MINNESOTA POLLUTION CONTROL AGENCY RMAD and Industrial Divisions Environment & Energy Section; Air Quality Permits Section

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5 005 MINNESOTA POLLUTION CONTROL AGENCY RMAD and Industrial Divisions Environment & Energy Section; Air Quality Permits Section The University of Minnesota Twin Cities Combined Heat and Power Project (1) Request for Approval of Findings of Fact, Conclusions of Law, and Order and Authorization to Issue a Negative Declaration on the Need for an Environmental Impact Statement; and (2) Request for Approval of Findings of Fact, Conclusion of Law, and Order, and Authorization to Issue Permit No January 27, 2015 ISSUE STATEMENT This Board Item involves two related, but separate, Citizens Board (Board) decisions: (1) Whether to approve a Negative Declaration on the need for an Environmental Impact Statement (EIS) for the proposed University of Minnesota Twin Cities Campus Combined Heat and Power Project (Project). (2) If the Board approves a Negative Declaration on the need for an EIS, decide whether to authorize the issuance of an air permit for the Project. The Minnesota Pollution Control Agency (MPCA) staff requests that the Board approve a Negative Declaration on the need for an EIS for the Project and approve the Findings of Fact, Conclusion of Law, and Order supporting the Negative Declaration. MPCA staff also requests that the Board approve the Findings of Fact, Conclusions of Law, and Order authorizing the issuance of Air Emissions Permit No Project Description. The University of Minnesota (University) proposes to construct a 22.8 megawatt (MW) combustion turbine generator with a 210 million British thermal units (MMBTU)/hr duct burner to produce steam for the Twin Cities campus. The Project will be located in the Old Main Steam Plant building, 1180 Main Street SE, Minneapolis, Minnesota. The University will retire two coal-fired boilers at the nearby Southeast Plant upon completion of the Project. Environmental Review. Because this Project will generate more than 100,000 tons per year of greenhouse gas (GHG) emissions, an Environmental Assessment Worksheet (EAW) must be prepared. The objective of an EAW is to determine whether the Project has the potential for significant environmental effects. Minnesota rules designate the MPCA as the governmental unit responsible for preparing the EAW. During the EAW comment period, the MPCA received six comments, including three requesting the preparation of an EIS. MPCA staff responded to the comments, and the decision on an EIS is now before this Board. 1

6 006 Issuance of Air Permit Amendment. The University also submitted a major amendment to its current air permit to the MPCA. The permit, if issued, will authorize construction of the Project. The MPCA received three written comments during the public comment period for the draft permit. Two requested a Public Informational Meeting, which the MPCA held on January 22, The MPCA staff responded to the comments on the draft permit. The Board will decide whether to authorize the issuance of the air permit amendment if it decides that environmental review is complete. I. BACKGROUND: A. Project Description The University of Minnesota Board of Regents (University) is proposing to construct a 22.8 MW combustion turbine generator in series with a 210 MMBTU/hr duct burner at the Twin Cities Campus (Project). Exhaust gases will be used to produce up to 270,000 pounds of steam per hour for the campus steam distribution system. A 500 kilowatt (kw) diesel emergency generator will also be installed. The Project will be located in the existing Old Main Steam Plant building, 1180 Main Street SE, Minneapolis, Minnesota. B. Procedural History EAW Because this Project will generate more than 100,000 tons per year of greenhouse gas emissions, an Environmental Assessment Worksheet (EAW) must be prepared. (Minn. R , subp. 15(B)). That rule designates the MPCA as the governmental unit responsible for preparing the EAW. The objective of an EAW is to determine whether the Project has the potential for significant environmental effects. The responsible governmental unit (RGU) decides whether an Environmental Impact Statement is needed based on the information gathered during the EAW process and the comments received on the EAW. (Minn. R , subp. 3). MPCA staff prepared the EAW for this Project following procedures described in the EQB rules (Minn. R ), and then began a public comment period on October 27, 2014 (Minn. R ). 2

7 007 During the public comment period, which ended on November 26, 2014, the MPCA received comment letters from the Minnesota Department of Natural Resources, the Metropolitan Council, and four citizens. Three of the citizen letters raised concerns about impacts related to air quality, stormwater runoff, and public safety (potential for natural gas explosion and site security). Three of the six comment letters requested the preparation of an EIS. The comment letters are in Appendix A to the Findings of Fact, Conclusion of Law, and Order for the EAW (Attachment 1). The MPCA prepared written responses to the comment letters received during the 30-day public comment period. The Responses are in Appendix B to Attachment 1. The MPCA staff found that the Project does not have the potential to significantly impact air quality, and that mitigation measures, including control equipment and permit conditions, will prevent any significant adverse impacts. On the risk of explosion or fire, the MPCA staff found that the risk of explosion or fire is low, with natural gas used throughout the Twin Cities as a fuel, and that safety precautions are designed into the construction and operation of the site. Third, on the potential impact of stormwater runoff, the MPCA staff found that the University s stormwater pollution prevention and management plan includes best management practices for construction and operation of the Project, and will be required as part of the Project s Construction Stormwater General Permit and Industrial Stormwater General Permit. C. Procedural History Air Permit The University submitted an amendment to the existing Federal Part 70 Air Permit for the Twin Cities campus. The MPCA drafted an air emissions permit amendment to cover the Project and issued a public notice of the preliminary decision to issue the permit. (Minn. R , subp. 2) The public notice established a thirty day public comment period for the permit from October 31, 2014, through 4:30 p.m. on December 1, The MPCA received three comment letters during the comment period, with two of the three commenters requesting a public informational meeting. One of the commenters stated concerns regarding air quality and emissions in the immediate vicinity of the Riverview Tower Condominiums neighborhood as a result of this Project. Another commenter had 3

8 008 concerns that under the right wind conditions the emissions from the Project will be sucked into the air intake on top of the building. The commenter also stated concerns about air quality and emissions in the immediate vicinity of his neighborhood as a result of this Project. The third commenter also expressed concern that the neighborhood air quality may be adversely affected by the Project. The comment letters are presented in Appendix A to the Findings of Fact, Conclusion of Law, and Order for the Permit (Attachment 2). MPCA staff prepared Responses to Comments (Appendix B to Attachment 2) and proposed Findings of Fact, Conclusions of Law, and Order for the Permit (Attachment 2). II. DISCUSSION: The MPCA, as the governmental agency responsible for the EAW, must consider four criteria in deciding whether a project has the potential for significant environmental effects. These criteria are: a) The type, extent, and reversibility of environmental effects; b) Cumulative potential effects; c) The extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority; and d) the extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs. (Minn. R ) MPCA staff applied these criteria to the Project, as discussed in the proposed Findings of Fact, Conclusions of Law, and Order for the EAW (Attachment 1) and the MPCA Responses to Comments on the EAW (Appendix B to Attachment 1). The MPCA staff has considered the information gathered during the EAW process and the permit comments received, and requests that the Board decide that the proposed Project does not have the potential for significant environmental effects and approve a Negative Declaration on the need for an EIS. 4

9 009 In order to issue the air permit amendment, the MPCA must find that certain preconditions specified in Minn. R , subp. 1 are satisfied: Preconditions for issuance. The agency shall issue a permit or permit amendment, or reissue a permit only if it determines that all of the following conditions have been met: A. The agency has received a complete application for a permit, permit amendment, or permit reissuance, except that a complete application need not be received before issuance of a general permit under part , subpart 4. B. The agency has complied with the public participation procedures for permit issuance, if required by part C. The agency has complied with the procedures for notifying and responding to affected states, if required by part D. If the administrator's review is required by part , the administrator has received a copy of the permit and any notices required and has not objected to issuance of the permit within the time period specified, or the administrator has objected but the objection has been resolved to the administrator's satisfaction. E. The conditions of the permit provide for compliance with all applicable requirements and the requirements of parts to , or include a schedule to achieve such compliance. F. The permit does not reflect a variance from any federally enforceable applicable requirement or requirement of parts to G. The agency anticipates that the applicant will, with respect to the stationary source and activity to be permitted, comply with all conditions of the permit. H. All applicable provisions of Minnesota Statutes, chapter 116D, and the rules adopted under Minnesota Statutes, chapter 116D, have been fulfilled. The MPCA staff has determined that each of these preconditions has been met. The grounds upon which the MPCA may refuse to issue a permit are provided in Minn. R , subp. 2. None of the grounds for denial apply to this draft permit. III. CONCLUSIONS: MPCA staff believes that the information in the EAW, as supplemented by the Responses to Comments and the entire record for this proposed Project, is adequate to make a reasoned decision on the need for an EIS, as set forth in detail in the proposed Findings of Fact, Conclusions of Law, and Order, as well as the MPCA staff s Responses to Comments. (Attachment 1 and Appendix B). Based on this record, MPCA staff concludes that the potential environmental impacts that are reasonably expected to occur from the proposed Project were identified during the environmental review and will be mitigated by MPCA rule requirements and binding conditions to be placed in MPCA permits, including the Air Permit Amendment, the Construction Stormwater and Industrial Stormwater 5

10 010 NPDES/SDS permits, as well as other state and local regulations and ordinances that apply to the proposed Project. MPCA staff further requests that this Board conclude, based on the analysis presented in the proposed Findings of Fact, Conclusions of Law, and Order, and evidence in the record of this proceeding, the proposed Project does not have the potential for significant environmental effects and approve the issuance of a Negative Declaration on the need to prepare an EIS. For the reasons discussed above and detailed in the Findings of Fact, Conclusions of Law and Order (Attachment 2), and in the Technical Support Document to the Draft Air Emissions Permit No (Attachment 4), the MPCA staff requests that, if the Board decides an EIS is not needed, the Board authorize the issuance of the air permit for the Project. IV. RECOMMENDATION: The MPCA staff requests that the Board approve the Findings of Fact, Conclusions of Law, and Order (Attachment 1) approving a negative declaration on the need for an EIS, because the Project does not have the potential for significant environmental effects, in accordance with Minn. R If the Board issues a negative declaration on the need for an EIS, the MPCA staff then recommends that the Board authorize the issuance of Air Emissions Permit No and adopt the Findings of Fact, Conclusions of Law, and Order (Attachment 2) supporting the permit. 6

11 011 SUGGESTED STAFF RESOLUTION BE IT RESOLVED, that, in accordance with Minn. R , the Minnesota Pollution Control Agency (MPCA) approves and adopts the attached Findings of Fact, Conclusions of Law, and Order, that the University of Minnesota Twin Cities Campus Combined Heat and Power Project does not have the potential for significant environmental effects. BE IT FURTHER RESOLVED that the MPCA authorizes the Commissioner to approve a Negative Declaration on the Need for an Environmental Impact Statement for the Project. BE IT FURTHER RESOLVED that the MPCA approves and adopts the attached Findings of Fact, Conclusions of Law, and Order approving the issuance of the University of Minnesota, Twin Cities Air Emission Permit No The Commissioner is hereby authorized to execute these Findings of Fact, Conclusions of Law, and Order on behalf of the MPCA. 7

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13 ATTACHMENT STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY IN THE MATTER OF THE DECISION ON THE NEED FOR AN ENVIRONMENTAL IMPACT STATEMENT FOR THE PROPOSED UNIVERSITY OF MINNESOTA TWIN CITIES COMBINED HEAT AND POWER (CHP) PROJECT MINNEAPOLIS, HENNEPIN COUNTY, MINNESOTA FINDINGS OF FACT CONCLUSIONS OF LAW AND ORDER This matter came before the Minnesota Pollution Control Agency (MPCA) Citizens Board (Board) at a regular meeting held in St. Paul, Minnesota on January 27, Based on the information gathered during the Environmental Assessment Worksheet (EAW) process, the comments received on the EAW, input from MPCA staff, and other information in the record, the MPCA hereby makes the following Findings of Fact, Conclusions of Law, and Order. FINDINGS OF FACT Project Description 1. The University of Minnesota Twin Cities Campus (University) is a teaching and research institution covering an area of approximately 1,154 acres and containing about 22 million square feet of buildings. 2. The University of Minnesota Board of Regents proposes to construct a new combined heat and power (CHP) project ( Project ) to provide steam for the Twin Cities campus steam distribution system and electricity. The Project includes the following equipment: a. A 22.8MW Combustion Turbine Generator (CTG) (EU 161); the CTG will use a stage, dry low NOx combustor; b. A 210 MMBTU/hr duct burner system (EU 162); c. A 270,000 lb steam/hr heat recovery steam generator (HRSG) using exhaust gases from the system; d. An aqueous ammonia-based selective catalytic reduction (SCR) system to control nitrogen oxides; e. An oxidation catalyst to control carbon monoxide (CO) emissions 3. The University also proposes to install a 500 kw emergency generator that would use ultra-low sulfur distillate (ULSD) oil for fuel. The Project will use natural gas as primary fuel and ULSD oil when gas is curtailed or physically unavailable. ULSD contains no more than 15 parts per million (ppm) sulfur, which will minimize both sulfur dioxide and particulate emissions from the generator. TDD (for hearing and speech impaired only): Printed on recycled paper containing at least 30% fibers from paper recycled by consumers

