Draft Air Individual Permit Major Amendment

Transcription

1 Draft Air Individual Permit Major Amendment Permittee: Facility name: Sappi Cloquet LLC Sappi Cloquet LLC 2201 Avenue B Cloquet, MN Carlton County Operating permit issuance date: March 13, 2012 Expiration date: March 13, 2017 * All Title I Conditions do not expire Major Amendment: [Amendment Issue Date] Stage 1 issuance date Authorization to Construct and Operate: [month day, year] Stage 2 issuance date Major Amendment: [Amendment Issue Date] Permit characteristics: Federal; Part 70/ Major for NSR; NSR Authorization * The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R , subp. 3. (Title V Reissuance Application was received 6/15/16.) 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. The conditions included in Stage 1 of this permit action are effective on the Stage 1 Issuance Date shown above. Stage 1 conditions authorize construction and modification of the facility and the operation of the modified emissions units at the address listed above until final action is taken on Stage 2. Air Emission Permit No remains effective until the Stage 2 Issue Date. Beginning on the Stage 2 Issue date Air Emission Permit No supersedes Air Emission Permit No and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in the permit. 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 SIP under 40 CFR and as such are enforceable by EPA Administrator or citizens under the Clean Air Act.

2 Stage 1 Issuance Approval: Signature: [ ] for This document has been electronically signed. Don Smith, P.E., Manager Supervisor, Air Quality Permits Unit 3 Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency Stage 2 Issuance Approval: Signature: [ ] for This document has been electronically signed. Don Smith, P.E., Manager Supervisor, Air Quality Permits Unit 3 Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

3 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B: Stack Parameters Relied Upon in Modeling Appendix C: Road Segment Speed Limit and Silt Load Test Areas Appendix D: Performance Test Recordkeeping Items and Testing Schedule Appendix E: Fugitive Emission Control Plan Page

4 Permit expires: [month day, year] Page 4 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 12/06/ Administrative Amendment 09/21/ Major Amendment 11/15/ Reopening 08/03/ Reopening 02/27/ Administrative Amendment 04/25/ Administrative Amendment 12/09/ Reopening 12/10/ Major Amendment 10/22/ Supplemental Information 02/06/ Reopening NA Administrative Amendment 05/06/ Major Amendment 09/30/

5 Permit expires: [month day, year] Page 5 of Where to send submittals Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R 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. 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: Fiscal Services 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term 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 Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

6 Permit expires: [month day, year] Page 6 of Facility description The Sappi Cloquet LLC (Facility) is located at 2201 Avenue B in Cloquet, MN, Carlton County, Minnesota. Sappi Cloquet, LLC (Sappi) is an existing pulp and paper mill which manufactures kraft paper pulp, specialized cellulose pulp (SC), and fine coated paper. The pulp-making procedure starts with wood being delivered onsite, debarked, and chipped. The wood chips are then fed into ten batch digesters where they are cooked with white liquor and steam. Exhaust gases from the digestion process are collected by the non-condensable gas systems (NCG), which consist of VOCs and odorous total reduced sulfur compounds (TRS) including hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The NCGs are vented to and controlled by the Incinerator- Quencher-Scrubber (IQS) system. The incinerator thermally oxidizes VOC, HAP, and TRS compounds from the gas stream to produce carbon dioxide (CO2), sulfur dioxide (SO2), and water vapor. The scrubber portion of the IQS controls SO2. After being discharged from the digesters the spent cooking liquor and pulp must be separated. The pulp is sent on to be washed, bleached, dried, sheeted. The spent cooking liquor and pulp wash water are combined to make weak black liquor solids (BLS). The weak BLS are concentrated in evaporators to make strong BLS, which can then be combusted in the recovery boiler. NCGs from the evaporators are vented to the IQS. In the recovery boiler, the organic portion of the BLS is burned and provides steam for electricity or heat for other processes at the plant. The cooking chemicals collect as molten smelt at the bottom of the boiler. The recovery boiler is a primary source of all criteria pollutant emissions, as well as sulfuric acid (H2SO4), TRS, and Hazardous Air Pollutants (HAPs). Particulate matter emissions from the recovery boiler are controlled by a high-efficiency electrostatic precipitator (ESP). The smelt from the recovery boiler is collected and dissolved in process water in the smelt dissolving tank (SDT) to make green liquor which is a mixture of sodium carbonate and sodium sulfide. The SDT emits particulate matter, sulfur dioxide (SO2), volatile organic compounds (VOC), TRS, and HAPs. Emissions from the SDT are controlled by a Spray Tower and a Venti-Rod Scrubber operated in series. The green liquor is then fed to the causticizers with slaked lime which reacts to produce white liquor. The white liquor is then returned to the fiberline to produce more pulp. Calcium carbonate (lime mud) is the byproduct of this reaction. The lime mud is sent to the Lime Kiln where it undergoes a calcination reaction to reproduce lime (CaO) and CO 2. The lime kiln is a source of all criteria pollutants, in addition to H 2 SO 4, TRS, and HAPs. Particulate matter emissions are controlled by a high-efficiency ESP. Other major sources of emissions are from the three power boilers #7, #8, and #9. Boilers #7 and #9 are permitted to burn distillate oil, natural gas, wood waste, and sludge, and are also used as backup controls for NCGs. Particulate matter emissions from boiler #7 and #9 are controlled by multiclones and high-efficiency ESPs at each boiler. Power boiler #8 combusts natural gas and distillate oil. All three boilers are used to produce steam for electrical generation for use on site and for process heat. Other emission sources include the bleach plant, paper machines #4 and #12, a coater, a market pulp machine, an emergency generator, a fire pump, a cooling tower, a research and development (R&D) boiler, and fugitive particulate matter sources such as dust from wood piles, paved and unpaved roads, track-out, a fuel yard, ash handling, and a landfill. The bleach plant consists of a chlorine dioxide plant and a bleach line. Chlorine dioxide emissions from the bleach plant and chlorine dioxide plant are controlled by a gas scrubber and a packed tower scrubber; the bleaching system is also a significant source of carbon monoxide (CO) and VOC emissions. Permit The Permittee was seeking to modify the pulp mill to manufacture chemical cellulose pulp (CCP), also known as

7 Permit expires: [month day, year] Page 7 of 243 dissolving pulp. The only pollutant subject to PSD review was ozone which was subject to Prevention of Significant Deterioration (PSD) requirements at any increase greater than zero. The project consisted of the installation of a new ozone bleaching system. The specific changes related to the proposed project included the following: Upgrade to the wood room. Installation of two additional digesters. This was necessary because of the lower yield and longer cook time needed during production of CCP compared to Kraft pulp. Increase in the production of Black Liquor Solids (BLS) and an increase in the utilization of the Recovery Boiler. The annual throughput limit of 904,200 tons of BLS was maintained. Increase in utilization of the Smelt Dissolving Tank and Lime Kiln. Addition of an ozone stage to the existing Bleach Plant. This resulted in a small actual decrease in VOC emissions, and an increase in ozone emissions. Market Pulp Machine (MPM) forming and press sections needed to be modified to accommodate the physical characteristics of CCP. Increase in weak black liquor production and a corresponding increase in the throughput of the evaporators, and thus the IQS, and a possible increase in concentrations of organics and reduced sulfur compounds in the feed streams, which resulted in a corresponding decrease in natural gas combustion. Increase in steam usage at the digesters, evaporator, bleach plant, and market pulp machine. With the increase in black liquor solids produced, it was expected that the recovery boiler would be able to provide the necessary steam for the changes identified. Two percent increase in paper production at the paper machines and coater on an annual basis. Changes to the truck traffic and routes. Permit Sappi proposed to increase the daily permitted capacity of the Lime Kiln from 440 ton Calcium Oxide (CaO) per day to 500 ton CaO per day and the annual permitted throughput limit from 146,000 ton CaO per year to 175,000 ton CaO per year. The project is a major modification under PSD for particulate matter smaller than 10 microns in size (PM10) and particulate matter smaller than 2.5 microns in size (PM2.5) emissions. As part of the PSD permitting process, Sappi underwent a Best Available Control Technology (BACT) analysis and determined that the existing Electrostatic Precipitator is BACT for PM10 and PM2.5 emissions. Sappi also proposed to install a low Nitrogen Oxides (NOx) burner on the Lime Kiln. The Lime Kiln has existing emission limits of 11.8 pounds per hour (lb/hr) for particulate matter (PM) and PM10 and 11.1 lb/hr for PM2.5. This permit action increased these emission limits to 13.6 lb/hr for PM and PM10 and 12.8 lb/hr for PM2.5. Sappi proposed to reduce the NOx emission limit from 62.2 lb/hr to 38.9 lb/hr, and to establish a new NOx limit of 120 ppmvd at 10% O2. The low NOx burner will reduce emissions to avoid a major modification under PSD for NOx emissions. Currently, the there is a physical constraint on the amount of lime mud that can be sent to the Lime Kiln on a daily basis. To increase the capacity to the desired 500 ton CaO/day, Sappi will modify the Lime Kiln to handle the increased throughput. This permit authorizes modification of the Lime Kiln. Permit This permit action authorizes construction of a Chip Pre-Steaming Bin (EQUI 316) prior to the digesters. The chip bin will help increase annual pulp production by reducing chip fill times and improving digester cycle times by presteaming the chips. The addition of the Chip Bin is one of several changes Sappi will make towards the overall goal of being able to produce 100% SC pulp at the annual capacity of the plant. Currently the pulp production rate for SC pulp (which results in more BLS than kraft pulp) is limited by the BLS throughput rate. A recent engineering analysis of the recovery boiler concluded that the maximum capacity of the boiler was 1,027,475 tons BLS per year (5.63 million pounds BLS per day), in contrast to the current permitted-limited capacity of 904,200 ton BLS per year (4.95 million pounds BLS per day). If Sappi produces paper up to the increased capacity of the recovery boiler (assuming a ratio of 5,000 pounds BLS per ton of pulp) they will be able to produce 410,990 tons of pulp per year, up from 361,000 tons of pulp annually. The increase in pulp production and BLS creation will result in increased utilization of other processes at the plant. The affected units are the bleach plant, the smelt dissolving tank, the lime kiln, the market pulp machine, the IQS system, and paved roads (from additional transport of wood chips). No utilization increase will be needed from the

8 Permit expires: [month day, year] Page 8 of 243 power boilers because the additional steam from the recovery boiler will be used to steam the chips in the chip bin and for the increase in steam demand for pulp production.

9 Permit expires: [month day, year] Page 9 of Summary of subject items SI ID: Description ACTV19: All IAs COMG1: Fuel limits: #7, #8 and #9 Boilers COMG2: NCG System COMG3: Process Condensates Relationship Type has members has members has members Related SI ID: Description EQUI2, EQUI4, EQUI18 EQUI15, EQUI17, EQUI20, EQUI24, EQUI28, EQUI49, EQUI204, EQUI295, EQUI296, EQUI297, EQUI300, EQUI303, EQUI305, EQUI306, EQUI307, EQUI308, EQUI309, EQUI310, EQUI312, EQUI313, EQUI314, STRU30, STRU40, STRU41, TREA30, TREA31 EQUI15, EQUI17, EQUI20, EQUI24, EQUI28, EQUI204, EQUI295, EQUI296, EQUI297, EQUI300, EQUI303, EQUI305, EQUI306, EQUI307, EQUI308, EQUI309, EQUI310, EQUI312, SI ID: Description COMG7: 40 CFR pt. 63, subp. DDDDD Requirements EQUI107: Power Boiler #9 - CO EQUI108: Rotary Lime Kiln - Opacity EQUI109: RB #10 - SDT - Scrubber Flow Relationship Type has members sends to sends to sends to EQUI110: RB#10 CO2 EQUI112: Power Boiler #8 - NOx EQUI113: Recovery Boiler sends to #10 - Opacity EQUI114: Recovery Boiler sends to #10 - NOx EQUI115: Recovery Boiler sends to #10 - SO2 EQUI116: Recovery Boiler sends to #10 - TRS EQUI117: Recovery Boiler sends to #10 - CO EQUI118: Recovery Boiler sends to #10 - O2 EQUI119: Power Boiler sends to #7 - SO2 EQUI120: Rotary Lime sends to Kiln - TRS EQUI121: Rotary Lime sends to Kiln - O2 EQUI122: Power Boiler sends to #7 - O2 EQUI123: Power Boiler sends to #7 - CO EQUI127: RB #10 - SDT - sends to Pressure Drop Related SI ID: Description EQUI313, EQUI314 EQUI2, EQUI4, EQUI18, EQUI290 EQUI63: RegPerfect EQUI63: RegPerfect EQUI65: Process Information System EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI65: Process Information System EQUI129: Bleach Plant - sends to EQUI65:

10 Permit expires: [month day, year] Page 10 of 243 SI ID: Description ph EQUI130: Bleach Plant - Flow EQUI131: Bleach Plant - Fan EQUI132: ClO2 Plant - Flow Relationship Type sends to sends to sends to Related SI ID: Description Process Information System EQUI65: Process Information System EQUI65: Process Information System EQUI65: Process Information System EQUI133: IQS - Temp sends to EQUI65: Process Information System EQUI134: IQS - Flow sends to EQUI65: Process Information System EQUI135: Power Boiler #7 - Opacity EQUI136: Power Boiler #9 - Opacity EQUI137: Power Boiler #9 - NOx EQUI138: Power Boiler #8 - O2 sends to sends to sends to EQUI63: RegPerfect EQUI63: RegPerfect EQUI63: RegPerfect EQUI15: Digester Relief sends to STRU30: Incinerator Quencher Scrubber EQUI15: Digester Relief sends to STRU40: Power Boiler #7 EQUI15: Digester Relief sends to STRU41: Power Boiler #9 EQUI15: Digester Relief EQUI15: Digester Relief is controlled by is controlled by TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI17: Condensate sends to STRU30: SI ID: Description Stripper EQUI17: Condensate Stripper EQUI17: Condensate Stripper EQUI17: Condensate Stripper EQUI17: Condensate Stripper EQUI18: Power Boiler #8 EQUI18: Power Boiler #8 Relationship Type sends to sends to is controlled by is controlled by is monitored by is monitored by Related SI ID: Description Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI112: Power Boiler #8 - NOx EQUI138: Power Boiler #8 - O2 EQUI18: Power Boiler #8 sends to EQUI63: RegPerfect EQUI18: Power Boiler #8 sends to STRU28: Power Boiler #8 EQUI204: Black Liquor / / EU047 EQUI204: Black Liquor / / EU047 EQUI20: Brownstock Washers EQUI20: Brownstock Washers EQUI20: Brownstock Washers EQUI20: Brownstock Washers EQUI20: Brownstock Washers EQUI23: Black Liquor Tanks (Washers) is controlled by is controlled by sends to sends to sends to is controlled by is controlled by sends to TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS STRU30: Incinerator Quencher

11 Permit expires: [month day, year] Page 11 of 243 SI ID: Description EQUI23: Black Liquor Tanks (Washers) EQUI23: Black Liquor Tanks (Washers) EQUI23: Black Liquor Tanks (Washers) EQUI23: Black Liquor Tanks (Washers) EQUI24: Digester Air Evacuation EQUI24: Digester Air Evacuation EQUI24: Digester Air Evacuation EQUI24: Digester Air Evacuation EQUI24: Digester Air Evacuation EQUI261: Methanol / / EU017 EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank Relationship Type sends to sends to is controlled by is controlled by sends to sends to sends to is controlled by is controlled by sends to sends to sends to is controlled by is controlled by Related SI ID: Description Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI290: R&D Boiler sends to STRU37: R&D Boiler EQUI291: Power Boiler #7 - Stack Flow SI ID: Description EQUI292: Power Boiler #9 - Stack Flow EQUI293: Recovery Boiler #10 - Stack Flow EQUI294: Digesters (10) EQUI294: Digesters (10) EQUI295: Black Liquor / / EU046 EQUI295: Black Liquor / / EU046 EQUI296: Black Liquor / / EU046 EQUI296: Black Liquor / / EU046 EQUI297: Black Liquor / / EU046 EQUI297: Black Liquor / / EU046 EQUI298: #4 Paper Machine EQUI299: #12 Paper Machine EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 Relationship Type is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by Related SI ID: Description TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS sends to STRU49: #4 Paper Machine sends to STRU50: #12 Paper Machine is monitored by is monitored by is monitored by is monitored by EQUI119: Power Boiler #7 - SO2 EQUI122: Power Boiler #7 - O2 EQUI123: Power Boiler #7 - CO EQUI135: Power Boiler #7 - Opacity is monitored EQUI291:

12 Permit expires: [month day, year] Page 12 of 243 SI ID: Relationship Related SI ID: Description Type Description (Spreader Stoker - Bark) by Power Boiler #7 - Stack Flow EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI2: Power Boiler #7 (Spreader Stoker - Bark) EQUI300: Evaporator Vacuum EQUI300: Evaporator Vacuum EQUI300: Evaporator Vacuum EQUI300: Evaporator Vacuum EQUI300: Evaporator Vacuum EQUI301: Chlorine Dioxide Plant EQUI301: Chlorine Dioxide Plant EQUI301: Chlorine Dioxide Plant EQUI301: Chlorine Dioxide Plant EQUI302: 140' Clarifier (covered) EQUI303: Oxygen Delignification System sends to sends to sends to is controlled by is controlled by sends to sends to sends to is controlled by is controlled by is monitored by sends to sends to is controlled by sends to sends to EQUI63: RegPerfect STRU27: Power Boiler #7 Bypass STRU40: Power Boiler #7 TREA11: Power Boiler #7 - Multiclones TREA15: Power Boiler #7 ESP STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI132: ClO2 Plant - Flow EQUI65: Process Information System STRU43: Chlorine Dioxide Plant TREA16: ClO2 Plant Scrubber STRU29: IA stack (140' Clarifier) STRU30: Incinerator Quencher Scrubber SI ID: Description EQUI303: Oxygen Delignification System EQUI303: Oxygen Delignification System EQUI303: Oxygen Delignification System EQUI303: Oxygen Delignification System Relationship Type sends to sends to is controlled by is controlled by Related SI ID: Description STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI304: #13 Coater sends to STRU51: #13 Off-Machine Coater EQUI305: Turpentine System EQUI305: Turpentine System EQUI305: Turpentine System EQUI305: Turpentine System EQUI305: Turpentine System EQUI306: Black Liquor / / EU045 EQUI306: Black Liquor / / EU045 EQUI307: Black Liquor / / EU045 EQUI307: Black Liquor / / EU045 EQUI308: Black Liquor / / EU045 EQUI308: Black Liquor / / EU045 sends to sends to sends to is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS

13 Permit expires: [month day, year] Page 13 of 243 SI ID: Description EQUI309: Black Liquor / / EU045 EQUI309: Black Liquor / / EU045 EQUI310: Black Liquor / / EU045 EQUI310: Black Liquor / / EU045 EQUI311: Black Liquor / / EU045 EQUI311: Black Liquor / / EU045 EQUI312: Black Liquor / / EU047 EQUI312: Black Liquor / / EU047 EQUI313: Black Liquor / / EU046 EQUI313: Black Liquor / / EU046 EQUI314: Black Liquor / / EU046 EQUI314: Black Liquor / / EU046 EQUI315: Emergency Diesel Fire Water Pump EQUI316: Chip Presteaming Bin EQUI317: Black Liquor / / EU045 EQUI317: Black Liquor / Relationship Type is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by sends to sends to is controlled by Related SI ID: Description TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS STRU60: Emergency Fire Pump Stack STRU59: Chip Presteaming Bin Stack TREA30: Incinerator for TRS on IQS is controlled TREA31: SO2 SI ID: Relationship Related SI ID: Description Type Description / EU045 by Scrubber for IQS EQUI38: I&I Emergency Generator EQUI42: Ozone bleaching system sends to sends to EQUI49: IQS - Incinerator is monitored by EQUI49: IQS - Incinerator is monitored by EQUI49: IQS - Incinerator sends to EQUI49: IQS - Incinerator is monitored by EQUI49: IQS - Incinerator sends to EQUI49: IQS - Incinerator sends to EQUI49: IQS - Incinerator sends to EQUI49: IQS - Incinerator is controlled by EQUI49: IQS - Incinerator is controlled by EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) is monitored by is monitored by is monitored by is monitored by sends to STRU31: I&I Emergency Generator STRU44: Bleach Plant EQUI133: IQS - Temp EQUI134: IQS - Flow EQUI65: Process Information System EQUI72: IQS - ph STRU30: Incinerator Quencher Scrubber STRU40: Power Boiler #7 STRU41: Power Boiler #9 TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS EQUI107: Power Boiler #9 - CO EQUI136: Power Boiler #9 - Opacity EQUI137: Power Boiler #9 - NOx EQUI292: Power Boiler #9 - Stack Flow EQUI63: RegPerfect

14 Permit expires: [month day, year] Page 14 of 243 SI ID: Description Relationship Type Related SI ID: Description SI ID: Description Relationship Type Related SI ID: Description EQUI4: Power Boiler #9 (Bark) is monitored by EQUI71: Power Boiler #9 - SO2 EQUI52: Rotary Lime Kiln - Kiln sends to EQUI63: RegPerfect EQUI4: Power Boiler #9 (Bark) is monitored by EQUI76: Power Boiler #9 - O2 EQUI52: Rotary Lime Kiln - Kiln sends to STRU38: Lime Kiln EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) EQUI4: Power Boiler #9 (Bark) sends to is controlled by is controlled by STRU41: Power Boiler #9 TREA18: Power Boiler #9 - Multiclones TREA19: Power Boiler #9 ESP EQUI52: Rotary Lime Kiln - Kiln EQUI53: Recovery Boiler #10 EQUI53: Recovery Boiler #10 is controlled by is monitored by is monitored by TREA21: Rotary Lime Kiln ESP EQUI110: RB#10 CO2 EQUI113: Recovery Boiler #10 - Opacity EQUI50: Market Pulp Machine - Pressing Equipment EQUI51: Smelt Dissolving Tank for RB #10 is monitored by EQUI109: RB #10 - SDT - Scrubber Flow EQUI53: Recovery Boiler #10 EQUI53: Recovery Boiler #10 is monitored by is monitored by EQUI114: Recovery Boiler #10 - NOx EQUI115: Recovery Boiler #10 - SO2 EQUI51: Smelt Dissolving Tank for RB #10 is monitored by EQUI127: RB #10 - SDT - Pressure Drop EQUI53: Recovery Boiler #10 is monitored by EQUI116: Recovery Boiler #10 - TRS EQUI51: Smelt Dissolving Tank for RB #10 is monitored by EQUI70: RB #10 - SDT - Supply Pressure EQUI53: Recovery Boiler #10 is monitored by EQUI117: Recovery Boiler #10 - CO EQUI51: Smelt Dissolving Tank for RB #10 EQUI51: Smelt Dissolving Tank for RB #10 EQUI51: Smelt Dissolving Tank for RB #10 is monitored by sends to is controlled by EQUI77: RB #10 - SDT - VRS Pressure Drop STRU47: Smelt Dissolving Tank for RB#10 TREA12: Smelt Dissolving Tank - Spray Tower EQUI53: Recovery Boiler #10 EQUI53: Recovery Boiler #10 EQUI53: Recovery Boiler #10 is monitored by is monitored by sends to EQUI118: Recovery Boiler #10 - O2 EQUI293: Recovery Boiler #10 - Stack Flow EQUI63: RegPerfect EQUI51: Smelt Dissolving Tank for RB #10 EQUI52: Rotary Lime Kiln - Kiln EQUI52: Rotary Lime Kiln - Kiln EQUI52: Rotary Lime Kiln - Kiln is controlled by is monitored by is monitored by is monitored by TREA6: Recovery Boiler #10 - Ventri- Rod Scrubber EQUI108: Rotary Lime Kiln - Opacity EQUI120: Rotary Lime Kiln - TRS EQUI121: Rotary Lime Kiln - O2 EQUI53: Recovery Boiler #10 EQUI53: Recovery Boiler #10 EQUI63: RegPerfect EQUI65: Process Information System EQUI70: RB #10 - SDT - Supply Pressure sends to is controlled by sends to STRU42: Recovery Boiler #10 TREA20: Recovery Boiler #10 ESP EQUI65: Process Information System

15 Permit expires: [month day, year] Page 15 of 243 SI ID: Description EQUI71: Power Boiler #9 - SO2 Relationship Type sends to Related SI ID: Description EQUI63: RegPerfect EQUI72: IQS - ph sends to EQUI65: Process Information System EQUI76: Power Boiler #9 - O2 EQUI77: RB #10 - SDT - VRS Pressure Drop EQUI7: Bleach Plant EQUI7: Bleach Plant EQUI7: Bleach Plant is monitored by is monitored by is monitored by EQUI129: Bleach Plant - ph EQUI130: Bleach Plant - Flow EQUI131: Bleach Plant - Fan EQUI7: Bleach Plant sends to EQUI65: Process Information System EQUI7: Bleach Plant sends to STRU44: Bleach Plant FUGI11: Track-out FUGI2: Existing Cooling Tower - zfugative FUGI3: Fuel Yard FUGI5: Landfill FUGI6: Paved Roads FUGI7: Unpaved Roads FUGI8: Fly Ash Handling FUGI9: Wood Chip Pile STRU10: Waste Treatment Office STRU11: Building 10 - Clarifier Lift Station STRU12: Building HD Storage and Pumphouse STRU13: Building Turpentine Storage STRU14: Building SI ID: Description Construction Warehouse No. 3 STRU15: Building Evaporator Cooling Tower STRU16: Building Peroxide Unloading Building STRU17: Building New Bleach Plant STRU18: Building Warehouse #3 STRU1: Causticizing Building STRU20: Building 78 - Bleached Hardwood MD Tower STRU21: OOS #10 Digester Blow Steam Acumulator Tk STRU24: Building 30 - ClO2 Storage STRU25: Building 31 - ClO2 Generator STRU27: Power Boiler #7 Bypass STRU28: Power Boiler #8 STRU29: IA stack (140' Clarifier) STRU2: Building 62 - Old Chlorine Evap Building STRU30: Incinerator Quencher Scrubber STRU31: I&I Emergency Generator STRU37: R&D Boiler STRU38: Lime Kiln STRU40: Power Boiler #7 STRU41: Power Boiler #9 STRU42: Recovery Boiler #10 STRU43: Chlorine Dioxide Plant STRU44: Bleach Plant Relationship Type Related SI ID: Description

16 Permit expires: [month day, year] Page 16 of 243 SI ID: Description STRU47: Smelt Dissolving Tank for RB#10 STRU49: #4 Paper Machine STRU4: Lime Kiln North Building STRU50: #12 Paper Machine STRU51: #13 Off- Machine Coater STRU59: Chip Presteaming Bin Stack STRU5: Building No. 4 Turbine Generator STRU60: Emergency Fire Pump Stack STRU6: Building Soap Skimmer STRU7: PURR Offices STRU8: Heavy Liquor Pumphouse STRU9: Lime Kiln South Building TFAC6: Sappi Cloquet LLC TREA11: Power Boiler #7 - Multiclones TREA12: Smelt Dissolving Tank - Spray Tower Relationship Type is controlled in series by Related SI ID: Description TREA15: Power Boiler #7 ESP SI ID: Description TREA15: Power Boiler #7 ESP TREA16: ClO2 Plant Scrubber TREA17: Bleach Plant Scrubber TREA18: Power Boiler #9 - Multiclones TREA19: Power Boiler #9 ESP TREA20: Recovery Boiler #10 ESP TREA21: Rotary Lime Kiln ESP TREA30: Incinerator for TRS on IQS TREA31: SO2 Scrubber for IQS TREA6: Recovery Boiler #10 - Ventri-Rod Scrubber TREA8: Catalytic Converter Relationship Type is controlled in series by is controlled in series by is controlled in series by Related SI ID: Description TREA19: Power Boiler #9 ESP TREA31: SO2 Scrubber for IQS TREA12: Smelt Dissolving Tank - Spray Tower

17 Permit expires: [month day, year] Page 17 of Limits and other requirements TFAC Sappi Cloquet LLC Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities Required to be Listed, Appendix C: Road Segment Speed Limit and Silt Load Test Areas, Appendix D: Performance Test Recordkeeping Items and Testing Schedule, and Appendix E: Fugitive Control Plan. Modeling parameters in Appendices B: Stack Parameters Relied Upon in Modeling are included for reference only as described elsewhere in this permit. [Minn. R , subp. 2] Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: The parameters used in PM and SO2 modeling completed in 1995, CO, NO2, and PM10 modeling completed in 2012, and PM2.5 modeling completed for permit number are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , Title I Condition: 40 CFR 52.21(k)] Changes to Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: Any permit amendment that affects any modeled parameter or emission rate for CO, NO2, PM, PM10, PM2.5, and SO2 listed in Appendix B must be a major amendment. Any addition to the information documented in Appendix B requires a major amendment. [Minn. R , Title I Condition: 40 CFR 52.21(k)] Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for CO, NO2, PM, PM10, PM2.5, and SO2: Changes that affect any modeled parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD Modeling Submittal requirement. [Minn. R , Title I Condition: 40 CFR 52.21(k)] EBD Modeling Submittal for CO, NO2, PM, PM10, PM2.5, and SO2: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (in the form of an issued permit amendment) before making such changes. [Minn. R , Title I Condition: 40 CFR 52.21(k)] EBD Modeling Submittal Content for CO, NO2, PM, PM10, PM2.5, and SO2: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of

18 Permit expires: [month day, year] Page 18 of 243 nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 1, Minn. R , subps. 2&4, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] Outdated EBD Baseline Modeling for CO, NO2, PM, PM10, PM2.5, and SO2: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 1, Minn. R , subps. 2&4, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] EBD Modeling Results for CO, NO2, PM, PM10, PM2.5, and SO2: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled September 25, 1995 (PM and SO2), March 5, 2012 (CO, NO2, and PM10 and 2017 (PM2.5). The Permittee shall demonstrate this equivalency in the proposal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 1, Minn. R , subp. 2&4, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] Computer Dispersion Modeling Triggers for CO, NO2, PM, PM10, PM2.5, and SO2: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for CO, NO2, PM, PM10, PM2.5,

19 Permit expires: [month day, year] Page 19 of 243 and/or SO2 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 9, Minn. Stat , subds. 4a, Title I Condition: 40 CFR 52.21(k)] Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for CO, NO2, PM, PM10, PM2.5, and/or SO2 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for CO, NO2, PM, PM10, PM2.5, and/or SO2. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. (4a), Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] All stacks listed in Appendix B must be vertical, with an unobstructed release point. No rain caps, rain hats, horizontal release, or tilted stacks are allowed. There are no exceptions to this. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Inspection and Maintenance: Inspect the fencing and gates established for access control once per year. All repairs and maintenance to the fence and gates shall be completed as soon as possible but no later than 60 days after the Permittee observes the need for repair or maintenance or after the MPCA notifies the Permittee of the need for repair or maintenance. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Access Control: All gates installed at access points shall be kept closed unless: 1. A guard is present controlling access at a gate; or 2. Authorized persons are entering or leaving the property through a gate. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] 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.

