 megawatts, and in combined cycle operation is 46 megawatts. The HRSG will also contain a selective catalytic reduction unit for control of nitrogen oxides control, and an oxidation catalyst for control of carbon monoxide.


This source is an affected source subject to the acid rain program, and therefore is required to obtain a part 70 permit. This source is a fossil fuel-fired steam electric plant with greater than 250 mmBtu/hour heat input, which is one of the listed source categories in 40 CFR § 52.21(b)(1)(i)(a). However, the permit contains requirements that limit emissions to less than the major source level under § 52.21.

TABLE A: LIMITS AND OTHER REQUIREMENTS 11/26/02

Simon Entergy LLC - Waterville Facility

16100033 - 001

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake 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 facilityrequirements.

Subject Item: Total Facility

What to do Why to do itOPERATIONAL REQUIREMENTS hdr

No owner or operator shall build, erect, install, or use any article, machine,equipment or process, the use of which conceals an emission which wouldotherwise constitute a violation of an applicable standard.

40 CFR Section 60.12

This facility is subject to U.S. EPA's Acid Rain Program codified at 40 CFR parts72, 73, 75, 77, and 78. Certain Acid Rain Program requirements are included inTables A and/or B of this permit for MPCA tracking purposes. All other Acid RainProgram requirements are referenced in the Phase II Permit Application attached tothis permit in Appendix 1.

40 CFR Section 72.6(a)(3)

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

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and shall include a preventativemaintenance program for that equipment, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipment toproper operation to meet applicable permit conditions, a description of theemployee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. 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 orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Limits set as a result of a performance test apply until superseded as specified byMinn. R. 7017.2025 following formal review of a subsequent performance test onthe same unit.

Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A or B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

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16100033 - 001

Facility Name:

Permit Number:

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

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

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain a file of all measurements, maintenance, reports andrecords for at least five years.

40 CFR Section 60.7(f); Minn. R. 7019.0100, subp. 1

Recordkeeping: Maintain records of the occurrence and duration of any startup,shutdown, or malfunction in the operation of the facility including any malfunction ofthe air pollution control equipment, or any period during which a continuousmonitoring system or monitoring device is inoperative.

40 CFR Section 60.7(b), Minn. R. 7019.0100, subp. 1

REPORTING/SUBMITTALS hdr

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

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired 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 operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman 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 anydeviation from permit conditions which could endanger human health or theenvironment. 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

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

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). Submit the Report on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

Notification of Any Physical or Operational Change Which Increases Emission Rateof Pollutant to Which a Standard Applies: due 60 days (or as soon as practical)before the change is commenced, in accordance with the requirements in 40 CFRSection 60.7(a)(4).

40 CFR Section 60.7(a)(4); Minn. R. 7019.0100, subp.1

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16100033 - 001

Facility Name:

Permit Number:

Subject Item: EU 001 Combustion Turbine

Associated Items: CE 001 Steam or Water Injection

CE 002 Catalytic Afterburner

CE 003 Catalytic Reduction

SV 001 Combustion Turbine - Simple Cycle Operation (26.6 MW; CE 001)

SV 002 Combustion Turbine - Combined Cycle Operation (46 MW; CE 002/CE 003)

What to do Why to do itEMISSION AND OPERATIONAL LIMITS hdr

Nitrogen Oxides: less than or equal to 95.7 tons/year using 12-month Rolling Sumtotal NOx emissions from simple and combined cycle operation of EU 001.

Title I Condition: To limit NOx emissions to less thanthe major source level under 40 CFR Section 52.21

Nitrogen Oxides: less than or equal to 109 parts per million using 3-hour Average 40 CFR Section 60.332(a)(1)

Carbon Monoxide: less than or equal to 21.2 lbs/hour when EU 001 is operating insimple cycle mode or combined cycle mode. During combined cycle operation, thislimit applies to the total emissions from EU 001 and EU 004 (heat recovery steamgenerator duct burner). This limit is on a 3-hr basis without a CO CEM. When COemissions are measured by a CEM, this limit is on a 30 day rolling average.

Note: EU 001 and EU 004 vent through SV 002 when EU 001 operates incombined cycle.

Title I Condition: To limit CO emissions to less thanthe major source level under 40 CFR Section 52.21

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained. This applies individually to SV 001 and SV 002.

Minn. R. 7011.2300, subp. 1

Simple Cycle Operating Hours: less than or equal to 830 hours/year using12-month Rolling Sum

Title I Condition: To avoid major source status under40 CFR Section 52.21

Permitted Fuel: Pipeline natural gas only as defined in 40 CFR Section 72.2. Minn. R. 7007.0800, subp. 2; meets requirements of40 CFR Section 60.333(b) and Minn. R. 7011.2300,subp. 2

CONTROL EQUIPMENT REQUIREMENTS hdr

Water (Steam) Injection Operation: The Permittee shall operate and maintain thewater injection system at all times during EU 001 simple cycle operation, except asallowed by 40 CFR Section 60.332(f).

Minn. R. 7007.0800, subp. 14; 40 CFR Section60.332(f)

The Permittee shall operate and maintain CE 002 AND CE 003 at all times that EU001 is operating in combined cycle. The control equipment shall be operated andmaintained according to the Operation and Maintenance Plan.

Title I Condition: To avoid major source status under40 CFR Section 52.21; Minn. R. 7007.0800, subp. 14

CE 002 Operating Parameters:

When EU 001 operates in combined cycle mode and CO emissions are notmeasured by a CEM, CE 002 shall be operated as follows:

Flue Gas Temperature: not less than 500 F and not greater than 700 F.Flue Gas Oxygen Content: not less than 12% by volume and not greater than 17%by volume


CE 003 Operating Parameters:

When EU 001 operates in combined cycle mode and NOx emissions are notmeasured by a NOx CEM, CE 003 shall be operated as follows:

Ammonia to Flue Gas Ratio: The ratio of the ammonia injection rate to flue gasflow rate shall be maintained within 10% of the ratio determined for each testedoperating level during the Part 75 Appendix E NOx performance testing. Inaddition, the Permittee shall use linear interpolation to determine the appropriateratio of ammonia injection rate and flue gas flow rate between each testedoperating level, and shall operate CE 003 within 10% of any such interpolated ratio.


MONITORING hdr

Acid Rain Program Monitoring Plan: Prepare and maintain a Monitoring Plan. Asrequired by 40 CFR Part 75, Appendix D, Section 2.3.1.4, the Plan must includeinformation demonstrating that the natural gas combusted by the facility meets thedefinition of pipeline natural gas in Section 72.2.