14 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order The Project emission units will be installed in the existing Main Plant Building. The University s Southeast Steam Plant, located at 600 Main Street SE, Minneapolis, about one-half mile from the Main Plant Building, is now the primary source of steam for the campus and the University s Medical Center. 5. The Southeast Steam Plant has five operational boilers: a. One fluidized bed boiler capable of burning coal, wood, oat hulls or natural gas [EU001]. This boiler uses acid gas controls and a fabric filter to control Particulate Matter (PM). b. Two natural gas- or No. 2 fuel oil-fired package boilers [EU002 and EU003]. These boilers are not equipped with any control equipment, but incorporate flue gas recirculation to limit emissions of nitrogen oxides (NOx). c. Two coal-fired boilers also capable of firing No. 2 fuel oil [EU004 and EU005]. The coal-fired boilers are each equipped with acid gas controls and with fabric filters to control PM emissions. 6. The two coal-fired boilers are more than 60 years old and the University indicates they no longer meet the University s reliability requirements or sustainability goals. The two coal fired boilers will be retired when the CHP project commences commercial operations. The University will continue operating the remaining three boilers at the Southeast Plant. The Southeast Plant will become the secondary source of steam, as a back-up to the CHP facility. 7. Outside of the Southeast Plant, the University has a number of diesel-fired generators and pumps, natural gas-fired generators, and natural gas-fired boilers. These units are not being modified, although the air quality permit will include some updates to the regulatory requirements for these units. ENVIRONMENTAL REVIEW OF THE PROJECT 8. Because this Project will generate more than 100,000 tons per year of greenhouse gas emissions, Minn. R , subp 15(B) requires the preparation of an Environmental Assessment Worksheet (EAW). 9. An EAW is a brief document designed to set out the basic facts necessary to determine whether an EIS is required for a proposed project or to initiate the scoping process for an EIS. (Minn. R. pt , subp. 24) The MPCA is the Responsible Governmental Unit (RGU) for preparing the EAW for this Project. 10. The MPCA provided public notice of the Project as follows: a. Notice of the availability of the EAW for public comment was published in the EQB Monitor on October 27, 2014, as required by Minn. R b. The EAW was available for review on the MPCA website at c. The MPCA provided a news release to media, Twin Cities metro counties, and other interested parties on October 27,

15 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order During the 30-day public comment period ending on November 26, 2014, the MPCA received comment letters from the Minnesota Department of Natural Resources, Metropolitan Council, and four citizens. A list of the comment letters received and copies of the letters are included as Appendix A to these Findings. 12. The MPCA prepared written responses to the comment letters received during the public comment period. The responses are included as Appendix B to these Findings. Standard for Decision on the Need for an EIS 13. The MPCA shall base its decision on the need for an EIS on the information gathered during the EAW process and the comments received on the EAW. (Minn. R , subp. 3) The agency must order an Environmental Impact Statement (EIS) for projects that have the potential for significant environmental effects. (Minn. R , subp. 1) In deciding whether a project has the potential for significant environmental effects, the MPCA must compare the impacts that may be reasonably expected to occur from the Project with the criteria set forth in Minn. R , subp. 7. These criteria are: A. Type, extent, and reversibility of environmental effects. B. Cumulative potential effects. The responsible governmental unit (RGU) shall consider the following factors: whether the cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effect; and the efforts of the proposer to minimize the contributions from the project. C. The extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority. The RGU may rely only on mitigation measures that are specific and that can be reasonably expected to effectively mitigate the identified environmental impacts of the project. D. The extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs. Type, Extent, and Reversibility of Environmental Effects 14. The MPCA finds that the types of impacts that may reasonably be expected to occur from the Project include: a. Air Quality impacts related to greenhouse gases. b. Air Quality impacts related to criteria pollutants (particulate matter, sulfur dioxide, nitrogen oxide, and carbon monoxide). 15. Written comments received during the comment period raised additional issues, as follows: Public Safety issues related to natural gas explosions. 3

16 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order 016 Site Security. Stormwater Runoff impacts to the Mississippi River. 16. With respect to the extent and reversibility of impacts that are reasonably expected to occur from the Project, the MPCA makes the following findings. Findings on greenhouse gas impacts. 17. The Project s greenhouse gas emissions will be generated from the combustion of fuel. 18. Combined heat and power systems, such as the system proposed in this Project, have been recognized by the EPA as an inherently lower-emitting design for GHG pollutants. 19. Total Project system efficiency will be approximately 80 percent. In comparison, a utility boiler will use no more than 38 percent of available energy to produce electricity. 20. The Project will use natural gas, which releases fewer greenhouse gases compared to coal, as the primary fuel and ULSD distillate oil when gas is curtailed or physically unavailable. 21. The Project will eliminate the use of two coal-fired boilers, reducing the need for coal as a fuel. 22. With respect to the reversibility of greenhouse gas impacts that are reasonably expected to occur from the Project, greenhouse gas emissions from the facility will continue while the facility remains in operation, and would cease only if the Project were to be temporarily or permanently closed. 23. The MPCA finds that information presented in the EAW and other information in the environmental review record is adequate to address the concerns related to air quality impacts of greenhouse gases. The greenhouse gas impacts on air quality that are reasonably expected to occur from the Project have been considered during the review process. 24. The MPCA finds that the Project, as it is proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of greenhouse gas impacts related to air quality that are reasonably expected to occur from the Project. Findings on impacts of criteria pollutants (particulate matter, sulfur dioxide, nitrogen oxide, and carbon monoxide). 25. The Project will eliminate the use of two coal-fired boilers, reducing the need for coal as fuel. 26. The Project will use natural gas as the primary fuel and ULSD distillate oil when gas is curtailed or unavailable. 27. The Project includes an oxidation catalyst to reduce carbon monoxide. In addition, the combustion turbine generator will use a stage, dry low NOx combustor as well as an aqueous ammonia-based 4

17 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order 017 selective catalytic reduction system to control NOx. The use of these control techniques will reduce the amount of CO and NOx release to the environment. 28. Screening modeling was conducted following an MPCA-approved protocol. The MPCA used the AERSCREEN dispersion model. Worst-case hourly emissions (ULSD as fuel, cold-weather operation) and stack temperature (226 F) were input to the model, along with actual local geography. Neighboring building dimensions were also input to the model. 29. Modeling results were compared to a screening value known as a Significant Impact Level (SIL), provided by the EPA. A SIL value is considered a de minimis or insignificant pollutant concentration that is used as a measure of whether a source may cause or contribute to a violation of the NAAQS, i.e. a significant deterioration of air quality. If any of the analysis conducted as part of this project modeled a pollutant concentration greater than the SIL, the MPCA would have requested additional analysis. The results of the air quality assessment demonstrate that the total ambient pollutant concentrations of the new project are at or below the EPA Significant Impact Level (SIL) of each criteria pollutant. With concentrations at or below the SIL for all criteria pollutants, further analysis based on AERSCREEN results is not needed. 30. With respect to the reversibility of air quality impacts from criteria pollutants that are reasonably expected to occur from the Project, air emissions from the facility will continue while the facility remains in operation, and would cease only if the Project were to be temporarily or permanently closed. While in operation, the Project is expected to meet applicable air quality standards and criteria. If excessive air emissions or violations of the ambient air standards were to occur, air quality impacts are likely to be temporary in nature and corrective measures could be implemented. Such measures could include the initiation of a complaint investigation by the MPCA and requiring the Project Proposer to make operation and maintenance changes. 31. The MPCA finds that information presented in the EAW and other information in the environmental review record is adequate to address the concerns related to air quality. The impacts on air quality that are reasonably expected to occur from the Project have been considered during the review process and appropriate mitigation measures are available and will be required to prevent significant adverse impacts. 32. The MPCA finds that the Project, as it is proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts related to air quality that are reasonably expected to occur from the Project. Findings on public safety related to natural gas explosion (raised in public comments). 33. Natural gas is used throughout the Twin Cities as a fuel source for home and business use. The risk of an explosion or fire is low. 34. In the unlikely event of a natural gas explosion at the Project site, the main hazard would be related to the direct impacts from the potential fire and/or explosion, which primarily would be expected to be limited to the immediate area. In the event of a fire, smoke may impact the local 5

18 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order 018 area depending on extent of the fire and the prevailing wind speed and direction. The impacts would be of a limited duration. 35. Precautions have been designed into the Project for construction and operation to reduce the risk of an explosion inside the Project site. 36. The gas turbine will be inside a building that contains infrared, temperature and gas monitors. These monitors will be tied to an automated carbon dioxide fire suppression system. The monitors also automatically call for fuel and air supply systems to shut down in the case of a potential fire. 37. Natural gas will be compressed prior to injection into the turbine. Only enough natural gas to fill the three-inch diameter supply pipe will be under compression. No compressed gas storage will be included in the project. Block and bleed valves will be located outside the plant to relieve gas pressure caused by a plant shutdown. 38. The University will comply with all State Fire Code and Minneapolis Fire Department guidelines including a fire hydrant coverage plan. 39. A fire sprinkler system will be installed. 40. The University has an ongoing relationship with the city of Minneapolis Fire Department regarding the Southeast Plant and will work with the City to ensure proper coordination in case of fire at the Main Plant. 41. The MPCA finds that information presented in the EAW and other information in the environmental review record is adequate to address the concerns related to public safety. The impacts on public safety related to natural gas explosion that are reasonably expected to occur from the Project have been considered during the review process and methods to prevent significant adverse impacts have been developed. 42. The MPCA finds that the Project, as proposed, does not have the potential for significant environmental effects based on type, extent, and reversibility of impacts related to public safety that are reasonably expected to occur from the Project. Findings on site security (raised in public comment). 43. During construction, the construction site will be surrounded by a perimeter fence that will be locked at the end of each day. 44. During operation, an eight foot tall security fence with three strands of barbed wire will surround the Project site. Access will be provided by a vertical pivot-lift gate equipped with an intercom and security card reader. Security cameras will be monitored and operated from the Project control room. 45. The MPCA finds that information presented in the EAW and other information in the environmental review record is adequate to address the concerns related to site security. The 6