20 Permit expires: [month day, year] Page 20 of 243 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. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R , (A)(1)-(2), Minn. R , C(2)] Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan in Appendix E. The Plan shall describe methods that the Permittee will use to control fugitive emissions from the property, including from paved and unpaved roads and from the Sappi Industrial Solid Waste landfill. The plan may be amended by the Permittee as needed, and the most recent version shall be maintained on site. If the Commissioner determines the Permittee is out of compliance with Minn. R , this requirement, or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. [Minn. R , Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a] Visual Inspection Training: The Permittee shall provide annual training to its employees that are directly involved in the loading operations for the coating department and pulp mill lime silos and ash silo. The training shall include instructions on procedures for making visual inspections of the silos, including transport lines. The person making the inspection shall be trained to look for accumulation of dust or particulate matter, as well as excess emissions or high opacity from the loading operations. The employees shall be trained on procedures to be followed if there are any problems observed from such things as line ruptures or spills which may result in dust accumulations or high opacity. The Permittee shall retain records of the training given. [Minn. Stat , subd. 4a, Minn. R , subp. 2] These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source

21 Permit expires: [month day, year] Page 21 of 243 Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R [Minn. R , subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing emission unit, and the projected post-change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R , subps. 4-5, Minn. R , subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and

22 Permit expires: [month day, year] Page 22 of 243 telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee shall submit a Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the protocol for PM10 and PM2.5 modeling that is required to be submitted by 9/13/2025. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM10 and PM2.5 that is required to be submitted by 9/13/2025. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] The Permittee shall comply 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment required by the permit whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] 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

23 Permit expires: [month day, year] Page 23 of 243 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. [Minn. R , subp. 14, Minn. R , subp. 16(J)] The O&M Plan shall include information for the following control equipment: TREA 6, TREA11, TREA12, TREA15-21, TREA30, TREA31, and the IQS (EQUI49). At a minimum, the O&M Plan shall include, for each pollution control equipment: - The parameters to be monitored and the parameter ranges to be used; - Corrective action procedures to be followed to return the control equipment to within specified range(s); - Corrective action procedures to be followed in the event of a malfunction or breakdown; and - A description of inspection procedures to be followed; and records kept to demonstrate plan implementation. [Minn. R , subp. 2] Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R [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. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in this permit. [Minn. R. ch. 7017]

24 Permit expires: [month day, year] Page 24 of Performance Test Notifications and Submittals Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Tet 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 an alternative format as allowed by Minn. R [Minn. R , Minn. R , subps. 1-4, Minn. R , subps. 1-2] Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 3] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, 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. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, 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). [Minn. R.

25 Permit expires: [month day, year] Page 25 of , subp. 5(C)] 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. [Minn. R , subp. 5(B)] If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R 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. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R , subp. 4] Recordkeeping: For each storage vessel as specified in 40 CFR b(a), the Permittee shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. These records will be kept for the life of the source. [40 CFR b(a) and (b)] 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. [Minn. R , subp. 3] Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24- hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R , subp. 2]

26 Permit expires: [month day, year] Page 26 of Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , subp. 1] Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. The preceding sentence does not apply if the effective date of the requirement is later than the date on which the permit is due to expire. [Minn. R , subp. 3, Minn. R ] Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). The Permittee may apply for an administrative amendment to extend a test deadline in a permit up to 365 days if the agency finds that the extension is needed to allow the Permittee to test at worst case conditions as required by Minn. R , subp. 2, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a

27 Permit expires: [month day, year] Page 27 of 243 form approved by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] The Permittee is not required to submit a Risk Management Plan (RMP) under 40 CFR pt. 68; no regulated substances are present above the threshold quantity. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever the Permittee fully updates and resubmits their RMP. If required, RMPs shall be submitted to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland RMP information may be obtained at or by calling [40 CFR pt. 68] For changes that do not require a permit amendment: - The Permittee shall submit a Part 1 MACT application within 30 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(a). - The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(b). 112(j) affected source is defined in 40 CFR Section [40 CFR 63.52(b)(1), 40 CFR 63.52(e)(1)] This permit contains many of the requirements from 40 CFR pt. 63, subps. A, S, MM, JJJJ, and DDDDD. Some of the requirements may be paraphrased in this permit. If there is a conflict between a permit term and the regulation, then the regulation takes precedence. [Minn. R , subp. 2] At all times the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control equipment in a manner consistent with good air pollution control practices for minimizing emissions to at least the levels required by all relevant standards.. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(i), Minn. R ] Startup, Shutdown, and Malfunction (SSM) plan: Develop a written

28 Permit expires: [month day, year] Page 28 of 243 plan as described in 40 CFR 63.6(e)(3) for each of the emission units subject to MACT standards that contains specific procedures for operating and maintaining the source during periods of SSM, and a program of corrective action for process malfunction and control systems used to comply with the standards. The SSM Plan must be located at the plant site and must be kept updated. When the SSM Plan is updated, the Permittee must keep all previous versions of the SSM Plan for a period of 5 years. The Permittee must submit the SSM Plan when required. In addition, the plan must include the following requirements: - Procedures to determine and record the cause of an operating parameter exceedance and the time the exceedance began and ended; - Corrective actions to be taken in the event of an operating parameter exceedance, to correct the malfunctioning process as quickly as practicable, including procedures for recording the actions taken to correct the exceedance. - A maintenance schedule for each control technique that is consistent with, but not limited to, the manufacturer's instructions and recommendations for routine and long-term maintenance; and - An inspection schedule for each CMS required under 40 CFR to ensure, at least once in each 24-hour period, that each CMS is properly functioning. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(3), 40 CFR (a), Minn. R , Minn. R ] Malfunctions must be corrected as soon as practicable after their occurrence. To the extent that an unexpected event arises during a startup, shutdown, or malfunction, the Permittee must comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution control practices. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(ii), Minn. R ] The Permittee shall maintain files of all information required by this part in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R , subp. 2(B)] The Permittee shall maintain, at a minimum, the following information in the files, as applicable to each standard: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation; 2. The occurrence and duration of each malfunction of the air

29 Permit expires: [month day, year] Page 29 of 243 pollution control equipment; 3. All maintenance performed on the pollution control equipment; 4. Actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's SSM Plan. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5. All information necessary to demonstrate conformance with the affected source's SSM Plan and actions taken in accordance with SSM Plan; 6. Each period during which a Continuous Monitoring System (CMS) is malfunctioning or inoperative; 7. All required measurements needed to demonstrate compliance with a relevant standard; 8. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10. All CMS calibration checks; 11. All adjustments and maintenance performed on CMS; 12. Any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13. All documents supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R , subp. 2(B)] Startup, shutdown, and malfunction reports shall be submitted only if there is an occurrence of startup, shutdown, or malfunction during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(5)(i), Minn. R , subp. 2(B)] If the Permittee deviates from the startup, shutdown, and malfunction plan (SSM Plan) the Permittee shall record the actions taken for that event and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event. The report must contain name, title, and signature of a responsible official who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the SSM Plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(5)(ii), 40 CFR 63.6(e)(3)(iv), Minn. R , Minn. R , subp. 2(B)] Prior to construction or reconstruction of an "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3), Minn. R.

30 Permit expires: [month day, year] Page 30 of ] MACT Requirements: This facility is subject to all pertinent requirements of the MACT, 40 CFR pt. 63, subp. S (NESHAPs from the Pulp and Paper Industry). [40 CFR pt. 63, subp. S, Minn. R ] Standards for Enclosures and Closed-vent Systems: Each enclosure shall maintain negative pressure at each enclosure or hood opening as demonstrated by procedures specified in 40 CFR (e). Each enclosure or hood opening closed during the initial performance test specified in 40 CFR (a) shall be maintained in the same closed and sealed position as during the performance test at all times except when necessary to use the opening for sampling, inspection, maintenance, or repairs. Each component of the closed-vent system used to comply with 40 CFR Sections (c) and (b) that is operated at positive pressure and located prior to a control device shall be designed for and operated with no detectable leaks as indicated by an instrument reading of less than 500 ppm by volume above background, as measured by the procedures in 40 CFR (d). Each bypass line in the closed-vent system that could divert vent streams containing HAP to the atmosphere without meeting the emission limitations in 40 CFR Section or shall comply with either of the following requirements: 1. On each bypass line, the owner or operator shall install, calibrate, maintain and operate according to manufacturer's specifications, a flow indicator that provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The flow indicator shall be installed in the bypass line in such a way as to indicate flow in the bypass line; or 2. For bypass line valves that are not computer controlled, the owner or operator shall maintain the bypass line valve in the closed position with a car seal or a seal placed on the valve or closure mechanism in such a way that the valve or closure mechanism cannot be opened without breaking the seal. [40 CFR (b), Minn. R ] Monitoring Requirements for Enclosure and Closed-vent Systems: 1. For each enclosure opening, a visual inspection of the closure mechanism specified in 40 CFR (b) shall be performed at least once every month to ensure the opening is maintained in the closed position and sealed. 2. Each closed-vent system required by 40 CFR (a) shall be visually inspected at least once every month with at least 21 days between inspections, and at other times as required by the Administrator. The visual inspection shall include inspection of ductwork, piping, enclosures and connections to covers for visible evidence of defects. 3. For positive pressure closed-vent systems or portions of closedvent systems, demonstrate no detectable leaks as specified in 40 CFR (c) measured initially and annually by the procedures in

31 Permit expires: [month day, year] Page 31 of CFR (d). 4. Demonstrate initially and annually that each enclosure opening is maintained at negative pressure as specified in 40 CFR (e). 5. The valve or closure mechanism specified in 40 CFR (d)(2) shall be inspected at least once every month with at least 21 days between inspections, to ensure that the valve is maintained in the closed position and the emission point gas stream is not diverted through the bypass line. 6. If an inspection required by paragraphs 1 through 5 of this section identified visible defects in ductwork, piping or enclosure or connections to covers required by 40 CFR , or if an instrument reading of 500 ppm by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions shall be taken as soon as practicable: i. A first effort to repair or correct the closed-vent system shall be made as soon as practicable but no later than 5 calendar days after the problem is identified. ii. The repair or corrective action shall be completed no later than 15 calendar days after the problem is identified. [40 CFR (k), Minn. R ] Site-Specific Inspection Plan: The Permittee shall prepare and maintain a site-specific inspection plan for each applicable enclosure opening, closed-vent system, and closed collection system. The Plan shall include a drawing or schematic of the components of applicable affected equipment. The Permittee shall record the information described in 40 CFR (b) for each inspection. [40 CFR (b), Minn. R ] The Permittee must maintain records of any occurrence when corrective action is required under 40 CFR (k)(1), and when a violation is noted under 40 CFR (k)(2). [40 CFR (b), Minn. R ] In addition to the general records required by 40 CFR 63.10(b)(2), maintain records of the following information: - Records of dry virgin black liquor solids firing rates in units of tons/day for all recovery furnaces; - Records and documentation of supporting calculations for compliance determinations made under 40 CFR (a)-(d); - Records of monitoring parameter ranges established for each process unit. [40 CFR (c), Minn. R ] The owner or operator of any affected source or process unit must submit the applicable notifications from 40 CFR pt. 63 subp. A, as specified in Table 1 of 40 CFR pt. 63 subp. MM. [40 CFR (a), Minn. R ] Excess emissions report: submit a report quarterly if measured parameters meet any of the conditions specified in 40 CFR (k)(1) or (2). The report must contain the information specified in 40 CFR 63.10(c), as well as the number and duration of occurrences when the conditions in in 40 CFR (k)(1) or (2) were met or exceeded. Reporting excess emissions below the

32 Permit expires: [month day, year] Page 32 of 243 violation thresholds of 40 CFR (k) does not constitute a violation of the applicable standard. When no exceedances of parameters have occurred, submit a semiannual report stating that no excess emissions occurred during the reporting period. Excess emissions and/or summary reports for the mill for requirements of subpart MM or subpart S may be combined into one report. [40 CFR (c), Minn. R ] The Permittee shall not have engines that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as the engine it replaced will be included in calculating the consecutive time period. [40 CFR ] For a nonroad engine that is excluded from any requirements of 40 CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part The Permittee may not circumvent or attempt to circumvent the residence-time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section [40 CFR (b)(3)] The Permittee shall keep records of all engines on-site that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite and operated by a vendor or contractor. The records shall include the following: 1) Date that the nonroad engine is brought onsite 2) Date that the nonroad engine is taken offsite and/or moved to a different location. 3) Identification number. 4) Rated capacity of the nonroad engine. 5) The model year and date of manufacture (as defined by the applicable nonroad engine rule). 6) Which nonroad provision that the nonroad engine is certified under. 7) Rental company information. 8) Function of the nonroad engine (e.g. compressor, welder). 9) Location of the engine within the stationary source. 10) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section [40 CFR (nonrd engn)(1)(iii), Minn. R , subps. 4-5]

33 Permit expires: [month day, year] Page 33 of A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if: 1. At any time, it meets the criteria specified in section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroad engine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). [40 CFR (e)] COMG 1 GP008 Fuel limits: #7, #8 and #9 Boilers All requirements under this subject item apply to EQUI 2 and EQUI 4 (Power Boilers #7 and #9) only, unless otherwise noted in the requirement below. See Subject Items EQUI 2, EQUI 4, and EQUI 18 for additional requirements. [Minn. R , subp. 2] Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF (combustible derived fuel, which consists of office paper, cardboard, scrap pallets, scrap lumber, press trials prints, waste lap pulp or other non-food product wood-based wastes generated at the Cloquet mill), and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in Power Boilers #7 and #9. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Fuel Usage <= tons per year 12-month rolling sum, on a wet basis (WOOD AND MILL WASTE USAGE LIMIT). The wood and mill waste usage limit includes railroad ties, CDF, knots and screen rejects and bark, peat and/or sawdust used to soak up oil and chemical spills. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Fuel Usage <= 4.0 million gallons per year 12-month rolling sum (#2 FUEL OIL USAGE LIMIT). The limit for #2 fuel oil is 4,000,000 gallons/year for a combined basis for #7, #8, and #9 boilers (EQUI2, EQUI18, and EQUI4) on a 12-month rolling sum basis. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Sulfur Content of Fuel <= 0.05 percent by weight for #2 fuel oil.

34 Permit expires: [month day, year] Page 34 of 243 [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R ] Fuel Usage <= tons per year 12-month rolling sum on a dry basis (WASTEWATER TREATMENT PLANT SLUDGE USAGE LIMIT). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Vendor Certifications: For all fuel oil burned in Power Boiler #7 (EQUI2) and Power Boiler #9 (EQUI4), maintain oil vendor information on site that documents oil sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of the fuel oil. This information shall be maintained on site. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2)& Minn. R ] Recordkeeping: By the 15th day of each month, record the wood and mill waste (including railroad ties, knots and screen rejects, bark, peat, and/or sawdust used to soak up oil and chemical spills) usage for the previous month, and the previous 12 months (12- month rolling sum). [Minn. R , subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Recordkeeping: By the 15th day of each month, record the fuel oil usage for the previous month and the previous 12 months (12- month rolling sum). [Minn. R , subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Recordkeeping: By the 15th day of each month, record the sludge usage for the previous month and the previous 12 months (12- month rolling sum). [Minn. R , subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] COMG 2 GP003 NCG System HAPs - Total <= 20 parts per million by volume, corrected to 10% oxygen on a dry basis. [40 CFR (a)(1)(i), 40 CFR (d)(2), Minn. R ] HAP Control: Gases from the LVHC, HVLC, and Stripper Off Gas systems shall be combusted in the Incinerator-Quencher-Scrubber (IQS), or Boiler #7 or #9 as backup. When gases are burned in the IQS, the Total HAPs limit applies, and the temperature of the IQS is to be monitored as described under TREA 30 (Incinerator for TRS on IQS). When the gases are burned in the backup (Boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. [40 CFR (a)(1)(i), 40 CFR (d)(2), Minn. R ] Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section and as described

35 Permit expires: [month day, year] Page 35 of 243 in the Total Facility subject item. [40 CFR (c), 40 CFR , Minn. R ] TRS Control: Gases from the NCG sources shall be combusted in the IQS (EQUI49), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. This requirement always applies, but is generally less stringent than the MACT requirement (40 CFR ) which also applies. [40 CFR (a)(1)(iii), Minn. R , subp. 2, Minn. R ] The Permittee is not subject to 40 CFR Section (b)(1) or 40 CFR Section (d)(3)(ii) and is protected by the permit shield provision of Minn. R from any expectation to comply with these requirements. The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EQUI2 and EQUI4) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, EPA "...deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi-annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. [40 CFR (b)(1), 40 CFR (d)(3)(ii), Minn. R (A)(2), Minn. R ] COMG 3 GP004 Process Condensates Pulping Process Condensates: Pulping process condensates as listed in 40 CFR Section (b) shall be conveyed in a closed collection system that is designed and operated to meet the requirements specified in 40 CFR Section (d)(1)-(2). [40 CFR (d), Minn. R ] HAPs - Total >= 11.1 pounds per ton of ODP of pulping process condensates from equipment systems listed in 40 CFR Section (b)(1)-(b)(5) shall be collected. [40 CFR (c)(3), Minn. R ] The Permittee shall reduce HAPs - Total >= 92 percent by weight. The pulping process condensates shall be: - Treated to reduce or destroy the total HAPs by 92% or more by weight; or - Recycled to an equipment system specified in 40 CFR Section (a); or - Treated by removing 10.2 lbs/ton of ODP or achieving a total HAP concentration of 330 ppm or less by weight at the outlet of the control device. [40 CFR (e), Minn. R ] Monitoring: Permittee shall install, calibrate, certify, operate, and maintain continuous monitoring systems as required by 40 CFR

36 Permit expires: [month day, year] Page 36 of 243 Section [40 CFR , Minn. R ] COMG 7 GP CFR pt. 63, subp. DDDDD Requirements COMG 7 contains requirements from 40 CFR pt. 63, subp. DDDDD that apply to all the emission units subject to DDDDD: EQUI 2 (Power Boiler #7), EQUI 4 (Power Boiler #9), EQUI 18 (Power Boiler #8), and EQUI 290 (R&D Boiler). Further requirements that apply specifically to each boiler can be found at the EQUI level. [Minn. R , subp. 2] CFR pt. 63 General Provisions: 40 CFR pt. 63, subp. DDDDD, Table 10 shows which parts of the General Provisions in 40 CFR Sections apply. [40 CFR , Minn. R ] At all times, the Permittee must operate and maintain any affected source (as defined in 40 CFR Section ), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR (a)(3), Minn. R ] General Compliance Requirements. The Permittee must be in compliance with the emission limits, work practice standards, and operating limits in 40 CFR pt. 63, subp. DDDDD. These limits apply at all times the affected unit is operating, except during periods of startup and shutdown during which time the Permittee must comply only with 40 CFR pt. 63, subp. DDDDD, Table 3. [40 CFR (f), 40 CFR (a), Minn. R ] General Compliance Requirements. The Permittee must demonstrate compliance with all applicable emission limits using performance stack testing, fuel analysis, or CMS, including a CEMS, COMS, CPMS, or PM CPMS, where applicable. The Permittee may demonstrate compliance with the applicable emission limit for HCl, mercury, or TSM using fuel analysis if the emission rate calculated according to 40 CFR Section (c) is less than the applicable emission limit. (For gaseous fuels, the Permittee may not use fuel analyses to comply with the TSM alternative standard or the HCl standard.) Otherwise, the Permittee must demonstrate compliance for HCl, mercury, or TSM using performance testing, if subject to an applicable emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR (c), Minn. R ] General Compliance Requirements - Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with 40 CFR pt. 63, subp. DDDDD. Such concealment includes, but is not limited to:

37 Permit expires: [month day, year] Page 37 of the use of diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD based on the concentration of a pollutant in the effluent discharged to the atmosphere; or - the use of gaseous diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD for visible emissions. [40 CFR 63.4(b), Minn. R ] General Compliance Requirements. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(2)(iii). [40 CFR 63.6(f)(2), Minn. R ] Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(f)(3), Minn. R ] Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with an opacity or visible emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD and any information available needed to determine whether proper operation and maintenance practices are being used. [40 CFR 63.6(h)(8), Minn. R ] If the Commissioner or the Administrator finds that the affected source is in compliance with all relevant standards for which initial performance tests were conducted, but during the time such performance tests were conducted fails to meet any relevant opacity emission standard, the Permittee may petition the Administrator to make appropriate adjustment to the opacity emission standard for the affected source. Until the Administrator notifies the Permittee, the relevant opacity emission standard remains applicable. [40 CFR 63.6(h)(9), Minn. R ] The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR Section 63.6(g). [40 CFR 63.6(g), Minn. R ] Methods for Determining Compliance. Compliance with opacity emission standards shall be determined by using the results from the COMS. [40 CFR 63.6(h)(2), Minn. R ] The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). [40 CFR 63.6(i), Minn. R ] Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. [40 CFR 63.6(i)(1), Minn. R ]

38 Permit expires: [month day, year] Page 38 of The Permittee must meet the work practice standard according to 40 CFR pt. 63, subp. DDDDD, Table 3. During startup and shutdown, the Permittee must only follow the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR (h), Minn. R ] For each boiler that is required or that the Permittee elects to demonstrate compliance with any of the applicable emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2 through performance testing, the initial compliance requirements include all the following: - Conduct performance tests according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 5. - Conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 6, except as specified in 40 CFR Section (a)(2)(i)-(iii). - Establish operating limits according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 7. - Conduct CMS performance evaluations according to 40 CFR Section [40 CFR (a), Minn. R ] For existing affected sources (as defined in 40 CFR Section ) that have not operated between the effective date of 40 CFR pt. 63, subp. DDDDD and January 31, 2016, the Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section (a)(10)(i)-(vi) no later than 30 days after the re-start of the affected source and complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3, no later than the compliance date specified in 40 CFR Section [40 CFR (j), Minn. R ] Following the date on which the initial compliance demonstration is completed or is required to be completed under 40 CFR Sections 63.7 and , whichever date comes first, operation above the established maximum or below the established minimum operating limits shall constitute a deviation of established operating limits listed in 40 CFR pt. 63, subp. DDDDD, Table 4 except during performance tests conducted to determine compliance with the emission limits or to establish new operating limits. Operating limits must be confirmed or reestablished during performance tests. [40 CFR (a)(1), Minn. R ] The Permittee must report each instance in which the Permittee did not meet each emission limit and operating limit in 40 CFR pt. 63, subp. DDDDD, Tables 2-4 that apply. These instances are deviations from the emission limits or operating limits, respectively, in 40 CFR pt. 63, subp. DDDDD. These deviations must be reported according to the requirements in 40 CFR Section [40 CFR (b), Minn. R ] The Permittee must report the results of performance tests and the associated fuel analyses within 60 days after the completion of the performance tests. This report must also verify that the

39 Permit expires: [month day, year] Page 39 of 243 operating limits for each boiler have not changed or provide documentation of revised operating limits established according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 7, as applicable. The reports for all subsequent performance tests must include all applicable information required in 40 CFR Section [40 CFR (f), Minn. R ] For affected sources that have not operated since the previous compliance demonstration and more than one year has passed since the previous compliance demonstration, you must complete the subsequent compliance demonstration, if subject to the emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2, no later than 180 days after the re-start of the affected source and according to the applicable provisions in 40 CFR Section 63.7(a)(2) as cited in 40 CFR pt. 63, subp. DDDDD, Table 10. The Permittee must complete a subsequent tune-up by following the procedures described in 40 CFR Section (a)(10)(i)-(vi) and the schedule described in 40 CFR Section (a)(13) for units that are not operating at the time of their scheduled tune-up. [40 CFR (g), Minn. R ] The Permittee must conduct tune-ups of boilers demonstrate compliance as specified below: - As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; - Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; - Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; - Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; - Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [40 CFR (a)(10)(i)-(v), Minn. R ] Maintain on-site and submit, if requested by the Administrator, a

40 Permit expires: [month day, year] Page 40 of 243 report containing the information below: - The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler; - A description of any corrective actions taken as a part of the tune-up; and - The type and amount of fuel used over the 12 months prior to the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [40 CFR (a)(10)(vi), Minn. R ] Stack Tests and Procedures. The Permittee must conduct all performance tests according to 40 CFR Section 63.7(c), (d), (f), and (h). The Permittee must also develop a Site-Specific Test Plan according to the requirements in 40 CFR Section 63.7(c). The Permittee shall conduct all performance tests under such conditions as the Administrator specifies based on the representative performance of each boiler for the period being tested. Upon request, the Permittee shall make available to the Administrator such records as may be necessary to determine the conditions of the performance tests. [40 CFR (a), Minn. R ] Stack Tests and Procedures. The Permittee must conduct each performance test according to the requirements in 40 CFR pt. 63, subp. DDDDD, Table 5. [40 CFR (b), Minn. R ] Stack Tests and Procedures. The Permittee must conduct each performance test under the specific conditions listed in 40 CFR pt. 63, subp. DDDDD, Tables 5 and 7. The Permittee must conduct performance tests at representative operating load conditions while burning the type of fuel or mixture of fuels that has the highest content of chlorine and mercury and the Permittee must demonstrate initial compliance and establish operating limits based on these performance tests. These requirements could result in the need to conduct more than one performance test. Following each performance test and until the next performance test, the Permittee must comply with the operating limit for operating load conditions specified in 40 CFR pt. 63, subp. DDDDD, Table 4. [40 CFR (c), Minn. R ] Stack Tests and Procedures. The Permittee must conduct a minimum of three separate test runs for each performance test required in 40 CFR Section , as specified in 40 CFR Section 63.7(e)(3). Each test run must comply with the minimum applicable sampling times or volumes specified in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR (d), Minn. R ] Stack Tests and Procedures. To determine compliance with the emission limits, the Permittee must use the F-Factor methodology and equations in Sections 12.2 and 12.3 of EPA Reference Method 19 to convert the measured PM concentrations that result from the performance test to pounds per million Btu heat input

41 Permit expires: [month day, year] Page 41 of 243 emission rates. [40 CFR (e), Minn. R ] Stack Tests and Procedures. Except for a 30-day rolling average based on CEMS data, if measurement results for any pollutant are reported as below the method detection level, the Permittee must use the method detection level as the measured emissions level for that pollutant in calculating compliance. The measured result for a multiple component analysis may include a combination of method detection level data and analytical data reported above the method detection level. [40 CFR (f), Minn. R ] Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must collect a minimum of 2 dry standard cubic meters of sample gas per run. [40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must: - Select sampling ports location and the number of traverse points using Method 1 at 40 CFR pt. 60, Appendix A-1; - Determine velocity and volumetric flow-rate of the stack gas using Method 2, 2F, or 2G at 40 CFR pt. 60, Appendix A-1 or A-2; - Determine oxygen or carbon dioxide concentration of the stack gas using Method 3A or 3B at 40 CFR pt. 60, Appendix A-2, or ANSI/ASME PTC ; - Measure the moisture content of the stack gas using Method 4 at 40 CFR pt. 60, Appendix A-3; - Measure the PM emission concentration using Method 5 or 17 at 40 CFR pt. 60, Appendix A-3 or A-6; and - Convert emissions concentration to lb per MMBtu emission rates using Method 19 F-factor methodology at 40 CFR pt. 60, Appendix A-7. [40 CFR pt. 63, subp. DDDDD(Table 5), Minn. R ] Site-Specific Test Plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Commissioner or the Administrator, shall submit a Site-Specific Test Plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). [40 CFR 63.7(c)(2), Minn. R ] Site-Specific Test Plan. The Administrator will notify the Permittee of approval or intention to deny approval of the Site-Specific Test Plan (if review of the Site-Specific Test Plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. [40 CFR 63.7(c)(3), Minn. R ] Performance Testing Facilities. The Permittee, at the request of the Commissioner or the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). [40 CFR 63.7(d), Minn. R ] Conduct of Performance Tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in 40 CFR pt. 63, subp. DDDDD, and, if required, in applicable