Whenever the owner or operator makes a replacement, modification, or change tothe monitoring methods as described in 40 CFR Section 75.53(b), the owner oroperator shall update the monitoring plan.

40 CFR Section 75.53(a)(2); 40 CFR Part 75,Sppendix D, Section 2.3.1.4

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16100033 - 001

Facility Name:

Permit Number:

Monitoring - Sulfur Dioxide Emissions: The Permittee shall follow the requirementsin 40 CFR Part 75, Appendix D, Section 2.3.1, to determine hourly, daily, quarterly,and annual EU 001 sulfur dioxide emissions. To meet the requirements of 40 CFRSection 60.334(b), the Permittee shall follow the requirements of part 75, AppendixD, sections 2.3.1.1 and 2.3.1.4(1).

40 CFR Section 75.10, 40 CFR Part 75, Appendix D,Section 2.3.1; meets requirements of 40 CFR Section60.334(b)

Monitoring - Nitrogen Oxides Emissions (lb/mmBtu): The Permittee shall follow therequirements of 40 CFR Part 75, Appendix E, to determine hourly, quarterly, andannual average EU 001 nitrogen oxide emissions, except as follows:

If EU 001 total (simple and combined cycle) operating hours exceed the operatinglevels described under the Section 72.2 peaking unit definition, the Permittee shallinstall, operate, and maintain a NOx CEM on each stack/vent that vents emissionsfrom EU 001, according to the timeline described in 40 CFR part 75 Appendix ESection 1.1. The CEM shall meet the applicable requirements of 40 CFR Section75.10.

Appendix E provides procedures to determine NOx emissions in lb/mmBtu, basedon calculation and fuel input measurement after testing the gas turbine at aminimum of 4 operating load points, and development of a predictive NOxemissions graph.

40 CFR Section 75.10, 40 CFR Part 75, Appendix E

Monitoring - Nitrogen Oxides Emissions (pounds/hour): Once each hour thePermittee shall calculate and record the hourly NOx emissions for the previoushour, in pounds per hour, when EU 001 is operating. Once each day, the Permitteeshall calculate and record the daily NOx emissions for the previous day, in tons perday, using the hourly NOx emissions.

The Permittee shall follow the requirements of 40 CFR Part 75.10, to determine todetermine the hourly lb/mmBtu NOx emission rate and hourly heat input. ThePermittee shall use the hourly heat input and lb/mmBtu NOx emission rate data todetermine hourly lb/hr NOx emission rates.

Title I Condition: To limit NOx emissions to less thanthe major source level under 40 CFR Section 52.21;Minn. R. 7007.0800, subp. 4 and 5

Monitoring - Nitrogen Oxides Emissions:

The Permittee may install a NOx CEM at the initial startup of combined cycleoperation while operating as a peaking unit, in lieu of monitoring CE 003 ammoniainjection rate and flue gas flow rate, and determining the injection to flow ratio.

Minn. R. 7007.0800, subp. 2

Monitoring - Selective Catalytic Reduction CE 003:

During the part 75 Appendix E testing for developing the predictive NOx emissionsgraph, the Permittee shall measure the CE 003 ammonia injection rate andassociated flue gas flow rate and determine the injection rate to flow rate ratio, foreach tested operating level. This data shall be included in the NOx test reportsubmittal.

Minn. R. 7007.0800, subp. 2

Monitoring - NOx Emissions From Simple Cycle Operation Without Water Injection:If the Permittee operates EU 001 without water injection and a NOx CEM is notused to measure NOx emissions, all NOx emissions calculations for simple cycleoperating periods without water injection shall be made using the most currentAP-42 NOx emission factor for an uncontrolled natural gas-fired gas combustionturbine, to calculate the lb/hr and lb/mmBtu NOx emission rates.

Minn. R. 7007.0800, subp. 2

Monitoring - Carbon Monoxide Emissions: If EU 001 total (simple and combinedcycle) operating hours exceed the operating levels described under the peakingunit definition in Section 72.2, the Permittee shall install, operate, and maintain aCO CEM on each stack/vent that will vent emissions from EU 001.

The CO CEM installation, certification, operation, and maintenance shall meet allapplicable requirements of Minn. Rules chapter 7017. The CO CEM installationshall follow the NOx CEM installation timeline described in 40 CFR part 75Appendix E Section 1.1, after the EU 001 no longer meets the definition of apeaking unit.]

The CO CEM shall be capable of measuring and recording CO emissions on apounds per hour basis, and tons per calendar month basis.

The Permittee may install a CO CEM at the initial startup of combined cycleoperation while operating as a peaking unit, in lieu of conducting CE 002 catalysttemperature and flue gas oxygen content monitoring.

Title I Condition: To limit CO emissions to less thanthe major source level under 40 CFR Section 52.21;Minn. R. 7007.0800, subp. 4 and 5; Minn. R.7017.1006

Monitoring - Carbon Dioxide Emissions: Determine daily, quarterly, and annualcarbon dioxide (CO2) emissions, in tons, in accordance with 40 CFR part 75,Appendix G. Appendix G allows determination of CO2 emissions based on themeasured carbon content of the fuel, and the quantity of fuel combusted.

40 CFR Section 75.13(b)

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16100033 - 001

Facility Name:

Permit Number:

Monitoring - Fuel Consumption and Water (Steam) to Fuel Ratio: The Permitteeshall install and operate a continuous monitoring system to monitor and record thefuel consumption and the ratio of water to fuel being fired in EU 001 during simplecycle operation. The system shall be accurate to within +/- 5 percent and shall beapproved by the Administrator. (Note that Section 75.10(c) requires determinationand recording of heat input based on fuel usage to this gas turbine for every hourthat any fuel is combusted, regardless of mode of operation.)

40 CFR Section 60.334(a)

EU 001 Simple Cycle Operating Hours Monitoring: By the end of each day that theEU 001 gas turbine operates in simple cycle, the Permittee shall calculate andrecord the simple cycle operating hours for that day.

If the Permittee operates EU 001 without water injection as allowed by 40 CFRSection 60.332(f), the operating hours record shall indicate the start and stop timesof such operation.