19 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order 019 impacts on site security related to natural gas explosion that are reasonably expected to occur from the Project have been considered during the review process and methods to prevent significant adverse impacts have been developed. 46. The MPCA finds that the Project, as proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts related to site security that are reasonably expected to occur from the Project. Impacts related to stormwater runoff (raised in public comments). 47. One concern raised during the public comment period is whether stormwater could impact the Mississippi River during construction and operation. This issue is addressed as follows. 48. The University will develop a stormwater pollution prevention and management plan (SWPPP), which include best management practices (BMPs) for the construction and operation of the Project, as required by the MPCA National Pollution Discharge Elimination System (NPDES)/State Disposal System (SDS) Construction Stormwater General Permit and NPDES/SDS Industrial Stormwater General Permit. These measures will mitigate the potential for adverse impacts to surface water quality related to stormwater runoff. The quality of surface waters is not expected to significantly change if managed in accordance with the BMP required by the NPDES/SDS Permit. 49. Although significant adverse impacts to water quality are not expected, if water quality impacts were to occur, the operation and management of the Project and the BMPs can be modified and impacts to waters could be reversed. Therefore, the water quality impacts that are reasonably expected to occur from the proposed project are found to be reversible. 50. The MPCA finds that information presented in the EAW and other information in the environmental review record is adequate to address the concerns related to stormwater runoff erosion prevention and sediment control BMPs. The impacts on stormwater runoff that are reasonably expected to occur from the Project have been considered during the review process and methods to prevent significant adverse impacts have been developed. 51. The MPCA finds that the Project, as it is proposed, does not have the potential for significant environmental effects based on the type, extent, and reversibility of impacts related to stormwater runoff that are reasonably expected to occur from the Project. Cumulative Potential Effects 52. The second criterion that the MPCA must consider when determining if a project has the potential for significant environmental effects is the cumulative potential effects. In making this determination, the MPCA must consider whether the cumulative potential effect is significant; whether the contribution from the project is significant when viewed in connection with other contributions to the cumulative potential effect; the degree to which the project complies with approved mitigation measures specifically designed to address the cumulative potential effects; and the efforts of the proposer to minimize the contributions from the project. (Minn. R subp.7.b). The MPCA findings on this criterion are set forth below. 7

20 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order The EAW, public comments, and MPCA follow-up evaluation did not disclose any related or anticipated future projects that may interact with this Project in such a way as to result in significant cumulative potential environmental effects. 54. The EAW evaluated the cumulative potential effects for the Project on air quality. Cumulative potential impacts on air quality. 43. The MPCA evaluated the cumulative potential effects on air quality by considering background concentrations for the downtown Minneapolis area. For each National Ambient Air Quality Standard (NAAQS), the background plus SIL was less than 90 percent of the NAAQS. Project impact for each NAAQS was equal or less than the SIL; therefore, the cumulative potential effects on air quality are not believed to be significant in the Project Area, and the Project is not expected to contribute significantly to adverse cumulative potential effects on air quality. 33. Based on information on the Project obtained from air screening modeling and permit application review processes, and presented in the EAW, and in consideration of potential effects due to related or anticipated future projects, the MPCA does not expect significant cumulative effects from the Project. 34. The MPCA finds that the Project does not have a significant cumulative potential effect. The Extent to Which the Environmental Effects Are Subject to Mitigation by Ongoing Public Regulatory Authority 35. The third criterion that the MPCA must consider when determining if a project has the potential for significant environmental effects is the extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority. Only mitigation measures that are specific and that can be reasonably expected to effectively mitigate the identified environmental impacts of the project can be considered. (Minn. R , subp. 7.C) The MPCA findings with respect to this criterion are set forth below. 36. The following permits or approvals will be required for the Project: Unit of Government MPCA MPCA MPCA MPCA MPCA MNDNR Metropolitan Council Environmental Services (MCES) University of Minnesota Permit or Approval Required Air Emissions Permit Amendment National Pollution Discharge Elimination System (NPDES)/State Disposal System (SDS) Construction Stormwater General Permit NPDES/SDS Industrial Stormwater General Permit NPDES/SDS Industrial Groundwater Pump Out Permit Municipal Separate Storm Sewer System (MS4) General Permit General Permit for Temporary Dewatering Industrial Waste Discharge Permit Building Permit 8

21 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order MPCA Air Emissions Permit Amendment. An Air Emissions Permit Amendment to the University s existing Federal Part 70 permit must be issued before construction can begin. The Air Emission Permit will contain operational and emission limits, including requirements for use of control equipment, that will help prevent or minimize the potential for significant environmental effects. 38. MPCA NPDES/SDS Construction Stormwater General Permit. An NPDES/SDS Construction Stormwater General Permit is required. A General NPDES Construction Stormwater Permit is required when a project disturbs one or more acres. It provides for the use of best management practices (BMPs) such as silt fences, bale checks, and prompt revegetation to prevent eroded sediment from leaving the construction site. The University must have a SWPPP that will provide more detail as to the BMPs to be implemented and will also address: phased construction; vehicle tracking of sediment; inspection of erosion control measures implemented; and timeframes in which erosion control measures will be implemented. The general permit also requires adequate stormwater treatment capacity be provided to assure that water quality will not be impacted by runoff once the project is constructed. 39. MPCA NPDES/SDS Industrial Stormwater General Permit. A NPDES/SDS Industrial Stormwater General Permit will be required for the construction of the Project. The NPDES/SDS Industrial Stormwater Permit requires that specific conditions be adhered to for the operation of the Project, and for overall compliance with water quality requirements. The University will need to prepare a Stormwater Pollution Prevention Plan. 40. MPCA NPDES/SDS Industrial Groundwater Pump Out Permit. A NPDES/SDS Industrial Groundwater Pump Out Permit may be required, if during construction, groundwater pump out is required and contaminant levels exceed permitting thresholds. 41. MPCA Municipal Separate Storm Sewer System (MS4) General Permit. The University has an existing MS4 General Permit, which includes the development of a Stormwater Pollution Prevention Program (SWPPP) designed to reduce the amount of sediment and pollution that enters surface and ground water from storm sewer systems to the maximum extent practicable. The project will meet all requirements laid out in the existing SWPPP. 42. MNDNR General Permit for Temporary Dewatering. A MNDNR General Permit for Temporary Dewatering may be required, if during construction, groundwater pump out is required and the amount of discharge exceeds 10,000 gallons per day. 43. Metropolitan Council Environmental Services (MCES) Industrial Waste Discharge Permit. An Industrial Waste Discharge Permit must be approved and the Project must meet standards and requirements set forth in MCES Waste Discharge Rules before operations can begin. 44. University of Minnesota Building Permit. A Building Permit issued by the University of Minnesota will be required before construction can begin. 45. The above-listed permits include general and specific requirements for mitigation of environmental effects of the Project. The MPCA finds that the environmental effects of the Project are subject to mitigation by ongoing public regulatory authority. 9

22 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order 022 The Extent to Which Environmental Effects can be Anticipated and Controlled as a Result of Other Available Environmental Studies Undertaken by Public Agencies or the Project Proposer, Including Other EISs 46. The fourth criterion that the MPCA must consider is the extent to which environmental effects can be anticipated and controlled as a result of other available environmental studies undertaken by public agencies or the project proposer, including other EISs. (Minn. R , subp. 7. D). The MPCA findings with respect to this criterion are set forth below. 47. The following documents were reviewed by MPCA as part of the environmental impact analysis for the Project. data presented in the EAW permit application air dispersion modeling report 48. This list is not intended to be exhaustive. The MPCA also relies on information provided by the project proposer, persons commenting on the EAW, staff experience, and other available information obtained by staff. 49. There are no elements of the Project that pose the potential for significant environmental effects that have not been addressed by the Project design and permit development processes and by ensuring conformance with regional and local plans. 50. Based on the environmental review, previous environmental studies by public agencies or the project proposer, and staff expertise and experience on similar projects, the MPCA finds that the environmental effects of the Project that are reasonably expected to occur can be anticipated and controlled. 51. The MPCA adopts the rationale stated in the attached Response to Comments (Appendix B) as the basis for response to any issues not specifically addressed in these Findings. CONCLUSIONS OF LAW 52. The MPCA is the governmental unit responsible for determining the need for an EIS for this Project. 53. The EAW, the permit development process, and the evidence in the record are adequate to support a reasoned decision regarding the potential significant environmental effects that are reasonably expected to occur from this Project. 54. Areas where the potential for significant environmental effects may have existed have been identified and appropriate mitigation measures have been incorporated into the Project design and permits. The Project is expected to comply with all MPCA standards. 55. Based on a comparison of the impacts that are reasonably expected to occur from the Project with the criteria established in Minn. R subp. 7, the Project does not have the potential for significant environmental effects. 10

23 On the Need for an Environmental Impact Statement The University of Minnesota Twin Cities Campus Combined Heat and Power Project Minneapolis, MN Findings of Fact Conclusions of Law And Order Based on the record, the MPCA makes a negative declaration on the need for an EIS for the Project. 57. Any findings that might properly be termed conclusions and any conclusions that might properly be termed findings are hereby adopted as such. ORDER 58. The MPCA issues a Negative Declaration on the need for an Environmental Impact Statement for the University of Minnesota Twin Cities Campus Combined Heat and Power (CHP) Project, based on the information gathered during the EAW process and the comments received on the EAW indicating that there are no potential significant environmental effects reasonably expected to occur. IT IS SO ORDERED Commissioner John Linc Stine Chair, Citizens Board Minnesota Pollution Control Agency Date 11

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25 APPENDIX A 025 Minnesota Pollution Control Agency The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Environmental Assessment Worksheet (EAW) LIST OF COMMENT LETTERS RECEIVED 1. Brooke Haworth, Minnesota Department of Natural Resources. Electronic communication received 11/21/ Beth Mercer-Taylor, Falcon Heights. Electronic communication received 11/25/ LisaBeth Barajas, Metropolitan Council. Electronic communication received 11/25/ Steven Cain, Minneapolis. Electronic communication and fax received 11/26/ Phill Kelly, West Bank Community Coalition. Fax received 11/26/ A.J. Siddiqui, Minneapolis. Electronic communication received 11/26/2014.

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41 APPENDIX B 041 Minnesota Pollution Control Agency The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Environmental Assessment Worksheet (EAW) RESPONSES TO COMMENTS ON THE EAW 1. Comments by Brooke Haworth, Minnesota Department of Natural Resources (MDNR). Electronic communication received 11/21/2014. Comment 1-1: The commenter stated that rare mussels have been documented in the Mississippi River in the vicinity of the project; therefore it is important that effective, wildlife-friendly erosion prevention and sediment control practices be implemented and maintained near the river. Response: Erosion prevention and sediment control Best Management Practices (BMPs) will be implemented and maintained during the construction phase and during the operational phase. These required BMPs will be regulated under the Minnesota Pollution Control Agency (MPCA) Construction Stormwater General Permit and the MPCA Industrial Stormwater General Permit. These items are addressed in Sections 11 and 13a of the EAW. The University has agreed to use only wildlife-friendly erosion control products. Comment 1-2: The commenter stated that if a peregrine falcon nest site is discovered during the course of construction, to please contact Lori Naumann, MDNR Nongame Program, regarding the removal and/or relocation. Response: The University has agreed to contact the MDNR Nongame Program if any peregrine falcon nest sites are found. 2. Comments by Beth Mercer-Taylor, Falcon Heights. Electronic communication received on 11/25/ Comment 2-1: The commenter stated support for the project. Response: No response necessary. 3. Comments by LisaBeth Barajas, Metropolitan Council. Electronic communication received 11/25/2014. Comment 3-1: The commenter stated that the EAW site is located within 0.5 mile of Mississippi Gorge Regional Park, and that construction of the new CHP facility as described in the EAW is not anticipated to impact the regional park. Response: No response necessary. Comment 3-2: The commenter stated that the Metropolitan Disposal System (MDS) has adequate capacity for projected flows from this project location. However, the construction of this new CHP

42 The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Minneapolis, Minnesota Responses to Comments on the Environmental Assessment Worksheet 042 facility may have the potential to impact multiple Metropolitan Council Interceptors in multiple locations in the vicinity of the project. To assess the potential for impacts to the MDS, preliminary plans should be sent to Scott Dentz, Metropolitan Council Environmental Services Interceptor Engineering Manager ( ) for review and comment prior to the project initiation. Response: The University has contacted MCES regarding this issue and will work with them as the project proceeds. 4. Comments by Steven Cain, Minneapolis. Electronic communication and fax received on 11/26/2014. Comment 4-1: The commenter stated concern that there should be further analysis of the pollution impact on daily pedestrians, joggers, and bike riders. The commenter specifically asked about the health risk to a pedestrian crossing the nearby Northern Pacific Bridge Number 9 twice daily. Also, the commenter specifically asked about the health risk to joggers or bikers, who will breathe in and out more forcefully than pedestrians, crossing the bridge. Response: The air quality assessment conducted for this project demonstrated that the proposed combination of emissions (CO, NO2, PM 2.5, PM 10 and SO2) with existing measured air quality concentrations were well below the National Ambient Air Quality (NAAQS) standards. The NAAQS are human health-based air quality standards set to be protective of people sensitive to pollutants. Concerns about the air quality around Northern Pacific Bridge Number 9, a thoroughfare for foot and bicycle traffic across the Mississippi River, are addressed by the air quality assessment, which analyzed the short term and annual standards for each appropriate pollutant (See Table 1). Table 1. Pollutant Standards and Modeled Max Concentrations Pollutant Averaging Time Modeled Max Concentration (ug/m3) SIL (ug/m3) NAAQS/ *MAAQS (ug/m3) CO 1-hr ,000/* hr ,000 NO2 1-hr Annual PM hr Annual PM hr Annual *50 SO2 1-hr hr * hr *365 Annual *60 *Minnesota Ambient Air Quality Standard 2