42 Permit expires: [month day, year] Page 42 of 243 appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). [40 CFR 63.7(e)(2), Minn. R ] Conduct of Performance Tests. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in 40 CFR pt. 63, subp. DDDDD. For the purpose of determining compliance with 40 CFR pt. 63, subp. DDDDD, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). [40 CFR 63.7(e)(3), Minn. R ] Data Analysis, Recordkeeping, and Reporting. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, or as otherwise approved by the Commissioner or Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The Permittee shall report the results of the performance test to the Commissioner or Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in 40 CFR pt. 63, subp. DDDDD or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. [40 CFR 63.7(g), Minn. R ] Waiver of Performance Tests. Until a waiver of a performance testing requirement has been granted by the Commissioner or the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). [40 CFR 63.7(h), Minn. R ] Conduct of Opacity or Visible Emission Observations. For initial compliance, opacity or visible emission observations shall be conducted concurrently with the initial performance test unless otherwise specified in 40 CFR Section 63.6(h)(5)(A) and (B). [40 CFR 63.6(h)(5), Minn. R ] General Fuel Analysis Requirements. The Permittee must conduct fuel analyses for chloride and mercury according to the procedures in 40 CFR Section (b)-(e) and 40 CFR pt. 63, subp. DDDDD, Table 6, as applicable. The Permittee is not required to conduct fuel analyses for fuels used for only startup, unit shutdown, and transient flame stability purposes. The Permittee is required to conduct fuel analyses only for fuels and units that are subject to emission limits for mercury or HCl in 40 CFR pt. 63, subp. DDDDD, Table 2. Gaseous and liquid fuels are exempt from the sampling requirements in 40 CFR Section (c) and (d) and 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR (a), Minn. R ]

43 Permit expires: [month day, year] Page 43 of Site-Specific Fuel Monitoring Plan. The Permittee must develop a Site-Specific Fuel Monitoring Plan according to the procedures and requirements in 40 CFR Section (b)(1) and (2). [40 CFR (b), Minn. R ] Site-Specific Fuel Monitoring Plan. If the Permittee intends to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must submit the fuel analysis plan to the Administrator for review and approval no later than 60 days before the date that the Permittee intends to conduct the initial compliance demonstration described in 40 CFR Section [40 CFR (b)(1), Minn. R ] Site-Specific Fuel Monitoring Plan. The Permittee must include the information below in the fuel analysis plan. - The identification of all fuel types anticipated to be burned in each boiler; - For each anticipated fuel type, the notification of whether the Permittee or a fuel supplier will be conducting the fuel analysis; - For each anticipated fuel type, a detailed description of the sample location and specific procedures to be used for collecting and preparing the composite samples if the procedures are different from 40 CFR Section (c) or (d). Samples should be collected at a location that most accurately represents the fuel type, where possible, at a point prior to mixing with other dissimilar fuel types; - For each anticipated fuel type, the analytical methods from 40 CFR pt. 63, subp. DDDDD, Table 6, with the expected minimum detection levels, to be used for the measurement of chlorine or mercury; - If the Permittee requests to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must also include a detailed description of the methods and procedures that the Permittee is proposing to use. Methods in 40 CFR pt. 63, subp. DDDDD, Table 6 shall be used until the requested alternative is approved; and - If the Permittee will be using fuel analysis from a fuel supplier in lieu of site-specific sampling and analysis, the fuel supplier must use the analytical methods required by 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR (b)(2), Minn. R ] Fuel Analysis Procedure. At a minimum, the Permittee must obtain three composite fuel samples for each fuel type according to the procedures in 40 CFR Section (c)(1) or (2), or the methods listed in 40 CFR pt. 63, subp. DDDDD, Table 6, or use an automated sampling mechanism that provides representative composite fuel samples for each fuel type that includes both coarse and fine material. [40 CFR (c), Minn. R ] Fuel Analysis Procedure. If sampling from a belt (or screw) feeder, the Permittee must collect fuel samples according to the requirements below. - Stop the belt and withdraw a 6-inch wide sample from the full

44 Permit expires: [month day, year] Page 44 of 243 cross-section of the stopped belt to obtain a minimum two pounds of sample. The Permittee must collect all the material (fines and coarse) in the full cross-section. The Permittee must transfer the sample to a clean plastic bag. - Each composite sample will consist of a minimum of three samples collected at approximately equal one-hour intervals during the testing period for sampling during performance stack testing. For monthly sampling, each composite sample shall be collected at approximately equal 10-day intervals during the month. [40 CFR (c)(1), Minn. R ] Fuel Analysis Procedure. If sampling from a fuel pile or truck, the Permittee must collect fuel samples according to the requirements below. - For each composite sample, the Permittee must select a minimum of five sampling locations uniformly spaced over the surface of the pile. - At each sampling site, the Permittee must dig into the pile to a uniform depth of approximately 18 inches. The Permittee must insert a clean shovel into the hole and withdraw a sample, making sure that large pieces do not fall off during sampling; use the same shovel to collect all samples. - The Permittee must transfer all samples to a clean plastic bag for further processing. [40 CFR (c)(2), Minn. R ] Fuel Analysis Procedure. The Permittee must prepare each composite sample according to the procedures below. - The Permittee must thoroughly mix and pour the entire composite sample over a clean plastic sheet; - The Permittee must break large sample pieces (e.g., larger than 3 inches) into smaller sizes; - The Permittee must make a pie shape with the entire composite sample and subdivide it into four equal parts; - The Permittee must separate one of the quarter samples as the first subset; - If this subset is too large for grinding, the Permittee must repeat the procedure in 40 CFR Section (d)(3) with the quarter sample and obtain a one-quarter subset from this sample; - The Permittee must grind the sample in a mill; and - The Permittee must use the procedure in 40 CFR Section (d)(3) to obtain a one-quarter subsample for analysis. If the quarter sample is too large, subdivide it further using the same procedure. [40 CFR (d), Minn. R ] Fuel Analysis Procedure. The Permittee must determine the concentration of pollutants in the fuel (mercury and/or chlorine) in units of pounds per million Btu of each composite sample for each fuel type according to the procedures in 40 CFR pt. 63, subp. DDDDD, Table 6, for use in Equations 7, 8, and 9 of 40 CFR pt. 63, subp. DDDDD. [40 CFR (e), Minn. R ] Mercury Fuel Analysis. To conduct a fuel analysis for mercury, the Permittee must:

45 Permit expires: [month day, year] Page 45 of Collect fuel samples using the procedure in 40 CFR Section (c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or EPA 1631 or EPA 1631E or ASTM D6323 (for solid), or EPA 821-R (for liquid or solid), or ASTM D4177 (for liquid), or ASTM D4057 (for liquid), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section (d) or equivalent; - Prepare composited fuel samples using EPA SW B (for solid samples), EPA SW A (for liquid samples), ASTM D2013/D2013M (for coal), ASTM D5198 (for biomass), or EPA 3050 (for solid fuel), or EPA 821-R (for liquid or solid), or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), or ASTM D5864 (for liquids and other solids), or ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173, ASTM E871, or ASTM D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Measure mercury concentration in fuel sample using ASTM D6722 (for coal), EPA SW B (for solid samples), or EPA SW A (for liquid samples), or equivalent; - Convert concentration into units of pounds of mercury per MMBtu of heat content using Equation 8 in 40 CFR Section ; and - Calculate the mercury emission rate from the boiler in units of pounds per million Btu using Equations 10 and 12 in 40 CFR Section [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R ] HCl Fuel Analysis. To conduct a fuel analysis for HCl, the Permittee must: - Collect fuel samples using the procedure in 40 CFR Section (c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or ASTM D6323 (for coal or biomass), ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section (d) or equivalent; - Prepare composited fuel samples using EPA SW B (for solid samples), EPA SW A (for liquid samples), ASTM D2013/D2013M (for coal), or ASTM D5198 (for biomass), or EPA 3050 or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), ASTM D5864, ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173 or ASTM E871, or D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels) or equivalent;

46 Permit expires: [month day, year] Page 46 of Measure chlorine concentration in fuel sample using EPA SW , ASTM D6721, ASTM D4208 (for coal), or EPA SW or ASTM E776 (for solid fuel), or EPA SW or SW (for solids or liquids) or equivalent. - Convert concentrations into units of pounds of HCl per MMBtu of heat content using Equation 7 in 40 CFR Section ; and - Calculate the HCl emission rate from the boiler in units of pounds per million Btu using Equations 10 and 11 in 40 CFR Section [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R ] General Compliance Requirements: If the Permittee demonstrates compliance with any applicable emission limit through performance testing and subsequent compliance with operating limits (including the use of CPMS), or with a CEMS, or COMS, the Permittee must develop a Site-Specific Monitoring Plan according to the requirements in 40 CFR Section (d)(1)-(4) for the use of any CEMS, COMS, or CPMS. This requirement also applies if the Permittee petitions the EPA Administrator for alternative monitoring parameters under 40 CFR Section 63.8(f). [40 CFR (d), Minn. R ] Site-Specific Monitoring Plan. For each CMS required in 40 CFR Section (including CEMS, COMS, or CPMS), the Permittee must develop, and submit to the Administrator for approval upon request, a Site-Specific Monitoring Plan that addresses design, data collection, and the quality assurance and quality control elements outlined in 40 CFR Section 63.8(d) and the elements described below: - Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device); - Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and - Performance evaluation procedures and acceptance criteria (e.g., calibrations, accuracy audits, analytical drift). [40 CFR (d)(1), Minn. R ] Site-Specific Monitoring Plan. The Permittee must submit this Site- Specific Monitoring Plan, if requested, at least 60 days before the initial performance evaluation of the CMS. This requirement to develop and submit a Site-Specific Monitoring Plan does not apply to affected sources with existing CEMS or COMS operated according to the performance specifications under 40 CFR pt. 60, Appendix B and that meet the requirements of 40 CFR Section Using the process described in 40 CFR Section 63.8(f)(4), the Permittee may request approval of alternative monitoring system quality assurance and quality control procedures in place of those specified in 40 CFR Section (d)(1) and, if approved, include the alternatives in the Site-Specific Monitoring Plan. [40 CFR (d)(1), Minn. R ]

47 Permit expires: [month day, year] Page 47 of Site-Specific Monitoring Plan. In the Site-Specific Monitoring Plan, the Permittee must also address the items below: - Ongoing operation and maintenance procedures in accordance with the general requirements of 40 CFR Section 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii); - Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR Section 63.8(d); and - Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR Section 63.10(c) (as applicable in 40 CFR pt. 63, subp. DDDDD, Table 10), (e)(1), and (e)(2)(i). [40 CFR (d)(2), Minn. R ] Site-Specific Monitoring Plan. The Permittee must conduct a performance evaluation of each CMS in accordance with the Site- Specific Monitoring Plan. [40 CFR (d)(3), Minn. R ] Site-Specific Monitoring Plan. The Permittee must operate and maintain the CMS in continuous operation according to the Site- Specific Monitoring Plan. [40 CFR (d)(4), Minn. R ] Monitoring Data. the Permittee must monitor and collect data according to 40 CFR Section and the Site-Specific Monitoring Plan required by 40 CFR Section (d). [40 CFR (a), Minn. R ] Monitoring Data. The Permittee must operate the monitoring system and collect data at all required intervals at all times that each boiler is operating and compliance is required, except for periods of monitoring system malfunctions or out of control periods, and required monitoring system quality assurance or control activities, including, as applicable, calibration checks, required zero and span adjustments, and scheduled CMS maintenance as defined in the Site-Specific Monitoring Plan. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. The Permittee is required to complete monitoring system repairs in response to monitoring system malfunctions or out-of-control periods and to return the monitoring system to operation as expeditiously as practicable. [40 CFR (b), Minn. R ] Monitoring Data. The Permittee may not use data recorded during monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, or required monitoring system quality assurance or control activities in data averages and calculations used to report emissions or operating levels. The Permittee must record and make available upon request results of CMS performance audits and dates and duration of periods when the CMS is out of control to completion of the corrective actions necessary to return the

48 Permit expires: [month day, year] Page 48 of 243 CMS to operation consistent with the Site-Specific Monitoring Plan. The Permittee must use all the data collected during all other periods in assessing compliance and the operation of the control device and associated control system. [40 CFR (c), Minn. R ] Monitoring Data. Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits, calibration checks, and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. In calculating monitoring results, do not use any data collected during periods when the monitoring system is out of control as specified in the Site-Specific Monitoring Plan, while conducting repairs associated with periods when the monitoring system is out of control, or while conducting required monitoring system quality assurance or quality control activities. The Permittee must calculate monitoring results using all other monitoring data collected while the process is operating. The Permittee must report all periods when the monitoring system is out of control in the annual report. [40 CFR (d), Minn. R ] Notification Requirements. The Permittee must meet the notification requirements in 40 CFR Section according to the schedule in 40 CFR Section and in 40 CFR pt. 63, subp. A. Some of the notifications must be submitted before the Permittee is required to comply with the emission limits and work practice standards in 40 CFR pt. 63, subp. DDDDD. [40 CFR (d), Minn. R ] General Notifications. The Permittee must submit to the Administrator all of the notifications in 40 CFR Sections 63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b)-(h) that apply by the dates specified. [40 CFR (a), Minn. R ] Notification of Intent. The Permittee must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin. [40 CFR (d), 40 CFR 63.9(e), Minn. R , Minn. R ] Notification of Solid Waste Combustion. If the Permittee intends to commence or recommence combustion of solid waste, the Permittee must provide 30 days prior notice of the date upon which the Permittee will commence or recommence combustion of solid waste. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that will commence burning solid waste, and the date of the notice. - The currently applicable subcategories under 40 CFR pt. 63, subp. DDDDD. - The date on which the Permittee became subject to the currently applicable emission limits. - The date upon which the Permittee will commence combusting

49 Permit expires: [month day, year] Page 49 of 243 solid waste. [40 CFR (g), Minn. R ] Notification of Fuel Switch or Physical Change. If the Permittee has switched fuels or made a physical change to the boiler and the fuel switch or physical change resulted in the applicability of a different subcategory, the Permittee must provide notice of the date upon which the Permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that have switched fuels, were physically changed, and the date of the notice; - The currently applicable subcategory under this subpart; and - The date upon which the fuel switch or physical change occurred. [40 CFR (h), Minn. R ] Notification of Performance Test. - The Permittee must notify the Commissioner and the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. - In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Commissioner and the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. [40 CFR 63.7(b), Minn. R ] Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible emission observations in accordance with 40 CFR Section 63.9(f). [40 CFR 63.6(h)(4), Minn. R ] Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible emission observations. The notification shall be submitted with the notification of the performance test date, or if no performance test is required or visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the initial performance test. The Permittee shall deliver or postmark the notification not less than 30 days before the opacity or visible emission observations are scheduled to take place. [40 CFR 63.9(f), Minn. R ] Change in Information Already Provided. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R ] Compliance Status Report Content. A compliance report must contain:

50 Permit expires: [month day, year] Page 50 of Information required in 40 CFR Section (c)(1)-(5); - If there are no deviations from any emission limitation (emission limit and operating limit) that applies and there are no deviations from the requirements for work practice standards in 40 CFR pt. 63, subp. DDDDD, Table 3 that apply, a statement that there were no deviations from the emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, including CEMS, COMS, CPMS, were outof-control as specified in 40 CFR Section 63.8(c)(7), a statement that there were no periods during which the CMSs were out-ofcontrol during the reporting period; - If the Permittee has a deviation from any emission limitation (emission limit and operating limit) where the Permittee is not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard during the reporting period, the report must contain the information in 40 CFR Section (d); and - If there were periods during which the CMSs, in including CEMS, COMS, CPMS, were out-of-control as specified in 40 CFR Section 63.8(c)(7), or otherwise not operating, the report must contain the information in 40 CFR Section (e). [40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] Compliance Status Report Content. A compliance report must contain the following information: - Company and Facility name and address; - Process unit information, emissions limitations, and operating parameter limitations; - Date of report and beginning and ending dates of the reporting period; and - The total operating time during the reporting period. [40 CFR (c)(5)(i)-(iv), Minn. R ] Compliance Status Report Content. A compliance report must contain the monitoring equipment manufacturer(s) and model numbers and the date of the last CMS certification or audit. [40 CFR (c)(5)(v), Minn. R ] Compliance Status Report Content. A compliance report must contain the total fuel use by each individual boiler subject to an emission limit within the reporting period, including, but not limited to, a description of the fuel, whether the fuel has received a non-waste determination by the EPA or the basis for concluding that the fuel is not a waste, and the total fuel usage amount with units of measure. [40 CFR (c)(5)(vi), Minn. R ] Compliance Status Report Content. If the Permittee is conducting performance tests once every 3 years consistent with 40 CFR Section (b) or (c), a compliance report must contain the date of the last 2 performance tests and a statement as to whether there have been any operational changes since the last performance test that could increase emissions. [40 CFR (c)(5)(vii), Minn. R ]

51 Permit expires: [month day, year] Page 51 of Compliance Status Report Content. A compliance report must contain a statement indicating that the Permittee burned no new types of fuel in an individual boiler subject to an emission limit. Or, if the Permittee did burn a new type of fuel, the Permittee must submit the calculation of HCl emission rate using Equation 16 of 40 CFR Section that demonstrates that the source is still meeting the emission limit for HCl emissions and the calculation of mercury emission rate using Equation 17 of 40 CFR Section that demonstrates that the source is still meeting the emission limit for mercury emissions. [40 CFR (c)(5)(viii), Minn. R ] Compliance Status Report Content. If the Permittee wishes to burn a new type of fuel in an individual boiler subject to an emission limit and cannot demonstrate compliance with the maximum chlorine input operating limit using Equation 7 of 40 CFR Section or the maximum mercury input operating limit using Equation 8 of 40 CFR Section , the Permittee must include in the Compliance Report a statement indicating the intent to conduct a new performance test within 60 days of starting to burn the new fuel. [40 CFR (c)(5)(ix), Minn. R ] Compliance Status Report Content. A compliance report must contain a summary of any monthly fuel analyses conducted to demonstrate compliance according to 40 CFR Sections and for individual boilers subject to emission limits, and any fuel specification analyses conducted according to 40 CFR Sections (f) and (g). [40 CFR (c)(5)(x), Minn. R ] Compliance Status Report Content. If there are no deviations from any emission limits or operating limits in 40 CFR pt. 63, subp. DDDDD that apply, a compliance report must contain a statement that there were no deviations from the emission limits or operating limits during the reporting period. [40 CFR (c)(5)(xi), Minn. R ] Compliance Status Report Content. If there were no deviations from the monitoring requirements including no periods during which the CMSs, including CEMS, COMS, and CPMS, were out of control as specified in 40 CFR Section 63.8(c)(7), a compliance report must contain a statement that there were no deviations and no periods during which the CMS were out of control during the reporting period. [40 CFR (c)(5)(xii), Minn. R ] Compliance Status Report Content. If a malfunction occurred during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the Permittee during a malfunction of a boiler or associated air pollution control device or CMS to minimize emissions in accordance with 40 CFR Section (a)(3),

52 Permit expires: [month day, year] Page 52 of 243 including actions taken to correct the malfunction. [40 CFR (c)(5)(xiii), Minn. R ] Compliance Status Report Content. A compliance report must contain the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown. [40 CFR (c)(5)(xiv), Minn. R ] Compliance Status Report Content. For each reporting period, the Compliance Reports must include all of the calculated 30 day rolling average values based on the daily CEMS and CPMS data. [40 CFR (c)(5)(xvi), Minn. R ] Compliance Status Report Content. A compliance report must contain a statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [40 CFR (c)(5)(xvii), Minn. R ] Compliance Status Report Content. For each deviation from an emission limit or operating limit in 40 CFR pt. 63, subp. DDDDD that occurs at an individual boiler where the Permittee is not using a CMS to comply with that emission limit or operating limit, the Compliance Report must additionally contain the information required in 40 CFR Section (d)(1)-(3). - A description of the deviation and which emission limit or operating limit from which the Permittee deviated; - Information on the number, duration, and cause of deviations (including unknown cause), as applicable, and the corrective action taken; and - If the deviation occurred during an annual performance test, provide the date the annual performance test was completed. [40 CFR (d), Minn. R ] Compliance Status Report Content. For each deviation from an emission limit, operating limit, and monitoring requirement in 40 CFR pt. 63, subp. DDDDD occurring at an individual boiler where the Permittee is using a CMS to comply with that emission limit or operating limit, the compliance report must additionally contain the information required in 40 CFR Section (e)(1)-(9). This includes any deviations from the Site-Specific Monitoring Plan as required in 40 CFR Section (d). - The date and time that each deviation started and stopped and description of the nature of the deviation; - The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks; - The date, time, and duration that each CMS was out of control, including the information in 40 CFR Section 63.8(c)(8); - The date and time that each deviation started and stopped; - A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period; - A characterization of the total duration of the deviations during

53 Permit expires: [month day, year] Page 53 of 243 the reporting period into those that are due to control equipment problems, process problems, other known causes, and other unknown causes; - A summary of the total duration of CMS's downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during that reporting period; - A brief description of the source for which there was a deviation; and - A description of any changes in CMSs, processes, or controls since the last reporting period for the source for which there was a deviation. [40 CFR (e), Minn. R ] Compliance Status Report Submittal. The Permittee must submit the Compliance Status Reports according to the procedures specified below. - Within 60 days after the date of completing each performance test as required by 40 CFR pt. 63, subp. DDDDD the Permittee must submit the results of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 63, subp. DDDDD and the compliance reports required in 40 CFR Section (b) to the EPA's WebFIRE database according to the methods in 40 CFR Section (h)(1). - Within 60 days after the date of completing each CEMS performance evaluation test (defined in 40 CFR Section 63.2) the Permittee must submit the relative accuracy test audit (RATA) data to the EPA's Central Data Exchange according to the methods in 40 CFR Section (h)(2). - The Permittee must submit all reports required by 40 CFR pt. 63, subp. DDDDD, Table 9 according to the methods in 40 CFR Section (h)(3). [40 CFR (h), Minn. R ] Use of a COMS. - The Permittee required to use a COMS shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results in accordance with the provisions of 40 CFR Section 63.10(e)(4). - The Permittee may submit, for compliance purposes, COMS data results produced during any performance test required under 40 CFR Section 63.7 in lieu of Method 9 data in accordance with the process specified in 40 CFR Section 63.6(h)(7). - COMS data shall be reduced to 6-minute averages over the duration of the mass emission performance test. - The Permittee is responsible for demonstrating that they have complied with the performance evaluation requirements of 40 CFR Section 63.8(e), that the COMS has been properly maintained, operated, and data quality-assured, as specified in 40 CFR Sections 63.8(c) and (d), and that the resulting data have not been altered in any way. [40 CFR 63.6(h)(7), Minn. R ] General Reporting Requirements. The Permittee shall submit

54 Permit expires: [month day, year] Page 54 of 243 reports to the Commissioner and shall send a copy of each report to the Administrator. [40 CFR 63.10(a), Minn. R ] Progress Reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. [40 CFR 63.10(d)(4), Minn. R ] Additional Reporting Requirements for Sources with Continuous Monitoring Systems. - When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. - The Permittee shall furnish the Commissioner and the Administrator a copy of a written report of the results of the CMS performance evaluation simultaneously with the results of the performance test, unless otherwise specified in 40 CFR pt. 63, subp. DDDDD. The Permittee using a COMS to determine opacity compliance during any performance test shall furnish the Commissioner and the Administrator two or, upon request, three copies of a written report of the results of the COMS performance evaluation. The copies shall be furnished at least 15 calendar days before the performance test is conducted. [40 CFR 63.10(e)(1) and (2), Minn. R ] Excess Emissions and Continuous Monitoring System Performance Report and Summary Report. Excess emissions and parameter monitoring exceedances are defined in 40 CFR pt. 63, subp. DDDDD. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner and the Administrator semiannually, except when more frequent reporting is specifically required by 40 CFR pt. 63, subp. DDDDD or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). [40 CFR 63.10(e)(3)(i) - (iv), Minn. R ] Summary Report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless 40 CFR pt. 63, subp. DDDDD standard specifies that more than one summary report is required). The summary report shall be entitled "Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi). [40 CFR 63.10(e)(3)(vi), Minn. R ] If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. [40 CFR 63.10(e)(3)(vii), Minn. R ]

55 Permit expires: [month day, year] Page 55 of Reporting Continuous Opacity Monitoring System Data Produced During a Performance Test. The Permittee shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results. The report of COMS data shall be submitted simultaneously with the report of the performance test results. [40 CFR 63.10(e)(4), Minn. R ] General Recordkeeping Requirements. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(1), Minn. R ] Records to Keep. The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Status Reports submitted, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv). [40 CFR (a)(1), Minn. R ] Records to Keep. The Permittee must keep records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). [40 CFR (a)(2), Minn. R ] Records to Keep. For each CEMS, COMS, and CMS, the Permittee must keep the following records: - Records described in 40 CFR Section 63.10(b)(2)(vii)-(xi); - Monitoring data for COMS during a performance evaluation as required in 40 CFR Section 63.6(h)(7)(i) and (ii); - Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); - Requests for alternatives to relative accuracy test for CEMS as required in 40 CFR Section 63.8(f)(6)(i); and - Records of the date and time that each deviation started and stopped. [40 CFR (b), Minn. R ] Records to Keep. The Permittee must keep the records required in 40 CFR pt. 63, subp. DDDDD, Table 8 including records of all monitoring data and calculated averages for applicable operating limits, such as opacity and operating load, to show continuous compliance with each emission limit and operating limit that applies. [40 CFR (c), Minn. R ] Records to Keep. The Permittee must keep records of monthly fuel use including the type(s) of fuel and amount(s) used. [40 CFR (d)(1), Minn. R ] Records to Keep. If the Permittee combusts non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR Section 241.3(b)(1) and (2), the Permittee must keep a record that documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If the Permittee combusts a fuel that has been

56 Permit expires: [month day, year] Page 56 of 243 processed from a discarded non-hazardous secondary material pursuant to 40 CFR Section 241.3(b)(4), the Permittee must keep records as to how the operations that produced the fuel satisfy the definition of processing in 40 CFR Section If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR Section 241.3(c), the Permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary materials as fuel per 40 CFR Section 241.4, the Permittee must keep records documenting that the material is listed as a non-waste under 40 CFR Section 241.4(a). Units exempt from the incinerator standards under Section 129(g)(1) of the Clean Air Act because they are qualifying facilities burning a homogeneous waste stream do not need to maintain the records described in 40 CFR Section (d)(2). [40 CFR (d)(2), Minn. R ] Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of HCl emission rates, using Equation 16 of 40 CFR Section , that were done to demonstrate compliance with the HCl emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of HCl emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate HCl emission rate for each boiler. [40 CFR (d)(4), Minn. R ] Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of mercury emission rates, using Equation 17 of 40 CFR Section , that were done to demonstrate compliance with the mercury emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum mercury emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate mercury emission rates for each boiler. [40 CFR (d)(5), Minn. R ] Records to Keep. If, consistent with 40 CFR Section (b), the Permittee chooses to stack test less frequently than annually, the Permittee must keep a record that documents that the emissions in the previous stack test(s) were less than 75 percent of the applicable emission limit and document that there was no change in source operations including fuel composition and operation of air pollution control equipment that would cause emissions of the relevant pollutant to increase within the past year. [40 CFR (d)(6), Minn. R ] Records to Keep. The Permittee must keep records of the occurrence and duration of each malfunction of the boiler or of the associated air pollution control and monitoring equipment. [40 CFR (d)(7), Minn. R ]

57 Permit expires: [month day, year] Page 57 of Records to Keep. The Permittee must keep records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR Section (a)(3), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. [40 CFR (d)(8), Minn. R ] Records to Keep. The Permittee must maintain records of the calendar date, time, occurrence and duration of each startup and shutdown. [40 CFR (d)(10), Minn. R ] Records to Keep. The Permittee must maintain records of the type(s) and amount(s) of fuels used during each startup and shutdown. [40 CFR (d)(11), Minn. R ] Recordkeeping Requirements. The Permittee must keep records in accordance with 40 CFR Sections and 63.10(b)(1). [40 CFR 63.10(b)(1), 40 CFR , Minn. R , Minn. R , subp. 2(B)] Recordkeeping - Visible Emissions. The Permittee shall make available, upon request by the Commissioner or Administrator, such records to determine the conditions under which the visual observations were made and shall provide evidence indicating proof of current visible observer emission certification. [40 CFR 63.6(h)(6), Minn. R ] Additional Recordkeeping Requirements for Sources with Continuous Monitoring Systems. The Permittee shall maintain records as specified within 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions. [40 CFR 63.10(c), Minn. R ] EQUI 2 EU002 Power Boiler #7 (Spreader Stoker - Bark) Particulate Matter <= 15.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 10 micron <= 21.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron <= 10.5 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Front-half Particulate Matter <= pounds per million Btu heat input (filterable PM). [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Opacity <= 10 percent opacity 24-hour block average. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Nitrogen Dioxide <= 90.0 pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

58 Permit expires: [month day, year] Page 58 of Nitrogen Oxides <= 90.0 pounds per hour 1-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= pounds per hour 1-hour average. This limit does not apply when boiler is used as back-up incineration for NCG. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= 4.0 pounds per million Btu heat input 3-hour rolling average while burning solid fuels (such as coal and wood). [Minn. R , subp. 1] Sulfur Dioxide <= 2.0 pounds per million Btu heat input 3-hour rolling average basis when burning fuel oil. [Minn. R , subp. 1] Sulfur Dioxide: When fossil fuels are burned in any combination, the SO2 standard shall be determined by proration using the following formula: PS = [y(2.0)+z(4.0)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil z = % heat input from solid fuel. All emission limits shall be determined on a 3-hour rolling average basis. An alternative limit to this proration equation may be proposed by the Permittee. [Minn. R , subp. 3(A)] Carbon Monoxide <= 2200 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Carbon Monoxide <= 720 parts per million 30-day rolling average calculated by volume on a dry 3% oxygen. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Sulfuric Acid Mist <= 0.13 pounds per hour 3-hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R ] Hydrochloric acid <= pounds per million Btu heat input. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Mercury <= 5.7E-6 pounds per million Btu heat input. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Mercury <= pounds per hour 3-hour average. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Steam Flow <= pounds per hour 8-hour block average while combusting bark, unless a new maximum is set pursuant to Minn. R , subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. [Minn. R , subp. 3] Fuel burned: limited to following fuel types: wood (including

59 Permit expires: [month day, year] Page 59 of 243 railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in Power Boiler #7. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Fuel Usage <= 28.5 tons per hour 8-hour block average unless a new maximum is set pursuant to Minn. R , subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (WOOD/BARK USAGE). Natural gas may be used in addition to bark up to the steam-generating limit. [Minn. R , subp. 3] Fuel Usage <= 502 tons per day 24-hour block average unless a new maximum is set pursuant to Minn. R , subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TIE USAGE LIMIT). [Minn. R , Minn. R , subp. 3, Title I Condition: 40 CFR 52.21] The Permittee shall operate and maintain the ESP (TREA15) at any time that the process equipment controlled by the ESP (EQUI2) is in operation. The Permittee shall document periods of nonoperation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Each day, calculate and record the three (3) 8-hour block average steam flows for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R , subp. 2] Each day, calculate and record the three (3) 8-hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R , subp. 2] Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more than the railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi-annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tie daily limit and shall include the determined railroad tie usage for that day. [Minn.

