AIR EMISSION PERMIT NO Minor Amendment IS ISSUED TO. Order of St Benedict/St John's Abbey

Transcription

1 AIR EMISSION PERMIT NO Minor Amendment IS ISSUED TO Order of St Benedict/St John's Abbey ORDER OF ST BENEDICT/ST JOHN'S ABBEY Power Plant Collegeville, Stearns County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the State Implementation Plan (SIP) under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal; Pt 70/Limits to Avoid NSR and NESHAPs Operating Permit Issue Date: 05/31/2006 Minor Amendment Issue Date: February 10, 2009 Expiration Date: 05/31/2011 Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit Reissuance 3/30/ Minor Amendment 5/19/08 004

3 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Appendices I: Insignificant Activities Required to be Listed II: Dispersion Modeling Parameters III: Calculation Method for Pollutants with Synthetic Minor Limits IV: Calculation Method for Particulate Emissions from the Wood Fired Kiln

4 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 Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 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 , 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 and , 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.

5 FACILITY DESCRIPTION: Action 003 (Reissuance) The Order of St. Benedict/St. John s Abbey, Saint John s University (SJU) is a higher education facility in Collegeville, Minnesota. SJU currently has six boilers, two electrical generators, four emergency electrical generators and a few other small emission units. The different boilers fire either coal or natural gas with fuel oil backup. In late 1997, a boiler that fired a mixture of wood waste and campus waste was shut down and removed from site. This permit reissuance incorporates limits on potential emissions that render the source less than major under 40 CFR and 40 CFR This permit also allows for the modification of Boiler No. 4. Action 004 (Minor Amendment) This minor amendment will allow the facility to use bituminous coal as a supplemental fuel to the subbituminous coal already being used in boilers No 1, 2, and 4. This will ensure a sufficient amount of coal be available should the subbituminous coal supply run out before the next shipment from the supplier. Performance test dates for Boilers No. 1, 2, 4, and 6 were updated. Boilers 1, 2, and 4 are going from one-time testing to periodic testing while boiler 6 is remaining at a 60 month testing frequency. The printing press and sand blasting operation were deleted from the insignificant activities required to be listed in the appendix to the permit since these operations no longer exist at the facility.

6 TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENTS Why to do it Sulfur Dioxide: less than or equal to 225 tons/year from the emission units listed in Table A based on a 12-month rolling sum. OPERATIONAL REQUIREMENTS Title I Condition: to avoid major source classification under 40 CFR Section and Minn. R The Permittee shall comply and upon written request demonstrate compliance, with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING 40 CFR pt. 50; Minn. Stat. Section , subds. 4a & 9; Minn. R , supbs. 7A, 7L & 7M; Minn. R , subps. 1, 2 & 4; Minn. R Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Minn. R. ch. 7017

7 TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Minn. Rs , subp. 1-4, and Minn. R , subp. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. MONITORING REQUIREMENTS Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. When the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Maintain records of fuel sulfur content of all fuel burned on site. Sulfur content of the fuel may be determined by fuel supplier certification or fuel sampling of each delivery of fuel. Calculate sulfur dioxide emissions by the 15th of each month for the previous month. Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 Title I Condition: to avoid major source classification under 40 CFR Section and Minn. R Title I Condition: to avoid major source classification under 40 CFR Section and Minn. R Add the results to the previous months operation and compare to the limit. Maintain records of the calculations and their results. Calculation methods are provided in the appendix to this permit. REPORTING/SUBMITTALS