43 The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Minneapolis, Minnesota Responses to Comments on the Environmental Assessment Worksheet 043 The University has conducted air quality dispersion modeling using an U.S. Environmental Protection Agency (EPA)-approved screening tool called AERSCREEN for the proposed project, and relevant emission data and source characteristics, along with terrain and meteorology, to evaluate potential impacts to ambient air quality. The air quality assessment conducted for the project was reviewed and approved by the MPCA. This assessment used actual stack height and building dimensions for the CHP Main Plant as well as other nearby structures that could affect the exhaust plume. Maximum permitted emission rates were combined with five years of meteorological data to help identify maximum 1-hour impact as well as 3-hour, 8-hour, 24-hour and annual impacts from all five years of modeled data. Maximum permitted emission rates are generally greater than what a facility will actually emit. Use of these maximum emission rates ensure that the predicted concentrations resulting from running the model are environmentally conservative. The air quality assessment conducted for the project was reviewed and approved by the MPCA. Modeling results were compared to a screening value known as a Significant Impact Level (SIL), provided by the EPA. Each of the NAAQS evaluated in this project have an applicable SIL value that is between two and five percent of the applicable NAAQS. A SIL value is considered a de minimus or insignificant pollutant concentration that is used as a measure of whether a source may cause or contribute to a violation of the NAAQS, i.e. a significant deterioration of air quality. If any of the analysis conducted as part of this project modeled a pollutant concentration greater than the SIL, the MPCA would have requested additional analysis. Background monitored pollutant concentrations for the downtown Minneapolis area were considered. For each NAAQS, the monitored background plus SIL was less than 90 percent of the NAAQS. Project impact for each NAAQS was less than or equal to the SIL; therefore, the cumulative potential effects on air quality are not believed to be significant in the Project Area. If any of the background plus SIL values were greater than 90 percent of the NAAQS, the MPCA would have requested additional analysis. The results of the air quality assessment demonstrate that the total ambient pollutant concentrations of the new project are at or below the EPA SIL of each criteria pollutant. The monitored background plus SIL was less than 90 percent of the NAAQS. As a result, the MPCA supports the conclusion of the EAW air assessment and finds no reason for further analysis. Comment 4-2: The commenter stated concern about the risks to the community in the case of an explosion inside the plant, assuming the worst case scenario. The commenter had specific concerns relating to (a) a gas explosion; with (b) propagation to the oil storage tanks and (c) association of the freight cars (some containing hazardous materials), traveling or stationed approximately 200 feet behind the CHP plant. Response: The facility has been designed and will be operated to reduce the risk of an explosion inside the facility. The gas turbine will be inside a building that contains infrared, temperature and gas monitors. These monitors will be tied to an automated carbon dioxide fire suppression system. The monitors also automatically call for fuel and air supply systems to shut down in the case of a potential fire. 3

44 The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Minneapolis, Minnesota Responses to Comments on the Environmental Assessment Worksheet 044 Natural gas will be compressed prior to injection into the turbine. Only enough natural gas to fill the three-inch diameter supply pipe will be under compression. No compressed gas storage will be included in the project. Block and bleed valves will be located outside the plant to relieve gas pressure caused by a plant shutdown. The University will comply with all State Fire Code and Minneapolis Fire Department guidelines including a fire hydrant coverage plan. A fire sprinkler system will be installed. In the unlikely event of a natural gas explosion at the facility, the main hazard would be related to the direct impacts from the potential fire and/or explosion, which are primarily expected to be limited to the immediate area. In the event of a fire, smoke may impact the local area depending on extent of the fire and the prevailing wind speed and direction. The impacts would be of a limited duration. The University already has an ongoing relationship with the city of Minneapolis Fire Department regarding the Southeast Plant. The University will work with the City to ensure proper coordination in case of fire at the Main Plant as well, as is typical for this facility type. In the very unlikely event that the oil storage tanks are involved in a fire, the local emergency responders have the capacity to properly address this situation to be protective of life and property. There is a potential that thick smoke may be produced during a potential fire related incident. The impacts of the smoke are in part weather dependent. If additional action is warranted, such as a localized evacuation or a shelter in place scenario, the local emergency responders are well suited to take appropriate action as warranted. It is very unlikely that a fire or explosion at the facility would directly impact any railcars in the area. In the event of an incident, the local emergency responders and the railroad would work together to eliminate or minimize any expansion of the incident to any railcars. The railroad is required to be prepared to respond to any incidents involving its rail or railcars on its rail lines. The railroad may be able to move the rail cars further away. If additional action is warranted, such as a localized evacuation or a shelter in place scenario, the local emergency responders are well suited to take appropriate action. Comment 4-3: The commenter stated concern about security measures to secure the site and prevent unauthorized access from malevolent actors. Response: Security measures will be implemented by the University of Minnesota during construction and operation of the facility. During construction, the facility will be surrounded by a perimeter fence that will be locked in the evening when construction activity has stopped. During operation of the facility, an eight foot tall security fence with three strands of barbed wire will surround the facility. Access will be provided by a vertical pivot-lift gate equipped with an intercom and security card reader. Security cameras will be monitored and operated from the facility control room. In addition, the University police will routinely patrol the area both during construction and operation. Comment 4-4: The commenter requested that an Environmental Impact Statement (EIS) be conducted. Response: The decision on the need for an EIS will be made by the MPCA Board. 4

45 The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Minneapolis, Minnesota Responses to Comments on the Environmental Assessment Worksheet Comments by Phill Kelly, West Bank Community Coalition. Fax received on 11/26/2014. Comment 5-1: The commenter requested that an Environmental Impact Statement (EIS) be conducted. Response: The decision on the need for an EIS will be made by the MPCA Board. Comment 5-2: The commenter stated concerns about the air quality and emissions in the immediate vicinity of their neighborhood as a result of this project. Response: Please refer to response to Comment 4-1. Comment 5-3: The commenter stated that most people do not have the time, inclination, understanding, or technical expertise to fully analyze and comprehensively understand the issues that may potentially arise as a result of this plant s operations. Response: One of the EAW s purposes is to provide public awareness of projects. Technical terms are used but there is an attempt to include plain language so non-experts can grasp environmental issues surrounding the project. In addition to the EAW itself, the University of Minnesota has conducted outreach to community stakeholders to inform them of the project. The University created a one-page summary of the project to aid the public s understanding (Attachment 6). The University s outreach efforts included direct personal contact, presentations, s, media announcements and an interview with the University s Facilities Management Assistance Vice President Mike Berthelsen on the Morning Blend program on KFAI radio. Details of this outreach campaign can be found in Attachment 7. MPCA air permitting staff held a public meeting on January 22, 2015, to discuss the project with interested parties. MPCA staff attended this meeting to discuss the EAW and answer questions. 6. Comments by A.J. Siddiqui, Minneapolis. Electronic communication received on 11/26/2014. Comment 6-1: The commenter stated concerns for air quality and emissions in the immediate vicinity of the Riverview Tower Condominiums neighborhood as a result of this project. The commenter stated that the building s air intake is on top of the building and under right wind conditions, the emissions from the stack above the plant will be sucked into the Riverview Tower Condominiums building. Response: Please refer to response to Comment 4-1. Since the air quality assessment demonstrates that the total ambient pollutant concentrations of the new project are at or below the EPA SIL of each criteria pollutant, air emissions from the project will not have a significant impact on the air intake for the Riverview Tower Condominiums. Comment 6-2: The commenter stated that most living in Riverview Tower Condominiums are nontechnical people who do not understand the technicalities involved in assessing the issues that may potentially rise as a result of this plant s operations. Response: Please see comment

46 The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Minneapolis, Minnesota Responses to Comments on the Environmental Assessment Worksheet 046 Comment 6-3: The commenter requested that an Environmental Impact Statement (EIS) be conducted. Response: The decision on the need for an EIS will be made by the MPCA board. 6

47 ATTACHMENT STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY IN THE MATTER OF THE DECISION ON THE PROPOSAL TO ISSUE UNIVERSITY OF MINNESOTA TWIN CITIES PERMIT NO FOR THE PROPOSED MAIN PLANT COMBINED HEAT & POWER PLANT HENNEPIN COUNTY MINNEAPOLIS, MINNESOTA FINDINGS OF FACT CONCLUSIONS OF LAW AND ORDER FINDINGS OF FACT The above-entitled matter came before the Minnesota Pollution Control Agency (MPCA) Citizens Board at a regular meeting held in St. Paul, Minnesota on January 27, Based on the MPCA staff review, comments, and information received during the comment period, and other information in the record of the MPCA, the MPCA hereby makes the following Findings of Fact, Conclusions of Law, and Order: Overview Facility History 1. The University of Minnesota Twin Cities (the Facility) is a teaching and research institution with two campuses in the Twin Cities: the Minneapolis campus and the St. Paul campus. The two campuses are approximately three miles apart and are connected by a transitway 80 feet wide owned by the University. The Facility covers an area of approximately 1,154 acres and contains approximately 22,000,000 gross square feet of buildings overall. 2. The Minneapolis campus consists of the East and West Bank, located on both sides of the Mississippi River. The campus has a variety of teaching and research facilities in the areas of engineering, liberal arts, business, health sciences, and athletics. The Minneapolis campus also includes dormitories and other support activities that are operated by the Facility. 3. A central steam plant (Southeast Plant), which directly provides steam for heating and cooling to the Minneapolis campus, is located on the East Bank. The Southeast Plant is owned by the Facility, but is currently operated by Veolia Energy Solutions, LLC (Veolia). The Southeast Plant provides steam to most on-campus buildings and to the Fairview University Medical Center through the University system. 4. The Southeast Plant has five operational boilers. One is a fluidized bed boiler capable of burning coal, wood, oat hulls or natural gas [EU001]. The fluidized bed boiler [EU001] uses acid gas controls and a fabric filter to control Particulate Matter (PM). Two boilers are natural gas- or No. 2 fuel oilfired package boilers [EU002 and EU003]. The two package boilers [EU002 and EU003] are not equipped with any control equipment, but incorporate flue gas recirculation to limit NO x 1

48 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 048 emissions. The fourth and fifth boilers are coal-fired also capable of firing No. 2 fuel oil [EU004 and EU005]. The coal-fired boilers are each equipped with acid gas controls and with fabric filters to control PM [EU004 and EU005]. 5. Outside of the Southeast Plant, the Facility has a number of diesel-fired generators and pumps, natural gas-fired generators, and natural gas-fired boilers distributed throughout both campuses. Regulatory Status of Permit/Permitting History 6. The Facility has an extensive permitting history. The Facility currently operates under a Federal Part 70 Permit. The Facility is classified as a major existing source under the Clean Air Act (CAA) New Source Review program. The Facility is classified as an area source under the CAA Hazardous Air Pollutants program. On May 16, 2006, the current operating permit was issued. 7. In November 2013, the first air permit application for the proposed Main Plant Combined Heat and Power Plant (CHP project) was submitted along with the Environmental Assessment Worksheet (EAW). At that time, Environmental Review required the Facility to conduct air dispersion modeling for the project. The final application was submitted in August 2014, after the air dispersion modeling was approved. 8. This permit action is a minor modification under the CAA Prevention of Significant Deterioration (PSD) program. Previous Environmental Review 9. In 1996, an EAW and Environmental Impact Statement were completed prior to the renovation of the Southeast Plant. Compliance/Enforcement History 10. In the past five years, there have been two minor enforcement actions at the Facility (one in the air program and one in the tanks program). Proposed Permit Modification Proposed Project Description 11. In August, 2014, the Facility submitted an application for a major permit amendment to its existing Federal Part 70 permit. This permit application was received August 7, This application requested approval to install the proposed CHP project. The CHP project includes a 22.8 MW Combustion Turbine Generator (CTG) (EU 161) in series with a 210 MMBtu/hr duct burner (EU 162). Exhaust gases will be used to produce up to 270,000 pounds of steam per hour for the Minneapolis campus steam distribution system. Also included in the request was approval to install a 500 kw emergency generator. The allowed fuel for the emergency generator is ultralow sulfur distillate (ULSD) distillate oil. 2