60 Permit expires: [month day, year] Page 60 of 243 R , subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI2. [40 CFR 64.7(a), Minn. R , Minn. R ] Emissions Monitoring: The Permittee shall use a CO, O2, and SO2 CEMS to measure CO, O2, and SO2 emissions from EQUI2. [Minn. R , Minn. R , Title I Condition: 40 CFR 52.21] Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS. [40 CFR 64.7(a) - (c), Minn. R , Minn. R ] CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of SO2 and CO; and O2 percent by volume on a dry basis. [Minn. R , subp. 2, Minn. R ] Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated according to 40 CFR Section (c) are less than the HCl and mercury emission limits. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Boiler Load. The Permittee must maintain the operating load of each unit such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra-low sulfur diesel, fuel oilsoaked rags, kerosene, hydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/biobased solids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section (b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio-based solids, heavy

61 Permit expires: [month day, year] Page 61 of 243 liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section (b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section (a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section (a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). [40 CFR (b) and (e), Minn. R ] HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR (c)(1), Minn. R ] HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the onesided t-statistic test described in Equation 15 of 40 CFR Section [40 CFR (c)(2), Minn. R ] HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section must not exceed the HCl emission limit. [40 CFR (c)(3), Minn. R ] Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section must not exceed the mercury emission limit. [40 CFR (c)(4), Minn. R ] CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to

62 Permit expires: [month day, year] Page 62 of CFR Section (a) no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). [40 CFR (c) and (e), Minn. R ] Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). (Requirements are found under PERFORMANCE TESTING REQUIREMENTS heading above.). [40 CFR (d) and (e), Minn. R ] Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section (c) using data from the operating load monitors or from steam generation monitors according to the following requirements: - The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; - Determine the average operating load by computing the hourly averages using all of the 15-minute readings taken during each PM performance test; and - Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR (a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R ] Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section (c)(1)-(7) by 01/31/2017. [40 CFR (c), Minn. R ] HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section for each type of fuel burned that is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 14 calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel

63 Permit expires: [month day, year] Page 63 of 243 analyses are again less than 75 percent of the compliance level. [40 CFR (e), Minn. R ] HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: - Conducting monthly fuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; - Reducing the data to 12-month rolling averages; and - Maintaining the 12-month rolling average at or below the HCl and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] HCl & Mercury Limits. As specified in 40 CFR Section (c), the Permittee must keep records of the type and amount of all fuels burned in each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions of HCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40 CFR (a)(2)(i), Minn. R ] HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section according to the requirements below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section (a)(2)(i)- (iii) and may exclude these fuels when recalculating the HCl emission rate. - The Permittee must determine the chlorine concentration for any new fuel type in units of lb/mmbtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section (b). - The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. - Recalculate the HCl emission rate from the boiler under these new conditions using Equation 12 of 40 CFR Section The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR (a)(3), Minn. R ] Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section (a)(2)(i)- (iii) and may exclude these fuels when recalculating the mercury emission rate. - The Permittee must determine the mercury concentration for any new fuel type in units of lb/mmbtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section (b).

64 Permit expires: [month day, year] Page 64 of The Permittee must determine the new mixture of fuels that will have the highest content of mercury. - Recalculate the mercury emission rate from the boiler under these new conditions using Equation 13 of 40 CFR Section The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR (a)(5), Minn. R , a(6)] CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below. - Continuously monitor CO according to 40 CFR Sections (a) and Maintain a CO emission level below or at the CO emission limit at all times the affected unit is operating. - Keep records of CO levels according to 40 CFR Section (b). - Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site-Specific Monitoring Plan. [40 CFR (a)(8), Minn. R ] Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: - Collecting the opacity monitoring system data according to 40 CFR Sections (c) and ; - Reducing the opacity monitoring data to 6-minute averages; and - Maintaining opacity to less than or equal to 10 percent (24-hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: - Collecting operating load data or steam generation data every 15 minutes; and - Maintaining the operating load such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test according to 40 CFR Section (c). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] Tune-Ups. The Permittee must conduct a tune-up of the boiler every five years to demonstrate continuous compliance as specified in 40 CFR Section (a)(10)(i)-(vi). Each tune-up must be no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section (10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect each burner at least once every 72 months. [40 CFR (d), 40 CFR (a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days

65 Permit expires: [month day, year] Page 65 of 243 of startup. [40 CFR (a)(13), Minn. R ] Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR (d), Minn. R ] EQUI 4 EU004 Power Boiler #9 (Bark) Total Particulate Matter <= pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Total Particulate Matter <= 0.10 pounds per million Btu heat input 3-hour average from fossil fuel or fossil fuel and wood residue. [40 CFR 60.42(a)(1), Minn. R ] PM < 10 micron <= pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron <= pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Front-half Particulate Matter <= pounds per million Btu heat input (filterable PM). [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Opacity <= 20 percent opacity 6-minute average except for one sixminute period per hour of not more than 27 percent opacity. [40 CFR 60.42(a)(2), Minn. R ] Opacity <= 10 percent opacity 24-hour block average. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Nitrogen Dioxide <= pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 3-hour rolling average while burning natural gas only. While burning oil, oil and wood, or natural gas and wood, the limit is 0.30 lb/mmbtu. While burning coal, coal and wood, or wood, the limit is 0.70 lb/mmbtu. While burning any other mixture of fuels, the limit shall be determined by proration using the following formula: PS(NOx) = [x(0.20)+y(0.30)+z(0.70)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil, oil and wood, or natural gas and wood z= % input from coal, coal and wood, or wood. All emission limits shall be determined on a 3-hour rolling average basis. [40 CFR 60.44, Minn. R ] Nitrogen Oxides <= pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

66 Permit expires: [month day, year] Page 66 of Sulfur Dioxide <= pounds per hour. This limit does not apply when boiler is used as back-up incineration for NCG. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= 0.8 pounds per million Btu heat input 3-hour rolling average while burning fuel oil or fuel oil and wood. While burning coal, wood, or coal and wood, SO2 must be less than or equal to 1.2 lb/mmbtu. These limits also apply if natural gas is being burned in combination with these fuels. When coal and oil are burned simultaneously, with or without natural gas and/or wood, the limit shall be determined by proration using the following formula: PS = [y(0.80)+z(1.2)] / (y+z) Where: y = % heat input from oil z = % input from coal. All emission limits shall be determined on a 3-hour rolling average basis. NCG is not considered a fuel, and the contribution from burning NCGs is to be disregarded when determining compliance with this limit. [40 CFR 60.43, Minn. R ] Carbon Monoxide <= 3400 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Carbon Monoxide <= 720 parts per million 30-day rolling average calculated by volume on a dry 3% oxygen. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Sulfuric Acid Mist <= 0.19 pounds per hour 3-hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R ] Hydrochloric acid <= pounds per million Btu heat input. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Mercury <= 5.7E-6 pounds per million Btu heat input. [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R ] Mercury <= pounds per hour 3-hour average. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in power boiler #9. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Fuel Usage <= 45.5 tons per hour 8-hour block average unless a

67 Permit expires: [month day, year] Page 67 of 243 new maximum is set pursuant to Minn. R , subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. The fuel usage limit is for wood/bark usage. Natural gas may be used in addition to bark, up to the steam generating limit. Eight-hour block average is calculated by dividing total weight by total operating time in each eight-hour block. Down time of 15 min. or more is not to be included as operating time. [Minn. R , subp. 3] Fuel Usage <= 1030 tons per day 24-hour block average unless a new maximum is set pursuant to Minn. R , subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TIE USAGE LIMIT). [Minn. R , Minn. R , subp. 3, Title I Condition: 40 CFR 52.21] The Permittee shall operate and maintain the ESP (TREA19) at any time that the process equipment controlled by the ESP (EQUI4) is in operation. The Permittee shall document periods of nonoperation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Each day, calculate and record the three (3) 8-hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R , subp. 2] Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more than the railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi-annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tie daily limit and shall include the determined railroad tie usage for that day. [Minn. R , subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI4. [40 CFR 64.7(a), Minn. R , Minn. R ] Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI4. [40 CFR 64.7(a), Minn. R , Minn. R ] Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisions in 40 CFR 60.13(b) & 60.45(a). [40 CFR 60.13(b), 40 CFR

68 Permit expires: [month day, year] Page 68 of (a), 40 CFR 64.7(a)-(c), Minn. R , Minn. R , Minn. R ] Emissions Monitoring: The Permittee shall use a CO, O2, NOx, and SO2 CEMS to measure CO, O2, NOx, and SO2 emissions from EQUI4. [Minn. R , Minn. R , Title I Condition: 40 CFR 52.21] CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx, SO2, CO, and O2. [40 CFR 60.45(a), Minn. R , Minn. R , Minn. R , subp. 2] Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated according to 40 CFR Section (c) are less than the HCl and mercury emission limits. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Boiler Load. The Permittee must maintain the operating load of each unit such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test. [40 CFR (a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R ] Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra-low sulfur diesel, fuel oilsoaked rags, kerosene, hydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/biobased solids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section (b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming with

69 Permit expires: [month day, year] Page 69 of 243 this work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section (b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section [40 CFR (a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFR Section and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section (a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section (a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). [40 CFR (b) and (e), Minn. R ] HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR (c)(1), Minn. R ] HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the onesided t-statistic test described in Equation 15 of 40 CFR Section [40 CFR (c)(2), Minn. R ] HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section must not exceed the HCl emission limit. [40 CFR (c)(3), Minn. R ] Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section must not exceed the mercury emission limit. [40 CFR (c)(4), Minn. R ] CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to 40 CFR Section (a) no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). [40 CFR (c) and (e), Minn. R ] Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section

70 Permit expires: [month day, year] Page 70 of and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section (j). [40 CFR (d) and (e), Minn. R ] Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section (c) using data from the operating load monitors or from steam generation monitors according to the following requirements: - The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; - Determine the average operating load by computing the hourly averages using all of the 15-minute readings taken during each PM performance test; and - Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR (a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R ] Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section (c)(1)-(7) by 01/31/2017. [40 CFR (c), Minn. R ] HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section for each type of fuel burned that is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 14 calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel analyses are again less than 75 percent of the compliance level. [40 CFR (e), Minn. R ] HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: - Conducting monthly fuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; - Reducing the data to 12-month rolling averages; and - Maintaining the 12-month rolling average at or below the HCl

71 Permit expires: [month day, year] Page 71 of 243 and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] HCl & Mercury Limits. As specified in 40 CFR Section (c), the Permittee must keep records of the type and amount of all fuels burned in each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions of HCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40 CFR (a)(2)(i), Minn. R ] HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section according to the requirements below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section (a)(2)(i)- (iii) and may exclude these fuels when recalculating the HCl emission rate. - The Permittee must determine the chlorine concentration for any new fuel type in units of lb/mmbtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section (b). - The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. - Recalculate the HCl emission rate from the boiler under these new conditions using Equation 12 of 40 CFR Section The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR (a)(3), Minn. R ] Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section (a)(2)(i)- (iii) and may exclude these fuels when recalculating the mercury emission rate. - The Permittee must determine the mercury concentration for any new fuel type in units of lb/mmbtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section (b). - The Permittee must determine the new mixture of fuels that will have the highest content of mercury. - Recalculate the mercury emission rate from the boiler under these new conditions using Equation 13 of 40 CFR Section The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR (a)(5), Minn. R , a(6)] CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below.

72 Permit expires: [month day, year] Page 72 of Continuously monitor CO according to 40 CFR Sections (a) and Maintain a CO emission level below or at the CO emission limit at all times the affected unit is operating. - Keep records of CO levels according to 40 CFR Section (b). - Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site-Specific Monitoring Plan. [40 CFR (a)(8), Minn. R ] Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: - Collecting the opacity monitoring system data according to 40 CFR Sections (c) and ; - Reducing the opacity monitoring data to 6-minute averages; and - Maintaining opacity to less than or equal to 10 percent (24-hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: - Collecting operating load data or steam generation data every 15 minutes; and - Maintaining the operating load such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test according to 40 CFR Section (c). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R ] Tune-Ups. The Permittee must conduct a tune-up of the boiler every 5 years to demonstrate continuous compliance as specified in 40 CFR Section (a)(10)(i)-(vi). Each tune-up must be no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section (10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect each burner at least once every 72 months. [40 CFR (d), 40 CFR (a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR (a)(13), Minn. R ] Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR (d), Minn. R ] EQUI 7 EU011 Bleach Plant Chlorine Dioxide <= 1.0 pounds per hour. This is a state only

73 Permit expires: [month day, year] Page 73 of 243 requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Carbon Monoxide <= 1.2 pounds per ton oven dried bleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Chloroform <= 1.10 pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Chloroform Emission Control: To reduce chloroform air emissions from the bleach plant, the Permittee shall use no hypochlorite or chlorine for bleaching in the bleaching system or line. [40 CFR (d)(2), Minn. R ] HAPs - Total <= 10 parts per million or less than or equal to lb per ton of oven-dried pulp or reduce the Total Chlorinated HAP mass entering the control device by 99% or more by weight. In this limit, Total HAPs refers to Total Chlorinated HAPs (not including chloroform). [40 CFR (c), Minn. R ] Volatile Organic Compounds <= 0.17 pounds per ton of air dried bleached pulp produced. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Enclosures and Venting: All equipment at each bleaching stage where chlorinated compounds are introduced shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section and as described in the Total Facility subject item. [40 CFR (b), Minn. R ] The Permittee shall vent emissions from EQUI7 to control equipment meeting the requirements of TREA17 whenever EQUI7 operates. [Minn. R , subp. 14] EQUI 18 EU037 Power Boiler # Particulate Matter <= pounds per hour (This is based on emissions rate of 0.08 lb/mmbtu.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Particulate Matter <= 0.10 pounds per million Btu heat input. [Minn. R , subp. 1] PM < 10 micron <= pounds per hour (This is based on emissions rate of 0.07 lb/mmbtu). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron <= 4.13 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 27 percent opacity. [Minn. R , subp. 2] Nitrogen Dioxide <= pounds per million Btu heat input 30- day rolling average (This is based on emission rate of 56 lb/hr.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

74 Permit expires: [month day, year] Page 74 of Nitrogen Oxides <= 56.0 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Nitrogen Oxides <= 0.30 pounds per million Btu heat input when burning fuel oil. [Minn. R , subp. 1] Nitrogen Dioxide <= 0.20 pounds per million Btu heat input when burning natural gas. [Minn. R , subp. 1] Sulfur Dioxide <= pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= 0.80 pounds per million Btu heat input when burning fuel oil. [Minn. R , subp. 1] Fuel Usage: limited to natural gas and #2 fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Content of Fuel <= 0.05 percent by weight of fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Fuel Usage <= 1.0 million gallons per year 12-month rolling sum of fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Vendor Certifications: For all fuel oil burned in Power Boiler #8 (EQUI18), maintain oil vendor information on site that documents oil sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of the fuel oil. This information shall be maintained on site. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Emissions Monitoring: The Permittee shall use a NOx and O2 CEMS to measure NOx and O2 emissions from EQUI18. [Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx and O2 percent by volume on a dry basis. [Minn. R , Minn. R , subp. 2] Recordkeeping: By the 15th day of each month, calculate the fuel oil usage for the previous month and the previous 12 months (12- month rolling sum). For the first 12 months of operation of #8 as a power boiler, monthly determination of the 12-month rolling sum limit for fuel oil usage shall be determined based on the following: Month 1: FOU < 1,000,000; Month 2-12: FOU(month n) < 1,000,000 - sum[fou(actual)]; Where: FOU = the fuel oil usage, in gallons/year; sum[fou(actual)] = the sum of FOU for all months previous to month n; month n = the month for which the limit is being calculated. The limit is being met when the formula is true for month n.

75 Permit expires: [month day, year] Page 75 of 243 [Minn. R , subp. 5] Compliance Date. The Permittee must comply with 40 CFR pt. 63, subp. DDDDD no later than January 31, 2016, except as provided in 40 CFR Section 63.6(i). [40 CFR (b), Minn. R ] Tune-Ups. The Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section (a)(10)(i)-(vi) no later than January 31, 2016, except as specified in 40 CFR Section (j). [40 CFR (e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Energy Assessment. The Permittee must complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3 no later than January 31, 2016, except as specified in 40 CFR Section (j). An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. DDDDD, Table 3, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO that includes the affected units also satisfies the energy assessment requirement. [40 CFR (e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Tune-Ups. The Permittee must conduct an annual tune-up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section (a)(10)(i)-(vi). Each annual tune-up must be conducted no more than 13 months after the previous tune-up. [40 CFR (d), 40 CFR (a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR (a)(13), Minn. R ] EQUI 38 EU082 I&I Emergency Generator Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuel. [Minn. R , subp. 2(A)] Sulfur Dioxide <= pounds per million Btu heat input. This limit is effective on January 31, The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuel. [Minn. R , subp. 2(B)] Fuel type: Natural gas only by design. [Minn. R , subp. 35a] Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency 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.

76 Permit expires: [month day, year] Page 76 of 243 [Minn. R , subps. 4-5] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] EQUI 42 EU088 Ozone bleaching system Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] EQUI 49 EU081 IQS - Incinerator Particulate Matter <= 8.80 pounds per hour 3-hour average. [Minn. R , subp. 2] PM < 10 micron <= 8.80 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron <= 7.50 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Nitrogen Oxides <= 9.10 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Volatile Organic Compounds <= 4.60 pounds per hour. [Minn. R , subp. 2] Carbon Monoxide <= pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur - Total Reduced including H2S <= 0.50 pounds per hour. [Minn. R , subp. 2] Sulfuric Acid Mist <= 1.0 pounds per hour. [Minn. R , subp. 2] HAPs - Total <= 20 parts per million by volume, corrected to 10 percent oxygen on a dry basis. [40 CFR (d)(2), Minn. R ] The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of nonoperation of the control equipment TREA30 while equipment being controlled is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall vent emissions from EQUI49 to TREA31 (SO2 Scrubber) whenever the equipment operates, and operate and maintain TREA31 at all times that any emissions are vented to TREA31. The Permittee shall document periods of non-operation

77 Permit expires: [month day, year] Page 77 of 243 of the control equipment whenever EQUI49 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee is allowed to conduct on-line acid washes on TREA30 in accordance with the O & M Plan. The Permittee shall record the time, date, and duration of on-line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on-line acid wash. [Minn. R , subp. 2] EQUI 51 EU031 Smelt Dissolving Tank for RB # Total Particulate Matter <= 12.5 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Total Particulate Matter <= 0.12 pounds per ton of black liquor solids fired (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= 0.20 pounds per ton of black liquor solids fired. [40 CFR (a)(2), 40 CFR (a)(1)(i)(B), Minn. R , Minn. R ] PM < 10 micron <= 12.5 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 10 micron <= 0.12 pounds per ton of black liquor solids fired (dry weight) using 3 Hour Average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 2.5 micron <= pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Opacity <= 20 percent opacity 6-minute average. [Minn. R , subp. 2] Sulfur Dioxide <= 6.25 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Volatile Organic Compounds <= 0.16 pounds per ton of air dried unbleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur - Total Reduced including H2S <= pounds per ton of black liquor solids (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur - Total Reduced including H2S < pounds per ton black liquor solids as H2S. [40 CFR (a)(4), Minn. R ] The Permittee shall operate and maintain the scrubber (TREA12) at any time that EQUI51 is in operation. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain the VRS (TREA6) at any time that EQUI51 is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2]

78 Permit expires: [month day, year] Page 78 of Continuous Parameter Monitoring System (CPMS). Install, calibrate, maintain, and operate a CPMS that can be used to determine and record the pressure drop across the scrubber and the scrubbing liquid flow rate at least once every successive 15- minute period using the procedures in 40 CFR 63.8(c), as well as: - The monitoring device used for the continuous measurement of the pressure drop of the gas stream across the scrubber must be certified by the manufacturer to be accurate to within a gage pressure of plus or minus 500 pascals (plus or minus 2 inches of water gage pressure); and - The monitoring device used for continuous measurement of the scrubbing liquid flow rate must be certified by the manufacturer to be accurate within plus or minus 5 percent of the design scrubbing liquid flow rate. [40 CFR (e)(10), Minn. R ] Determination of operating ranges: - Establish operating ranges for the pressure drop across the scrubber and the scrubbing liquid flow rate based on values recorded during previous performance tests. - The Permittee shall certify that all control techniques and processes have not been modified subsequent to the testing upon which the data used to establish the operating parameter ranges were obtained. - The Permittee may establish expanded or replacement operating ranges during subsequent performance tests using the test methods required in 40 CFR The Permittee shall continuously monitor each parameter and determine the arithmetic average value of each parameter during each performance test. Multiple performance tests may be conducted to establish a range of parameter values. [40 CFR (j), Minn. R ] EQUI 52 EU033 Rotary Lime Kiln - Kiln Total Particulate Matter <= grains per dry standard cubic 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= 13.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot 3- hour 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= 13.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling)] PM < 2.5 micron <= grains per dry standard cubic foot 3- hour 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT)

79 Permit expires: [month day, year] Page 79 of 243 & Minn. R ] PM < 2.5 micron <= 12.8 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling)] Front-half Particulate Matter < grains per dry standard cubic foot corrected to 10 percent oxygen (filterable PM). [40 CFR a(a)(5)(i), 40 CFR (a)(1)(i)(C), Minn. R ] Opacity <= 20 percent opacity. The exemptions to opacity standards under 40 CFR Section 60.11(c) do not apply. [40 CFR a(a)(5)(ii)] Nitrogen Dioxide <= 220 parts per million (calculated on a dry 10% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= 120 parts per million (calculated on a dry 10% O2). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R ] Nitrogen Oxides <= 39.0 pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Nitrogen Oxides <= 39.0 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= 8.4 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Volatile Organic Compounds <= 1.0 pounds per ton (units are lbs/ton of calcined product). (This is based on emission rate of 20.0 lb/hr). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 75 parts per million (calculated on a dry 10% O2). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 12.9 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur - Total Reduced including H2S <= 8 parts per million as a 12- hour average (calculated on a dry 10% O2). (This is based on emission rate of 1.7 lb/hr). [40 CFR a(a)(5), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfuric Acid Mist <= 0.53 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Mercury <= pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R , subp. 2] Calcium Oxide Production Process Throughput <= tons per year 12-month rolling sum. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Fuel use: limited to natural gas. [Minn. R , subp. 2]

80 Permit expires: [month day, year] Page 80 of Process Throughput <= 500 tons per day 24-hour block average (limit is for calcium oxide production). 24-hour block average is calculated by dividing total weight by total operating time in each 24-hour block. Down time of 15 minutes or more is not to be included as operating time. [Minn. R , subp. 3, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R ] The Permittee shall operate and maintain the ESP (TREA21) at any time that the process equipment controlled by the ESP (EQUI52) is in operation. The Permittee shall document periods of nonoperation of the control equipment. [Minn. R , subps. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: 40 CFR pt. 50] Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI52. [40 CFR 64.7(a), Minn. R , Minn. R ] Continuous Opacity Monitoring System (COMS): Install, calibrate, maintain, and operate a COMS to monitor and record opacity. The span of this system must be set at 70 percent opacity. The Permittee must install, certify, and operate the COMS in accordance with Performance Specification 1 in 40 CFR part 60, Appendix B and the appropriate provisions in 40 CFR Sections 63.6(h) & [40 CFR 60.13(b), 40 CFR a(a)(1), 40 CFR (d), 40 CFR 64.7(a)-(c), Minn. R , Minn. R , Minn. R ] Emissions Monitoring: The Permittee shall use an oxygen and TRS CEMS to measure oxygen and TRS emissions from EQUI52. [Minn. R , Minn. R , Title I Condition: 40 CFR 52.21] CEMS Installation: Install, calibrate, maintain and operate a CEMS to monitor and record the concentration of TRS on a dry basis and O2 percent by volume on a dry basis. The Permittee must install, certify, and operate the continuous TRS monitoring system in accordance with Performance Specification 5 in 40 CFR part 60, Appendix B. The Permittee must install, certify, and operate the continuous oxygen monitoring system in accordance with Performance Specification 3 in 40 CFR part 60, Appendix 3. These systems must be located downstream of the control device(s). The range of the continuous monitoring system must encompass all expected concentration values, including the zero and span values used for calibration. The spans of these continuous monitoring systems must be set: - At a TRS concentration of 30 ppm for the TRS CEMS; and

81 Permit expires: [month day, year] Page 81 of At 21 percent oxygen for the O2 CEMS. [40 CFR a(a)(2), Minn. R , Minn. R , subp. 2] The Permittee must install, calibrate, maintain, and operate: - A monitoring device for the continuous measurement of the secondary voltage of each ESP collection field; and - A monitoring device for the continuous measurement of the secondary current of each ESP collection field. Total secondary power may be calculated as the product of the secondary voltage and secondary current measurements for each ESP collection field and used to demonstrate compliance as an alternative to the secondary voltage and secondary current measurements. [40 CFR a(b)(3)] The Permittee must follow the procedures for collecting and reducing monitoring data and setting operating limits in 40 CFR Section a(c)(1)-(6). 40 CFR pt. 60, subp. A specifies methods for reducing continuous opacity monitoring system data. [40 CFR a(c)] The Permittee must perform the following: - Calculate and record on a daily basis 12-hour average TRS concentrations for the two consecutive periods of each operating day. Each 12-hour average must be determined as the arithmetic mean of the appropriate 12 contiguous 1-hour average TRS concentrations provided by each continuous monitoring system installed under 40 CFR Section a(a)(2). - Calculate and record on a daily basis 12-hour average oxygen concentrations for the two consecutive periods of each operating day for the lime kiln. These 12- hour averages must correspond to the 12-hour average TRS concentrations under 40 CFR Section a(c)(1)(i) and must be determined as an arithmetic mean of the appropriate 12 contiguous 1-hour average oxygen concentrations provided by each continuous monitoring system installed under 40 CFR Section a(a)(2). - Using the following equation, correct all 12-hour average TRS concentrations to 10 volume percent oxygen: Ccorr = Cmeas x (21 - X) / (21 - Y) Where: Ccorr = the concentration corrected for oxygen. Cmeas = the 12-hour average of the measured concentrations uncorrected for oxygen. X = the volumetric oxygen concentration in percentage to be corrected to (10 percent for lime kilns). Y = the 12-hour average of the measured volumetric oxygen concentration. [40 CFR a(c)(1)] The Permittee must record at least once each successive 15- minute period all measurements obtained from the continuous