8 TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon Minn. R , subp. 1 as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R through Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment Minn. R , subp. 1(H) to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year Minn. R through Minn. R following permit issuance. To be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R DISPERSION MODELING PARAMETERS The following requirements in this section are state only requirements and not enforceable by the EPA Administrator or citizens under the Clean Air Act. Parameters Used in Modeling: The parameters used in the modeling performed for determining emission and/or operational limits for this facility are listed in the Appendix of this permit. If the Permittee intends to change any of these parameters, the Permittee must submit the revised parameters to the Commissioner and receive written approval before making any changes. The revised parameter information submittal must include, but is not limited to: the locations, heights and diameters of the stacks; locations and dimensions of nearby buildings; velocity and temperatures of the gases emitted; and the emission rates. The plume dispersion characteristics due to the parameter revisions must equal or exceed the dispersion characteristics modeled for this permit, and the Permittee shall demonstrate this in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. For changes that do not involve an increase in an emission rate and that do not require a permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before making the change to any parameter. Minn. R Minn. R Minn. R

9 TABLE A: LIMITS AND OTHER REQUIREMENTS A-4 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: ADDITION OF EMISSION UNITS The Permittee may add or modify boilers, generators, and/or kilns using the appropriate permit amendment. The added or modified emission units must comply with the synthetic minor emission limits given above. Title I Condition: to avoid major source classification under 40 CFR Section and Minn. R

10 TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: Subject Item: GP 001 Old Boilers Associated Items: EU 001 Boiler #1 EU 002 Boiler #2 EU 003 Boiler #3 EU 005 Boiler #5 EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input. This limit applies applies individually to each emission unit in this Group. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies applies individually to each emission unit in this Group. MONITORING Monitoring: once each day during operation the Permittee shall monitor and record the presence or absence of visible emissions from each emission unit. If visible emissions are observed, the Permittee shall take corrective action as soon as possible and make a record of the corrective action taken. Sulfur content: the Permittee shall maintain records of the sulfur content of the coal and oil used in the boilers. Additional requirements are located at the EU level for these boilers. Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 4 Title I Condition: to avoid major source classification under 40 CFR Section and Minn. R

11 TABLE A: LIMITS AND OTHER REQUIREMENTS A-6 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: Subject Item: GP 002 Generators Associated Items: EU 007 Generator #1 EU 008 Generator #2 EMISSION LIMITS What to do Why to do it Sulfur Dioxide: less than or equal to 0.05 lbs/million Btu heat input. Use of diesel fuel with a sulfur content less than 0.05 weight percent satisfies this requirement. Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. OPERATING LIMITS Minn. R. 7009, also meets the requirements of Minn. R , subp. 2 Minn. R , subp. 1 Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum calculated monthly. The limit applies to each generator individually. Operating Hours: limited to 12 per day. Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section and Minn. R RECORDKEEPING Recordkeeping: once each operating day record the number of hours each generator operated that day Recordkeeping: maintain signed fuel certification records with each shipment of fuel received that indicates the percent sulfur by weight of the fuel oil. The certification may specify a guaranteed maximum. Minn. R , subp. 5 Minn. R , subp. 5

12 TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: Subject Item: GP 003 Emergency Generators Associated Items: EU 014 Emergency Generator #1 EU 015 Emergency Generator #2 EMISSION LIMITS What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input. Use of diesel fuel with a sulfur content less than 0.5 weight percent satisfies this requirement. OPERATING LIMITS Hours of Operation: The Permittee shall maintain documentation on site that each unit is an emergency diesel generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. RECORDKEEPING Recordkeeping: once each operating day record the number of hours each generator operated that day Recordkeeping: maintain signed fuel certification records with each shipment of fuel received that indicates the percent sulfur by weight of the fuel oil. The certification may specify a guaranteed maximum. Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 4 and 5 Minn. R , subp. 5 Minn. R , subp. 5