49 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order The CHP project will use natural gas as primary fuel and ULSD distillate oil when gas is curtailed or physically unavailable. The CHP system includes an oxidation catalyst to reduce CO. In addition, the CTG will use a stage, dry low NOx combustor as well as an aqueous ammonia-based selective catalytic reduction system to control NOx. 14. Upon the commencement of commercial operation of the CHP project, two coal fired boilers (EU 004 and EU 005) will be retired. 15. There are several, additional minor changes to the operating permit that are proposed to be authorized in this permit action. These additional changes pertain to updating the existing operating permit. 16. The PSD program is a preconstruction permitting program for proposed projects with emissions that exceed its major modification thresholds. The proposed CHP project emission increases were below the PSD major modification thresholds. Because the CHP project emissions alone were below the PSD major modification thresholds, the Facility did not need to analyze any netting emission decreases in this permit action. Environmental Review 17. A mandatory EAW is triggered for this project because greenhouse gas emissions will be greater than 100,000 tons per year. Minn. R , subp. 15.B Air Pollution. On October 27, 2014, an EAW was public noticed for this project in the Environmental Quality Board (EQB) Monitor. 18. On January 27, 2014, the MPCA Citizens Board (Board) voted to approve the Findings of Fact, Conclusions of Law, and Order for a negative declaration on the need for an Environmental Impact Statement. Air Quality Impacts 19. As a minor PSD modification, the Facility was not required to conduct air dispersion modeling as part of the CHP project permitting process. Dispersion modeling is required for major PSD major modifications to ensure compliance with National Ambient Air Quality Standards (NAAQS) and other air quality protection indicators. The Facility did, however, conduct air dispersion screening modeling. 20. Screening modeling was conducted following an MPCA-approved protocol. The AERSCREEN dispersion model was used. Worst-case hourly emissions (ULSD as fuel, cold-weather operation) and stack temperature (226 F) were input to the model, along with actual local geography. Neighboring building dimensions were also input to the model. 21. Modeling results were compared to a screening value known as a Significant Impact Level (SIL), provided by the U.S. Environmental Protection Agency (EPA). Each of the NAAQS evaluated in this project have an applicable SIL value that is between two and five percent of the applicable NAAQS, A SIL value is considered a de minimus or insignificant pollutant concentration that is used as a 3

50 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 050 measure of whether a source may cause or contribute to a violation of the NAAQS, i.e. a significant deterioration of air quality. If any of the analysis conducted as part of this project modeled a pollutant concentration greater than the SIL, the MPCA would have requested additional analysis. The results of the air quality assessment demonstrate that the total ambient pollutant concentrations of the new project are below the EPA SIL of each criteria pollutant. As a result, the MPCA supports the conclusion of the EAW air assessment and no reason for further analysis based on AERSCREEN results, NAAQS thresholds met, and final values being below the SIL. Because AERSCREEN results demonstrated that the predicted values were below the SIL, the MPCA supports the conclusion of the EAW that no further analysis is necessary. 22. Modeling results can be considered environmentally conservative because they do not take into account: i. The retirement of two coal-fired boilers at the neighboring Southeast Plant. ii. Reduced operation of the remaining Southeast Plant boilers due to baseload operation of the Main CHP Plant. Public Notice of Draft Permit Procedural History 23. On October 30, 2014, pursuant to Minn. R , subp. 2, the MPCA Commissioner issued a public notice of the preliminary decision to issue the permit. The public notice notified the public of the public comment period. The notice was published in the Star Tribune on that date. In addition, the public notice was made available for review on the MPCA website at and mailed to interested parties. The notice included the information required by rule. 24. The public comment period for the Draft Permit began on October 31, 2014, and ended at 4:30 p.m. on December 1, During the 30-day comment period, the MPCA received comment letters from citizens. Public Comment and MPCA Consideration of Comments Regarding Draft Permit 25. During the public comment period, the MPCA received comments from three parties. Two of the three commenters requested a public informational meeting (both on December 1, 2014). The first commenter stated concerns regarding air quality and emissions in the immediate vicinity of the Riverview Tower Condominiums neighborhood as a result of this project. The second commenter had concerns that under right wind conditions the emissions from the CHP Project will be sucked into the air intake on top of his building. The commenter also stated concerns about the air quality and emissions in the immediate vicinity of his neighborhood as a result of this project. The third commenter stated that his neighborhood is concerned with air quality which may be adversely affected by the CHP Project. 26. The MPCA prepared responses to all comments received during the 30-day public comment period. Comment letters received have been hereby incorporated by reference as Appendix A to these 4

51 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 051 findings. The MPCA responses to comments received are hereby incorporated by reference as Appendix B to these findings. Public Notice of Public Informational Meeting 27. On December 22, 2014, the MPCA published a notice of a public informational meeting on January 22, The notice was published in the Star Tribune on that date. In addition, the public notice was made available for review on the MPCA website at This notice was also mailed to the interested party list as well as the commenters on the EAW and draft permit. The notice included the information required by rule. The meeting was conducted in a local, neighborhood building. Community Involvement in Process 28. As part of the permitting process and in consultation with the EPA, the MPCA has evaluated available socio-economic information about residents in the area around the Facility to evaluate the potential for environmental justice concerns. In the case of University of Minnesota s CHP project, the EPA and MPCA have identified possible concerns for environmental justice based on information about income and ethnicity of area residents. 29. To address these concerns, the Facility conducted enhanced outreach to area residents to facilitate their awareness of and involvement in the decision-making process. Beginning in 2011 and continuing throughout the permitting process, this included outreach on multiple occasions to local community groups, community radio, informal communication, and community information meetings. A summary of the community engagement conducted by the University of Minnesota is as follows: 2011 and 2012, during the early planning stage of this project: advisory to potentially interested community leaders and organizations on both sides of the river community information meetings advertised to the general public and campus area communities In 2014, in anticipation of the comment period for EAW and permit: direct personal outreach to Minnesota and Minneapolis elected officials; state, regional, and local agencies with a potential interest (e.g. Minnesota Department of Natural Resources, Minneapolis Park Board, others); and community and resident associations in neighboring communities on both sides of the river presentations to groups: three neighborhood associations and one homeowners' association a mass to 190+ potentially interested parties, community leaders, campus neighbors postings about the project and the opportunity to comment on neighborhood list serves and a Cedar Riverside neighborhood online forum official public notice of the EAW and permit application in the Star Tribune, the Pioneer Press, the MN Daily; and in the EQB Monitor Fourteen paid media announcements on community radio, in three languages 5

52 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 052 an interview on a drive-time community radio news program additional media coverage by the MN Daily and Midwest Energy News In December/January in preparation for the MPCA community information meeting: direct personal outreach to the West Bank Community Coalition, and to Minneapolis Council members with potentially interested constituents two notices to the interested parties list, including community leaders, campus neighbors, and all who have commented on the project or attended a meeting posting on a neighborhood online forum A detailed record of the Facility s community engagement is found in Appendix C Fact Sheet and Appendix D Outreach Update With the removal of two coal burning boilers at the Southeast Plant, this permit action will result in an overall low risk in pollutants of concern for health issues. Accordingly, the MPCA did not recommend additional community involvement actions to further address emissions. FINAL DETERMINATION ON ISSUANCE OF THE PERMIT 31. The MPCA s decision to issue the proposed permit is governed by its permit rule, Minn. R , which provides: Subpart 1. Preconditions for issuance. The agency shall issue a permit or permit amendment, or reissue a permit only if it determines that all of the following conditions have been met: A. The agency has received a complete application for a permit, permit amendment, or permit reissuance, except that a complete application need not be received before issuance of a general permit under part , subpart 4. B. The agency has complied with the public participation procedures for permit issuance if required by part C. The agency has complied with the procedures for notifying and responding to affected states, if required by part D. If the administrator s review is required by part , the administrator has received a copy of the permit and any notices required and has not objected to issuance of the permit within the time period specified, or the administrator has objected by the objection has been resolved to the administrator s satisfaction. E. The conditions of the permit provide for compliance with all applicable requirements and the requirements of parts to , or include a schedule to achieve such compliance. F. The permit does not reflect a variance from any federally enforceable applicable requirement or requirement of parts to G. The agency anticipates that the applicant will, with respect to the stationary source and activity to be permitted, comply with all conditions of the permit. H. All applicable provisions of Minn. Stat., ch. 116D, and the rules adopted under Minn. Stat., ch. 116D, have been fulfilled. 6

53 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 053 Subp. 2. Grounds for denial. The following constitute grounds for the agency to refuse to issue a new or modified permit, or to refuse permit reissuance: A. The agency is unable to make any of the determinations required under subpart 1. B. There exists at the stationary source to be permitted unresolved noncompliance with applicable state or federal pollution control statutes or rules administered by the agency, or conditions of a previous or existing air emission permit, and the applicant will not undertake a schedule of compliance to resolve the noncompliance. C. An applicant has failed to disclose fully all facts relevant to the stationary source or activity to be permitted, or the applicant has knowingly submitted false or misleading information to the agency. D. The permitted facility or activity would endanger human health or the environment and the danger cannot be removed by an amendment to the permit. E. With respect to the stationary source or activity to be permitted, the applicant has not complied with the requirement to pay fees under chapter F. With respect to the stationary source of activity to be permitted, the applicant has failed to pay a penalty owed pursuant to court order, consent decree, stipulation agreement, schedule of compliance, or an order issued under Minn. Statutes, section G. The applicant has failed to prepare a pollution prevention plan or submit a pollution prevention progress report to the commissioner as required by Minn. Stat., 115D.07 and 115D As documented in the findings above, the MPCA received a complete application, has followed all required steps for obtaining EPA review and public comment, and has included all conditions necessary in the permit to ensure compliance with applicable state and federal law (the NAAQS, New Source Performance Standard (NSPS) Subpart KKKK, and NSPS Subpart IIII), and that the Facility will comply with the conditions of the permit. CONCLUSIONS OF LAW 33. Any findings that might properly be termed conclusions and any conclusions that might properly be termed findings are hereby adopted as such. 34. The MPCA has jurisdiction over this matter. 35. Due, adequate, and timely public notice of the proposed permit was given in accordance with Minn. R , and

54 Main Plant Combined Heating & Power Plant Air Permit # Minneapolis, Minnesota Findings of Fact Conclusions of Law And Order 054 The conditions under which the MPCA is authorized to issue this permit set forth in Minn. R have been met, and no condition for the denial of the permit is present. Proper operation of the project in accordance with the conditions of the permit issued by this order will achieve compliance with applicable state and federal air pollution control statues and rules and the conditions of the permit. ORDER 36. The Minnesota Pollution Control Agency approves the air permit for the University of Minnesota Twin Cities Main Plant Combined Heat & Power Project. IT IS SO ORDERED Commissioner John Linc Stine Chair, Citizens Board Minnesota Pollution Control Agency Date 8

55 APPENDIX A 055 Minnesota Pollution Control Agency The University of Minnesota, Twin Cities Combined Heat and Power (CHP) Project Air Permit # LIST OF COMMENT LETTERS RECEIVED 1. Phill Kelly, West Bank Community Coalition. Fax received 12/1/ A.J. Siddiqui, Minneapolis. Electronic communication received 12/1/ Janet Curiel, Minneapolis. Electronic communication received 12/1/2014.