Minn. R. 7007.0800, subp. 4

Fuel Sulfur Content Monitoring: Monitor the sulfur content of natural gascombusted in EU 001. Natural gas nitrogen content monitoring is not required asprovided for by an August 14, 1987, EPA memorandum from John B. Rasnic titled"Authority for Approval of Custom Fuel Monitoring Schedules under NSPS SubpartGG". The Permittee may use the procedures in 40 CFR Part 75, Appendix D,Section 2.3.1.1 and 2.3.1.4(1), as a a custom fuel monitoring schedule to determinesulfur dioxide emissions, instead of the requirements in Section 60.334(b).


CE 002 Temperature Monitoring: When CO is not measured by a CEM, thePermittee shall install, operate, and maintain an automatic temperature recorder tomeasure and record catalyst bed temperature, when EU 001 operates in combinedcycle.


CE 002 Corrective Actions: When CO is not measured by a CEM, if the CE 002temperature is below the minimum specified by this permit or if the catalytic oxidizeror any of its components are found during the inspections to need repair, thePermittee shall take corrective action as soon as possible. Corrective actions shallreturn the temperature to at least the permitted minimum and/or include completionof necessary repairs identified during the inspection, as applicable. Correctiveactions include, but are not limited to, those outlined in the O & M Plan for thecatalytic oxidizer. The Permittee shall keep a record of the type and date of anycorrective action taken

Minn. R. 7007.0800, subp. 4 and 5

CE 002 Daily Monitoring: When CO is not measured by a CEM, the Permittee shallphysically check the CE 002 temperature recording device at least once eachoperating day to verify that it is working and recording properly.

Minn. R. 7007.0800, subp. 4 and 5

CE 002 Monthly Monitoring: When CO is not measured by a CEM, at least onceeach month during normal operation, the Permittee shall record the temperaturerise across the CE 002 catalyst (outlet temperature - inlet temperature) while EU001 and EU 004 are operating. If it is determined that the catalyst reactivity hasbeen impaired, by comparison of the observed temperature rise to the pasttemperature rise records, the Permittee shall follow the corrective actions in theOperation and Maintenance Plan. The Permittee shall maintain written records ofthe monitoring and any corrective actions taken.

Minn. R. 7007.0800, subp. 4, 5, and 14

CE 002 Quarterly Inspections: When CO is not measured by a CEM, at least onceper calendar quarter, or more frequently if required by the manufacturerspecifications, the Permittee shall inspect the CE 002 catalytic oxidizer internal andexternal system components, including but not limited to the refractory, heatexchanger, and electrical systems. The Permittee shall maintain a written record ofthe inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 4 and 5

CE 002 Annual Calibration: When CO is not measured by a CEM, the Permitteeshall calibrate the CE 002 temperature monitor at least annually and shall maintaina written record of the calibration and any corrective action resulting from thecalibration.

Minn. R. 7007.0800, subp. 4 and 5

Sample Analysis: due before end of each 24 months following EquipmentInstallation, if the Permittee does not install and operate a CO CEM. The Permitteeshall send a representative sample of the catalyst from CE 002, to a laboratory totest the catalyst's destruction efficiency at 24-month intervals following CE 002installation. If test results show a destruction efficiency of less than 95%, thePermittee shall follow the corrective actions contained in the Operation andMaintenance Plan.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21;Minn. R. 7007.0800, subps. 4, 5, and 14

CE 003 Ammonia Injection Rate Monitoring: When NOx is not measured by aCEM, the Permittee shall install, operate, and maintain a monitor to continuouslyrecord the ammonia injection rate to CE 003, when EU 001 operates in combinedcycle.


CE 003 Flue Gas Flow Rate Monitoring: When NOx is not measured by a CEM,the Permittee shall install, operate, and maintain a monitor to continuously recordthe flue gas flow rate through CE 003, when EU 001 operates in combined cycle.


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16100033 - 001

Facility Name:

Permit Number:

CE 003 Monitoring - Ammonia Injection Rate to Flue Gas Flow Rate Ratio: WhenNOx is not measured by a CEM, the Permittee calculate and record the CE 003ammonia injection rate to flue gas flow rate ratio once every 15 minutes, when EU001 operates in combined cycle.

Minn. R. 7007.0800, subp. 4

CE 003 Corrective Actions: When NOx is not measured by a CEM, if the CE 003ammonia injection rate to flue gas flow rate ratio is outside the range allowed bythis permit, or if any of its components are found during the inspections to needrepair, the Permittee shall take corrective action as soon as possible. Correctiveactions shall return the ratio to within the permitted range and/or include completionof necessary repairs identified during the inspection, as applicable. Correctiveactions include, but are not limited to, those outlined in the O & M Plan for theselective catalytic reduction unit. The Permittee shall keep a record of the type anddate of any corrective action taken

Minn. R. 7007.0800, subp. 4 and 5

CE 003 Daily Monitoring: When NOx is not measured by a CEM, the Permitteeshall physically check the CE 003 ammonia injection rate and flue gas flow raterecording devices at least once each operating day to verify that they are workingand recording properly.

Minn. R. 7007.0800, subp. 4 and 5

CE 003 Quarterly Inspections: When NOx is not measured by a CEM, at leastonce per calendar quarter, or more frequently if required by the manufacturerspecifications, the Permittee shall inspect the CE 003 selectic catalytic reductionunit internal and external system components. The Permittee shall maintain awritten record of the inspection and any corrective actions taken resulting from theinspection.

Minn. R. 7007.0800, subp. 4 and 5

CE 003 Annual Calibration: When NOx is not measured by a CEM, the Permitteeshall calibrate the CE 003 ammonia injection and flue gas flow rate monitors atleast annually and shall maintain a written record the calibrations and anycorrective action resulting from the calibrations.

Minn. R. 7007.0800, subp. 4 and 5

RECORDKEEPING hdr

Recordkeeping - EU 001 Gas Turbine Simple Cycle Operating Hours: By the lastday of each month, the Permittee shall calculate and record the following:

1. the total EU 001 simple cycle operating hours during the previous month;

2. the total EU 001 simple cycle operating hours during the previous 12-monthperiod, by summing the monthly EU 001 simple cycle operating hours for the past12 months.


Recordkeeping - NOx Emissions: By the last day of each month, the Permitteeshall calculate and record:

1. Monthly NOx emissions in tons, for the previous month, using the daily NOxemissions data;2. 12-month rolling sum NOx emissions by summing the monthly NOx emissionsdata for the previous 12 months.