82 Permit expires: [month day, year] Page 82 of 243 monitoring devices installed under 40 CFR Section a(b)(3) and reduce the data by calculating semiannual averages from the recorded measurements of ESP parameters (secondary voltage and secondary current, or total secondary power) for ESPcontrolled lime kilns that measure opacity in addition to ESP parameters. [40 CFR a(c)(3)] During the initial performance test required in 40 CFR Section a, the Permittee must establish site-specific operating limits for the monitoring parameters in 40 CFR Section a(b)(3) by continuously monitoring the parameters and determining the arithmetic average value of each parameter during the performance test. The arithmetic average of the measured values for the three test runs establishes the minimum site-specific operating limit for each ESP parameter. Multiple performance tests may be conducted to establish a range of parameter values. The Permittee may establish replacement operating limits for the monitoring parameters during subsequent performance tests using the test methods in 40 CFR Section a. [40 CFR a(c)(4)] The Permittee must operate the continuous monitoring systems required in 40 CFR Section a(a) and (b) to collect data at all required intervals at all times the affected facility is operating except for periods of monitoring system malfunctions or out-ofcontrol periods, repairs associated with monitoring system malfunctions or out-of-control periods, and required monitoring system quality assurance or quality control activities including, as applicable, calibration checks and required zero and span adjustments. [40 CFR a(c)(5)] The Permittee may not use data recorded during monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, or required monitoring system quality assurance or control activities in calculations used to report emissions or operating limits. The Permittee must use all the data collected during all other periods in assessing the operation of the control device and associated control system. [40 CFR a(c)(6)] For emissions from any lime kiln, periods of excess emissions are: - All 12-hour average TRS concentrations above 8 ppm by volume at 10-percent oxygen during times when lime mud is fired; and - All 6-minute average opacities that exceed 20 percent during times when lime mud is fired. [40 CFR a(d)(2)] The Administrator will not consider periods of excess emissions reported under 40 CFR Section a(a) to be indicative of a violation of the standards provided that: - The percent of the total number of possible contiguous periods of excess emissions in the semiannual reporting period does not exceed: 1% for TRS emissions provided that the 12-hour average TRS concentration does not exceed 22 ppm corrected to 10- percent oxygen or 1% for average opacities provided that the ESP

83 Permit expires: [month day, year] Page 83 of 243 secondary voltage and secondary current (or total secondary power) averaged over the semiannual period remained above the minimum operating limits established during the performance test; and - The Administrator determines that the affected facility, including air pollution control equipment, is maintained and operated in a manner which is consistent with good air pollution control practice for minimizing emissions during periods of excess emissions. [40 CFR a(e)] The procedures under 40 CFR Section must be followed for installation, evaluation, and operation of the continuous monitoring systems required under 40 CFR Section a. All continuous monitoring systems must be operated in accordance with the applicable procedures under Performance Specifications 1, 3, and 5 of 40 CFR pt. 60, Appendix B. [40 CFR a(f)] Each day, calculate and record the 24-hour block average calcium oxide production rate for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the lime kiln. [Minn. R , subp. 2] Recordkeeping: By the 15th day of each month, calculate and record the calcium oxide production rate for the previous month and the previous 12 months (12-month rolling sum). [Minn. R , subp. 2] The Permittee must maintain records of the performance evaluations of the continuous monitoring systems. [40 CFR a(a)] For each continuous monitoring system, the Permittee must maintain records of the following information: - Records of the opacity of the gases discharged into the atmosphere and records of the ESP secondary voltage and secondary current (or total secondary power) averaged over the reporting period for the opacity allowances specified in 40 CFR Section a(e)(1)(iv); - Records of the concentration of TRS emissions on a dry basis and the percent of oxygen by volume on a dry basis in the gases discharged into the atmosphere; - Records of the secondary voltage of each ESP collection field, records of the secondary current of each ESP collection field, and, if used as an alternative to secondary voltage and current, records of the total secondary power of each ESP collection field; and - Records of excess emissions as defined in 40 CFR Section a(d). [40 CFR a(b)] For each malfunction, the Permittee must maintain records of the following information:

84 Permit expires: [month day, year] Page 84 of Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment; and - Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR a(c)] Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R , subp. 1] Recordkeeping: Maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR pt. 60 recorded in a permanent form suitable for inspection for at least five years. 40 CFR Section 60.7(f) specifies two years. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(4), Minn. R , subp. 1] The Permittee shall submit a notification of the date upon which demonstration of the continuous monitoring system performance commences in accordance with 40 CFR Section 60.13(c). Notification shall be postmarked not less than 30 days prior to such date. [40 CFR 60.7(a)(5), Minn. R , subp. 1] Notification of Anticipated Date for Conducting Opacity Observations: due 30 days prior to observation date. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(6), Minn. R , subp. 1] Within 60 days after the date of completing each performance test as required by 40 CFR pt. 60, subp. BBa, the Permittee must submit the results of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 60, subp. BBa to the EPA as specified in 40 CFR Section a(b). [40 CFR a(b)] Within 60 days after the date of completing each CEMS performance evaluation test as defined in 40 CFR Section 60.13, the Permittee must submit relative accuracy test audit (RATA) data to the EPA's Central Data Exchange (CDX) by using CEDRI in

85 Permit expires: [month day, year] Page 85 of 243 accordance with 40 CFR Section a(b). Only RATA pollutants that can be documented with the ERT (as listed on the ERT Web site) are subject to this requirement. For any performance evaluations with no corresponding RATA pollutants listed on the ERT Web site, the Permittee must submit the results of the performance evaluation to the Administrator at the appropriate address listed in 40 CFR Section [40 CFR a(c)] If a malfunction occurred during the reporting period, the Permittee must submit a report that contains the following: - The number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded; and - A description of actions taken by the Permittee during a malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including actions taken to correct a malfunction. [40 CFR a(d)] EQUI 53 EU005 Recovery Boiler # [Stage 1] Filterable Particulate Matter <= grains per dry standard cubic foot 3-hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] [Stage 1] Particulate Matter <= 40.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Total Particulate Matter <= grains per dry standard cubic foot (calculated at 8% O2). [40 CFR (a)(1)(i), 40 CFR (a)(1)(i)(A), Minn. R , Minn. R ] Total Particulate Matter <= pounds per million Btu heat input. This limit applies at all times when fuel oil is being combusted, except during periods of startup, shutdown, or malfunction. [40 CFR 60.43b(h)(1), Minn. R ] [Stage 1] PM < 10 micron <= grains per dry standard cubic foot 3-hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] [Stage 1] PM < 10 micron <= 40.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

86 Permit expires: [month day, year] Page 86 of [Stage 1] PM < 2.5 micron <= grains per dry standard cubic foot 3- hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] [Stage 1] PM < 2.5 micron <= 37.9 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Opacity <= 20 percent opacity 6-minute average, except for one 6- minute period per hour of not more than 27 percent opacity. [40 CFR 60.43b(f), Minn. R ] Opacity <= 35 percent opacity. [40 CFR (a)(1)(ii), Minn. R ] [Stage 1] Nitrogen Dioxide <= 100 parts per million 30-day rolling average by volume (dry) corrected to 8% oxygen. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Dioxide <= pounds per hour 30-day rolling average. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Nitrogen Dioxide <= pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] [Stage 1] Nitrogen Oxides <= pounds per hour 1-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 30-day rolling average while burning natural gas only or fuel oil combined with black liquor. [40 CFR 60.44b(f)(2), Minn. R ] Sulfur Dioxide <= pounds per hour. (This limit is based on a concentration of 250 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfur Dioxide <= 73.0 pounds per hour 30-day rolling average. (This limit is based on a concentration of 50 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Volatile Organic Compounds <= 44.0 pounds per hour 3-hour average. (This limit is based on a concentration of 60 8% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= pounds per hour 24-hour rolling average. (This limit is based on a concentration of 300

87 Permit expires: [month day, year] Page 87 of 243 8% O2.). [Minn. R , subp. 2, Minn. Stat , subd. 4a] Carbon Monoxide <= pounds per hour 24-hour rolling average (This limit is based on a concentration of 300 8% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur - Total Reduced including H2S <= 5 parts per million on a dry basis, corrected to 8% oxygen, using 12-hour block average. (This limit is based on an emission rate of 4.8 lb/hr.). [40 CFR (a)(2), Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfuric Acid Mist <= 3.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Mercury <= pounds per hour 3-hour average. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R , subp. 2, Minn. Stat , subd. 4a] [Stage 1] Carbon Dioxide Equivalent <= 207 pounds per million Btu heat input. This emission rate limit is based on emission factors and global warming potentials listed in 40 CFR Part 98 as of September, [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] [Stage 1] Fuel burned: Limited to natural gas, black liquor, and black liquor blended with distillate fuel oil (includes on-road diesel fuel oil). The combustion of fuel oil alone (i.e. not blended with black liquor) is not authorized. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Fuel Usage <= 1.0 gallons per minute of distillate fuel oil. This is in addition to the other fuels allowed. This is a physical limitation of the design of the fuel oil feed system (pump capacity). [Minn. R , subp. 35a] Sulfur Content of Fuel <= percent by weight for distillate oil. This limit also exempts the unit from the sulfur dioxide emission limits of 40 CFR Section 60.42b (40 CFR Section 60.42b(k)(2)). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R ] Steam Flow <= pounds per hour 8-hour block average unless a new maximum is set pursuant to Minn. R , subp. 3, based on the average steam flow recorded during the most recent MPCA approved performance test where compliance was demonstrated. Limit is for Steam Production. Eight-hour block average is calculated by dividing total steam produced by total operating time in each eight-hour block. Down time of 15 min. or more is not to be included as operating time. [Minn. R , subp. 3]

88 Permit expires: [month day, year] Page 88 of Annual capacity factor for fossil fuels: less than or equal to 10%. [40 CFR 60.44b(c), Minn. R ] Annual Capacity Factor Daily Recordkeeping and Fuel Type Recordkeeping: On each day of operation the Permittee shall record and maintain records of the amounts of each fuel combusted in the Recovery Boiler (EQUI 53). [40 CFR 60.49b(d), Minn. R , subps. 4-5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Annual Capacity Factor Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total amount of each type of fuel combusted in the recovery boiler during the previous month. 2) The annual capacity factor of fossil fuels (natural gas and distillate oil) for the previous 12-month period. [40 CFR 60.49b(d), Minn. R , subps. 4-5, Minn. R ] [Stage 1] The Permittee shall operate and maintain the ESP (TREA20) at any time that the process equipment controlled by the ESP (EQUI53) is in operation. The Permittee shall document periods of nonoperation of the control equipment. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Each day, calculate and record the three (3) 8-hour block average steam flows for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R , subp. 2] Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI53. [40 CFR 64.7(a), Minn. R , Minn. R ] Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisions in 40 CFR 63.6(h) & [40 CFR 60.13(b), 40 CFR (a)(1), 40 CFR 60.48b(a), 40 CFR (d), 40 CFR 64.7(a)- (c), Minn. R , Minn. R , Minn. R , Minn. R ] [Stage 1] Emissions Monitoring: The Permittee shall use an CO, NOx, SO2, and TRS CEMS to measure CO, NOx, SO2, and TRS emissions from EQUI53. [40 CFR (e), Minn. R , Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of

89 Permit expires: [month day, year] Page 89 of 243 NOx, SO2, CO, CO2; and the concentration of TRS on a dry basis; and O2 percent by volume on a dry basis. [40 CFR (a)(2), Minn. R , Minn. R , Minn. R , subp. 2] Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b)] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), 40 CFR , Minn. R , Minn. R ] Record and maintain records of the amount of fuel combusted each day. [40 CFR 60.49b(d)(1), Minn. R ] Maintain records each operating day of the information listed under 40 CFR Section 60.49b(g). [40 CFR 60.49b(g), Minn. R ] Obtain and maintain fuel receipts from the fuel oil supplier that certify that the oil meets the definition of distillate oil as defined in 40 CFR Section 60.41b, and the sulfur content of the fuel oil. [40 CFR 60.49b(r)(1), Minn. R ] EQUI 71 MR004 Power Boiler #9 - SO The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, subp. D, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change

90 Permit expires: [month day, year] Page 90 of 243 which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The

91 Permit expires: [month day, year] Page 91 of 243 zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] EQUI 76 MR044 Power Boiler #9 - O The CEMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R , subp. 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ]

92 Permit expires: [month day, year] Page 92 of QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures in 40 CFR Section (a)(1)-(7). [40 CFR (a), Minn. R ] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] Install the oxygen CEMS by January 31, The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR (a)(1)] The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site-specific monitoring plan developed according to 40 CFR Section (d), and the requirements in 40 CFR Sections (a)(8) and (a). [40 CFR (a)(2), Minn. R ] Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two

93 Permit expires: [month day, year] Page 93 of minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR (a)(3), Minn. R ] CEMS O&M. The Permittee shall maintain and operate the oxygen CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R ] CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 107 MR027 Power Boiler #9 - CO The CEMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test.

94 Permit expires: [month day, year] Page 94 of 243 The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 40 CFR Section (a)(1)-(7). [40 CFR (a), Minn. R ] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] Install the CO CEMS by January 31, The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR (a)(1)]

95 Permit expires: [month day, year] Page 95 of The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site- Specific Monitoring Plan developed according to 40 CFR Section (d), and the requirements in 40 CFR Sections (a)(8) and (a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site-Specific Monitoring Plan developed according to 40 CFR Section (d), and the requirements in in 40 CFR Sections (a)(8) and (a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR (a)(2), Minn. R ] The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: - The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 4, 4A, or 4B at 40 CFR part 60, Appendix B. - During each relative accuracy test run of the CO CEMS, the Permittee must collect emission data for CO concurrently (or within a 30- to 60-minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. - The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable CO emission limit, expressed as a concentration. - Any CO CEMS that does not comply with 40 CFR Section (a) cannot be used to meet any requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. - Complete the initial performance evaluation no later than July 29, [40 CFR (a)(2)(i)-(v), Minn. R ] Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR (a)(3), Minn. R ] Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR (a)(4), Minn. R ] Calculate one-hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one-hour arithmetic averages required shall be used to calculate the 30-day or 10-day rolling average emissions. Use Equation in Section of Method 19 of 40 CFR pt. 60, Appendix A-7 for calculating the average CO concentration

96 Permit expires: [month day, year] Page 96 of 243 from the hourly values. [40 CFR (a)(5), Minn. R ] For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section (b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section (c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section (d). [40 CFR (a)(6), Minn. R ] CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R ] CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 108 MR030 Rotary Lime Kiln - Opacity The COMS requirements listed in this permit outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R ] Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, Subp. BBa, Minn. R , Minn. R , subp 1] NSPS COMS Performance Evaluation: Due before the performance test required under 40 CFR Section 60.8 is conducted as specified in Performance Specification 1, Appendix B of 40 CFR pt. 60. Otherwise, the Permittee shall conduct a performance evaluation of the COMS during any performance test required under Section 60.8 or within 30 days thereafter. The Permittee shall conduct COMS performance evaluations at such other times as may be

97 Permit expires: [month day, year] Page 97 of 243 required by the Administrator under Section 114 of the Clean Air Act. (Provided all applicable deadlines are met, the performance evaluation may be completed at the same time as the Minn. R. required Certification Test.) Sappi completed this requirement on October 16, [40 CFR 60.13(c), Minn. R ] NSPS COMS Performance Evaluation Report: Due 10 days before the performance test required under 40 CFR Section 60.8 and as described in Section 60.11(e)(5) if the Permittee elects to submit COMS data In lieu of the performance test to demonstrate compliance with the opacity standard. If instead the performance evaluation is completed during the performance test or within 30 days thereafter as allowed by Section 60.13(c), the report is due within 60 days of completion. [40 CFR 60.13(c)(1) & (2), Minn. R ] COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.a, 40 CFR pt. 60, Appendix F, Minn. R ] Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R , subp. 3. [Minn. R , subp. 1-3] Monitoring Data: All COMS data must be reduced to six-minute averages. Six-minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R , subp. 1-3] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies

98 Permit expires: [month day, year] Page 98 of 243 where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R ] COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R , subp. 2] COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R ] COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R , subp. 2] Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)] COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, Appendix B(7), Minn. R ] EQUI 110 MR043 RB#10 CO Carbon Dioxide: Monitoring: The Permittee shall use a CEMS to measure CO2 diluent gas concentratoin from EQUI 53 (Recovery Boiler #10). [Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall

99 Permit expires: [month day, year] Page 99 of 243 include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3]

100 Permit expires: [month day, year] Page 100 of Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 112 MR013 Power Boiler #8 - NOx Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI 18 (Power Boiler #8). [Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies

101 Permit expires: [month day, year] Page 101 of 243 where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 113 MR014 Recovery Boiler #10 - Opacity The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R ] Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, Subp. BB, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All COMS data must be reduced to six-minute averages. Six-minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R , subp. 1-3]

102 Permit expires: [month day, year] Page 102 of Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R , subp. 1-4] Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R ] COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R ] COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R ] COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R , subp. 2] Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)] COMS Certification/Recertification Test: due 90 days after the first

103 Permit expires: [month day, year] Page 103 of 243 excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, Appendix B(7), Minn. R ] EQUI 114 MR015 Recovery Boiler #10 - NOx The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. D, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies

104 Permit expires: [month day, year] Page 104 of 243 whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 115 MR016 Recovery Boiler #10 - SO Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure SO2 emissions from EQUI 53 (Recovery Boiler #10). [Minn. R , subp 1]

105 Permit expires: [month day, year] Page 105 of Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B.

106 Permit expires: [month day, year] Page 106 of CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 116 MR017 Recovery Boiler #10 - TRS The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Sulfur - Total Reduced including H2S: Emissions Monitoring: The owner or operator shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test.

107 Permit expires: [month day, year] Page 107 of 243 The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1]

108 Permit expires: [month day, year] Page 108 of 243 EQUI 117 MR018 Recovery Boiler #10 - CO Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure CO emissions from EQUI 53 (Recovery Boiler #10). [Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R ,

109 Permit expires: [month day, year] Page 109 of 243 subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 118 MR019 Recovery Boiler #10 - O The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1]

110 Permit expires: [month day, year] Page 110 of Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days

111 Permit expires: [month day, year] Page 111 of 243 after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 119 MR020 Power Boiler #7 - SO Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for

112 Permit expires: [month day, year] Page 112 of 243 inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 120 MR021 Rotary Lime Kiln - TRS The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Sulfur - Total Reduced including H2S: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subp. BBa, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance;

113 Permit expires: [month day, year] Page 113 of 243 C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five

114 Permit expires: [month day, year] Page 114 of 243 years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 121 MR022 Rotary Lime Kiln - O The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subp. BBa, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format

115 Permit expires: [month day, year] Page 115 of 243 specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1]

116 Permit expires: [month day, year] Page 116 of 243 EQUI 122 MR023 Power Boiler #7 - O The CEMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Oxygen: Monitoring: The owner or operator shall use a CEMS to measure O2 diluent gas concentration from EQUI 2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R , Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B.

117 Permit expires: [month day, year] Page 117 of CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Emissions Monitoring: The Permittee shall use an oxygen CEMS to measure oxygen emissions from EQUI2. [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R ] The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures in 40 CFR Section (a)(1)-(7). [40 CFR (a), Minn. R ] The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site-specific monitoring plan developed according to 40 CFR Section (d), and the requirements in 40 CFR Sections (a)(8) and (a). [40 CFR (a)(2), Minn. R ] Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR (a)(3), Minn. R ] CEMS O&M. The Permittee shall maintain and operate the oxygen CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R ] CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1]

118 Permit expires: [month day, year] Page 118 of 243 EQUI 123 MR025 Power Boiler #7 - CO The CEMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R , Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The

119 Permit expires: [month day, year] Page 119 of 243 zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 40 CFR Section (a)(1)-(7). [40 CFR (a), Minn. R ] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] Install the CO CEMS by January 31, The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR (a)(1)] The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site- Specific Monitoring Plan developed according to 40 CFR Section (d), and the requirements in 40 CFR Sections (a)(8) and (a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site-Specific Monitoring Plan developed according to 40 CFR Section (d), and the requirements in in 40 CFR Sections (a)(8) and (a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR (a)(2), Minn. R ] The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: - The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 4, 4A, or 4B at 40 CFR part 60, Appendix B. - During each relative accuracy test run of the CO CEMS, the Permittee must collect emission data for CO concurrently (or within a 30- to 60-minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing

120 Permit expires: [month day, year] Page 120 of 243 must be at representative operating conditions. - The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable CO emission limit, expressed as a concentration. - Any CO CEMS that does not comply with 40 CFR Section (a) cannot be used to meet any requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. - Complete the initial performance evaluation no later than July 29, [40 CFR (a)(2)(i)-(v), Minn. R ] Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR (a)(3), Minn. R ] Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR (a)(4), Minn. R ] Calculate one-hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one-hour arithmetic averages required shall be used to calculate the 30-day or 10-day rolling average emissions. Use Equation in Section of Method 19 of 40 CFR pt. 60, Appendix A-7 for calculating the average CO concentration from the hourly values. [40 CFR (a)(5), Minn. R ] For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section (b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section (c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section (d). [40 CFR (a)(6), Minn. R ] CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R ] CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R.

121 Permit expires: [month day, year] Page 121 of ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 135 MR001 Power Boiler #7 - Opacity The COMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R ] Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R ] Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR (c)(1), Minn. R ] The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR (c)(2), Minn. R ] As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. [40 CFR (c)(3), Minn. R ] The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR (c)(5), Minn. R ] The Permittee must include in the Site-Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR (c)(5), Minn. R ] The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFR Section 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6-minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from

122 Permit expires: [month day, year] Page 122 of 243 the monitoring requirements. [40 CFR (c)(6), Minn. R ] The Permittee must determine and record all the 6-minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR (c)(7), Minn. R ] COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R , subp. 3. [Minn. R , subp. 1-3] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R ] COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative

123 Permit expires: [month day, year] Page 123 of 243 span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [Minn. R ] COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R ] COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R , subp. 2] Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [Minn. R ] EQUI 136 MR002 Power Boiler #9 - Opacity The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 and 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R ] Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, Subp. D, Minn. R , subp 1] Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI4. [40 CFR pt. 63, subp. DDDDD, Minn. R , Minn. R ] Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR (c)(1), Minn. R ] The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR (c)(2), Minn. R ] As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. [40 CFR (c)(3), Minn. R ] The COMS data must be reduced as specified in 40 CFR Section

124 Permit expires: [month day, year] Page 124 of (g)(2). [40 CFR (c)(5), Minn. R ] The Permittee must include in the Site-Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR (c)(5), Minn. R ] The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFR Section 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6-minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR (c)(6), Minn. R ] The Permittee must determine and record all the 6-minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR (c)(7), Minn. R ] COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R ] COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F, Minn. R ] Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R , subp. 3. [Minn. R , subp. 1-3] Monitoring Data: All COMS data must be reduced to six-minute averages. Six-minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R , subp. 1-3] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test.

125 Permit expires: [month day, year] Page 125 of 243 Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R , subp. 1-3, Minn. R ] Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R ] COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R ] COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R ] COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R , subp. 2] Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)] COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1]

126 Permit expires: [month day, year] Page 126 of The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, Appendix B(7), Minn. R ] EQUI 137 MR003 Power Boiler #9 - NOx The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R ] Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, subp. D, Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R , subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [40 CFR 60.13(b), Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R , subp. 1-3, Minn. R ] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or

127 Permit expires: [month day, year] Page 127 of 243 plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R , subp. 2] CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R , subp. 3] Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R ] CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI 138 MR012 Power Boiler #8 - O Oxygen: Monitoring: The Permittee shall use a CEMS to measure O2 diluent gas concentration from EQUI 18 (Power Boiler #8). [Minn. R , subp 1] Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R ,

128 Permit expires: [month day, year] Page 128 of 243 subp. 1] Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R , subps. 1-2] CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R , subp. 2. [Minn. R , subp. 1] Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report - Microfiche Copy due 105 days after Certification Test. Certification Test Report due 45 days after Certification Test. The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R , subp. 2. [Minn. R , subp. 1-3, Minn. R , subp. 1-4] Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R , Minn. R ] QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R , subp. 2] CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section shall be used to determine out-of-control periods for CEMS. [Minn. R , subp. 3]

129 Permit expires: [month day, year] Page 129 of Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R ] Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R , subp. 3] Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R , subp. 1] EQUI Methanol / / EU Methanol <= 0.28 tons per year (tank is equipped with a conservation vent). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Inspection: due before end of each calendar quarter starting 9/25/1998. The Permittee shall inspect the conservation vent on a quarterly basis to ensure that the vent is working properly. The results of the inspection shall be recorded and maintained on site. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 290 EU089 R&D Boiler Total Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. [Minn. R , subp. 1] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R , subp. 2] Allowable Fuel: Natural Gas only, by design. [Minn. R , subp. 35a] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] Tune-Ups. The Permittee must conduct a 5-year tune-up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section (a)(10)(i)-(vi). Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section (a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the Permittee must inspect each burner at least once every 72 months. [40 CFR (e), 40 CFR (d), 40 CFR (a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R ] Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR (a)(13), Minn. R ]

130 Permit expires: [month day, year] Page 130 of 243 EQUI 298 EU049 #4 Paper Machine Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from being emitted from the associated stack/vent (STRU49). [Minn. R , subp. 4] EQUI 299 EU050 #12 Paper Machine Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from being emitted from the associated stack/vent (STRU50). [Minn. R , subp. 4] EQUI 304 EU051 #13 Coater The Permittee must limit organic HAP emissions to the level specified below: - No more than 5 percent of the organic HAP applied for each month; or - No more than 4 percent of the mass of coating materials applied for each month; or - No more than 20 percent of the mass of coating solids applied for each month. These limits apply to the collection of all web coating lines (as defined in 40 CFR ). [40 CFR (b)(1)-(3), Minn. R ] Maintain the following records as applicable on a monthly basis as specified in 40 CFR Sect (b)(2) of all measurements as needed to demonstrate compliance, including: 1. Continuous emission monitor data in accordance with 40 CFR Sect (d); 2. Control device and capture system operating parameter data in accordance with 40 CFR Sect (c), (e), & (f); 3. Organic HAP content data used for demonstrating compliance in accordance with 40 CFR Sect (c);

131 Permit expires: [month day, year] Page 131 of Volatile matter and coating solids content data used for demonstrating compliance with 40 CFR Sect (d); 5. Overall control efficiency determination using capture efficiency and control device destruction or removal efficiency test results in accordance with 40 CFR Sect (e) & (f); 6. Material usage, organic HAP usage, volatile matter usage, and coating solids usage and compliance demonstrations using these data in accordance with 40 CFR Sect (b)-(d). [40 CFR 63.10(b)(1), 40 CFR (a), Minn. R ] Determine the organic HAP or volatile matter and coating solids content of the coating materials according to procedures in 40 CFR Section (c) & (d). If applicable, determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere according to 40 CFR Section (g). [40 CFR (a), Minn. R ] Determine the organic HAP mass fraction of each coating material "as-purchased" by following one of the procedures (Method 311, Method 24, or Formulation Data) in 40 CFR Section (c)(1)- (3), and determine the organic HAP mass fraction of each coating material "as-applied" by following the procedures in 40 CFR Section (c)(4). If the organic HAP content values are not determined using the procedures in 40 CFR Section (c)(1)- (3), the Permittee must submit an alternative test method for determining the values for approval by the Administrator in accordance with 40 CFR Section 63.7(f). The recovery efficiency of the test method must be determined for all of the target organic HAP and a correction factor, if necessary, must be applied. [40 CFR (c), Minn. R ] If you choose to use the volatile organic content as a surrogate for the organic HAP content of coatings, you must determine the aspurchased volatile organic content and coating solids content of each coating material applied by following the procedures (Method 24 or Formulation Data) in 40 CFR Section (d)(1) or (2), and the as-applied volatile organic content and coating solids content of each coating material by following the procedures of 40 CFR Section (d)(3). [40 CFR (d), Minn. R ] Volatile matter retained in the coated web or otherwise not emitted to the atmosphere - If you choose to take this into account when determining compliance with the emission standards, you must develop a testing protocol to determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere and submit it to the Administrator for approval with your site-specific test plan under 40 CFR Section 63.7(f). If you intend to take into account the mass of volatile matter retained in the coated web after curing or drying or otherwise not emitted to the atmosphere and demonstrate compliance according to 40 CFR Section (c)(3), (c)(4), or (d), then the protocol must determine the mass of organic HAP retained in the coated web or otherwise not emitted to the atmosphere. Otherwise, compliance must be shown using the

132 Permit expires: [month day, year] Page 132 of 243 volatile organic matter content as a surrogate for the HAP content of the coatings. [40 CFR (g), Minn. R ] Demonstrate compliance by one of the following methods: 1. Use of "as-purchased" compliant coating materials 2. Use of "as-applied" compliant coating materials 3. Tracking total monthly organic HAP applied 4. Use of a capture system and control device. [40 CFR (a), Minn. R ] Demonstrate, using the procedures in 40 CFR Section (b), that each coating material used does not exceed: kg organic HAP per kg coating material as purchased; or kg organic HAP per kg coating solids as purchased. [40 CFR (a)(1)&(b), Minn. R ] Demonstrate that each coating material as-applied during the month does not exceed: kg organic HAP per kg coating material applied, as determined in accordance with 40 CFR Section (c)(1)(i) & (ii); or kg organic HAP per kg coating solids applied, as determined in accordance with 40 CFR Section (c)(2)(i) & (ii); or Demonstrate that the monthly average as-applied organic HAP content of all coating materials applied does not exceed: kg organic HAP per kg coating material as-applied, as determined in accordance with 40 CFR Section (c)(3); or kg organic HAP per kg coating solids as-applied, as determined in accordance with 40 CFR Section (c)(4). [40 CFR (a)(2) & (c), Minn. R ] Demonstrate that the total monthly organic HAP applied does not exceed the calculated limit as determined by 40 CFR Section (l)(5), in accordance with the procedures set out in 40 CFR Section (d). [40 CFR (a)(3), (d) & (l), Minn. R ] EQUI 315 EU085 Emergency Diesel Fire Water Pump Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuel. [Minn. R , subp. 2(A)] Sulfur Dioxide <= pounds per million Btu heat input. This limit is effective on January 31, [Minn. R , subp. 2(B)] The Permittee shall limit Particulate Matter <= 0.60 grams per horsepower-hour. [40 CFR (c), 40 CFR (c), Minn. R , Minn. R ]