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61 061 3 Original Message From: PCA, WebMaster (MPCA) Sent: Monday, December 01, :51 PM Subject: Web Feedback Form The following information was submitted: The following comments were submitted about our web site: From: Janet Curiel ( jacur001@gmail.com) Who is a: Educator And access the internet from: The following words were deemed important by our users: air quality,environmental quality,environmental innovation Comments: I am offering feedback out of concern for the proposed burner which would replace the coal burning burner on the U of Mn campus. While we applaud the end of coal burning, we in the Cedar Riverside neighborhood are concerned with air quality which may be adversely affected by the new facility, which will be just across the river from the West Bank. We feel that we were not given adequate notification regarding this facility. We are requesting time for a public information forum as well as an extensive environmental review for this project. Sincerely, Janet Curiel

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63 APPENDIX B 063 Minnesota Pollution Control Agency University of Minnesota Twin Cities Air Permit # RESPONSES TO COMMENTS ON THE PERMIT 1. Comments by West Bank Community Coalition. Letter received December 1, Comment 1-1: The first commenter stated concerns regarding air quality and emissions in the immediate vicinity of the Riverview Tower Condominiums neighborhood as a result of this project. Response 1-1: The air quality assessment conducted for this project demonstrated that the proposed combination of emissions (CO, NO2, PM 2.5, PM 10 and SO2) with existing measured air quality concentrations were well below the National Ambient Air Quality (NAAQS) standards. The NAAQS are human health-based air quality standards set to be protective of people sensitive to pollutants. Concerns about the air quality around Northern Pacific Bridge Number 9, a thoroughfare for foot and bicycle traffic across the Mississippi River, are addressed by the air quality assessment, which analyzed the short term and annual standards for each appropriate pollutant (See Table 1). Table 1. Pollutant Standards and Modeled Max Concentrations Pollutant Averaging Time Modeled Max Concentration (ug/m3) SIL (ug/m3) NAAQS/ *MAAQS (ug/m3) CO 1-hr ,000/* hr ,000 NO2 1-hr Annual PM hr Annual PM hr Annual *50 SO2 1-hr hr * hr *365 Annual *60 *Minnesota Ambient Air Quality Standard

64 University of Minnesota Twin Cities Responses to Comments on the Minneapolis, Minnesota Air Permit # The University has conducted air quality dispersion modeling using an U.S. Environmental Protection Agency (EPA)-approved screening tool called AERSCREEN for the proposed project, and relevant emission data and source characteristics, along with terrain and meteorology, to evaluate potential impacts to ambient air quality. The air quality assessment conducted for the project was reviewed and approved by the Minnesota Pollution Control Agency (MPCA). This assessment used actual stack height and building dimensions for the Combined Heat and Power (CHP) Main Plant as well as other nearby structures that could affect the exhaust plume. Maximum permitted emission rates were combined with five years of meteorological data to help identify maximum 1-hour impact as well as 3-hour, 8-hour, 24-hour and annual impacts from all five years of modeled data. Maximum permitted emission rates are generally greater than what a facility will actually emit. Use of these maximum emission rates ensure that the predicted concentrations resulting from running the model are environmentally conservative. The air quality assessment conducted for the project was reviewed and approved by the MPCA. Modeling results were compared to a screening value known as a Significant Impact Level (SIL), provided by the EPA. Each of the NAAQS evaluated in this project have an applicable SIL value that is between two and five percent of the applicable NAAQS. A SIL value is considered a de minimus or insignificant pollutant concentration that is used as a measure of whether a source may cause or contribute to a violation of the NAAQS, i.e. a significant deterioration of air quality. If any of the analysis conducted as part of this project modeled a pollutant concentration greater than the SIL, the MPCA would have requested additional analysis. Background monitored pollutant concentrations for the downtown Minneapolis area were considered. For each NAAQS, the monitored background plus SIL was less than 90 percent of the NAAQS. Project impact for each NAAQS was less than or equal to the SIL; therefore, the cumulative potential effects on air quality are not believed to be significant in the Project Area. If any of the background plus SIL values were greater than 90 percent of the NAAQS, the MPCA would have requested additional analysis. The results of the air quality assessment demonstrate that the total ambient pollutant concentrations of the new project are at or below the EPA SIL of each criteria pollutant. The monitored background plus SIL was less than 90 percent of the NAAQS. As a result, the MPCA supports the conclusion of the EAW air assessment and finds no reason for further analysis. 2. Comments by AJ Siddiqui. Letter received December Comment 2-1: The commenter stated concerns for air quality and emissions in the immediate vicinity of the Riverview Tower Condominiums neighborhood as a result of this project. The commenter stated that air intake is on top of the building where under right wind conditions the emissions from the stack above the plant will be sucked into our building. Please refer to response to Comment

65 University of Minnesota Twin Cities Responses to Comments on the Minneapolis, Minnesota Air Permit # Comments by Janet Curiel. Letter received December 1, Comment 3-1: The commenter stated concerns about the air quality and emissions in the immediate vicinity of their neighborhood as a result of this project. Please refer to response to Comment

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67 ATTACHMENT DRAFT/PROPOSED AIR EMISSION PERMIT NO Major Amendment IS ISSUED TO University of Minnesota Board of Regents University of MN Twin Cities 202 Morrill Hall Minneapolis, Hennepin County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No , and authorizes the Permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R 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 as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal; Pt 70/Major for NSR Operating Permit Issue Date: 5/16/2006 Major Amendment Issue Date: <issue date> Expiration Date: 5/16/2011* Title I Conditions do not expire. * 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 December 22, 2010.) Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Linc Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

68 068 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit January 1, Moderate Amendment September 19, Moderate Amendment January 16, Moderate Amendment April 17, Moderate Amendment May 22, Moderate Amendment November 14, Moderate Amendment February 6, Moderate Amendment February 11, Administrative Amendment May 15, Moderate Amendment September 13, Minor Amendment December 23, Major Amendment August 7, TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Appendices Appendix A Insignificant Activities and Applicable Requirements Appendix B Parameters Used in Air Dispersion Modeling Analysis

69 069 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: The University of Minnesota is a teaching and research institution with two campuses in the Twin Cities: the Minneapolis campus and the St. Paul campus. The two campuses are approximately three miles apart and are connected by a transitway 80 feet wide owned by the University. The Facility covers an area of approximately 1154 acres and contains approximately 22,000,000 gross square feet of buildings overall. The Facility employs approximately 15,000 people and serves a population of 40,000 full time and 11,000 part time students. The Facility owns and operates, or contracts with other parties who operate, a variety of facilities that support its teaching and research functions. The Minneapolis Campus consists of the East and West Bank locations adjacent to the industrial downtown Minneapolis stretch of the Mississippi River. The campus has a variety of teaching and research facilities in the areas of engineering, liberal arts, business, health sciences, and athletics. The Minneapolis Campus provides dormitory and other facilities that are operated by the Facility. A central steam plant (Southeast Plant), which directly provides steam for heating and cooling to the Minneapolis Campus, is located on the East Bank. The Southeast Plant is owned by the Facility, but is currently operated by Veolia Energy Solutions, LLC (Veolia). The Southeast Plant provides steam to most oncampus buildings and to several off campus customers through the University system.

70 070 The St. Paul Campus is generally located east of Cleveland Avenue, south of Larpenteur Avenue, west of the Minnesota State Fairgrounds, and north of Como Avenue in St. Paul. The campus has its primary teaching and research emphasis in agricultural studies. Prominent facilities include a veterinary medicine teaching and research facility, biological sciences complex, agricultural engineering building, agronomy and plant research facilities, and animal husbandry facilities. The facility is an existing major source under New Source Review regulations. The facility has a limited potential to emit over 250 tons per year of Carbon Monoxide (CO), Nitrogen Oxides (NO X ), Particulate Matter less than 10 microns (PM 10 ), Particulate Matter (PM), and Sulfur Oxides (SO X ). PERMIT ACTION 002 DESCRIPTION: This permit action was two moderate amendments and one minor amendment to a Part 70 permit to authorize the construction and operation of five emergency generators at four different buildings at the facility. These units qualified for the amendment based on the potential emissions being below significant thresholds. The generators, which were modified or reconstructed after July 11, 2005, or manufactured after April 1, 2006, are subject to 40 CFR pt. 60, subp. IIII. PERMIT ACTION 003 DESCRIPTION: This permit action was a moderate amendment that authorized the construction and operation of an emergency generator at the Medical Biosciences Building at the facility. The unit qualified for the amendment based on the potential emissions being below significant thresholds. The generator is subject to 40 CFR pt. 60, subp. IIII. PERMIT ACTION 004 DESCRIPTION: This permit action was a moderate amendment that authorized the construction and operation of two diesel emergency generators, one portable (EU 152), and one at the Science Teaching and Student Services Center (EU 153). These units qualified for the amendment based on the potential emissions being below significant thresholds. These generators are subject to 40 CFR pt. 60, subp. IIII. PERMIT ACTION 005 DESCRIPTION: This permit action was a moderate amendment to a Part 70 permit to authorize the construction and operation of two diesel emergency generators (EU 154, 155) and two boilers (EU 156, 157) at the new Cancer/Cardio Research Facility. These units qualified for a moderate amendment because the potential emissions are below significant thresholds. These generators are subject to 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ. The boilers are subject to 40 CFR pt. 60, subp. Dc. PERMIT ACTION 006 DESCRIPTION: This permit action was a moderate amendment to authorize the construction and operation of: Two diesel emergency generators (EU 158, 159) at the new Ambulatory Care Clinic. Construction was authorized, prior to permit issuance, via a letter on October 23, These generators are subject to 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ. One diesel emergency generator (EU 160) at the new Microbiology Research Facility located within the Biomedical Discovery District of the East Bank Campus. This generator is subject to 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ. The permit also authorized a 120 day extension to submit computer dispersion modeling information.

71 071 PERMIT ACTION 007 DESCRIPTION: This permit action is for a major amendment. This permit action will authorize the construction of the proposed Main Plant Combined Heat & Power (CHP) system. The CHP system includes a 22.8 MW combustion turbine (EU 161) generated in series with a 210 million British thermal units per hour (MMBtu/hr) duct burner (EU 162). Exhaust gases will be used to produce up to 270,000 pounds of steam per hour for the Minneapolis campus steam distribution system. The CHP system can operate under a number of scenarios: Full or partial combustion turbine generator (CTG) operation with no supplemental duct burner firing. Steam is produced from only the CTG exhaust gas. Full CTG operation with full or partial duct burner operation. The system will use natural gas as primary fuel and ultra low sulfur distillate oil (ULSD) when gas is curtailed or physically unavailable. The CHP system includes an oxidation catalyst to reduce CO. In addition, the CTG uses a stage, dry low NOx combustor as well as an aqueous ammonia based selective catalytic reduction system to control NOx. The CHP is subject to 40 CFR pt. 60, subp. KKKK. A 500 kilowatt (kw) diesel emergency generator (EU 163) will also be installed. The generator is subject to 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ. Six existing coal fired boilers will be designated as limited use boilers under the provisions of 40 CFR pt. 63, subp. JJJJJJ. To do so, annual capacity limits of 10 percent were added to EU004, EU005, EU Upon the commencement of commercial operation of the Main Plant Combined Heating Plant's turbine and duct burner, two coal fired boilers (EU 004 and EU 005) will be retired.

72 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-1 01/02/ Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENTS Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R 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. The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections and 40 CFR pt. 82 to determine all the requirements that apply to your facility. Inapplicable Requirement: Standards of Performance for Commercial and Industrial Solid Waste Incineration Units, 40 CFR pt. 60, subp. CCCC do not apply to this facility. The permit shield applies in accordance with Minn. R , subp. A(2). Inapplicable Requirement: Standards of Performance for Grain Elevators, 40 CFR pt. 60, subp. DD do not apply to this facility. The permit shield applies in accordance with Minn. R , subp. A(2). Inapplicable Requirement: Minnesota Standards of Performance for Waste Combustors do not apply to this facility. The permit shield applies in accordance with Minn. R , subp. A(2). DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW 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 40 CFR Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. Why to do it Minn. Stat. Section , subd. 4a; Minn. R ; Minn. R , subp. 2; Minn. R ; Minn. R CFR pt CFR pt. 60, subp. CCCC; Minn. R , subp. (A)(2) 40 CFR pt. 60, subp. DD; Minn. R , subp. (A)(2) Minn. R , subp. (A)(2); Minn. Rules Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subp. 4; Minn. R , subps. 4 & 5 The Permittee shall maintain records of this documentation.