NOx CONTINUOUS EMISSION MONITORING REQUIREMENTS hdr

NOx CEM Installation: the Permittee shall install and certify a continuous NOxemission monitoring system, on each EU 001 stack/vent, no later than Decmeber31 of the following calendar year after EU 001 operation exceeds the 'Peaking Unit'operating levels defined in 40 CFR Section 72.2. The NOx CEM(s) shall beinstalled in the proper location as described in Minn. R. 7017.1040, subp. 2.

40 CFR Appendix E, Section 1.1; Minn. R. 7017.1040,subp. 2

NOx CEM Installation Notification: due 60 days before installing a continuousemissions monitoring system.

Minn. R. 7017.1040, subp. 1

NOx CEMS Certification Test: due in accordance with 40 CFR Section 75.4(b).Certify all CEMS required by the Acid Rain Program in accordance with 40 CFR pt.75, Appendix A.


NOx CEMS Certification Test Plan: due 45 days before each CEMS CertificationTest

40 CFR Section 75.62; 40 CFR Section 75.20; Minn.R. 7017.1060, subps. 1 & 2

NOx CEMS Certification Test Pretest Meeting: due 7 days before each CEMSCertification Test.

Minn. R. 7017.1060, subp. 3

NOx CEMS Certification Test Report: due 30 days after each CEMS CertificationTest.

40 CFR Section 75.63; Minn. R. 7017.1080, subp. 1

NOx CEMS Certification Test Report - Microfiche Copy: due 105 days after eachCEMS Certification Test.

Minn. R. 7017.1080, subp. 3

NOx CEMS QA/QC: The owner or operator of an affected facility shall operate,calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFRpt. 75, Appendix B as amended.


NOx CEMS Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMSrequired by the Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B.

40 CFR pt. 75, Appendix B, section 2.1

A-6



16100033 - 001

Facility Name:

Permit Number:

NOx CEMS Linearity and Leak Check Test (Acid Rain Program): due before end ofeach QA operating quarter (as defined in Section 72.2) in accordance withprocedures in part 75 Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A,Section 6.2.

Perform a leak check at least once during each QA operating quarter (calendarquarter in which there are at least 168 unit operating hours) and no less than 30days apart.

40 CFR pt. 75, Appendix A, section 6.2 and AppendixB, sections 2.2.1 and 2.2.2; Minn. R. 7017.1020

NOx CEMS Relative Accuracy Test Audit (RATA): due before end of eachcalendar half-year following CEM Certification Test, i.e., once every two successiveQA operating quarters (calendar quarter in which there are at least 168 unitoperating hours). Conduct a RATA on all CEMS required by the Acid RainProgram, in accordance with 40 CFR pt. 75, Appendix B. Relative accuracy testaudits may be performed annually (once every four successive QA operatingquarters, rather than once every two successive QA operating quarters) if any ofthe conditions listed in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) throughSection 2.3.1.2(i) are met.

40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R.7017.1020

NOx CEMS Relative Accuracy Test Audit (RATA) Notification: due 30 days beforeCEMS Relative Accuracy Test Audit (RATA)).

Minn. R. 7017.1180, subp. 2

NOx CEMS Relative Accuracy Test Audit (RATA) Results Summary: due 30 daysafter end of each calender quarter in which the CEMS RATA was conducted.

Minn. R. 7017.1180, subp. 3

NOx CEMS Linearity Test Results Summary: due 30 days after end of eachcalendar quarter following Linearity and Leak Check Test if performed.

Minn. R. 7017.1180, subp. 4

NOx Emissions Monitoring: The owner or operator shall use a CEMS to measureNOx emissions and flow rate for each affected unit in accordance with 40 CFRSection 75.10.


NOx CEMS Recordkeeping: The owner or operator must retain records of all NOxCEMS monitoring data and support information for a period of five years from thedate of the monitoring sample, measurement or report. Records shall be kept atthe source.

Minn. R. 7017.1130; 40 CFR Section 75.50

CO CONTINUOUS EMISSION MONITORING REQUIREMENTS hdr

CO CEMS QA Plan: Develop and implement a written quality assurance plan thatcovers each CO CEMS. The plan shall be on site and available for inspectionwithin 30 days after monitor certification. The plan shall contain all of theinformation required by 40 CFR part 60, Appendix F, section 3.

Minn. R. 7017.1170, subp. 2

CO CEM Installation: the Permittee shall install and certify a continuous COemission monitoring system, on each EU 001 stack/vent, no later than Decmeber31 of the following calendar year after EU 001 operation exceeds the 'Peaking Unit'operating levels defined in 40 CFR Section 72.2. The CO CEM(s) installation shallmeet the applicable requirements of Minn. R. ch. 7017.

Minn. R. 7017.1006

CO CEM Installation Notification: due 60 days before installing a continuousemissions monitoring system.

Minn. R. 7017.1040, subp. 1

CO CEMS Certification Test: due within 90 days after the due date of the firstexcess emissions report required for the CEMS. Follow the PerformanceSpecifications listed in 40 CFR pt. 60, Appendix B.

Minn. R. 7017.1050, subp. 1

CO CEMS Certification Test Pretest Meeting: due 7 days before each CEMSCertification Test.

Minn. R. 7017.1060, subp. 3

CO CEMS Certification Test Report: due 45 days after CEMS Certification Test Minn. R. 7017.1080, subp. 1, 2, & 4

CO CEMS Certification Test Report - Microfiche Copy: due 105 days after eachCEMS Certification Test.

Minn. R. 7017.1080, subp. 3

CO CEMS Daily Calibration Drift (CD) Test: the CD shall be quantified andrecorded at zero (low-level) and upscale (high-level) gas concentrations at leastonce daily. The CEMS shall be adjusted whenever the CD exceeds twice thespecification of 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall beused to determine out-of-control periods for CEMS. Follow the procedures in 40CFR pt. 60, Appendix F.

Minn. R. 7017.1170, subp. 3

CO CEMS Certification Test Plan: due 45 days before each CEMS CertificationTest

75.20; Minn. R. 7017.1060, subps. 1 & 2

CO CEMS Certification Test Report: due 30 days after each CEMS CertificationTest.

Minn. R. 7017.1080, subp. 1

CO CEMS Cylinder Gas Audit (CGA): due before end of each calendar half-yearfollowing CEMS Certification Test. Conduct CGA at least 3 months apart and notgreater than 8 months apart. Follow the procedures in 40 CFR pt. 60, Appendix F.