13 TABLE A: LIMITS AND OTHER REQUIREMENTS A-8 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 001 Boiler #1 Associated Items: GP 001 Old Boilers SV 001 Boiler 1, 2, and 3 OPERATING CONDITIONS What to do Why to do it Fuel Usage: limited to coal for Boiler #1. Minn. R , subp. 2 Minn. R Bituminous coal shall be used only as a supplemental fuel to subbituminous coal Minn. R , subp. 2 for Boiler #1 and not as a primary fuel source. The bituminous coal shall only be used when subbituminous coal shipments from the supplier are unable to meet the fuel demands of Boiler #1. All permitted emission limits met by subbituminous coal usage must also be met by bituminous coal usage. PERFORMANCE TESTING Performance Test: due before end of each 36 months starting 03/15/2007 for particulate matter and opacity for Boiler #1. For additional applicable performance requirements see "General Performance Test Requirements" in Table A, subject item "Total Facility". See GP001 citations for additional requirements associated with EU001. Minn. R , subp. 2

14 TABLE A: LIMITS AND OTHER REQUIREMENTS A-9 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 002 Boiler #2 Associated Items: GP 001 Old Boilers SV 001 Boiler 1, 2, and 3 OPERATING CONDITIONS What to do Why to do it Fuel Usage: limited to coal for Boiler #2. Minn. R , subp. 2 Minn. R Bituminous coal shall be used only as a supplemental fuel to subbituminous coal Minn. R , subp. 2 for Boiler #2 and not as a primary fuel source. The bituminous coal shall only be used when subbituminous coal shipments from the supplier are unable to meet the fuel demands of Boiler #2. All permitted emission limits met by subbituminous coal usage must also be met by bituminous coal usage. PERFORMANCE TESTING Performance Test: due before end of each 36 months starting 03/15/2007 for particulate matter and opacity for Boiler #2. For additional applicable performance requirements see "General Performance Test Requirements" in Table A, subject item "Total Facility". See GP001 citations for additional requirements associated with EU002. Minn. R , subp. 2

15 TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 003 Boiler #3 Associated Items: GP 001 Old Boilers SV 001 Boiler 1, 2, and 3 OPERATING CONDITIONS What to do Why to do it Fuel Usage: limited to natural gas for Boiler #3. Minn. R , subp. 2 Minn. R See GP001 citations for additional requirements associated with EU003.

16 TABLE A: LIMITS AND OTHER REQUIREMENTS A-11 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 004 Boiler #4 Associated Items: CE 002 Fabric Filter - High Temperature, i.e., T>250 Degrees F SV 013 Boiler 4 (new stack) EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to lbs/million Btu heat input. This limit applies at all times except startup, shutdown and malfunction. Opacity: less than or equal to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. 40 CFR Section 60.43c(a)(1) and Minn. R CFR Section 60.43c(c) and Minn. R This limit applies at all times except startup, shutdown and malfunction. Sulfur Dioxide: less than or equal to 1.2 lbs/million Btu heat input 40 CFR Section 60.42c(e)(2) and Minn. R OPERATING CONDITIONS Bituminous coal shall be used only as a supplemental fuel to subbituminous coal for Boiler #4 and not as a primary fuel source. The bituminous coal shall only be used when subbituminous coal shipments from the supplier are unable to meet the fuel demands of Boiler #4. All permitted emission limits met by subbituminous coal usage must also be met by bituminous coal usage. POLLUTION CONTROL EQUIPMENT Pressure Drop: greater than or equal to 1 inches water column across the baghouse. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. Inspect quarterly, or as required by manufacturing specifications, all components that are not subject to wear or plugging including structural components, housings, ducts, and hoods. Maintain a written record of the inspection and any action resulting from the inspection. Inspect monthly, or as required by manufacturing specifications, all components that are subject to wear or plugging for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. Maintain a written record of the inspection and any action resulting from the inspection. PERFORMANCE TESTS Performance Test: due before end of each 60 months starting 03/15/2007 to test for particulate matter emissions and opacity using the methods specified in 40 CFR Section 60.45c and Section For additional applicable performance requirements see "General Performance Test Requirements" in Table A, subject item "Total Facility". Daily Performance Test: for sulfur dioxide as stated below. (h) For affected facilities subject to 40 CFR Section 60.42c(h)(1), (2), or (3) where the owner or operator seeks to demonstrate compliance with the SO2 standards based on fuel supplier certification, the performance test shall consist of the certification, the certification from the fuel supplier, as described under 40 CFR Section 60.48c(f)(1), (2), or (3), as applicable. Performance Test: due 90 days after achieving maximum capacity while burning coal from a different source other than Decker Coal Company in Big Horn County, Montana. The testing shall be for HCl and Cl emissions. The emission factors developed from stack testing shall be used in the calculation of total facility HAP emissions to verify that the source remains non-major as defined by 40 CFR Part 63. MONITORING Minn. R , subp. 2 Minn. R , subp CFR Part 64 Minn. R , subp. 4 and 5 40 CFR Part 64 Minn. Rules , subp. 2 and CFR Part 64 Minn. Rules , subp. 2 and CFR Part CFR Section CFR Part CFR Section 60.44c(b), 40 CFR Section 60.8 and Minn. R Title I Condition: to avoid major source classification under 40 CFR Section 63.2