73 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-2 01/02/ 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. The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. OPERATIONAL REQUIREMENTS Ambient Air Quality Standards: The Permittee shall comply, and upon written request demonstrate compliance, with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment 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 the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subps. 4 & 5 Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subps. 4 & 5 40 CFR pt. 50; Minn. Stat. Sec , subds. 4a and 9; Minn. R , subps. 7A, 7L and 7M; Minn. R , subps. 1, 2, and 4; Minn. R Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Minn. R. ch. 7017

74 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-3 01/02/ Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Minn. Rs , subp. 1-4, and Minn. R , subp. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R Minn. R , subp. 4(D) 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. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. MODELING REQUIREMENT RECORDKEEPING Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. REPORTING/SUBMITTALS 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. Minn. R , subp. 4(D) Minn. R , subp. 5(C) Minn. R , subp. 5(B) 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.

75 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-4 01/02/ Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon Minn. R , subp. 1 as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Application for Permit Reissuance: due 180 days before expiration of existing Minn. R , subp. 2 permit. Extension Requests: The Permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) 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). 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). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R Minn. R

76 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 001 New and modified boilers (annual limits to avoid mod) A-5 01/02/ Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler EU 002 SG202 - Medium Pressure Package Boiler EU 003 SG203 - High Pressure Package Boiler EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) SV 001 SG201 - CFB Boiler SV 002 SG202/SG203 - Med/High Pressure Package Boilers SV 003 SE3 - Pulverized Coal Boiler SV 004 SE4 - Spreader Stoker Boiler SV 005 SG231 - Med. pressure package boiler (new St. Paul boiler) What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 32.9 tons/year using 12-month Rolling Sum, not including condensible emissions to be calculated by the 15th day of each month for the previous 12-month period. PM < 10 micron: less than or equal to 91.7 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. Sulfur Dioxide: less than or equal to tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. Nitrogen Oxides: less than or equal to tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. Carbon Monoxide: less than or equal to tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. Volatile Organic Compounds: less than or equal to 31.2 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. OPERATIONAL REQUIREMENTS Daily Coal Sampling: Sample and analyze for the sulfur content and heating value of the coal daily for EU001, EU004 and EU005 according to the procedures specified in GP008 of this permit. [Please be aware that further analysis of the coal is specified in other parts of this permit to comply with other requirements contained within this permit.] Why to do it Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section 52.21and Minn. R Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section 52.21, 40 CFR Section 51 Appendix S and Minn. R Title I Condition: Limit to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. This information may be used to calculate sulfur emissions for EU002, EU003 and EU006. CALCULATIONS Daily Emissions Calculations: Calculate daily the amount of Total PM, PM10, SO2, Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) emitted from the amount of fuel combusted in the emission units listed above. Calculate emissions using the emission factors below except that the daily average CEMS value shall be used for calculation of actual SO2 and NOx emissions where available. Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO)

77 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-6 01/02/ Daily Emissions Calculation: The following equation shall be used for this calculation: F = SUMiSUMj [EFij x THIij) where: F = the total emission in tons/year of a specific pollutant SUM = sum over all values of i or j i = a number from 1 to 6 identifying each emission unit in the group j = identifies the type of fuel combusted EFij = emission factor as listed below or as determined by performance testing for emission unit i when combusting fuel j, or for pollutants monitored by CEMS in lb/mmbtu, the average value for each day THIij = the total heat input to the emission unit in a day in MMBtu, based on fuel consumption for fuel of type j in emission unit i, (or for pollutants monitored by a CEMS in lb/mmbtu) Monthly Emissions Calculations: By the 15th day of each month, the Permittee shall calculate the 12-month rolling sum value for each pollutant. EMISSION FACTORS Emission factors for total PM, lb/mmbtu: EU001: all fuels, EU002: fuel oil, 0.036; natural gas, EU003: fuel oil, 0.036; natural gas, EU004: coal, 0.034; fuel oil, EU005: coal and approved biomass, 0.038; fuel oil, EU006: fuel oil, 0.036; natural gas, Emission factors for PM < 10 micron, lb/mmbtu EU001: all fuels, EU002: fuel oil, 0.056; natural gas, EU003: fuel oil, 0,056; natural gas, EU004: coal, 0.106; fuel oil, EU005: coal and approved biomass, 0.084; fuel oil, EU006: fuel oil, 0.056; natural gas, Emission factors for S02, lb/mmbtu EU001: coal, fuel oil and approved biomass, CEMS data; natural gas, EU002: fuel oil, fuel oil receipts; natural gas, EU003: fuel oil, fuel oil receipts; natural gas, EU004: coal, CEMS data; fuel oil, CEMS data EU005: coal and approved biomass, CEMS data; fuel oil, CEMS data EU006: fuel oil, fuel oil receipts; natural gas, Emission factors for nitrogen oxides, lb/mmbtu EU001: all fuels, CEMS data EU002: all fuels, CEMS data EU003: all fuels, CEMS data EU004: coal, 1.18; fuel oil, EU005: coal and approved biomass, 0.783; fuel oil, EU006: CEMS data Emission factors for carbon monoxide, lb/mmbtu EU001: coal, 0.100; fuel oil, 0.200; natural gas, 0.200; wood and approved biomass when operating at Maximum Continuous Rating (MCR). Emission of CO is not expected to exceed 30 lb/hr at 50% or more of MCR when firing coal only. EU002: all fuels, EU003: all fuels, EU004: coal, 0.034; fuel oil, EU005: coal and approved biomass, 0.280; fuel oil, EU006: all fuels, Emission factors for volatile organic compounds, lb/mmbtu EU001: coal, 0.015; fuel oil, 0.015; natural gas, 0.001; approved biomass, EU002: all fuels, EU003: all fuels, EU004: coal, 0.003; fuel oil, EU005: coal, 0.003; fuel oil, 0.001; approved biomass, EU006: all fuels, Emisison Factor Adjustments: The Permittees may propose adjustments to the emission factors. Submit the appropriate modification request for approval and subsequent permit amendment. RECORDKEEPING REQUIREMENTS Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Minn. R , subp. 4 and 6

78 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-7 01/02/ Recordkeeping: Record daily the amount of coal combusted in emission units EU001, EU004, and EU005 and the sulfur content and heating value of the coal. Recordkeeping: Record daily the amount of fuel other than coal combusted in emission units EU001, EU002, EU003, EU004, EU005, and EU006 and the heating value of the fuel. Recordkeeping: Maintain a record of the daily emissions of each pollutant and a 12-month rolling sum of emissions for each pollutant that has a limit within GP001. PERFORMANCE TESTING Performance Testing Required: Test each emission unit within this group (EU001-EU006) by the date stated within the approved Testing Frequency Plan for PM, PM10, SO2, NOx, CO and VOC to verify emission factors. If the emission factor requirement for a unit specifies that CEMS or fuel receipts are to be used, then a performance test is not required for that pollutant at that unit. A specific testing frequency for each required pollutant for each boiler is located at the Stack/Vent level of this permit for each boiler in this group. The purpose of the testing is to verify that the emission factors listed in GP001 are not exceeded. They are not to be adjusted downward as a result of performance testing unless the procedures in the "Emission Factor Adjustments" requirement are followed. Calculations of actual emissions for Emission Inventory shall follow the process and hierarchy described in Minn. R Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21, Minn. R and 40 CFR Section 51 Appendix S (for CO) Minn. R , subp. 1

79 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-8 01/02/ Subject Item: GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler EU 002 SG202 - Medium Pressure Package Boiler EU 003 SG203 - High Pressure Package Boiler EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler EU 009 SP5 - Spreader Stoker Boiler EU 010 SP6 - Spreader Stoker Boiler EU 011 SP7 - Oil/Gas Package Boiler EU 161 Main Plant CHP Turbine EU 162 Main Plant CHP Duct Burner What to do EMISSION LIMITS Hydrochloric acid: less than or equal to 7 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period (emissions as Hydrogen Chloride) for emissions units within GP002. See requirements labeled Hydrogen Chloride Monitoring and Monthly Hydrogen Chloride Emissions Calculations below. Hexane: less than or equal to 7780 million cubic feet/year using 12-month Rolling Sum of natural gas to be calculated by the 15th day of each month for the previous 12-month period for emissions units within GP002. Use current emission factors from AP-42 and/or emission factors derived from MPCA-approved stack testing to calculate emissions. HAPs - Total: less than or equal to 15 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. HAP emissions for each fuel shall be calculated by use of current AP-42 emission factors based upon actual fuel usage and/or by use of emission factors derived from MPCA-approved stack testing. OPERATIONAL LIMITS Heat input from natural gas and approved biomass: Natural gas and approved biomass shall account for greater than or equal to 70% of the total fuel heat input to steam generators in GP002, based on a 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period. Approved biomass is defined within EU 001 and EU005. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. MONITORING REQUIREMENTS Hydrogen Chloride Monitoring: Determine hydrogen chloride emissions by collecting daily coal and/or biomass samples in an as-fired condition at the inlet to the steam generating units according to the procedures in GP008 for EU001, EU004, EU005,and EU found within GP002. Combine the samples into a monthly composite, and analyze the monthly composite for chlorine content. For all emission units that burn fuel oil, collect a fuel oil sample from the fuel oil storage tank after each delivery of fuel oil and analyze for chlorine and heating value. Instead of by fuel analyses, the Permittee may determine hydrogen chloride emissions from solid fuels at EU001 with an emission factor of lb HCl/ton fuel (the emission factor shall be adjusted if testing of any solid fuel indicates a fuel chlorine content greater than 1900 mg/kg or an HCl control efficiency less than 99%). The Permittee may propose HCl emission factors based on performance test results for other emission units. CALCULATIONS Monthly Hydrogen Chloride Emissions Calculations: Calculate monthly the amount of Hydrogen Chloride emitted from the emission units listed within GP002. For coal, fuel oil and biomass fuels, calculate emissions using the amount and type of fuel combusted, the heating value of the fuel combusted and the results of chlorine content sampling, and/or MPCA-approved emission factors derived from stack-testing results. Why to do it Title I Condition: Limit to avoid classification as a major source under 40 CFR Section 63.2 and Minn. R Title I Condition: Limit to avoid major source classification under 40 CFR Section 63.2 and Minn. R Title I Condition: Limit to avoid major source classification under 40 CFR Section 63.2 and Minn. R Minn. Stat. Section , subd. 4a Title I Condition: Limit to avoid major source classification under 40 CFR Section 63.2 and Minn. R Title I Condition: Limit to avoid major source classification under 40 CFR Section 63.2 and Minn. R

80 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-9 01/02/ Monthly Total HAPs Emissions Calculations: By the end of the previous operating day, calculate the amount of Hydrogen Chloride and Total HAPs emitted from the amount of fuel combusted in the emission units listed within GP002. Calculate emissions using current AP-42 emission factors or MPCA-approved stack-testing results. Calculate monthly the amount of Total HAPs emitted from the emission units listed within GP002. Calculate emissions using the amount and type of fuel combusted, the heat content of the fuel combusted, current AP-42 factors, and/or MPCA-approved emission factors derived from stack-testing results. Monthly Fuel Usage Calculations: By the 15th day of each month, the Permittee shall calculate the 12-month rolling sum value for natural gas usage within GP002 boilers (to ensure Hexane emissions are below major source threshold limits for a single HAP). RECORDKEEPING Daily Recordkeeping: By the end of the previous operating day,maintain records of the type, amount and heating value of each fuel combusted including clear indication of the type and quantity of any alternative biomass fired during a test burn. Recordkeeping: Maintain records of the monthly calculation for Heating Value limit, the hydrogen chloride limit, the fuel usage limit and the total HAPs limit. Recordkeeping: Maintain records of the sampling and analysis of coal and fuel oil for chlorine content. Title I Condition: Limit to avoid major source classification under 40 CFR Section 63.2 and Minn. R Title I Condition: To avoid classification as a major source under 40 CFR Section 63.2 and Minn. R. Title I Condition: To avoid classification as a major source under 40 CFR Section 63.2; Minn. R , subp. 4 and 5 Minn. R , subp. 4 and 5 Minn. R , subp. 4 and 5