Minn. R. 7017.1170, subp. 4

CO CEMS Cylinder Gas Audit (CGA) Results Summary: due 30 days after end ofeach calendar half-year following Cylinder Gas Audit (CGA)

Minn. R. 7017.1180, subp. 1

CO CEMS Relative Accuracy Test Audit (RATA): due before end of each calendaryear following CEMS Certification Test. If the relative accuracy is 15% or less thenext CEMS RATA is not due for 24 months. Follow the procedures in 40 CFR pt.60, Appendix B and Appendix F.

Minn. R. 7017.1170, subp. 5

A-7



16100033 - 001

Facility Name:

Permit Number:

CO CEMS Relative Accuracy Test Audit (RATA) Notification: due 30 days beforeCEMS Relative Accuracy Test Audit (RATA).

Minn. R. 7017.1180, subp. 2

CO CEMS Relative Accuracy Test Audit (RATA) Results Summary: due 30 daysafter end of each calender quarter in which the CEMS RATA was conducted.

Minn. R. 7017.1180, subp. 3

CO CEMS Recordkeeping: The owner or operator must retain records of all COCEMS monitoring data and support information for a period of five years from thedate of the monitoring sample, measurement or report. Records shall be kept atthe source.

Minn. R. 7007.1130

CEMS Continuous Operation: CEMS must be operated and data recorded duringall periods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A CEMS must not be bypassed except in emergencies where failure tobypass 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.

Minn. R. 7017.1090, subp. 1

PERFORMANCE TESTING hdr

Initial Performance Test: due 180 days after Initial Startup of simple cycleoperation, but no later than 60 days after achieving maximum production rate, tomeasure NOx and SO2 emissions from SV 001. Testing shall be conductedaccording to the requirements in 40 CFR Section 60.335. The NOx testingrequired by 40 CFR part 75 Appendix E at maximum operating load, may be usedfor meeting the NOx testing requirement in 40 CFR Section 60.335(c).

Title I Condition: To limit NOx emissions to less thanthe major source level under 40 CFR Section 52.21; 40CFR Section 60.8(a); Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup in combined cycleoperation but no later than 60 days after achieving maximum production rate, tomeasure NOx and SO2 emissions from SV 002. Testing for NOx and SO2 shall beconducted according to the requirements in 40 CFR Section 60.335. The NOxtesting required by 40 CFR part 75 Appendix E at maximum operating load, may beused for meeting the NOx testing requirement in 40 CFR Section 60.335(c).

Both EU 001 and EU 004 shall be operating during these tests.

Title I Condition: To limit NOx emissions to less thanthe major source level under 40 CFR Section 52.21; 40CFR Section 60.8(a); Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup in combined cycleoperation but no later than 60 days after achieving maximum production rate, tomeasure CO emissions from SV 002.

Both EU 001 and EU 004 shall be operating during this test.

Title I Condition: To limit CO emissions to less thanthe major source level under 40 CFR Section 52.21;Minn. R. 7017.2020, subp. 1

General Performance Test Requirements:

Performance Test Requirements are due as outlined below:

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

Minn. R. 7017.2030, subp. 1-4 and Minn. R.7017.2035, subp. 1-2

A-8



16100033 - 001

Facility Name:

Permit Number:

Subject Item: EU 002 Diesel Starting Engine (Vents Inside Turbine Building)

What to do Why to do itOpacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

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

Permitted Fuel: Diesel Fuel only Minn. R. 7007.0800, subp. 2

Determination of Diesel Fuel Sulfur Content: The Permittee shall obtain a dieselfuel analysis report from the fuel vendor for each fuel delivery. The report shallspecify the sulfur content of the fuel in percent by weight.

Diesel fuel with a sulfur content of less than 0.5% by weight when combusted byEU 002 will not emit more than 0.5 lb SO2/mmBtu heat input.

Minn. R. 7007.0800, subp. 4 and 5

EU 002 Operating Hours: less than or equal to 50.25 hours/year using 12-monthRolling Sum

Minn. R. 7007.0800, subp. 2

Recordkeeping - EU 002 Operating Hours:

1. For each day of operation of EU 002, the Permittee shall record all operatingtime to the nearest minute;

2. By the last day of each month, the Permittee shall calculate and record the EU002 operating time, in total minutes, for the previous month;

3. By the last day of each month, the Permittee shall calculate and record the totalEU 002 operating time for the previous 12-month period in total minutes, and totalhours.

Minn. R. 7007.0800, subp. 4 and 5

A-9



16100033 - 001

Facility Name:

Permit Number:

Subject Item: EU 003 Auxiliary Boiler

Associated Items: SV 004 Auxiliary Boiler

What to do Why to do itOperating Hours: less than or equal to 830 hours/year using 12-month Rolling Sum Title I Condition: To avoid major source status under

40 CFR Section 52.21Permitted Fuel: Pipeline natural gas only as defined in 40 CFR Section 72.2. Minn. R. 7007.0800, subp. 2

Recordkeeping: Record and maintain records of the amounts of each fuelcombusted on a monthly basis. These records may consist of purchase records orfuel receipts.

40 CFR Section 60.13(i) and February 20, 1992, EPAmemorandum to meet the requirements of 40 CFRSection 60.48c(g) and (i)

Recordkeeping - EU 003 Operating Hours: By the end of each EU 003 operatingday, the Permittee shall calculate and record the operating hours for that day.

Title I Condition: To avoid major source status under40 CFR Section 52.21; Minn. R. 7007.0800, subps. 4and 5

Recordkeeping - EU 003 Operating Hours: By the last day of each month, thePermittee shall calculate and record the following:

1. the total EU 003 operating hours during the previous month;

2. the total EU 003 operating hours during the previous 12-month period, bysumming the monthly EU 003 operating hours for the past 12 months.

Title I Condition: To avoid major source status under40 CFR Section 52.21; Minn. R. 7007.0800, subps. 4and 5

A-10



16100033 - 001

Facility Name:

Permit Number:

Subject Item: EU 004 HRSG Duct Burner

Associated Items: CE 002 Catalytic Afterburner

CE 003 Catalytic Reduction

SV 002 Combustion Turbine - Combined Cycle Operation (46 MW; CE 002/CE 003)

What to do Why to do itRecordkeeping: Record and maintain records of the amounts of each fuelcombusted on a monthly basis. These records may consist of purchase records orfuel receipts.