17 TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: (c) After the initial performance test required under paragraph (b) and Section 60.8, compliance with the SO2 emission limits under Section 60.42c is based on the average SO2 emission rates for 30 consecutive steam generating unit operating days. A separate performance test is completed at the end of each steam generating unit operating day, and a new 30-day average SO2 emission rate is calculated to show compliance with the standard. 40 CFR Section 60.44c(c) and (d), and Minn. R (d) If only coal, only oil, or a mixture of coal and oil is combusted in an affected facility, the procedures in Method 19 are used to determine the hourly SO2 emission rate (Eho) and the 30-day average SO2 emission rate (Eao). The hourly averages used to compute the 30-day averages are obtained from the continuous emission monitoring system (CEMS). Method 19 shall be used to calculate Eao when using daily fuel sampling or Method 6B. (d) As an alternative to operating a CEMS at the inlet to the SO2 control device (or outlet of the steam generating unit if no SO2 control device is used) as required under paragraph (a) of this section, an owner or operator may elect to determine the average SO2 emission rate by sampling the fuel prior to combustion. As an alternative to operating a CEMS at the outlet from the SO2 control device (or outlet of the steam generating unit if no SO2 control device is used) as required under paragraph (a) of this section, an owner or operator may elect to determine the average SO2 emission rate by using Method 6B. Fuel sampling shall be conducted pursuant to either paragraph (d)(1) or (d)(2) of this section. Method 6B shall be conducted pursuant to paragraph (d)(3) of this section. (1) For affected facilities combusting coal or oil, coal or oil samples shall be collected daily in an as-fired condition at the inlet to the steam generating unit and analyzed for sulfur content and heat content according the Method 19. Method 19 provides procedures for converting these measurements into the format to be used in calculating the average SO2 input rate. (3) Method 6B may be used in lieu of CEMS to measure SO2 at the inlet or outlet of the SO2 control system. An initial stratification test is required to verify the adequacy of the Method 6B sampling location. The stratification test shall consist of three paired runs of a suitable SO2 and carbon dioxide measurement train operated at the candidate location and a second similar train operated according to the procedures in Section 3.2 and the applicable procedures in section 7 of Performance Specification 2 (appendix B). Method 6B, Method 6A, or a combination of Methods 6 and 3 or Methods 6C and 3A are suitable measurement techniques. If Method 6B is used for the second train, sampling time and timer operation may be adjusted for the stratification test as long as an adequate sample volume is collected; however, both sampling trains are to be operated similarly. For the location to be adequate for Method 6B 24-hour tests, the mean of the absolute difference between the three paired runs must be less than 10 percent (0.10). (a) The owner or operator of an affected facility combusting coal, residual oil, or wood that is subject to the opacity standards under Section 60.43c shall install, calibrate, maintain, and operate a COMS for measuring the opacity of the emissions discharged to the atmosphere and record the output of the system. 40 CFR Section 60.46c(d) and Minn. R continued from above continued from above continued from above 40 CFR Section 60.47c(a) and (b) (b) All COMS for measuring opacity shall be operated in accordance with the applicable procedures under Performance Specification 1 (appendix B). The span value of the opacity COMS shall be between 60 and 80 percent. RECORDKEEPING AND REPORTING Application for major permit amendment: Submit an application for a major amendment to set total facility hazardous air pollutant limits if emission testing for HCl or Cl shows that the facility would exceed major source thresholds as defined by 40 CFR Part 63. Title I Condition: to avoid major source classification under 40 CFR Part 63 The application is to be submitted with the performance test results, and specify a compliance plan for demonstrating that annual emissions of hazardous air pollutants do not exceed major source thresholds.