133 Permit expires: [month day, year] Page 133 of The Permittee shall limit NMHC+NOx <= 7.8 grams per horsepower-hour. [40 CFR (c), 40 CFR (c), Minn. R , Minn. R ] The Permittee shall limit Carbon Monoxide <= 3.7 grams per horsepower-hour. [40 CFR (c), 40 CFR (c), Minn. R , Minn. R ] Fuel type: Ultra-Low-Sulfur #2 Fuel Oil only. [Minn. R , subp. 35a] Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency 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. [Minn. R , subps. 4-5] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] The Permittee shall operate and maintain the stationary CI ICE in accordance with the emission standards as required in Sections and , and according to the manufacturer's written instructions or procedures developed by the Permittee that are approved by the engine manufacturer, over the entire life of the engine. The Permittee many only change those settings that are permitted by the manufacturer. [40 CFR , 40 CFR (a), 40 CFR (c), Minn. R , Minn. R ] The Permittee shall limit Sulfur Content of Fuel <= 15.0 parts per million and either a minimum cetane index of 40 or a maximum aromatic content of 35 percent by volume, as required by 40 CFR Section (b). [40 CFR (b), 40 CFR (c), Minn. R , Minn. R ] EQUI 315 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, the facility is a major source as defined at 40 CFR Section 63.2, and EQUI 315 is a compression ignition (CI) stationary RICE with a site rating of less than or equal to 500 brake HP. The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. IIII. No further requirements of 40 CFR pt. 63, subp. ZZZZ apply to EQUI 315. [40 CFR (c)(7), Minn. R ] The Permittee must install a non-resettable hour meter prior to startup of the emergency engine. [40 CFR (a), 40 CFR (c), Minn. R , Minn. R ] The Permittee must demonstrate compliance with the emissions standards of 40 CFR Section (c) according to one of the following methods: (1) Purchase an engine certified according to 40 CFR Part 89 or 94, as applicable, for the same model year and maximum engine power. The engine must be installed and configured according the manufacturer's specifications. (2) Keep record of the performance test for each pollutant for a

134 Permit expires: [month day, year] Page 134 of 243 test conducted on a similar engine. The test must have been conducted using the same methods specified in 40 CFR pt. 60, subp. IIII, and must have been followed correctly. (3) Keep records of engine manufacturer data indicating compliance with the standards. (4) Keep records of control device vendor data indicating compliance with the standards. (5) Conduct an initial performance test to demonstrate compliance with the emission standards according to the requirements specified in 40 CFR Section [40 CFR (b), 40 CFR (c), Minn. R , Minn. R ] The Permittee may conduct maintenance checks and readiness testing provided that the tests are recommended by Federal, State, or local government; the manufacturer; the vendor; or the insurance company associated with the engine. Maintenance checks and readiness testing are limited to 100 hours/year. There is no time limit on the use of emergency stationary ICE in emergency situations unless otherwise prohibited by the permit. The Permittee may petition the Administrator for approval of additional hours. A petition is not required if the Permittee maintains records indicating that the Federal, State or local standards require maintenance and testing beyond 100 hours/year. Any other operation other than emergency operation, and maintenance and testing as permitted in this section, is prohibited. [40 CFR (f), 40 CFR (c), Minn. R , Minn. R ] If the emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the Permittee must keep records of the operation of the engine in emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must record the time of operation of the engine and the reason the engine was in operation during that time. [40 CFR (b), 40 CFR (c), Minn. R , Minn. R ] The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), 40 CFR (c), Minn. R , Minn. R , subp. 1] Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), 40 CFR (c), Minn. R , Minn. R , subp. 1] Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section

135 Permit expires: [month day, year] Page 135 of (f), which specifies two years. [40 CFR 60.7(f), 40 CFR (c), Minn. R , subp. 5(C), Minn. R , Minn. R , subp. 1] No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, 40 CFR (c), Minn. R , Minn. R ] Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: (1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. [40 CFR 63.4(b), Minn. R ] Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R , subp. 2(B)] The Permittee shall maintain, at a minimum, the following information in the files: 1) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 2) all required measurements needed to demonstrate compliance with a relevant standard; 3) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 4) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 5) all CMS calibration checks; 6) all adjustments and maintenance performed on CMS; 7) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 8) All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test, if the source has been granted such permission under 40 CFR 63.8(f)(6); and 9) all documentation supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R , subp. 2(B)]

136 Permit expires: [month day, year] Page 136 of Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3)& Minn. R ] After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major-emitting or reconstructs an affected source that is not major-emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b). [40 CFR 63.5(b)(4)& Minn. R ] After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b), Minn. R ] EQUI 316 Chip Presteaming Bin [Stage 1] The Permittee is authorized to construct EQUI316. The construction authorization expires if construction does not commence within 18 months after Issuance of Air Emissions Permit No , if construction is discontinued for a period of 18 months or more, or if construction is not completed within a reasonable time. [40 CFR 52.21(r)(2)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] FUGI 2 EU087 Existing Cooling Tower - zfugative Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)]

137 Permit expires: [month day, year] Page 137 of 243 FUGI 6 FS008 Paved Roads 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 [Minn. R ] Speed Limits: Not to exceed 5 miles per hour (mph) on the scale road (Segment A) or 15 mph on the paved road encompassing the roundwood storage yards (Segments F, G, H, I, J, and K). See figure in Appendix C. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Modeled Silt Load Limit (grams/square meter [g/m2]): Segment A: g/m2 The limit is the silt loading value for the listed segment from the MPCA's Standardized Air Modeling (SAM) spreadsheet, column AF. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Silt Load Testing: As requested by the MPCA, the facility shall conduct separate on-site silt load testing for the paved road segment listed above (Modeled Silt Load Limit), in accordance with a performance test plan approved by the MPCA. Silt load tests shall be conducted in accordance with EPA guidance in Appendices C-1 and C-2 of AP-42. The Permittee shall keep records of all silt load testing. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] The Permittee must conduct sweeping of FUGI6 in accordance with the approved Fugitive Dust Control Plan. [Minn. R , subp. 2] FUGI 7 FS005 Unpaved Roads Chemical Dust Suppression: At least once per month during May, June, July, August, and September of each calendar year, a chemical dust suppressant shall be applied to the travel routes at a rate of at least 0.17 gallons per square yard. Additional applications of chemical dust suppressant shall be made in other months as necessary. The travel routes must also be watered at least once between each chemical dust suppressant application, to reactivate the chemical dust suppressant. Additional waterings shall be

138 Permit expires: [month day, year] Page 138 of 243 performed as necessary. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] The Permittee shall regularly observe travel routes for traffic in the unpaved areas to determine if there is excessive spillage of dust that could become airborne, and if so, take steps to control fugitive emissions, including watering and/or the use of a calcium chloride solution or other chemical dust suppression, as described above. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] TREA 6 CE030 Recovery Boiler #10 - Ventri- Rod Scrubber The Permittee shall vent emissions from EQUI51 to TREA6 whenever EQUI51 operates, and operate and maintain TREA6 at all times that any emissions are vented to TREA6. The Permittee shall document periods of non-operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2] The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R , subp. 14] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 94 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 14, Minn. R , subp. 2] Liquid Flow Rate >= 300 gallons per minute unless a new limit is

139 Permit expires: [month day, year] Page 139 of 243 set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R , subp. 14, Minn. R , subp. 2] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [Minn. R , subp. 4] Recordkeeping of Pressure Drop: The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop for TREA6. [Minn. R , subps. 4-5] Recordkeeping of Liquid Flow Rate. The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid flow rate for TREA6. [Minn. R , subps. 4-5] Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R , subps. 4-5] Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA6. The record shall include the time and date of the reading and whether or not it was within the range specified by this permit. [Minn. R , subp. 14, Minn. R , subp. 2] Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R , subp. 14, Minn. R , subps. 4-5] Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R , subp. 14, Minn. R , subps. 4-5] Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and

140 Permit expires: [month day, year] Page 140 of 243 shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R , subps. 4-5, Minn. R , subp. 14] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the recorded liquid flow rate is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or liquid flow rate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber. [Minn. R , subp. 14, Minn. R , subps. 4-5] TREA 12 CE017 Smelt Dissolving Tank - Spray Tower The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 95 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 80 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur - Total Reduced including H2S >= 98 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Pressure Drop <= 0 inches of water column. A negative draft must be present for TREA12 properly operate. [40 CFR 64.3(a), Minn. R , subp. 14, Minn. R ] Water pressure >= 10 and <= 20 psi (gauge) (Liquid Supply Pressure) unless a new range is set pursuant to Minn. R.

141 Permit expires: [month day, year] Page 141 of , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded water pressure is outside the required range, this shall be reported as a deviation. [40 CFR 64.3(a), Minn. R , subp. 14, Minn. R ] Liquid Flow Rate >= 300 gallons per minute unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded scrubber liquid flow rate is outside the required range, this shall be reported as a deviation. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [40 CFR 64.3(a), Minn. R , subp. 14, Minn. R ] Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 14, Minn. R , subp. 2] Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the scrubbing liquid supply pressure to the control equipment. The monitoring device is to be certified by the manufacturer to be accurate within +/- 15 percent of design scrubbing liquid supply pressure. The pressure sensor or tap is to be located close to the scrubber liquid discharge point. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR (b)(2)(ii), 40 CFR 64.7(a), Minn. R , Minn. R ] Liquid Flow Rate >= 300 gallons per minute unless a new limit is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R , subp. 14, Minn. R , subp. 2] Install, calibrate, maintain, and operate a monitoring device for

142 Permit expires: [month day, year] Page 142 of 243 the continuous measurement of the pressure loss of the gas stream through the control equipment. The monitoring device is to be certified by the manufacturer to be accurate to within a gage pressure of +/- 2 inches water gage pressure. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR (b)(2)(i), 40 CFR 64.7(a), Minn. R , Minn. R ] Record once per shift, measurements obtained from the monitoring device for the continuous measurement of the pressure loss of the gas stream through the control equipment and from the monitoring device for the continuous measurement of the scrubbing liquid supply pressure to the control equipment. This requirement is met through recordkeeping provided by continuous measurement devices for the control equipment. The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop of the gas stream and scrubbing liquid supply pressure and calculated eight-hour rolling average for the control equipment. [40 CFR (c)(4), Minn. R ] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [Minn. R , subp. 4] Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [40 CFR 64.3, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded liquid supply pressure is outside the required operating range; or - the recorded water flow rate is outside the required operating range; or - the recorded pressure drop is outside the required operating range; or - the spray tower or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or water flow rate and/or liquid supply pressure to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the spray tower. The Permittee shall keep a record of the type and date of any corrective action taken for the filter. [40 CFR 64.7(d)(1), Minn. R ] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording

143 Permit expires: [month day, year] Page 143 of 243 pressure drop, water flow rate, and water supply pressure as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R ] The Permittee shall calibrate the gauges at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.3, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Section 6 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] TREA 15 CE003 Power Boiler #7 ESP The Permittee shall vent emissions from EQUI2 (Power Boiler #7) to TREA15 whenever EQUI2 operates, and operate and maintain TREA15 at all times that any emissions are vented to TREA15. The Permittee shall document periods of non-operation of the control equipment TREA15 whenever EQUI2 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] If the Permittee replaces TREA15, the replacement control must meet or exceed the control efficiency requirements of TREA15 as well as comply with all other requirements of TREA15. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee

144 Permit expires: [month day, year] Page 144 of 243 shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] ESP monitoring: The COMS (EQUI102) for the emission unit (EQUI2) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R , subp. 2, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn.

145 Permit expires: [month day, year] Page 145 of 243 R , subp. 14] Opacity <= 10.0 percent opacity 3-hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Section 64.6(c)(2). [40 CFR 64.3, Minn. R ] Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI102 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R ] Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R ] Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 10%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R ] TREA 16 CE010 ClO2 Plant Scrubber The Permittee shall vent emissions from EQUI301 (Chlorine Dioxide Plant) to TREA16 whenever EQUI301 operates, and operate and maintain TREA16 at all times that any emissions are

146 Permit expires: [month day, year] Page 146 of 243 vented to TREA16. The Permittee shall document periods of nonoperation of the control equipment TREA16 whenever EQUI301 is operating. [Minn. R , subp. 14, Minn. R , subp. 2] The Permittee shall operate and maintain TREA16 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 82 percent control efficiency. [Minn. R , subp. 2] Pressure Drop >= 0 and <= 5.0 psi (gauge) (gas pressure loss) unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R , subp. 14, Minn. R , subp. 2] Liquid Flow Rate >= 120 gallons per minute unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R , subp. 14, Minn. R , subp. 2] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording the liquid flow rate and pressure drop, as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when TREA16 is in operation. [Minn. R , subp. 4] Control Equipment Monitoring: The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid supply flow rates for TREA16. [Minn. R , subp. 14, Minn. R , subp. 2] Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R , subps. 4-5] Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA16. The record shall include the time and date of the reading and whether or not it was within the range specified by this permit. [Minn. R , subp. 14, Minn. R , subp. 2]

147 Permit expires: [month day, year] Page 147 of Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R , subps. 4-5, Minn. R , subp. 14] Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R , subps. 4-5, Minn. R , subp. 14] Corrective Actions: If the liquid flow rate is below the minimum listed above, or if the pressure drop is outside the specified ranges, or if the control device or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the liquid flow rate and/or pressure drops to the specified limits/ranges and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the condenser. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R , subps. 4-5, Minn. R , subp. 14] TREA 17 CE011 Bleach Plant Scrubber The Permittee shall vent emissions from EQUI7 (Bleach Plant) to TREA17 whenever EQUI7 operates, and operate and maintain TREA17 at all times that any emissions are vented to TREA17. The Permittee shall document periods of non-operation of the control equipment TREA17 whenever EQUI7 is operating. [Minn. R , subp. 14, Minn. R , subp. 2] Control Equipment Operation: The Permittee shall operate the gas scrubber in a manner consistent with the minimum or maximum (as appropriate) operating parameter value or procedure required to be monitored under paragraphs (a) - (n) of 40 CFR and as described in 40 CFR (o). Operation of the control device below minimum operating parameter values or above maximum operating parameter values established under 40 CFR pt. 63, subp. S shall constitute a violation of the applicable emission standard of 40 CFR pt. 63, subp. S and shall be reported as a period of excess emissions. [40 CFR (o), Minn. R ] Control Equipment Monitoring: The Permittee shall maintain an electronic copy with calculated 8-hour averages for TREA17 of the: - ph or Oxidation Reduction Potential and calculated eight-hour rolling average; - Gas Scrubber Liquid Flow Rate; and - Gas Scrubber Vent Gas Inlet Fan. [40 CFR (c), Minn. R.

148 Permit expires: [month day, year] Page 148 of , subp. 14, Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 99 percent control efficiency. [Minn. R , subp. 2] ph >= 10.5 (no units) or Oxidation Reduction Potential <= -400 mv; or as determined during the most recent performance test. [40 CFR (c)(1), (n), & (o), Minn. R , subp. 4, Minn. R ] Liquid Flow Rate >= 225 gallons per minute (Gas Scrubber Liquid Rate) or as determined during most recent performance test. [40 CFR (c)(3), (n), & (o), Minn. R , subp. 14, Minn. R ] Gas Scrubber Fan Amperage: >= 33%; or as determined during the most recent performance test. [40 CFR (c)(2), (n), & (o), Minn. R , subp. 14, Minn. R ] CMS for Scrubber: The Permittee shall install, calibrate, certify, operate, and maintain a CMS to measure the following parameters for the gas scrubber: 1. The ph or the oxidation/reduction potential of the gas scrubber effluent; 2. The fan amperage; and 3. The gas scrubber liquid influent flow rate. An option to the CMS requirement above, is to install, calibrate, certify, operate, and maintain a CMS to measure the chlorine outlet concentration of each gas scrubber used to comply with the bleaching system outlet concentration requirement specified in 40 CFR Section (c)(2). [40 CFR (a),(c),&(d), Minn. R ] Scrubber Parameter Values: To establish or reestablish the value for each operating parameter required to be monitored under 40 CFR Section , the Permittee shall use the procedures described in 40 CFR Section (n). [40 CFR (n), Minn. R ] Corrective Actions: If the monitored parameter is out of the range as described above, the Permittee shall follow the facility O&M Plan and perform the necessary corrective actions) as soon as possible to get the parameters back into the correct range. The Permittee shall keep a record of the type and date of all corrective actions taken. [Minn. R , subp. 14, Minn. R , subp. 5] TREA 19 CE006 Power Boiler #9 ESP The Permittee shall vent emissions from EQUI4 (Power Boiler #9) to TREA19 whenever EQUI4 operates, and operate and maintain TREA19 at all times that any emissions are vented to TREA19. The Permittee shall document periods of non-operation of the control equipment TREA19 whenever EQUI4 is operating. [Title I

149 Permit expires: [month day, year] Page 149 of 243 Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] If the Permittee replaces TREA19, the replacement control must meet or exceed the control efficiency requirements of TREA19 as well as comply with all other requirements of TREA19. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] ESP monitoring: The COMS (EQUI136) for the emission unit (EQUI4) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R , subp. 2, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

150 Permit expires: [month day, year] Page 150 of The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Opacity <= 10.0 percent opacity 3-hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Section 64.6(c)(2). [40 CFR 64.3, Minn. R ] Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI136 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R ] Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R ] Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 10%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any

151 Permit expires: [month day, year] Page 151 of 243 corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R ] TREA 20 CE007 Recovery Boiler #10 ESP [Stage 1] The Permittee shall vent emissions from EQUI53 (Recovery Boiler #10) to TREA20 whenever EQUI53 operates, and operate and maintain TREA20 at all times that any emissions are vented to TREA20. The Permittee shall document periods of non-operation of the control equipment TREA20 whenever EQUI53 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] If the Permittee replaces TREA20, the replacement control must meet or exceed the control efficiency requirements of TREA20 as well as comply with all other requirements of TREA20. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] ESP monitoring: The COMS (EQUI113) for the emission unit (EQUI53) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R , subp. 2, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor

152 Permit expires: [month day, year] Page 152 of 243 performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Opacity <= 15.0 percent opacity 3-hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Section 64.6(c)(2). [40 CFR 64.3, Minn. R ] Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI113 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R ] Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R ] Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall

153 Permit expires: [month day, year] Page 153 of 243 inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 15%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R ] TREA 21 CE019 Rotary Lime Kiln ESP The Permittee shall vent emissions from EQUI52 (Rotary Lime Kiln) to TREA21 whenever EQUI52 operates, and operate and maintain TREA21 at all times that any emissions are vented to TREA21. The Permittee shall document periods of non-operation of the control equipment TREA21 whenever EQUI52 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] If the Permittee replaces TREA21, the replacement control must meet or exceed the control efficiency requirements of TREA21 as well as comply with all other requirements of TREA21. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] ESP monitoring: The COMS (EQUI108) for the emission unit (EQUI52) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R , subp. 2, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results

154 Permit expires: [month day, year] Page 154 of 243 of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Opacity <= 15.0 percent opacity 3-hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Section 64.6(c)(2). [40 CFR 64.3, Minn. R ] Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI108 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R.

155 Permit expires: [month day, year] Page 155 of ] Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R ] Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 15%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R ] TREA 30 CE022 Incinerator for TRS on IQS The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of nonoperation of the control equipment TREA30. If the incinerator TREA30 is not operational emissions must be vented to Power Boiler #7 or #9 as specified elsewhere in the permit. [Minn. R , subp. 2] If the Permittee replaces TREA30, the replacement control must meet or exceed the control efficiency requirements of TREA30 as well as comply with all other requirements of TREA30. Prior to

156 Permit expires: [month day, year] Page 156 of 243 making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R , subp. 2] The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 98.0 percent control efficiency. [Minn. R , subp. 2] The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Sulfur - Total Reduced including H2S >= 98 percent destruction efficiency. [Minn. R , subp. 2] Temperature >= 1200 degrees Fahrenheit at the combustion chamber outlet (a minimum residence time of 0.5 seconds is also required), unless a new limit is required to be set pursuant to Minn. R , subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC and TRS emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [40 CFR (a)(1)(iii), 40 CFR 64.3(a), Minn. R , Minn. R ] Temperature >= 1500 degrees Fahrenheit 3-hour rolling average at the combustion chamber outlet, unless a new limit is required to be set pursuant to Minn. R , subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [40 CFR (d)(3), 40 CFR 64.3(a), Minn. R , subp. 2, Minn. R , Minn. R , Minn. R , subp. 3] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify

157 Permit expires: [month day, year] Page 157 of 243 the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] CMS: A CMS shall be operated to measure the temperature in the firebox or in the ductwork immediately downstream of the firebox and before any substantial heat exchange occurs. [40 CFR (b), Minn. R ] Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 2.5 degrees Celsius. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [40 CFR 64.3(b)(4)(ii) and Minn. R , Minn. R , subp. 2] Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R , subp. 2, Minn. R ] Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring at the point of incineration of effluent gases. The monitoring equipment must be

158 Permit expires: [month day, year] Page 158 of 243 installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR , 40 CFR 64.7(b), Minn. R , Minn. R ] The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R , subp. 2, Minn. R ] Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R ] Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R ] For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. [Minn. R , subp. 2] Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d), Minn. R ] TREA 31 CE023 SO2 Scrubber for IQS The Permittee shall operate and maintain the scrubber in

159 Permit expires: [month day, year] Page 159 of 243 accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R , subp. 14] The Permittee is allowed to conduct on-line acid washes on TREA28 in accordance with the O & M Plan. The Permittee shall record the time, date, and duration of the on-line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on-line acid wash. [Minn. R , subp. 2] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur Dioxide >= 99 percent destruction efficiency. [Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] ph >= 7.4 (no units) 3-hour block average, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. This limit does not apply during on-line acid washes as allowed in the O & M Plan. [40 CFR 64.3(a), Minn. R , Minn. R , Minn. R , subp. 3, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Liquid Flow Rate >= 584 gallons per minute 3-hour block average, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [40 CFR 64.3(a), Minn. R , Minn. R , Minn. R , subp. 3, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Monitoring: Install, calibrate, maintain, and operate a continuous monitoring system to measure and record the ph and flow rate in the scrubber. [40 CFR 64.7(a), Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Daily Monitoring: The Permittee shall physically verify the operation of the ph and liquid flow rate recording devices at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall maintain a continuous hard copy readout or computer disk file of the ph and liquid flow rate readings and calculated three hour rolling averages. [40 CFR 64.9(b), Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ]

160 Permit expires: [month day, year] Page 160 of Annual Calibration: The Permittee shall calibrate the ph monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R ] Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R ] Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R ] Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Section 5 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm,

161 Permit expires: [month day, year] Page 161 of 243 computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] 6. Submittal/action requirements This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Sappi Cloquet LLC The Permittee shall submit a computer dispersion modeling protocol : Due before 09/13/2025 for PM10 and PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)] The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar halfyear 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 occurred, the Permittee shall submit the report stating no deviations. [Minn. R , subp. 6(A)(2)] The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R , subp. 6(C)] The Permittee shall submit excess emission/downtime report : Due by 30 days after the end of each calendar quarter following permit issuance. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypasses during the quarter. [40 CFR 60.7(c), Minn. R , subp. 1-2]

162 Permit expires: [month day, year] Page 162 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation EQUI 2 EU002 Power Boiler #7 (Spreader Stoker - Bark) The Permittee shall submit an initial compliance status report : Due before 07/31/2017. The Initial Compliance Status Report must cover the reporting period beginning on January 31, 2017 and ending on June 30, The Compliance Status Report must contain the information specified in 40 CFR Section (c). [40 CFR (b)(1)and (2), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in 40 CFR Section (e)(1)-(8), as applicable. The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR (d), 40 CFR (e), Minn. R ] The Permittee shall submit a compliance status report : Due semiannually, by the 31st of January and July according to 40 CFR Section (h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Compliance Status Report must contain the information specified in 40 CFR Section (c). [40 CFR (b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] PM < 10 micron : The Permittee shall conduct a performance test : Due before 10/19/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required:

163 Permit expires: [month day, year] Page 163 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/19/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Particulate Matter : The Permittee shall conduct a performance test : Due before 10/21/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR

164 Permit expires: [month day, year] Page 164 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 52.21(k)(modeling) & Minn. R ] Front-half Particulate Matter : The Permittee shall conduct a performance test : Due before 10/19/2017 every 12 months thereafter to measure emissions according to 40 CFR Section , except as specified in 40 CFR Section (b)-(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive 2-year period are at or below 75 percent of the emission limit. [40 CFR (a)-(c), Minn. R ] Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/10/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 11/20/2018 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, using Method OTM 13A, or other method approved by MPCA in the performance test plan approval. This permit contains process

165 Permit expires: [month day, year] Page 165 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation throughput limits for EQUI 2. The process throughput limits will be defined by the operating rates sustained during the test, and may be reset within a Notice of Compliance letter. Target process throughput rates as of permit # are listed in Appendix D along with other recordkeeping items that must be included in the performance test report. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R ] Mercury : The Permittee shall conduct a performance test : Due before 05/28/2020 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 30B, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] EQUI 4 EU004 Power Boiler #9 (Bark) The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2).

166 Permit expires: [month day, year] Page 166 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation The Notification of Compliance Status report must contain all the information specified in 40 CFR Section (e)(1)-(8), as applicable. The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR (d), 40 CFR (e), Minn. R ] The Permittee shall submit a compliance status report : Due by 31 days after end of each calendar half-year according to 40 CFR Section (h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Compliance Status Report must contain the information specified in 40 CFR Section (c). [40 CFR (b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] PM < 10 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C).

167 Permit expires: [month day, year] Page 167 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Front-half Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2020 every 36 months thereafter to measure emissions according to 40 CFR Section , except as specified in 40 CFR Section (b)-(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance

168 Permit expires: [month day, year] Page 168 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation tests until all performance tests over a consecutive 2-year period are at or below 75 percent of the emission limit. [40 CFR (a)-(c), Minn. R ] Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R ] Mercury : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 30B, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] EQUI 7 EU011 Bleach Plant Chlorine Dioxide : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions.

169 Permit expires: [month day, year] Page 169 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 20, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] Carbon Monoxide : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be

170 Permit expires: [month day, year] Page 170 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] HAPs - Total (Total Chlorinated HAP) : The Permittee shall conduct a performance test : Due before 09/01/2020 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60- month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using NCASI Method 520, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR (a)(2), Minn. R ] EQUI 18 EU037 Power Boiler # Particulate Matter : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of combustion of fuel oil, to measure Total Particulate Matter emissions while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] PM < 10 micron : The Permittee shall conduct initial performance test : Due 150 calendar days after Initial Startup Date of combustion of fuel oil to measure emissions of Particulate Matter < 10 micron while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R.

171 Permit expires: [month day, year] Page 171 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation , subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date of combustion of fuel oil. [Minn. R , subp. 1] The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section (e)(1) and (8). The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR (d), 40 CFR (e), Minn. R ] The Permittee shall submit a compliance status report : Due by January 31 of each calendar year according to 40 CFR Section (h). The Compliance Status Reports must cover the applicable 1-year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than January 31 of the year in which it is due. The Compliance Status Report must contain the information in 40 CFR Section (c)(5)(i)-(iv) and (xiv). [40 CFR (b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] EQUI 49 EU081 IQS - Incinerator PM < 10 micron : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies

172 Permit expires: [month day, year] Page 172 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Particulate Matter : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C).. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 02/19/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests

173 Permit expires: [month day, year] Page 173 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 09/01/2017 every 12 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 12-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfur - Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be

174 Permit expires: [month day, year] Page 174 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1] HAPs - Total : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using procedures in 40 CFR Section , or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR (a)(2), Minn. R , Minn. R , subp. 1] EQUI 51 EU031 Smelt Dissolving Tank for RB # Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ]

175 Permit expires: [month day, year] Page 175 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfur - Total Reduced including H2S : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial Performance Test Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36- month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R ,

176 Permit expires: [month day, year] Page 176 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfur - Total Reduced including H2S: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days after Initial Performance Test Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] EQUI 52 EU033 Rotary Lime Kiln - Kiln Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Carbon Monoxide : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfur Dioxide : The Permittee shall conduct an initial performance

177 Permit expires: [month day, year] Page 177 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 6C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Mercury : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R , subp. 1] Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for sulfuric acid mist: Due 60 calendar days after Initial Performance Test Date for sulfuric acid mist emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36- month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Carbon Monoxide: The Permittee shall submit a test frequency plan for Carbon Monoxide: Due 60 calendar days after Initial Performance Test Date for CO emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60- month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ]

178 Permit expires: [month day, year] Page 178 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Sulfur Dioxide: The Permittee shall submit a test frequency plan for Sulfur Dioxide: Due 60 calendar days after Initial Performance Test Date for SO2 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days after Initial Performance Test Date for VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36- month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Mercury: The Permittee shall submit a test frequency plan for Mercury: Due 60 calendar days after Initial Performance Test Date for Mercury emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] PM < 10 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at

179 Permit expires: [month day, year] Page 179 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Filterable Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60- month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval and by following the provisions in 40 CFR Sections 60.8 and a(b)(1) and (2).