40 CFR Section 60.13(i) and February 20, 1992, EPAmemorandum to meet the requirements of 40 CFRSection 60.48c(g) and (i)

Permitted Fuel: Pipeline natural gas only as defined in 40 CFR Section 72.2. Minn. R. 7007.0800, subp. 2

A-11

TABLE B: SUBMITTALSFacility Name: Simon Entergy LLC - Waterville Facility

Permit Number: 16100033 - 001

11/26/02

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

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

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

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

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

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Simon Entergy LLC - Waterville Facility


11/26/02

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup. Thenotification shall specify the name andnumber (as listed in this permit) of eachemission unit subject to a new sourceperformance standard (EU 001, EU 003, andEU 004) and the initial startup date of eachemission unit. Seperate startup notificationsshall be submitted for EU 001 simple cycleoperation and for EU 001 combined cycleoperation.

Total Facility

Notification of the Date Construction Began due 30 days after Start Of Construction. Thenotification shall specify the name andnumber (as listed in this permit) of eachemission unit subject to a new sourceperformance standard (EU 001, EU 003, andEU 004) and the date construction of eachemission unit commenced.

Total Facility

Testing Frequency Plan due 60 days after Initial Performance Testafter initial performance tests for NOx and CO,while operating in combined cycle mode. Theplan shall specify a NOx and CO testingfrequency based on the inital combined cycleperformance test data, Part 75 Appendix E,and MPCA guidance. Future performancetests based on one-year (12-month),36-month, and 60-month intervals, or asapplicable, shall be required upon writtenapproval of the test plan by the MPCA.

EU001

Testing Frequency Plan due 60 days after Initial Performance Testafter initial performance tests for NOx whileoperating in simple cycle mode. The planshall specify a NOx testing frequency basedon the inital simple cycle performance testdata, Part 75 Appendix E, and MPCAguidance. Future performance tests based onone-year (12-month), 36-month, and60-month intervals, or as applicable, shall berequired upon written approval of the test planby the MPCA.

EU001

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Simon Entergy LLC - Waterville Facility


11/26/02

What to send When to send Portion of Facility AffectedExcess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar

quarter following Initial Startup of the Monitor.This applies to each and CO and NOx CEM.Submit the report on the Deviations ReportingForm DRF-1 as amended. The EER shallindicate all periods of NOx and/or CO CEMbypass and all periods of exceedances of thelimit including exceedances allowed by anapplicable standard, i.e. during startup,shutdown, and malfunctions.

EU001

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter following Initial Startup of the Monitor.This applies to the monitoring system formeasuring water to fuel ratio. Reports shallbe submitted and include information asdescribed under Section 60.334(c).

EU001

Semiannual Deviations Report due 30 days after end of each calendarhalf-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification Report (Acid RainProgram)

due 60 days after end of each calendar yearfollowing Initial Startup. The Report shallinclude all information required by 40 CFRSection 72.90(b) and (c).

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). Submit the Certification on aform approved by the Commissioner, both tothe Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

B-3

APPENDIX 1 Facility Name: Simon Entergy LLC - Waterville Facility Permit Number: 16100033-001

Phase II Permit Application For more information, see instructions and refer to 40 CFR 72.30 and 72.31 This submission is New Revised Simon Entergy LLC – Waterville Facility Plant Name

Minnesota State

ORIS Code 55832

Compliance Plan a

Unit ID# b

Unit Will Hold Allowances in

Accordance with 40 CFR

72.9(c)(1)

c Repowering Plan

d New Units

Commence

Operation Date

e New Units

Monitor

Certification Deadline

EU 001 Yes May 1, 2004 July 29, 2004

Standard Requirements Permit Requirements. (1) The designated representative of each affected source and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit. Monitoring Requirements. (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements. (1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the unit's compliance subaccount (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the previous calendar year from the unit; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements. (1) The designated representative of an affected unit that has excess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall: (i) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeeping and Reporting Requirements. (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period

until such documents are superseded because of the submission of a new certificate of representation changing the designated representative;

(ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year period shall apply;

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability. (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. Except as provided under 40 CFR 72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NO x averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit shall not be liable for any violation by any other affected unit of which they are not owners or operators or the designated representative and that is located at a source of which they are not owners or operators or the designated representative. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act. Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Act, including the provisions of title I of the Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold; provided, that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. CERTIFICATION I am authorized to make this submission on behalf of the owners and operators of the affected source or affected units for which the submission is made. I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.

Name E. J. Simon Signature E. J. Simon

Dated May 28, 2002

APPENDIX 2 INSIGNIFICANT ACTIVITIES Required To Be Listed Cooling Towers – potential PM/PM10 emissions less than 2000 lb of PM, PM10, and VOC In addition, there are the following insignificant activities that are not required to be listed, but were included in the permit applicaiton: 1. Anhydrous Ammonia Storage Tank – Approximately 900 gallons 2. Diesel Fuel Storage Tank – less than 1500 gallons

Permit Action Number: 16100033-001 Date: 3/9/2004

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 16100033-001 This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

Owner and Operator Address and Phone Number (list both if different)

Facility Address (SIC Code: 4911)

Simon Industries (Owner) 541 West 98th Street Suite357 Bloomington, MN 55420 phone 952/891-2589 fax 952/891-2518 Simon Entergy LLC (Operator) 505 State Street Waseca, MN 56093 phone 507/835-8555 fax 507/835-4393

Highway 13 & 270th Street West Waseca Waseca County

1.2. Description of the facility

This facility will be composed of a natural gas-fired gas turbine, a mechanically driven electric generator, a heat recovery steam generator (HRSG) with natural gas-fired duct burner, a steam turbine electric generator, a gas-fired auxiliary boiler, and a diesel-fired starting engine. The gas turbine will be able to operate in simple cycle (at 315 mmBtu/hr heat input), without the HRSG, or in combined cycle with the HRSG (432 mmBtu total heat input; 349 mmBtu/hr from gas turbine and 83 mmBtu/hr from duct burner in HRSG). Net simple cycle electric production capacity will be 26.6 MW, and 46 MW in combined cycle operation at 59° F. The turbine will be equipped with inlet cooling to maximize electrical production during warm weather. The auxiliary boiler will generate steam for injection into the combustion turbine for NOx control during simple cycle operation. In combined cycle operation, NOx and CO will be controlled by a selective catalytic reduction (SCR) unit, and an oxidation catalyst, respectively. These control devices will be integral to the HRSG. The diesel starting engine only operates 9 minutes during each turbine start up, and vents inside the gas turbine building.