18 TABLE A: LIMITS AND OTHER REQUIREMENTS A-13 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: (4) Submit a notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in Section 60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Administrator may request additional relevant information subsequent to this notice. (5) Submit a notification of the date upon which demonstration of the continuous monitoring system performance commences in accordance with Section 60.13(c). Notification shall be postmarked not less than 30 days prior to such date. 40 CFR Section 60.7(a)(4) 40 CFR Section 60.7(a)(5) and (6) (6) Submit a notification of the anticipated date for conducting the opacity observations required by Section 60.11(e)(1) of this part. The notification shall also include, if appropriate, a request for the Administrator to provide a visible emissions reader during a performance test. The notification shall be postmarked not less than 30 days prior to such date. (7) Submit a notification that continuous opacity monitoring system data results will be used to determine compliance with the applicable opacity standard during a performance test required by Section 60.8 in lieu of Method 9 observation data as allowed by Section 60.11(e)(5) of this part. This notification shall be postmarked not less than 30 days prior to the date of the performance test. (b) Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (b) The owner or operator of each affected facility subject to the SO2 emission limits of Section 60.42c, or the PM or opacity limits of Section 60.43c, shall submit to the Administrator the performance test data from the initial and any subsequent performance tests and, if applicable, the performance evaluation of the CEMS and/or COMS using the applicable performance specifications in appendix B. (c) The owner or operator of each coal-fired affected facility subject to the opacity limits under Section 60.43c(c) shall submit excess emission reports for any excess emissions from the affected facility which occur during the reporting period. (d) The owner or operator of each affected facility subject to the SO2 emission limits, fuel oil sulfur limits, or percent reduction requirements under Section 60.42c shall submit reports to the Administrator. (e) The owner or operator of each affected facility subject to the SO2 emission limits, under Section 60.43c shall keep records and submit reports as required under paragraph (d) of this section, including the following information, as applicable. 40 CFR Section 60.7(a)(7) 40 CFR Section 60.7(b) 40 CFR Section 60.48c(b) and Minn. R CFR Section 60.48c(c) and Minn. R CFR Section 60.48c(d) and Minn. R CFR Section 60.48c(e) and Minn. R (1) Calendar dates covered in the reporting period. (11) If fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification as described under paragraph (f)(1), (2), or (3) of this section, as applicable. In addition to records of fuel supplier certifications, the report shall include a certified statement signed by the owner or operator of the affected facility that the records of fuel supplier certifications submitted represent all of the fuel combusted during the reporting period. 40 CFR Section 60.48c(e) and (f) and Minn. R (f) Fuel supplier certification shall include the following information:

19 TABLE A: LIMITS AND OTHER REQUIREMENTS A-14 02/10/09 Facility Name: Order of St Benedict/St John's Abbey Permit Number: (3) For coal: continued from above (i) The name of the coal supplier; (ii) The location of the coal when the sample was collected for analysis to determine the properties of the coal, specifically including whether the coal was sampled as delivered to the affected facility or whether the sample was collected from coal in storage at the mine, at a coal preparation plant, at a coal supplier's facility, or at another location. The certification shall include the name of the coal mine (and coal seam), coal storage facility, or coal preparation plant (where the sample was collected); (iii) The results of the analysis of the coal from which the shipment came (or of the shipment itself) including the sulfur content, moisture content, ash content, and heat content; and (iv) The methods used to determine the properties of the coal. (g) The owner or operator of each affected facility shall record and maintain records of the amounts of each fuel combusted during each day. (i) All records required under this section shall be maintained by the owner or operator of the affected facility for a period of two years following the date of such record. 40 CFR Section 60.48c(g) and Minn. R CFR Section 60.48c(i) and (j) and Minn. R (j) The reporting period for the reports required under this subpart is each six-month period. All reports shall be submitted to the Administrator and shall be postmarked by the 30th day following the end of the reporting period.

20 TABLE A: LIMITS AND OTHER REQUIREMENTS A-15 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 005 Boiler #5 Associated Items: GP 001 Old Boilers SV 003 Boiler 5 OPERATING CONDITIONS What to do Why to do it Fuel Usage: limited to natural gas and distillate oil (0.5% sulfur) for Boiler #5. Minn. R , subp. 2 Minn. R See GP001 citations for additional requirements associated with EU005.

21 TABLE A: LIMITS AND OTHER REQUIREMENTS A-16 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 009 Kiln #1 (natural gas) Associated Items: SV 006 Kiln #1 EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input. Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. OPERATING CONDITIONS Minn. R , subp. 2 Fuel Usage: limited to natural gas. Minn. R , subp. 2

22 TABLE A: LIMITS AND OTHER REQUIREMENTS A-17 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 010 Kiln #2 (wood) Associated Items: SV 007 Kiln #2 EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input. Minn. R , subp. 1 Total Particulate Matter: less than or equal to 0.83 lbs/hour based on a 24 hour average. The emission rate will be calculated using AP42 factors and the equation given in the appendix to this permit. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. OPERATING CONDITIONS Minn. R Minn. R , subp. 2 Fuel Usage: limited to wood. Minn. R , subp. 2 Operation limited to 30 days per year and to operation during September, October and November. MONITORING Minn. R Monitoring: once each day during operation the Permittee shall monitor and record Minn. R , subp. 4 the presence or absence of visible emissions from each emission unit. If visible emissions are observed, the Permittee shall take corrective action as soon as possible and make a record of the corrective action taken. Record each day of operation, including the date. Minn. R , subp. 2

23 TABLE A: LIMITS AND OTHER REQUIREMENTS A-18 02/10/09 Facility Name: Permit Number: Order of St Benedict/St John's Abbey Subject Item: EU 013 Boiler #6 Associated Items: SV 010 Boiler 6 What to do Fuels allowed: natural gas and distillate fuel oil Sulfur Content of Fuel: less than or equal to 0.05 percent by weight sulfur in distillate fuel oil Opacity: less than or equal to 20 percent opacity using 6-minute Average when burning oil, except for one 6-minute period per hour of not more than 27 percent opacity. This limit does not apply during periods of startup, shutdown, or malfunction. Performance Test: due before end of each 60 months starting 12/19/2005 to measure opacity from SV 010 while combusting distillate fuel oil. Why to do it Title I Condition: limit to avoid classfication as a major source under 40 CFR Section and Minn. R Minn. R. 7009, also meets the requirements of 40 CFR Section 60.42c(d); Minn. R CFR Section 60.43c(c); Minn. R CFR Section 60.45c(a); Minn. R For additional applicable performance requirements see "General Performance Test Requirements" in Table A, subject item "Total Facility". Semiannual Report Content: the quarterly report shall contain records of the fuel supplier certifications and a certified signed statement by the owner or operator that the records of fuel supplier certifications submitted represent all of the fuel combusted during the quarter. Fuel Supplier Certification Content: the certification shall include the name of the oil supplier and a statement from the supplier that the oil complies with the fuel oil sulfur limit in this permit, 0.5 % sulfur by weight. Recordkeeping: record and maintain records of the amounts of each fuel combusted during each day. 40 CFR Section 60.48c(e); Minn. R CFR Section 60.48c(f); Minn. R CFR Section 60.48c(g); Minn. R