180 Permit expires: [month day, year] Page 180 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR a(b)(4)] Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/30/2017 every 12 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 12-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfur - Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 10/18/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60- month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required:

181 Permit expires: [month day, year] Page 181 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR a(d)(4), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 53 EU005 Recovery Boiler # [Stage 1] Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R ] [Stage 1] PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] [Stage 1] PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum

182 Permit expires: [month day, year] Page 182 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R , subp. 3(C). [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial Performance Test Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36- month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R ] Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days after Initial Performance Test Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36- month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ]

183 Permit expires: [month day, year] Page 183 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation EQUI 71 MR004 Power Boiler #9 - SO The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 76 MR044 Power Boiler #9 - O The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 107 MR027 Power Boiler #9 - CO The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 108 MR030 Rotary Lime Kiln - Opacity The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve quality assured data for four consecutive quarters may reduce

184 Permit expires: [month day, year] Page 184 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation audit frequency to semi-annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R ] EQUI 110 MR043 RB#10 CO The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 112 MR013 Power Boiler #8 - NOx The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 113 MR014 Recovery Boiler #10 - Opacity The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve

185 Permit expires: [month day, year] Page 185 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation quality assured data for four consecutive quarters may reduce audit frequency to semi-annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R ] EQUI 114 MR015 Recovery Boiler #10 - NOx The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 115 MR016 Recovery Boiler #10 - SO The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 116 MR017 Recovery Boiler #10 - TRS The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three

186 Permit expires: [month day, year] Page 186 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 117 MR018 Recovery Boiler #10 - CO The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 118 MR019 Recovery Boiler #10 - O The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 119 MR020 Power Boiler #7 - SO The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a]

187 Permit expires: [month day, year] Page 187 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 120 MR021 Rotary Lime Kiln - TRS The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 121 MR022 Rotary Lime Kiln - O The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 122 MR023 Power Boiler #7 - O The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1] EQUI 123 MR025 Power Boiler #7 - CO The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

188 Permit expires: [month day, year] Page 188 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation EQUI 135 MR001 Power Boiler #7 - Opacity The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve quality assured data for four consecutive quarters may reduce audit frequency to semi-annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R ] EQUI 136 MR002 Power Boiler #9 - Opacity The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve quality assured data for four consecutive quarters may reduce audit frequency to semi-annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R ] EQUI 137 MR003 Power Boiler #9 - NOx The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 138 MR012 Power Boiler #8 - O The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA

189 Permit expires: [month day, year] Page 189 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R , subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R , subp. 4a] The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R , subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R , subp. 5a] EQUI 290 EU089 R&D Boiler The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section (e)(1) and (8). The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR (d), 40 CFR (e), Minn. R ] The Permittee shall submit an initial compliance status report : Due before 01/31/2021 according to 40 CFR Section (h). The Initial Compliance Status Report must cover the reporting period beginning on January 31, 2016 and ending on December 31, The Compliance Status Report must contain the information in 40 CFR Section (c)(5)(i)-(iv) and (xiv). [40 CFR (b)(1)and (2), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] Compliance Status Report: due 31 days after end of each calendar 60 months starting 01/01/2021, according to 40 CFR Section (h). The Compliance Status Reports must cover the applicable 5-year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than January 31 of the year in which it is due. The Compliance Status Report must contain the information in 40 CFR Section (c)(5)(i)-(iv) and (xiv). [40 CFR (b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R ] EQUI 304 EU051 #13 Coater The Permittee shall submit a submit a semiannual compliance report : Due by 30 days after end of each calendar half-year for each emission unit subject to a standard in 40 CFR pt. 63. This may be submitted with the annual Compliance Certification. The report must contain the information listed in 40 CFR Section

190 Permit expires: [month day, year] Page 190 of 243 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation (c)(2). [40 CFR (c), Minn. R ] EQUI 316 Chip Presteaming Bin Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to verify the emission factor of ton VOC (as mass) per ton green chips. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 2, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1] Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days after Initial Performance Test Date for VOC emission factor. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a notification of the date construction began: Due 30 calendar days after Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. [Minn. R , subp. 16(L)] The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R , subp. 42a. [Minn. R , subp. 16(L)]

191 Permit expires: [month day, year] Page 191 of Appendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements. Minn. R. Rule description of the activity General applicable requirement Minn. R , subp. 3(A) Fuel Use: space heaters fueled by kerosene, natural gas, or propane, less than 420,000 Btu/hr Sappi has fewer than 10 space heaters located throughout the facility which combust kerosene, propane, and natural gas. Combined capacity is less than 420,000 Btu/hour. Minn. R , subp. Infrared electric ovens 3(B)(1) Sappi has infrared dryers on the coater. Minn. R , subp. 3(B)(2) Minn. R , subp. 3(E)(1) Minn. R , subp. 3(E)(2) Indirect heating equipment with a capacity less than 420,000 Btu/hour, etc. Sappi has 2 portable air compressors, and fewer than 10 pumps which fire gasoline. Capacity of each is less than 420,000 Btu/hour, and the total combined capacity is less than 1.4 MMBtu/hour. Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons See Table C-3 Nonhazardous air pollutant VOC storage tanks with total capacity not more than 10,000 gallons meeting certain vapor pressure requirements See Table C-3 Minn. R , subp. 3(G) Emissions from a laboratory, as defined in Minn. R , subp. 3(G) Sappi has four laboratories at its facility: Pulp QC, Paper QC; Technical and Environmental Department QC and environmental analysis; and Research and Development. Materials processed in all four of these laboratories are not sold for profit. Sappi has process control labs within the mill operating departments Minn. R , subp. 3(H)(3) Brazing, soldering or welding equipment Brazing, soldering and welding are performed for maintenance, repair and PM <= 0.6 or 0.4 lb/mmbtu, depending on year constructed Opacity <= 20% with exceptions (Minn. R /0515) Opacity <= 20% (Minn. R or ) Opacity <= 20%; SO2 <= 0.50 pounds per million Btu heat input (Minn. R ) Minn. R /0715 and/or Minn. R , subp. 2(B)/1505, subp. 3(B) and/or Minn. R /0110 Minn. R /0715 and/or Minn. R , subp. 2(B)/1505, subp. 3 (B) and/or Minn. R /0110 PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715)

192 Permit expires: [month day, year] Page 192 of 243 Minn. R. Rule description of the activity General applicable requirement fabrication. Sappi has a maximum of 75 welding units on-site including electric welders and oxy/acetylene torches. Minn. R , subp. 3(H)(5) Minn. R , subp. 3(H)(7) Minn. R , subp. 3(I) Minn. R , subp. 4 Equipment used exclusively for melting or application of wax Sappi has several units on site that melt petroleum wax which is used as an adhesive in packaging activities. Cleaning operations: alkaline/phosphate cleaners and associated cleaners Parts cleaners Individual units with potential emissions less than 2000 lb/year of certain pollutants Chlorine bleach plant cooling tower, potential emissions are 0.13 tpy PM, and 0.12 tpy PM10 Individual units with potential or actual emissions meeting the criteria in Minn. R , subp. 4(A)-(D) See Table C-3. PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) PM, variable depending on airflow Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) Table C-3. Insignificant Activities Listed under Minn. R , subps. 3(E) and 4 Area Emission Source Pollutants Emitted Generally Applicable Requirement Lime Kiln/ Lime Mud Washer Vents TRS/VOC Minn. R /0715 Recausticizing Area Lime Mud Storage Tank Vent TRS/VOC White Liquor Clarifier TRS/VOC Green Liquor Clarifier TRS/VOC Lime Mud Washer Head Tank TRS/VOC White Liquor Head Tank TRS/VOC Green Liquor Head Tank TRS/VOC Slaker Vent TRS/VOC Causticizer Tanks (4) TRS/VOC Causticizer Liquor Storage TRS/VOC NaSH Storage Tanks (2) TRS/VOC Dregs Storage Tank TRS/VOC Interceptor Sewer Vent TRS/VOC Green Liquor Stabilization Tank TRS/VOC NaOH Unloading Building Vent NaOH Sample Sink Vent Fan TRS/VOC Lime Storage Silos (2) PM Formic Acid Wash Tank Vent TRS White Liquor Oxidizer VOC Bleach Plant Area Sulfuric Acid Storage Tank Vent H2SO4 Minn. R /0715 Bleached Pulp Storage Tanks (3) ClO2/VOC EOP Tower TRS/VOC Unbleached Pulp Storage Towers (3) TRS/VOC Power And Chemical Weak Liquor Storage Tanks (2) TRS/VOC Minn. R /0715

193 Permit expires: [month day, year] Page 193 of 243 Area Emission Source Pollutants Emitted Generally Applicable Requirement Recovery Area Boilout Tank Relief Valve TRS/VOC Spill Tank Vents (2) TRS/VOC Soap Tank Vent TRS/VOC Soap Skimmer Tank TRS/VOC Steam Stripper Vent TRS/VOC Waste Treatment Sulfuric Acid Tank H2SO4 Sample Sink Vent Fan TRS/VOC 80 Thickener VOC/HAP 80 Clarifier VOC/HAP Paper Machine/ Dry Bulk Storage Silos (6) PM Minn. R /0715 Coating/ Finishing/ Dry Bulk Reclaim Receivers (4) PM Shipping Area Color Kitchen Roof Fans (2) PM Broke Bins Criteria Pollutants Box Shop (Finishing Department) Criteria Pollutants Color Kitchen Cowles Mixers PM Leveling Towers / Stock Chest VOC Petroleum Fuel Fuel Oil Tank Vents (2) VOC Minn. R /0715 Storage Tanks Hydroelectric Plant Diesel Tank VOC 40 CFR Part 60, Subpart Kb Roundhouse Diesel Fuel Tank Vent VOC (recordkeeping only) Roundhouse Gasoline Storage Tank VOC Wood Prep. Diesel Fuel Tank VOC Railroad Diesel Tanks (2) VOC Fuel Yard Diesel Tank VOC R & D Building Pilot Coater Dryer Criteria Pollutants Minn. R

194 Permit expires: [month day, year] Page 194 of 243 Appendix B: Stack Parameters Relied Upon in Modeling Note: the parameters listed in this appendix reflect the worst-case operation condition for the standard listed. Table B-1: SO2, NOx, CO, and PM Modeling Parameters used in 2012 modeling Modeling Parameter Units #7 Boiler #8 Boiler #9 Boiler #10 Recovery Boiler Lime Kiln #10 SDT IQS Stack Height ft Stack Diameter ft Exit Velocity ft/sec Temperature F PM lb/hr tpy SO2 lb/hr 1200* * tpy NOx (annual) lb/hr NOx (1-hour) lb/hr NO2/NOx ratio** % CO lb/hr *The combined SO2 PTE for PB7 and PB9 is 1,200 lbs per hour when burning NCGs. The PTE from permitted fuels is 17.1 lbs/hr for PB7 and 24.6 lbs/hr for PB9. **The NO2/NOx ratio was added at permit , to reflect assumptions made in the NO2 modeling for the Cloquet area (Sappi, USG, Jarden Home Brands, and Specialty Minerals). Table B-2: NAAQS/MAAQS Modeling Results Pollutant Averaging Period NAAQS MAAQS Total modeled concentration (includes background and nearby sources) Percent of Standard (ug/m 3 ) (ug/m 3 ) (ug/m 3 ) NAAQS MAAQS CO 1-hr 40,000 35,000 10, % 30.1% 8-hr 10,000 10,000 3, % 35.7% NO2 1-hr 188 NA % NA Annual % 27.9% PM10 24-hr % 64.2% Annual NA NA 76.7% PM hr % 50.7% Annual % 92.5%

195 Permit expires: [month day, year] Page 195 of 243 Table B-3. Point Source Parameters for PM 2.5 and PM hour NAAQS Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Diameter (ft) Temp ( F) Stack Velocity (ft/min) SV , ,174, , , SV , ,174, , , SV , ,174, , , SV , ,174, , , SV , ,174, , , SV , ,174, , , IQS 543, ,174, , , PM1 543, ,174, , , PM2 543, ,174, , , PM3 543, ,174, , , PM4 543, ,174, , , PM5 543, ,174, , , PM6 543, ,174, , , C1 543, ,174, , ,500 13C2 543, ,174, , ,500 13C3 543, ,174, , ,500 13C4 543, ,174, , ,200 13C5 543, ,174, , ,500 13C6 543, ,174, , ,200 4PM1 543, ,174, , ,350 4PM2 543, ,174, , ,350 4PM3 543, ,174, , ,000 4PM4 543, ,174, , ,350 4PM5 543, ,174, ,600 Air Flow (ACFM)

196 Permit expires: [month day, year] Page 196 of 243 Table B-4. Area Source Parameters for PM 2.5 and PM hour NAAQS Source ID EASTING NORTHING PM2.5 PM2.5 PM10 PM10 Height X-Diameter X-Diameter Y-Diameter Y-Diameter (lb/hr) (tpy) (lb/hr) (tpy) (ft) (ft) (m) (ft) (m) SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD019a 543, ,174, SPRD019b 543, ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD026a 543, ,174, SPRD026b 543, ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174,

197 Permit expires: [month day, year] Page 197 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) X-Diameter (ft) X-Diameter (m) Y-Diameter (ft) Y-Diameter (m) SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD047b 543, ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,174, SPRD , ,173, SPRD , ,173, SPRD , ,173, SPRD , ,173, SPRD , ,174, SPRD , ,174, SPRD , ,174,

198 Permit expires: [month day, year] Page 198 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) X-Diameter (ft) X-Diameter (m) Y-Diameter (ft) Y-Diameter (m) SPRD , ,175, SPRD , ,175, SAPCT , ,174, Table B-5. Volume Source Parameters for PM 2.5 and PM hour NAAQS Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPMH01 543, ,174, E E E E SAPMH02 544, ,173, E E E E SAPMH03 543, ,174, E E E E SAPMH04 543, ,174, E E E E SAPMH05 542, ,174, E E E E SAPMH06 542, ,174, E E E E SAPMH07 542, ,174, E E E E SAPMH08 542, ,174, E E E E SAPMH09 543, ,174, E E E E SAPMH10 543, ,174, E E E E SAPMH11 543, ,174, E E E E SAPWE01 542, ,174, E E E E SAPWE02 542, ,174, E E E E SAPWE03 542, ,174, E E E E SAPWE04 542, ,174, E E E E SAPWE05 543, ,174, E E E E SAPWE06 544, ,173, E E E E SAPWE07 543, ,173, E E E E SAPWE08 543, ,173, E E E E SPRD , ,174, E E E E SPRD095a 544, ,173, E E E E Internal Lat Dimension (m)

199 Permit expires: [month day, year] Page 199 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SPRD095b 543, ,173, E E E E SPRD095c 544, ,173, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E Internal Lat Dimension (m)

200 Permit expires: [month day, year] Page 200 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRA , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E Internal Lat Dimension (m)

201 Permit expires: [month day, year] Page 201 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRC , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRD , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRE , ,174, E E E E SAPRF , ,174, E E E E Internal Lat Dimension (m)

202 Permit expires: [month day, year] Page 202 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E Internal Lat Dimension (m)

203 Permit expires: [month day, year] Page 203 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRF , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRG , ,174, E E E E SAPRH , ,174, E E E E Internal Lat Dimension (m)

204 Permit expires: [month day, year] Page 204 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,174, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E Internal Lat Dimension (m)

205 Permit expires: [month day, year] Page 205 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRH , ,175, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E Internal Lat Dimension (m)

206 Permit expires: [month day, year] Page 206 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E Internal Lat Dimension (m)

207 Permit expires: [month day, year] Page 207 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRI , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRJ , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E Internal Lat Dimension (m)

208 Permit expires: [month day, year] Page 208 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,174, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E Internal Lat Dimension (m)

209 Permit expires: [month day, year] Page 209 of 243 Source ID EASTING NORTHING PM2.5 (lb/hr) PM2.5 (tpy) PM10 (lb/hr) PM10 (tpy) Height (ft) Internal Lat Dimension (ft) Internal Lat Dimension (m) Internal Lat Dimension (ft) SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E SAPRK , ,175, E E E E Internal Lat Dimension (m)

210 Permit expires: [month day, year] Page 210 of 243 Table B-6. PM 10 and PM 2.5 Modeled Parameters for permit # Source Operating PM10 PM2.5 Height Diameter Temperature Stack Velocity Air Flow Easting Northing Scenario (lb/hr) (tpy) (lb/hr) (tpy) (m) (m) (K) (m/s) (acfm) EU 033/SV 002 Pre-Project 543, ,174, ,500 Post-Project 543, ,174, ,625 Table B-7. PM 10 SIL Analysis for permit # Averaging Period SIL Total Modeled Concentration Percent of Standard (µg/m 3 ) (µg/m 3 ) (%) 24-hr Annual Table B-8. PM 2.5 SIL-like Increment Screening for permit # Averaging Period Modeled Concentration Increment Consumption Net Concentration Change PSD Class II Increment Percent of Increment (µg/m 3 ) (µg/m 3 ) (µg/m 3 ) (µg/m 3 ) (%) 24-hr Annual Table B-9. PM 2.5 NAAQS Screening for permit # Averaging Period Modeled Concentration SIL Percent of Standard (µg/m 3 ) (µg/m 3 ) (%) 24-hr Annual

211 Permit expires: [month day, year] Page 211 of 243 Table B-10: Parameters used in SIL analysis for permit # SI ID# EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI53 EQUI51 EQUI51 EQUI51 Description Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 Recovery Boiler #10 RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank AERMOD ID Pollutant Averaging Time Operating Scenario Release Type Easting (m) Northing Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) Height (m) Exit Temp (K) Exit Velocity (m/s) Diameter (m) Flow Rate (ACFM) SV6PRE PM10 24-Hour 1 VERTICAL 543, ,174, ,053 SV6POST PM10 24-Hour 2 VERTICAL 543, ,174, ,053 SV6PRE PM10 Annual 1 VERTICAL 543, ,174, ,053 SV6POST PM10 Annual 2 VERTICAL 543, ,174, ,053 SV6PRE PM Hour 1 VERTICAL 543, ,174, ,053 SV6POST PM Hour 2 VERTICAL 543, ,174, ,053 SV6PRE PM2.5 Annual 1 VERTICAL 543, ,174, ,053 SV6POST PM2.5 Annual 2 VERTICAL 543, ,174, ,053 SV6PRE NOx 1-hour 1 VERTICAL 543, ,174, ,053 SV6POST NOx 1-hour 2 VERTICAL 543, ,174, ,053 SV6PRE NOx Annual 1 VERTICAL 543, ,174, ,053 SV6POST NOx Annual 2 VERTICAL 543, ,174, ,053 SV29PRE PM10 24-Hour 1 VERTICAL 543, ,174, ,000 SV29POST PM10 24-Hour 2 VERTICAL 543, ,174, ,000 SV29PRE PM10 Annual 1 VERTICAL 543, ,174, ,000

212 Permit expires: [month day, year] Page 212 of 243 SI ID# EQUI51 EQUI51 EQUI51 EQUI51 EQUI51 EQUI52 EQUI52 EQUI52 EQUI52 EQUI52 EQUI52 EQUI52 EQUI52 EQUI52 Description RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank RB #10 - Smelt Dissolving Tank Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln Rotary Lime Kiln AERMOD ID Pollutant Averaging Time Operating Scenario Release Type Easting (m) Northing Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) Height (m) Exit Temp (K) Exit Velocity (m/s) Diameter (m) Flow Rate (ACFM) SV29POST PM10 Annual 2 VERTICAL 543, ,174, ,000 SV29PRE PM Hour 1 VERTICAL 543, ,174, ,000 SV29POST PM Hour 2 VERTICAL 543, ,174, ,000 SV29PRE PM2.5 Annual 1 VERTICAL 543, ,174, ,000 SV29POST PM2.5 Annual 2 VERTICAL 543, ,174, ,000 SV2PRE PM10 24-Hour 1 VERTICAL 543, ,174, ,500 SV2POST PM10 24-Hour 2 VERTICAL 543, ,174, ,500 SV2PRE PM10 Annual 1 VERTICAL 543, ,174, ,500 SV2POST PM10 Annual 2 VERTICAL 543, ,174, ,500 SV2PRE PM Hour 1 VERTICAL 543, ,174, ,500 SV2POST PM Hour 2 VERTICAL 543, ,174, ,500 SV2PRE PM2.5 Annual 1 VERTICAL 543, ,174, ,500 SV2POST PM2.5 Annual 2 VERTICAL 543, ,174, ,500 SV2PRE NOx 1-hour 3 VERTICAL 543, ,174, ,500

213 Permit expires: [month day, year] Page 213 of 243 SI ID# Description EQUI52 Rotary Lime Kiln EQUI52 Rotary Lime Kiln EQUI52 Rotary Lime Kiln EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator EQUI49 IQS - Incinerator AERMOD ID Pollutant Averaging Time Operating Scenario Release Type Easting (m) Northing Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) Height (m) Exit Temp (K) Exit Velocity (m/s) Diameter (m) Flow Rate (ACFM) SV2POST NOx 1-hour 4 VERTICAL 543, ,174, ,500 SV2PRE NOx Annual 5 VERTICAL 543, ,174, ,500 SV2POST NOx Annual 6 VERTICAL 543, ,174, ,500 SV31PRE PM10 24-Hour 1 VERTICAL 543, ,174, ,000 SV31POST PM10 24-Hour 2 VERTICAL 543, ,174, ,000 SV31PRE PM10 Annual 1 VERTICAL 543, ,174, ,000 SV31POST PM10 Annual 2 VERTICAL 543, ,174, ,000 SV31PRE PM Hour 1 VERTICAL 543, ,174, ,000 SV31POST PM Hour 2 VERTICAL 543, ,174, ,000 SV31PRE PM2.5 Annual 1 VERTICAL 543, ,174, ,000 SV31POST PM2.5 Annual 2 VERTICAL 543, ,174, ,000 SV31PRE NOx 1-hour 1 VERTICAL 543, ,174, ,000 SV31POST NOx 1-hour 2 VERTICAL 543, ,174, ,000 SV31PRE NOx Annual 1 VERTICAL 543, ,174, ,000 SV31POST NOx Annual 2 VERTICAL 543, ,174, ,000

214 Permit expires: [month day, year] Page 214 of 243 Table B-11: Point Source Parameters used in annual PM2.5 NAAQS analysis for permit # SI ID# AERMOD ID Pollutant Averaging Time Release Type Easting (m) Northing (m) Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) STRU30 SAP_IQS PM2.5 Annual VERTICAL 543, ,174, ,325 STRU50 SAP12PM1 PM2.5 Annual VERTICAL 543, ,174, ,071 STRU50 SAP12PM2 PM2.5 Annual VERTICAL 543, ,174, ,354 STRU50 SAP12PM3 PM2.5 Annual VERTICAL 543, ,174, ,861 STRU50 SAP12PM4 PM2.5 Annual VERTICAL 543, ,174, ,861 STRU50 SAP12PM5 PM2.5 Annual VERTICAL 543, ,174, ,825 STRU50 SAP12PM6 PM2.5 Annual VERTICAL 543, ,174, ,553 STRU51 SAP13C1 PM2.5 Annual VERTICAL 543, ,174, ,584 STRU51 SAP13C2 PM2.5 Annual VERTICAL 543, ,174, ,928 STRU51 SAP13C3 PM2.5 Annual VERTICAL 543, ,174, ,928 STRU51 SAP13C4 PM2.5 Annual VERTICAL 543, ,174, ,543 STRU51 SAP13C5 PM2.5 Annual VERTICAL 543, ,174, ,488 STRU51 SAP13C6 PM2.5 Annual VERTICAL 543, ,174, ,543 STRU49 SAP4PM1 PM2.5 Annual VERTICAL 543, ,174, ,278 STRU49 SAP4PM2 PM2.5 Annual VERTICAL 543, ,174, ,278 STRU49 SAP4PM3 PM2.5 Annual VERTICAL 543, ,174, ,910 STRU49 SAP4PM4 PM2.5 Annual VERTICAL 543, ,174, ,278 STRU49 SAP4PM5 PM2.5 Annual VERTICAL 543, ,174, ,400 STRU38 SAPSV002 PM2.5 Annual VERTICAL 543, ,174, ,745 STRU40 SAPSV003 PM2.5 Annual VERTICAL 543, ,174, ,955 STRU28 SAPSV004 PM2.5 Annual VERTICAL 543, ,174, ,320 STRU41 SAPSV005 PM2.5 Annual VERTICAL 543, ,174, ,454 STRU42 SAPSV006 PM2.5 Annual VERTICAL 543, ,174, ,052 STRU47 SAPSV029 PM2.5 Annual VERTICAL 543, ,174, ,922 JHBSV003 PM2.5 Annual VERTICAL JHBSV004 PM2.5 Annual VERTICAL JHBSV012 PM2.5 Annual VERTICAL JHBSV015 PM2.5 Annual VERTICAL Height (m) Exit Temp (K) Exit Velocity (m/s) Diameter (m) Flow Rate (ACFM)

215 Permit expires: [month day, year] Page 215 of 243 JHBSV018 PM2.5 Annual VERTICAL JHBV2 PM2.5 Annual VERTICAL JHBV3 PM2.5 Annual VERTICAL JHBV4 PM2.5 Annual VERTICAL JHBV5 PM2.5 Annual VERTICAL JHBV7 PM2.5 Annual VERTICAL JHBV9 PM2.5 Annual VERTICAL SMI_GPIT PM2.5 Annual VERTICAL USGH7NE PM2.5 Annual VERTICAL USGH7NW PM2.5 Annual VERTICAL USGH7SE PM2.5 Annual VERTICAL USGH7SW PM2.5 Annual VERTICAL USGSH10Z PM2.5 Annual VERTICAL USGSH11Z PM2.5 Annual VERTICAL USGSH12Z PM2.5 Annual VERTICAL USGSH13Z PM2.5 Annual VERTICAL USGSH14Z PM2.5 Annual VERTICAL USGSH15Z PM2.5 Annual VERTICAL USGSH16Z PM2.5 Annual VERTICAL USGSH17Z PM2.5 Annual VERTICAL USGSH18Z PM2.5 Annual VERTICAL USGSH19Z PM2.5 Annual VERTICAL USGSH1B PM2.5 Annual VERTICAL USGSH1C PM2.5 Annual VERTICAL USGSH1I PM2.5 Annual VERTICAL USGSH1Q PM2.5 Annual VERTICAL USGSH1Z PM2.5 Annual VERTICAL USGSH20Z PM2.5 Annual VERTICAL USGSH21Z PM2.5 Annual VERTICAL USGSH22Z PM2.5 Annual VERTICAL USGSH23Z PM2.5 Annual VERTICAL

216 Permit expires: [month day, year] Page 216 of 243 USGSH24Z PM2.5 Annual VERTICAL USGSH25Z PM2.5 Annual VERTICAL USGSH26Z PM2.5 Annual VERTICAL USGSH27Z PM2.5 Annual VERTICAL USGSH28Z PM2.5 Annual VERTICAL USGSH29Z PM2.5 Annual VERTICAL USGSH2C PM2.5 Annual VERTICAL USGSH2Z PM2.5 Annual VERTICAL USGSH30Z PM2.5 Annual VERTICAL USGSH31Z PM2.5 Annual VERTICAL USGSH32S PM2.5 Annual VERTICAL USGSH32Z PM2.5 Annual VERTICAL USGSH33S PM2.5 Annual VERTICAL USGSH33Z PM2.5 Annual VERTICAL USGSH34S PM2.5 Annual VERTICAL USGSH34Z PM2.5 Annual VERTICAL USGSH35S PM2.5 Annual VERTICAL USGSH35Z PM2.5 Annual VERTICAL USGSH36S PM2.5 Annual VERTICAL USGSH36Z PM2.5 Annual VERTICAL USGSH37S PM2.5 Annual VERTICAL USGSH3B PM2.5 Annual VERTICAL USGSH3C PM2.5 Annual VERTICAL USGSH3Z PM2.5 Annual VERTICAL USGSH4Z PM2.5 Annual VERTICAL USGSH5Z PM2.5 Annual VERTICAL USGSH6Z PM2.5 Annual VERTICAL USGSH7Z PM2.5 Annual VERTICAL USGSH8Z PM2.5 Annual VERTICAL USGSH9Z PM2.5 Annual VERTICAL USGSV005 PM2.5 Annual VERTICAL