The combustion turbine is a utility unit as defined in 40 CFR § 72.2. 40 CFR § 72.6(a)(3) states this utility unit is an affected source subject to the Acid Rain Program requirements. Minn. R. 7007.0200, subp. 4 states that an affected source is required to obtain a part 70 permit. The Permittee has submitted a Phase 2 Acid Rain Permit Application to the U.S. EPA. The Permittee intends to (at least initially) operate the facility as a peaking plant. Therefore NOx emissions will be monitored according to 40 CFR part 75 Appendix E. However, the permit does not restrict operation to that as a peaking unit, so if unit operation exceeds the allowable peaking unit operating levels as defined in 40 CFR § 72.2, the Permittee is required to install, operate, and maintain a NOx CEM system in the timeframe specified at part 75 Appendix E Section 1.1. The Permit also requires installation, operation, and maintenance of a CO CEM if unit operation exceeds the peaking unit operating levels defined in § 72.2. SO2 emissions will be monitored according to the requirements of 40 CFR Part 75 Appendix D Section 2.3. In EPA’s applicability determination index, an authorization was found in an April 3, 2001, letter from George Czerniak, U.S. EPA Region 5 to Don Smith, Minnesota Pollution Control Agency (Applicability Determination Index Control No. 0100067) for a similar gas turbine electric generator. The letter authorized the use of Part 75 Appendix D Section 2.3 as a custom fuel monitoring schedule as provided at 40 CFR § 60.334(b)(2), for sulfur monitoring for two gas turbines at Rochester Public Utilities in Rochester, Minnesota, when firing natural gas. The source is in the of fossil fuel fired steam generators with greater than 250 mmBtu/hr heat input listed source category in § 52.21 . Therefore it is subject to the 100 tpy PSD major source cutoff. This draft permit contains enforceable limits to restrict emissions to less than 100 tpy for each regulated pollutant under § 52.21. In addition, emissions are non-major under part 70, but because the source is an affected source subject to the acid rain program, it must obtain a part 70 permit.

1.3 Description of any changes allowed with this permit issuance

This permit authorizes construction and operation of this new source. 1.4. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary:

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Pb tpy

All HAPs

tpy Total Facility Limited

12.92 12.92 1.17 97.24 94.0 5.27 0 2.24


Potential Emissions

Table 2. Facility and Permit Classification

Classification Major/Affected

Source *Synthetic

Minor *Minor

PSD CO, NOx PM, PM10, SO2, VOC, Pb NAAR NA NA NA Part 70 Acid Rain Program PM10, SO2, VOC, Lead, HAPs

* Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 2. Regulatory and/or Statutory Basis Summary Regulatory and/or Statutory Basis of the Emission or operational Limit Regulatory Overview of Facility

EU # Applicable Regulations Comments:

EU 001 40 CFR pt 60 subp. GG 40 CFR parts 72, 73, 75, 77, 78 Title I Conditions

Standards of Performance for Stationary Gas Turbines Acid Rain Program Simple Cycle Operating Hours Limit to avoid major source status under § 52.21; NOx limit to avoid major source status under § 52.21; SCR and oxidation catalyst operating requirements to avoid major source status under § 52.21

EU002 Minn. R. 7011.2300 Minn. R. 7007.0800, subp. 2

Standards of Performance for Internal Combustion Engines Operating hours limit

EU003 40 CFR 60 Subp. Dc Title I Condition

Standards of Performance for Small and Industrial Commercial and Institutional Steam Generating Units Operating Hours Limit to avoid major source status under § 52.21

EU004 40 CFR 60 Subp. Dc

Standards of Performance for Small and Industrial Commercial and Institutional Steam Generating Units


3. Technical Information

New Source Review: This source is a fossil fuel-fired steam electric facility, and is subject to the 100 tpy major source cutoff under § 52.21.

NOX AND CO LIMITS: A 12-month rolling sum emission limit for NOx, a simple cycle mode operating hours limit, a CO lb/hr limit, along with control equipment operating and compliance requirements, will restrict NOx and CO emissions to less than the major source level. Note that the CO limit averaging period is 3 hours, to coincide with a 3-hr reference method 10 (or equivalent) test for CO emissions, unless a CEM is installed, in which case the limit is on a 30-day rolling average basis. A 30-day rolling average basis is acceptable because the limit is not a performance standard, but is a limit to avoid PSD major source status by limiting 12-month CO emissions to less than 100 tons.

NOX PERFORMANCE TESTING: Stack testing is required for NOx, to meet the part 60 subp. GG and §60.8 requirement, as well as to generate data to develop the NOx emissions curve pursuant to part 75 Appendix E (and also to determine lb/hr emissions for calculating 12-month rolling sum emissions). Separate NOx testing is required for each operating mode (simple cycle mode, and combined cycle mode), to meet the requirements of part 75, Appendix E. NOx emissions testing is also necessary for each mode of operation to verify manufacturer’s emission factors used in simple cycle and combined cycle NOx emission calculations, and to verify that total 12-month NOx emissions from both modes of operation will not exceed 100 tpy.

CO PERFORMANCE TESTING: Stack testing is also required for CO, when operating in combined cycle mode, to verify that the oxidation catalyst will restrict CO emissions to less than 100 tpy, and to verify oxidation catalyst operating and monitoring parameter ranges. CO stack testing and emissions monitoring is not required when operating in simple cycle, because with simple cycle operation limited to 830 hr/yr, limited potential CO emissions are under 4 tpy which is well below applicable PSD major source thresholds.

LIMITED POTENTIAL EMISSIONS: Worst case turbine emissions occur during combined cycle operation at 8760 hr/yr for all pollutants except for NOx. Worst case NOx is at 830 hours simple cycle operation, and 7930 hours combined cycle operation for a total limited NOx PTE of 95.7 tpy, and a total facility limited PTE of 97.3 tpy NOx. SCR MONITORING: Although the facility will use the NOx emission curve/predictive NOx emissions monitoring method as described in part 75 Appendix E, the permit also requires monitoring and recording of SCR operating parameters. This is necessary in order to ensure that the SCR is operating in the same a manner as when the NOx emission curve graph was developed, to ensure that the curve is still accurate.