24 TABLE B: SUBMITTALS Facility Name: Order of St Benedict/St John's Abbey Permit Number: 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. B-1 02/10/09 Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota

25 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Order of St Benedict/St John's Abbey Permit Number: B-2 02/10/09 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit Notification due 30 days before Initial Fuel Analysis of EU004 coal to be burned in the boilers that if from a different source than the Decker Coal Company, Big Horn County, Montana. Testing Frequency Plan due 60 days after Performance Test for Boiler EU001 #1 for particulate matter and opacity emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Performance Test for Boiler EU002 #2 for particulate matter and opacity emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Performance Test for particulate matter and opacity. The plan could include a 1, 3 or 5 year testing interval, or an alternate proposal, based on MPCA guidance. EU004

26 TABLE B: RECURRENT SUBMITTALS Facility Name: Order of St Benedict/St John's Abbey Permit Number: B-3 02/10/09 What to send When to send Portion of Facility Affected Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter following Initial Startup of the Monitor for opacity, and the monitoring for sulfur dioxide emissions. EU004 The reports shall contain the information specified in 40 CFR Section 60.48c(c). Semiannual Compliance Report due 31 days after end of each calendar half-year starting 02/04/2000. The initial quarterly report shall be postmarked by the 30th day following the third month following the completion of the initial performance test. Semiannual Deviations Report due 30 days after end of each calendar half-year starting 05/31/2006. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occured, the Permittee shall submit the report stating no deviations. Compliance Certification due 30 days after end of each calendar year starting 05/31/2006 (for the previous calendar year). To be submitted to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. EU013 Total Facility Total Facility

27 APPENDIX MATERIAL Facility Name: Order of St Benedict/St John's Abbey Permit Number: I: Insignificant Activities Required to be Listed: Emission Unit Description Applicable Subpart ( x) Description Applicable Performance Standard Laboratories , subp. 3(G) Natural Gas Fired , subp. 3 (I) PTE < 1 tpy Minn. R Emergency Generators (2) Diesel Fired Emergency , subp. 3 (I) PTE < 1 tpy Minn. R Generators (2) Bottom and Fly Ash , subp. 3 (I) PTE < 1 tpy Minn. R Handling Systems Gasoline Storage Tank , subp. 4 Actual Emissions < 1 tpy Wood Kiln , subp. 4 Actual Emissions < 1 tpy Minn. R Natural Gas Kiln , subp. 3 (I) PTE < 1 tpy, <2 tpy for CO Minn. R Parts Washer , subp. 3 (I) PTE < 1 tpy Spray Booth/ Misc , subp. 4 Actual Emissions < 1 tpy Minn. R Painting Sander Baghouse , subp. 3 (I) Actual Emissions < 1 tpy Minn. R Fly Ash Silo , subp. 3 (I) Actual Emissions < 1 tpy Minn. R

28 II: Dispersion Modeling Parameters Air Dispersion Modeling Parameters Point Sources/Stacks Stack ID Description Stack Parameters Emissions (lb/hr) Height Diameter Temperature Flow m ft m ft K F m/s acfm SO2 NOX PM10 STK1 Boilers 1,2, & STK2 Boiler STK3 Boiler STK4 Gen No. 1 (EU7) STK5 Gen No. 2 (EU8) STK6 Boiler 6 (EU13) STK7 Wood Fired Kiln Area Sources/Fugitives Source ID FUG1 Description Coal Pile Fugitives Emissio n Rate (g/s-m2) 1.50E- 05 Emissio n Rate (lb/hr) Release Height (m) X Dimensio n (m) Y Dimensio n (m) Angle Z Dimensio n (m) 1.57E =Equal to or higher than predicted by emission factors or performance standard limits. =Lower than predicted. See discussion in the technical support document.