217 Permit expires: [month day, year] Page 217 of 243 USGSV006 PM2.5 Annual VERTICAL USGSV007 PM2.5 Annual VERTICAL USGSV030 PM2.5 Annual VERTICAL USGSV033 PM2.5 Annual VERTICAL USGSV035 PM2.5 Annual VERTICAL USGSV036 PM2.5 Annual VERTICAL USGSV037 PM2.5 Annual VERTICAL USGSV038 PM2.5 Annual VERTICAL USGSV052 PM2.5 Annual VERTICAL USGSV053 PM2.5 Annual VERTICAL USGSV057 PM2.5 Annual VERTICAL USGSV066 PM2.5 Annual VERTICAL USGSV067 PM2.5 Annual VERTICAL USGSV070 PM2.5 Annual VERTICAL USGSV071 PM2.5 Annual VERTICAL USGSV075 PM2.5 Annual VERTICAL USGSV076 PM2.5 Annual VERTICAL USGSV077 PM2.5 Annual VERTICAL USGSV078 PM2.5 Annual VERTICAL USGSV079 PM2.5 Annual VERTICAL USGSV108 PM2.5 Annual VERTICAL USGSV114 PM2.5 Annual VERTICAL USGSV115 PM2.5 Annual VERTICAL USGSV116 PM2.5 Annual VERTICAL USGSV118 PM2.5 Annual VERTICAL USGV1 PM2.5 Annual VERTICAL USGV10 PM2.5 Annual VERTICAL USGV11 PM2.5 Annual VERTICAL USGV12 PM2.5 Annual VERTICAL USGV13 PM2.5 Annual VERTICAL USGV14 PM2.5 Annual VERTICAL

218 Permit expires: [month day, year] Page 218 of 243 USGV15 PM2.5 Annual VERTICAL USGV16 PM2.5 Annual VERTICAL USGV17 PM2.5 Annual VERTICAL USGV18 PM2.5 Annual VERTICAL USGV19 PM2.5 Annual VERTICAL USGV2 PM2.5 Annual VERTICAL USGV20 PM2.5 Annual VERTICAL USGV21 PM2.5 Annual VERTICAL USGV22 PM2.5 Annual VERTICAL USGV23 PM2.5 Annual VERTICAL USGV24 PM2.5 Annual VERTICAL USGV25 PM2.5 Annual VERTICAL USGV26 PM2.5 Annual VERTICAL USGV28 PM2.5 Annual VERTICAL USGV29 PM2.5 Annual VERTICAL USGV3 PM2.5 Annual VERTICAL USGV30 PM2.5 Annual VERTICAL USGV31 PM2.5 Annual VERTICAL USGV32 PM2.5 Annual VERTICAL USGV33 PM2.5 Annual VERTICAL USGV35 PM2.5 Annual VERTICAL USGV36 PM2.5 Annual VERTICAL USGV4 PM2.5 Annual VERTICAL USGV41 PM2.5 Annual VERTICAL USGV42 PM2.5 Annual VERTICAL USGV43 PM2.5 Annual VERTICAL USGV48 PM2.5 Annual VERTICAL USGV49 PM2.5 Annual VERTICAL USGV5 PM2.5 Annual VERTICAL USGV50 PM2.5 Annual VERTICAL USGV51 PM2.5 Annual VERTICAL

219 Permit expires: [month day, year] Page 219 of 243 USGV52 PM2.5 Annual VERTICAL USGV54 PM2.5 Annual VERTICAL USGV55 PM2.5 Annual VERTICAL USGV56 PM2.5 Annual VERTICAL USGV58 PM2.5 Annual VERTICAL USGV6 PM2.5 Annual VERTICAL USGV60 PM2.5 Annual VERTICAL USGV61 PM2.5 Annual VERTICAL USGV62 PM2.5 Annual VERTICAL USGV63 PM2.5 Annual VERTICAL USGV64 PM2.5 Annual VERTICAL USGV65 PM2.5 Annual VERTICAL USGV66 PM2.5 Annual VERTICAL USGV67 PM2.5 Annual VERTICAL USGV7 PM2.5 Annual VERTICAL USGV7NE PM2.5 Annual VERTICAL USGV7NW PM2.5 Annual VERTICAL USGV7SE PM2.5 Annual VERTICAL USGV7SW PM2.5 Annual VERTICAL USGV8 PM2.5 Annual VERTICAL USGV9 PM2.5 Annual VERTICAL Table B-12: Area Source Parameters used in annual PM2.5 NAAQS analysis for permit # SI ID# AERMOD ID Pollutant Averaging Time Easting (m) Northing (m) Base Elevation (m) Emission Rate (g/sec/m2) Height (m) Length_X (m) Length_Y (m) Rotation Angle (deg) FUGI2 SAPCT001 PM2.5 Annual E FUGI6 SPRD007 PM2.5 Annual E FUGI6 SPRD008 PM2.5 Annual E FUGI6 SPRD009 PM2.5 Annual E FUGI6 SPRD010 PM2.5 Annual E FUGI6 SPRD011 PM2.5 Annual E FUGI6 SPRD012 PM2.5 Annual E Sigma z (m)

220 Permit expires: [month day, year] Page 220 of 243 FUGI6 SPRD013 PM2.5 Annual E FUGI6 SPRD019A PM2.5 Annual E FUGI6 SPRD019B PM2.5 Annual E FUGI6 SPRD020 PM2.5 Annual E FUGI6 SPRD021 PM2.5 Annual E FUGI6 SPRD022 PM2.5 Annual E FUGI6 SPRD023 PM2.5 Annual E FUGI6 SPRD024 PM2.5 Annual E FUGI6 SPRD025 PM2.5 Annual E FUGI6 SPRD026A PM2.5 Annual E FUGI6 SPRD026B PM2.5 Annual E FUGI6 SPRD027 PM2.5 Annual E FUGI6 SPRD028 PM2.5 Annual E FUGI6 SPRD029 PM2.5 Annual E FUGI6 SPRD030 PM2.5 Annual E FUGI6 SPRD031 PM2.5 Annual E FUGI6 SPRD032 PM2.5 Annual E FUGI6 SPRD033 PM2.5 Annual E FUGI6 SPRD034 PM2.5 Annual E FUGI6 SPRD035 PM2.5 Annual E FUGI6 SPRD036 PM2.5 Annual E FUGI6 SPRD037 PM2.5 Annual E FUGI6 SPRD038 PM2.5 Annual E FUGI6 SPRD039 PM2.5 Annual E FUGI6 SPRD040 PM2.5 Annual E FUGI6 SPRD041 PM2.5 Annual E FUGI6 SPRD042 PM2.5 Annual E FUGI6 SPRD043 PM2.5 Annual E FUGI6 SPRD044 PM2.5 Annual E FUGI6 SPRD045 PM2.5 Annual E FUGI6 SPRD046 PM2.5 Annual E FUGI6 SPRD047B PM2.5 Annual E FUGI6 SPRD048 PM2.5 Annual E FUGI6 SPRD049 PM2.5 Annual E FUGI6 SPRD051 PM2.5 Annual E FUGI6 SPRD052 PM2.5 Annual E FUGI6 SPRD053 PM2.5 Annual E FUGI6 SPRD055 PM2.5 Annual E FUGI6 SPRD056 PM2.5 Annual E FUGI6 SPRD057 PM2.5 Annual E

221 Permit expires: [month day, year] Page 221 of 243 FUGI6 SPRD059 PM2.5 Annual E FUGI6 SPRD060 PM2.5 Annual E FUGI7 SPRD061 PM2.5 Annual E FUGI7 SPRD062 PM2.5 Annual E FUGI7 SPRD063 PM2.5 Annual E FUGI7 SPRD087 PM2.5 Annual E FUGI7 SPRD088 PM2.5 Annual E FUGI7 SPRD096 PM2.5 Annual E FUGI7 SPRD097 PM2.5 Annual E Table B-13: Volume Source Parameters used in annual PM2.5 NAAQS analysis for permit # SI ID# AERMOD ID Pollutant Averaging Time Easting (m) Northing (m) Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) Height (m) Lateral Dimension (m) Vertical Dimension (m) Length (m) FUGI3 SAPMH01 PM2.5 Annual E E FUGI8 SAPMH02 PM2.5 Annual FUGI5 SAPMH03 PM2.5 Annual E E FUGI5 SAPMH04 PM2.5 Annual E E FUGI9 SAPMH05 PM2.5 Annual E E FUGI9 SAPMH06 PM2.5 Annual E E FUGI9 SAPMH07 PM2.5 Annual E E FUGI9 SAPMH08 PM2.5 Annual E E FUGI9 SAPMH09 PM2.5 Annual FUGI3 SAPMH10 PM2.5 Annual FUGI3 SAPMH11 PM2.5 Annual FUGI9 SAPWE01 PM2.5 Annual E E FUGI9 SAPWE02 PM2.5 Annual E E FUGI9 SAPWE03 PM2.5 Annual E E FUGI9 SAPWE04 PM2.5 Annual E E FUGI9 SAPWE05 PM2.5 Annual FUGI5 SAPWE06 PM2.5 Annual FUGI5 SAPWE07 PM2.5 Annual FUGI5 SAPWE08 PM2.5 Annual

222 Permit expires: [month day, year] Page 222 of 243 FUGI11 SPRD094 PM2.5 Annual FUGI5 SPRD095A PM2.5 Annual FUGI5 SPRD095B PM2.5 Annual FUGI5 SPRD095C PM2.5 Annual FUGI11 SAPRA004 PM2.5 Annual FUGI11 SAPRA005 PM2.5 Annual FUGI11 SAPRA006 PM2.5 Annual FUGI11 SAPRA007 PM2.5 Annual FUGI11 SAPRA008 PM2.5 Annual FUGI11 SAPRA009 PM2.5 Annual FUGI11 SAPRA010 PM2.5 Annual FUGI11 SAPRA011 PM2.5 Annual FUGI11 SAPRA012 PM2.5 Annual FUGI11 SAPRA013 PM2.5 Annual FUGI11 SAPRA014 PM2.5 Annual FUGI11 SAPRA015 PM2.5 Annual FUGI11 SAPRA016 PM2.5 Annual FUGI11 SAPRA017 PM2.5 Annual FUGI11 SAPRA018 PM2.5 Annual FUGI11 SAPRA019 PM2.5 Annual FUGI11 SAPRA020 PM2.5 Annual FUGI11 SAPRA021 PM2.5 Annual FUGI11 SAPRA022 PM2.5 Annual FUGI11 SAPRA023 PM2.5 Annual FUGI11 SAPRA024 PM2.5 Annual FUGI11 SAPRA025 PM2.5 Annual FUGI11 SAPRA026 PM2.5 Annual FUGI11 SAPRA027 PM2.5 Annual FUGI11 SAPRA028 PM2.5 Annual FUGI11 SAPRA029 PM2.5 Annual

223 Permit expires: [month day, year] Page 223 of 243 FUGI11 SAPRA030 PM2.5 Annual FUGI11 SAPRA031 PM2.5 Annual FUGI11 SAPRA032 PM2.5 Annual FUGI11 SAPRA033 PM2.5 Annual FUGI11 SAPRA034 PM2.5 Annual FUGI11 SAPRA035 PM2.5 Annual FUGI11 SAPRA036 PM2.5 Annual FUGI11 SAPRA037 PM2.5 Annual FUGI11 SAPRA038 PM2.5 Annual FUGI11 SAPRA039 PM2.5 Annual FUGI11 SAPRA040 PM2.5 Annual FUGI11 SAPRA041 PM2.5 Annual FUGI11 SAPRA042 PM2.5 Annual FUGI11 SAPRA043 PM2.5 Annual FUGI11 SAPRA044 PM2.5 Annual FUGI11 SAPRA045 PM2.5 Annual FUGI11 SAPRA046 PM2.5 Annual FUGI11 SAPRA047 PM2.5 Annual FUGI11 SAPRA048 PM2.5 Annual FUGI11 SAPRA049 PM2.5 Annual FUGI11 SAPRA050 PM2.5 Annual FUGI11 SAPRA051 PM2.5 Annual FUGI11 SAPRA052 PM2.5 Annual FUGI11 SAPRA053 PM2.5 Annual FUGI11 SAPRA054 PM2.5 Annual FUGI11 SAPRC001 PM2.5 Annual FUGI11 SAPRC002 PM2.5 Annual FUGI11 SAPRC003 PM2.5 Annual FUGI11 SAPRC004 PM2.5 Annual FUGI11 SAPRC005 PM2.5 Annual

224 Permit expires: [month day, year] Page 224 of 243 FUGI11 SAPRC006 PM2.5 Annual FUGI11 SAPRC007 PM2.5 Annual FUGI11 SAPRC008 PM2.5 Annual FUGI11 SAPRC009 PM2.5 Annual FUGI11 SAPRC010 PM2.5 Annual FUGI11 SAPRD001 PM2.5 Annual FUGI11 SAPRD002 PM2.5 Annual FUGI11 SAPRD003 PM2.5 Annual FUGI11 SAPRD004 PM2.5 Annual FUGI11 SAPRD005 PM2.5 Annual FUGI11 SAPRD006 PM2.5 Annual FUGI11 SAPRD007 PM2.5 Annual FUGI11 SAPRD008 PM2.5 Annual FUGI11 SAPRD009 PM2.5 Annual FUGI11 SAPRD010 PM2.5 Annual FUGI11 SAPRE001 PM2.5 Annual FUGI11 SAPRE002 PM2.5 Annual FUGI11 SAPRE003 PM2.5 Annual FUGI11 SAPRE004 PM2.5 Annual FUGI11 SAPRE005 PM2.5 Annual FUGI11 SAPRE006 PM2.5 Annual FUGI11 SAPRE007 PM2.5 Annual FUGI11 SAPRE008 PM2.5 Annual FUGI11 SAPRE009 PM2.5 Annual FUGI11 SAPRE010 PM2.5 Annual FUGI11 SAPRF001 PM2.5 Annual FUGI11 SAPRF002 PM2.5 Annual FUGI11 SAPRF003 PM2.5 Annual FUGI11 SAPRF004 PM2.5 Annual FUGI11 SAPRF005 PM2.5 Annual

225 Permit expires: [month day, year] Page 225 of 243 FUGI11 SAPRF006 PM2.5 Annual FUGI11 SAPRF007 PM2.5 Annual FUGI11 SAPRF008 PM2.5 Annual FUGI11 SAPRF009 PM2.5 Annual FUGI11 SAPRF010 PM2.5 Annual FUGI11 SAPRF011 PM2.5 Annual FUGI11 SAPRF012 PM2.5 Annual FUGI11 SAPRF013 PM2.5 Annual FUGI11 SAPRF014 PM2.5 Annual FUGI11 SAPRF015 PM2.5 Annual FUGI11 SAPRF016 PM2.5 Annual FUGI11 SAPRF017 PM2.5 Annual FUGI11 SAPRF018 PM2.5 Annual FUGI11 SAPRF019 PM2.5 Annual FUGI11 SAPRF020 PM2.5 Annual FUGI11 SAPRF021 PM2.5 Annual FUGI11 SAPRF022 PM2.5 Annual FUGI11 SAPRF023 PM2.5 Annual FUGI11 SAPRF024 PM2.5 Annual FUGI11 SAPRF025 PM2.5 Annual FUGI11 SAPRF026 PM2.5 Annual FUGI11 SAPRF027 PM2.5 Annual FUGI11 SAPRF028 PM2.5 Annual FUGI11 SAPRF029 PM2.5 Annual FUGI11 SAPRF030 PM2.5 Annual FUGI11 SAPRF031 PM2.5 Annual FUGI11 SAPRF032 PM2.5 Annual FUGI11 SAPRF033 PM2.5 Annual FUGI11 SAPRF034 PM2.5 Annual FUGI11 SAPRF035 PM2.5 Annual

226 Permit expires: [month day, year] Page 226 of 243 FUGI11 SAPRG001 PM2.5 Annual FUGI11 SAPRG002 PM2.5 Annual FUGI11 SAPRG003 PM2.5 Annual FUGI11 SAPRG004 PM2.5 Annual FUGI11 SAPRG005 PM2.5 Annual FUGI11 SAPRG006 PM2.5 Annual FUGI11 SAPRG007 PM2.5 Annual E FUGI11 SAPRG008 PM2.5 Annual E FUGI11 SAPRG009 PM2.5 Annual FUGI11 SAPRG010 PM2.5 Annual FUGI11 SAPRG011 PM2.5 Annual FUGI11 SAPRG012 PM2.5 Annual FUGI11 SAPRG013 PM2.5 Annual FUGI11 SAPRG014 PM2.5 Annual FUGI11 SAPRG015 PM2.5 Annual FUGI11 SAPRG016 PM2.5 Annual FUGI11 SAPRG017 PM2.5 Annual FUGI11 SAPRG018 PM2.5 Annual FUGI11 SAPRG019 PM2.5 Annual FUGI11 SAPRG020 PM2.5 Annual FUGI11 SAPRG021 PM2.5 Annual FUGI11 SAPRH001 PM2.5 Annual FUGI11 SAPRH002 PM2.5 Annual FUGI11 SAPRH003 PM2.5 Annual FUGI11 SAPRH004 PM2.5 Annual FUGI11 SAPRH005 PM2.5 Annual FUGI11 SAPRH006 PM2.5 Annual FUGI11 SAPRH007 PM2.5 Annual FUGI11 SAPRH008 PM2.5 Annual FUGI11 SAPRH009 PM2.5 Annual

227 Permit expires: [month day, year] Page 227 of 243 FUGI11 SAPRH010 PM2.5 Annual FUGI11 SAPRH011 PM2.5 Annual FUGI11 SAPRH012 PM2.5 Annual FUGI11 SAPRH013 PM2.5 Annual FUGI11 SAPRH014 PM2.5 Annual FUGI11 SAPRH015 PM2.5 Annual FUGI11 SAPRH016 PM2.5 Annual FUGI11 SAPRH017 PM2.5 Annual FUGI11 SAPRH018 PM2.5 Annual FUGI11 SAPRH019 PM2.5 Annual FUGI11 SAPRH020 PM2.5 Annual FUGI11 SAPRH021 PM2.5 Annual FUGI11 SAPRH022 PM2.5 Annual FUGI11 SAPRH023 PM2.5 Annual FUGI11 SAPRH024 PM2.5 Annual FUGI11 SAPRH025 PM2.5 Annual FUGI11 SAPRH026 PM2.5 Annual FUGI11 SAPRH027 PM2.5 Annual FUGI11 SAPRH028 PM2.5 Annual FUGI11 SAPRH029 PM2.5 Annual FUGI11 SAPRH030 PM2.5 Annual FUGI11 SAPRH031 PM2.5 Annual FUGI11 SAPRH032 PM2.5 Annual FUGI11 SAPRH033 PM2.5 Annual FUGI11 SAPRH034 PM2.5 Annual FUGI11 SAPRH035 PM2.5 Annual FUGI11 SAPRH036 PM2.5 Annual FUGI11 SAPRH037 PM2.5 Annual FUGI11 SAPRH038 PM2.5 Annual FUGI11 SAPRH039 PM2.5 Annual

228 Permit expires: [month day, year] Page 228 of 243 FUGI11 SAPRH040 PM2.5 Annual FUGI11 SAPRH041 PM2.5 Annual FUGI11 SAPRH042 PM2.5 Annual FUGI11 SAPRH043 PM2.5 Annual FUGI11 SAPRH044 PM2.5 Annual FUGI11 SAPRH045 PM2.5 Annual FUGI11 SAPRH046 PM2.5 Annual FUGI11 SAPRH047 PM2.5 Annual FUGI11 SAPRH048 PM2.5 Annual FUGI11 SAPRH049 PM2.5 Annual FUGI11 SAPRH050 PM2.5 Annual FUGI11 SAPRH051 PM2.5 Annual FUGI11 SAPRH052 PM2.5 Annual FUGI11 SAPRH053 PM2.5 Annual FUGI11 SAPRH054 PM2.5 Annual FUGI11 SAPRI001 PM2.5 Annual E FUGI11 SAPRI002 PM2.5 Annual E FUGI11 SAPRI003 PM2.5 Annual E FUGI11 SAPRI004 PM2.5 Annual FUGI11 SAPRI005 PM2.5 Annual FUGI11 SAPRI006 PM2.5 Annual FUGI11 SAPRI007 PM2.5 Annual FUGI11 SAPRI008 PM2.5 Annual FUGI11 SAPRI009 PM2.5 Annual FUGI11 SAPRI010 PM2.5 Annual FUGI11 SAPRI011 PM2.5 Annual FUGI11 SAPRI012 PM2.5 Annual FUGI11 SAPRI013 PM2.5 Annual FUGI11 SAPRI014 PM2.5 Annual FUGI11 SAPRI015 PM2.5 Annual

229 Permit expires: [month day, year] Page 229 of 243 FUGI11 SAPRI016 PM2.5 Annual FUGI11 SAPRI017 PM2.5 Annual FUGI11 SAPRI018 PM2.5 Annual FUGI11 SAPRI019 PM2.5 Annual FUGI11 SAPRI020 PM2.5 Annual FUGI11 SAPRI021 PM2.5 Annual FUGI11 SAPRI022 PM2.5 Annual FUGI11 SAPRI023 PM2.5 Annual FUGI11 SAPRI024 PM2.5 Annual FUGI11 SAPRI025 PM2.5 Annual FUGI11 SAPRI026 PM2.5 Annual FUGI11 SAPRI027 PM2.5 Annual FUGI11 SAPRI028 PM2.5 Annual FUGI11 SAPRI029 PM2.5 Annual FUGI11 SAPRI030 PM2.5 Annual FUGI11 SAPRI031 PM2.5 Annual FUGI11 SAPRI032 PM2.5 Annual FUGI11 SAPRI033 PM2.5 Annual FUGI11 SAPRI034 PM2.5 Annual FUGI11 SAPRI035 PM2.5 Annual FUGI11 SAPRI036 PM2.5 Annual FUGI11 SAPRI037 PM2.5 Annual FUGI11 SAPRI038 PM2.5 Annual FUGI11 SAPRI039 PM2.5 Annual FUGI11 SAPRI040 PM2.5 Annual E FUGI11 SAPRI041 PM2.5 Annual E FUGI11 SAPRJ001 PM2.5 Annual E FUGI11 SAPRJ002 PM2.5 Annual FUGI11 SAPRJ003 PM2.5 Annual FUGI11 SAPRJ004 PM2.5 Annual

230 Permit expires: [month day, year] Page 230 of 243 FUGI11 SAPRJ005 PM2.5 Annual FUGI11 SAPRJ006 PM2.5 Annual FUGI11 SAPRJ007 PM2.5 Annual FUGI11 SAPRJ008 PM2.5 Annual FUGI11 SAPRJ009 PM2.5 Annual FUGI11 SAPRK001 PM2.5 Annual E FUGI11 SAPRK002 PM2.5 Annual FUGI11 SAPRK003 PM2.5 Annual FUGI11 SAPRK004 PM2.5 Annual FUGI11 SAPRK005 PM2.5 Annual FUGI11 SAPRK006 PM2.5 Annual FUGI11 SAPRK007 PM2.5 Annual FUGI11 SAPRK008 PM2.5 Annual FUGI11 SAPRK009 PM2.5 Annual FUGI11 SAPRK010 PM2.5 Annual FUGI11 SAPRK011 PM2.5 Annual E FUGI11 SAPRK012 PM2.5 Annual E FUGI11 SAPRK013 PM2.5 Annual E FUGI11 SAPRK014 PM2.5 Annual E FUGI11 SAPRK015 PM2.5 Annual E FUGI11 SAPRK016 PM2.5 Annual E FUGI11 SAPRK017 PM2.5 Annual E FUGI11 SAPRK018 PM2.5 Annual E FUGI11 SAPRK019 PM2.5 Annual E FUGI11 SAPRK020 PM2.5 Annual E FUGI11 SAPRK021 PM2.5 Annual E FUGI11 SAPRK022 PM2.5 Annual E FUGI11 SAPRK023 PM2.5 Annual E FUGI11 SAPRK024 PM2.5 Annual E FUGI11 SAPRK025 PM2.5 Annual E

231 Permit expires: [month day, year] Page 231 of 243 FUGI11 SAPRK026 PM2.5 Annual E FUGI11 SAPRK027 PM2.5 Annual E FUGI11 SAPRK028 PM2.5 Annual E FUGI11 SAPRK029 PM2.5 Annual E FUGI11 SAPRK030 PM2.5 Annual E FUGI11 SAPRK031 PM2.5 Annual E FUGI11 SAPRK032 PM2.5 Annual E FUGI11 SAPRK033 PM2.5 Annual E FUGI11 SAPRK034 PM2.5 Annual E FUGI11 SAPRK035 PM2.5 Annual E FUGI11 SAPRK036 PM2.5 Annual E FUGI11 SAPRK037 PM2.5 Annual E FUGI11 SAPRK038 PM2.5 Annual E FUGI11 SAPRK039 PM2.5 Annual E FUGI11 SAPRK040 PM2.5 Annual E FUGI11 SAPRK041 PM2.5 Annual E FUGI11 SAPRK042 PM2.5 Annual E FUGI11 SAPRK043 PM2.5 Annual E FUGI11 SAPRK044 PM2.5 Annual E FUGI11 SAPRK045 PM2.5 Annual E FUGI11 SAPRK046 PM2.5 Annual E FUGI11 SAPRK047 PM2.5 Annual E FUGI11 SAPRK048 PM2.5 Annual E FUGI11 SAPRK049 PM2.5 Annual E USGFSA PM2.5 Annual USGFSB PM2.5 Annual E E USGFSC PM2.5 Annual USGFSD PM2.5 Annual E USGUPR01 PM2.5 Annual E USGUPR02 PM2.5 Annual E

232 Permit expires: [month day, year] Page 232 of 243 USGUPR03 PM2.5 Annual E USGUPR04 PM2.5 Annual E USGUPR05 PM2.5 Annual E USGUPR06 PM2.5 Annual E USGUPR07 PM2.5 Annual E USGUPR08 PM2.5 Annual E USGUPR09 PM2.5 Annual E USGUPR10 PM2.5 Annual E USGUPR11 PM2.5 Annual E USGUPR12 PM2.5 Annual E USGUPR13 PM2.5 Annual USGUPR14 PM2.5 Annual USGUPR15 PM2.5 Annual USGUPR16 PM2.5 Annual USGUPR17 PM2.5 Annual USGUPR18 PM2.5 Annual USGUPR19 PM2.5 Annual USGUPR20 PM2.5 Annual USGUPR21 PM2.5 Annual USGUPR22 PM2.5 Annual USGUPR23 PM2.5 Annual USGUPR24 PM2.5 Annual USGUPR25 PM2.5 Annual USGUPR26 PM2.5 Annual USGUPR27 PM2.5 Annual USGUPR28 PM2.5 Annual USGUPR29 PM2.5 Annual USGVOLO PM2.5 Annual JHBVS001 PM2.5 Annual JHBVS002 PM2.5 Annual

233 Permit expires: [month day, year] Page 233 of 243 JHBVS003 PM2.5 Annual JHBVS004 PM2.5 Annual JHBVS005 PM2.5 Annual JHBVS006 PM2.5 Annual JHBVS007 PM2.5 Annual JHBVS008 PM2.5 Annual JHBVS009 PM2.5 Annual JHBVS010 PM2.5 Annual JHBVS011 PM2.5 Annual JHBVS012 PM2.5 Annual JHBVS013 PM2.5 Annual JHBVS014 PM2.5 Annual JHBVS015 PM2.5 Annual JHBVS016 PM2.5 Annual JHBVS017 PM2.5 Annual JHBVS018 PM2.5 Annual JHBVS019 PM2.5 Annual JHBVS020 PM2.5 Annual JHBVS021 PM2.5 Annual JHBVS022 PM2.5 Annual JHBVS023 PM2.5 Annual JHBVS024 PM2.5 Annual JHBVS025 PM2.5 Annual JHBVS026 PM2.5 Annual JHBVS027 PM2.5 Annual JHBVS028 PM2.5 Annual JHBVS029 PM2.5 Annual JHBVS030 PM2.5 Annual JHBVS031 PM2.5 Annual JHBVS032 PM2.5 Annual

234 Permit expires: [month day, year] Page 234 of 243 JHBVS033 PM2.5 Annual JHBVS034 PM2.5 Annual JHBVS035 PM2.5 Annual JHBVS036 PM2.5 Annual JHBVS037 PM2.5 Annual JHBVS38A PM2.5 Annual JHBVS38B PM2.5 Annual Table B-14: Source Parameters used in annual PM2.5 Increment analysis for permit # SI ID# AERMOD ID Pollutant Averaging Time Operating Scenario Release Type Easting (m) Northing (m) N/A SV6PRE PM2.5 Annual 1 VERTICAL STRU42 SV6POST PM2.5 Annual 2 VERTICAL N/A SV29PRE PM2.5 Annual 1 VERTICAL STRU47 SV29POST PM2.5 Annual 2 VERTICAL N/A SV2PRE PM2.5 Annual 1 VERTICAL STRU38 SV2POST PM2.5 Annual 2 VERTICAL N/A SV31PRE PM2.5 Annual 1 VERTICAL STRU30 SV31POST PM2.5 Annual 2 VERTICAL Base Elevation (m) Emission Rate (lb/hr) Emission Rate (g/sec) Height (m) Exit Temp (K) Exit Velocity (m/s) Diameter (m) Flow Rate (ACFM)

235 Permit expires: [month day, year] Page 235 of 243 Appendix C: Road Segment Speed Limit and Silt Load Test Areas