CEMS: Part 75 Appendix E Section 1.1 requires NOx CEM installation after operation exceeds the peaking unit definition in § 72.2. Therefore, accurate NOx emissions data will be obtained well before actual NOx emissions approach the 100 tpy major source cutoff for part 70 and 52.21. The permit also requires installation of a CO CEM after the unit no longer qualifies as a peaking unit (per §72.2 definition), in order to accurately measure CO. Use of a CO CEM to obtain accurate CO emissions data is especially important as overall unit usage increases and 12-month CO emissions approach the 100 tpy PSD major source threshold, because during startup the oxidation catalyst is less efficient and CO emissions are higher (due to lower operating temperatures during unit startup).

Acid Rain Program: This source is a utility unit that is subject to the Acid Rain Program. The Permittee intends to operate as a peaking unit, but is not limited to such under combined cycle operation. Therefore, requirements for NOx CEM installation, operation, and maintenance are included, if gas turbine operation exceeds the requirements for a peaking unit as defined in §72.2. Part 70 Permit Program: The source is an affected facility and therefore must obtain a part 70 permit, even though limited emissions are less than the major source thresholds under part 70. New Source Performance Standards: The combustion turbine is subject to 40 CFR Part 60 subp. GG. The HRSG duct burner and auxiliary boiler are subject to 40 CFR part 60 subp. Dc. The Permittee is requesting use of part 75, Appendix D, Section 2.3.1 SO2 monitoring as the custom fuel monitoring schedule for part 60 subp. GG sulfur monitoring requirements (see attached letter). Fuel nitrogen monitoring is not required for natural gas according to an August 14, 1987, EPA memorandum (ADI control number NS33), which says “nitrogen monitoring can be waived for pipeline quality natural gas, since there is no fuel-bound nitrogen and since the free nitrogen does not contribute appreciably to NOx emissions”. On August 6, 2002, Mr. Kevin Villner of US EPA Region 5 contacted Marshall Cole by telephone regarding the July 23, 2002, MPCA custom fuel monitoring schedule request letter. Mr. Villner was inquiring about which parts of part 75 Appendix D section 2.3.1 were going to be used as the custom fuel monitoring schedule. Marshall Cole informed Mr. Villner that it would be sections 2.3.1.1 and 2.3.1.4(1). Mr. Villner indicated that this would be acceptable to US EPA, and gave verbal approval (with a written approval to follow) for use of these sections of part 75 Appendix D, as a custom fuel monitoring schedule as allowed by § 60.334(b)(2). EU 001 Delta Emissions Data: The combustion turbine emissions data in the delta facility description is entered under EU 001, except for NOx and CO. Worst case CO is from 8760 hr/yr of combined cycle operation. Combined cycle operation vents through SV 002 (emissions from both EU 001 and EU 004 duct burner). Therefore, under SV 002, limited potential emissions for CO are 92.9 tpy, which is the annual equivalent of the EU 001 CO permit limit of 21.2 lb/hr. 92.9 tpy was selected by the permit writer, because this will limit total facility CO to 94 tpy, and provide a margin above the potential emissions based on the manufacturer’s guarantee of 84.70 tpy (total CO from SV 002).


Worst case NOx is emitted by 830 hr/yr simple cycle operation and 7930 hr/yr combined cycle operation. At 830 hrs simple cycle operation, 20.17 tons of NOx are emitted. This value is shown under SV 001 in the delta facility description. The difference of the 95.7 tpy EU 001 NOx limit and the limited SV 001 NOx is 75.53 tpy, which is found under SV 002 in the delta facility description. The total EU 001 NOx limit of 95.7 was proposed by the Permittee, and results in a total facility limited NOx potential of 97.3 tpy. Environmental Review: The Environmental Quality Board is the Responsible Governmental Unit for this project as stated in Minn. R. 4410.4300, subp. 3. The EQB has prepared an Environmental Assessment Worksheet for this project. NESHAP part 63: This facility is an affected facility subject to the future promulgated subp. YYYY MACT for combustion turbines. However, it will not be located at a major HAP source, and is not itself a major HAP source (total HAPs PTE is 2.0 tpy). Air Toxics: Current MPCA policy does not require any air toxics assessment for this facility because it is restricted to burning only pipeline natural gas. However, the permit writer did use the CAPHAPs program to evaluate impacts from 3 HAPs with the highest emissions from SV 002: formaldehyde, hexane, and toluene. CAPHAPs predicted a maximum formaldehyde (acute) 1 hr concentration of 82 ug/m3 at 0 meters and beyond with building downwash, compared to an ambient standard of 94 ug/m3. CAPHAPs also predicted a chronic (annual) concentration that is 2.4 times the ambient standard of 3.0 ug/m3, and a long-term cancer concentration that is 9.1 times the ambient standard of 0.8 ug/m3. Because CAPHAPs predicted formaldehyde concentrations would exceed the chronic and cancer risk ambient concentrations, staff modeled formaldehyde emissions using SCREEN3. SCREEN3 showed that CAPHAPs predicted the 1 hour (acute) formaldehyde concentration was 1414 times higher than the maximum predicted by SCREEN3. Considering that CAPHAPs predicted the acute 1-hr concentration 1414 times higher than SCREEN3, due to CAPHAPs conservative assumptions regarding stack temperature and velocity, it is very likely that CAPHAPs has done the same with the chronic and cancer concentrations. Also, both the chronic and cancer formaldehyde ambient air standards are greater than the 1-hr SCREEN3 predicted concentration, by factors of 51.63 for the chronic concentration, and of 13.77 for the cancer concentration. Therefore, the permit writer is assuming the chronic and cancer ambient concentrations predicted by CAPHAPs for formaldehyde, are generously over-predicted, and that actual annual and longer term formaldehyde ambient concentrations due to emission from SV 002 will be well below the 3.0 ug/m3 and 0.8 ug/m3 values, respectively. Toluene and hexane emission data was also entered into CAPHAPs for this facility, but no exceedances of ambient standards was predicted for these pollutants. Other HAPs were not screened due to their very low emission rate. SCREEN3 NOx Modeling: Predicted ambient concentrations were well below thresholds.


Minnesota Rules: The combustion turbine and diesel starting engine are subject to Minn. R. 7011.2300, standards of performance form stationary internal combustion engines. Comments During Public Notice and EPA Review: No comments were received during the 30-day public notice or during the 45-day EPA review period.

4. Conclusion Based on the information provided by the Simon Industries, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 16100033-001 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Marshall Cole, Tom Sinn, Jenny Reinertsen (peer review) Attachment: Emission Calculations, Acid Rain Permit Application (An Appendix to the Draft Permit); Custom Fuel Monitoring Schedule Letter

air emission permit no. 16100033-001 is issued to

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