81 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 003 Db Boilers - General and CEMS/COMS requirements A-10 01/02/ Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler EU 002 SG202 - Medium Pressure Package Boiler EU 003 SG203 - High Pressure Package Boiler EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) SV 001 SG201 - CFB Boiler SV 002 SG202/SG203 - Med/High Pressure Package Boilers SV 005 SG231 - Med. pressure package boiler (new St. Paul boiler) What to do Why to do it CONTINUOUS EMISSIONS MONITORING SYSTEM (CEMS) Continuous Operation: CEMS must be operated and data recorded during all 40 CFR Section 60.13(e), Minn. R , subp. 1 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. [EU001- Sulfur Dioxide and NOx CEMS; EU002, EU003 and EU006 - NOx CEMS, see EU level requirements] Excess Emissions/Downtime Reports (EERs): due 30 days after end of each Minn. R , subp. 1; 40 CFR Section 60.7(c) 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. QA Plan: Develop and implement a written quality assurance plan that covers each Minn. R , subp. 2; 40 CFR pt. 60, App. F; CEMS. The plan shall be on site and available for inspection within 30 days after section 3, Minn. R , subp. 1(C) monitor certification. The plan shall contain all of the information required by 40 CFR Section 60, App. F, section 3. CEMS QA/QC: The owner or operator of an affected facility is subject to the 40 CFR pt. 60, Appendix F; 40 CFR Section 60.13(a), performance specifications listed in 40 CFR 60, Appendix B and shall operate, Minn. R , subp. 1 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. CEMS Daily Calibration Drift Check: Permittees must automatically check the zero 40 CFR pt. 60, Appendix F, section 4.1; 40 CFR (low level value between 0 and 20 percent of span value) and span (50 to 100 Section 60.13(d)(1) regarding CEMS; Minn. R. percent of span value) calibration drifts at least once daily. The zero and span , subp. 3 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 shall be used to determine out-of-control periods for CEMS. Additional citation: Minn. R , subp. 1 Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEMS certification test. A CGA is not required during any calendar quarter in which a RATA was performed. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEMS Certification Test. Follow the procedures in 40 CFR pt. 60, Appendix F. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each Minn. R , subp.1 calendar quarter following Cylinder Gas Audit (CGA). Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS RATA. Minn. R , subp. 2 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calender quarter in which the CEMS RATA was conducted. 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. Monitoring Data: Reduce all NOx and SOx data to 1-hour averages, in accordance with 40 CFR Section 60.13(h). 1-hour averages shall be computed from four or more data points equally spaced over each 1-hour period. CONTINUOUS OPACITY MONITORING SYSTEM (COMS) 40 CFR pt. 60, Appendix F, section 5.1.2; Minn. R , subp. 4; Minn. R , subp. 1(C) 40 CFR pt. 60, Appendix F, section 5.1.1; Minn. R , subp. 5; Minn. R , subp. 1(C) Minn. R , subp. 3 Minn. R ; meets requirements of 40 CFR Section 60.7(f) 40 CFR Section 60.13(h) regarding continuous monitoring systems other than COMS.

82 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-11 01/02/ All COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. 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. Excess Emissions/Downtime Reports (EERs): due 30 days after end of each calendar quarter following initial startup of COMS. QA Plan Required: Develop and implement a written quality assurance plan which covers each COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain the written procedures listed in Minn. R , subp. 1. COMS 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 COMS according to the QA/QC procedures in Minn. R COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity. Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R , subp. 3. Attenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in Code of Federal Regulations, Title 40, Part 60, Appendix B, Section , within the time frame of opaciy stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be on site available for inspection. COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to 6 minute averages. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the 6 minute averaging period. 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 , subp. 1, 2 & 3; 40 CFR Section 60.13(e)(1) Minn. R , subp. 1; 40 CFR Section 60.13(e) Minn. R , subp. 1; 40 CFR Section 60.7(c) Minn. R CFR Section 60.13(a); Minn. R Minn. R , subp. 2; 40 CFR Section 60.13(d)(1) regarding COMS and 60.13(d)(2)[40CFR48(e)(2)] Minn. R , subp. 3 Minn. R , subp. 4 Minn. R Minn. R , subp. 2; 40 CFR Section 60.13(h) Minn. R

83 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 004 Boilers SG231 and SP7 - fuel oil usage limit A-12 01/02/ Associated Items: EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) EU 011 SP7 - Oil/Gas Package Boiler What to do Fuel Usage: less than or equal to 45,200 gallons/day of distillate fuel oil. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Daily Recordkeeping and Calculation: maintain a daily record of the amount of fuel oil combusted in these emission units and the sum of the amount used in each of the units daily. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Minn. R Minn. R Why to do it

84 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 005 CEMS req'd by state rule A-13 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 161 Main Plant CHP Turbine EU 162 Main Plant CHP Duct Burner SV 003 SE3 - Pulverized Coal Boiler SV 004 SE4 - Spreader Stoker Boiler SV 093 Main Plant CHP What to do 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. Why to do it Minn. R , subps. 1 and 2; Minn. R , supb. 10(A)-(C) Acceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R , subp. 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 pt. 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. The Commissioner may approve requested exclusions if the Commissioner determines that it is not reasonable to keep a specific part on-site after consideration of the consequences of a malfunction of the part, the likelihood of a malfunction, the time required to obtain the part, and other pertinent factors. CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily. The CEMS shall be adjusted whenever the CD exceeds twice the specification of 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CEMS. Follow the procedures in 40 CFR pt. 60, Appendix F. Cylinder Gas Audit (CGA): due before end of each calendar half-year following CEMS Certification Test. Conduct CGA at least 3 months apart and not greater than 8 months apart. Follow the procedures in 40 CFR pt. 60, Appendix F. CEMS Relative Accuracy Test Audit (RATA): due before end of each year starting 01/01/1997. If the relative accuracy is 15% or less the next CEMS RATA is not due for 24 months. Follow the procedures in 40 CFR pt. 60, Appendix B and Appendix F. Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after the end of each calendar quarter in which the CEMS Relative Accuracy Test Audit was conducted. Recordkeeping: The Permittee 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. The records may be maintained in either electronic or paper format, unless it is expressly prohibited. CEMS 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 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. Minn. R , subp. 2 Minn. R , subp. 3 Minn. R , subp. 4 Minn. R , subp. 5 Minn. R , subp. 3 Minn. R CFR Section 60.13(a); 40 CFR pt. 60, Appendix F; Minn. R

85 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers A-14 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler EU 009 SP5 - Spreader Stoker Boiler EU 010 SP6 - Spreader Stoker Boiler EU 011 SP7 - Oil/Gas Package Boiler SV 003 SE3 - Pulverized Coal Boiler SV 004 SE4 - Spreader Stoker Boiler SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers SV 007 SP7 - Oil/Gas Package Boiler What to do Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Acceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R , subp. 2. QA Plan Required: Develop and implement a written quality assurance plan which covers each COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain the written procedures listed in Minn. R , subp. 1. COMS 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 COMS according to the QA/QC procedures in Minn. R COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. The optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity. Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR 60.13(d)(2). COMS Calibration Error Audit: due before end of each calendar half-year following COMS Certification Test Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Conduct audits in accordance with Minn. R , subp. 3. Attenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in Code of Federal Regulations, Title 40, Part 60, Appendix B, Section , within the time frame of opaciy stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be on site available for inspection. COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. All COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data for each successive 6-minute period. COMS monitoring data: The owners or operators of all COMS shall reduce all data to 6-minute averages. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the 6-minute averaging period. 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. Why to do it Minn. R , subp. 1; 40 CFR Section 60.13(e) Minn. R , subp CFR Section 60.13(a); Minn. R Minn. R , subp. 2; 40 CFR Section 60.13(d)(l) regarding COMS and 60.13(d)(2) Minn. R , subp. 3 Minn. R , subp. 4 Minn. R Minn. R , subp. 1, 2 & 3; 40 CFR Section 60.13(e)(1); 40 CFR Section 60.13(h) Minn. R Minn. R

86 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 007 Low-temperature Fabric Filters (GP009, GP010, FS001) A-15 01/02/ Associated Items: CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 031 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 032 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 036 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 037 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 038 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 017 SE Plant Coal Receiving Hopper and Coneyor System with Two Transfer Points - Carter Day #1 EU 018 SE Plant Coal Receiving Hopper and Conveyor System with Three Transfer Points - Carter Day #2 EU 019 SE Plant Coal Conveyors with Six Transfer Points - F-111 Carter Day EU 020 SE Plant CFB Coal Handling - F-104 MAC EU 021 SE Plant Coal Transfer System with Three Transfer Points - F-109 EU 022 SE Plant Coal Transfer System with Three Transfer Points - F-110 EU 023 SE Plant Limestone Bin - F-202 EU 024 SE Plant Sand Bin - F-203 EU 025 SE Plant Lime Silo EU 026 SE Plant New Ash Silo - F-106 EU 027 SE Plant New Ash Silo Vent - F-108 EU 028 SE Plant Ash Silo EU 029 SE Plant Ash Silo Breather Vent EU 030 St. Paul Plant Ash Silo EU 031 St. Paul Plant Ash Silo Breather Vent EU 040 Coal Storage Bldg Exhaust FS 001 Southeast Coal and Biomass Bunker What to do Total Particulate Matter: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 99 percent. This limit applies to each unit individually. PM < 10 micron: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 99 percent. This limit applies to each unit individually. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R

87 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-16 01/02/ Visible Emissions: The Permittee shall check the associated fabric filter stacks (SV013-SV027, SV029) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Monitoring for Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R ; Minn. R , subp. 4 and 5 Title I Condition: Monitoring for Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R ; Minn. R , subp. 4 and 5 Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R ; Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

88 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 008 Boilers subject to coal sampling and analysis A-17 01/02/ Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler EU 009 SP5 - Spreader Stoker Boiler EU 010 SP6 - Spreader Stoker Boiler What to do Why to do it COAL SAMPLING AND ANALYSIS Coal Sampling: collect coal samples according to the most recent version of ASTM Minn. R , subp. 2 and 14 D-2234 as described following. Samples collected according to this methodology for EU001 may include allowable alternate fuels. Increment Sample Frequency: Collect a sample every 2 hours from each operating Minn. R , subp. 2 and 14 boiler from the coal scale for each boiler, by cutting (sweeping) the full width of the free-falling coal stream from the scale feeder belt. Increment Sample Size: the weight of each increment sample size shall be 2 lb. Minn. R , subp. 2 and 14 Gross Sample Preparation: Combine the gross samples from each operating boiler to make a total plant gross (composite) sample each day for each steam service facility. Crush and reduce the gross sample as specified in ASTM Method D 2013, Sample Preparation, to form the sample for laboratory analysis. Coal Analysis: analyze the composite sample daily for sulfur content using ASTM D 3177, moisture content using ASTM D 3173 and as-received heating value using ASTM D-2015 or D Minn. R , subp. 2 and 14 Minn. R , subp. 2 and 14

89 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 009 Coal handling operations A-18 01/02/ Associated Items: CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 038 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 017 SE Plant Coal Receiving Hopper and Coneyor System with Two Transfer Points - Carter Day #1 EU 018 SE Plant Coal Receiving Hopper and Conveyor System with Three Transfer Points - Carter Day #2 EU 019 SE Plant Coal Conveyors with Six Transfer Points - F-111 Carter Day EU 020 SE Plant CFB Coal Handling - F-104 MAC EU 021 SE Plant Coal Transfer System with Three Transfer Points - F-109 EU 022 SE Plant Coal Transfer System with Three Transfer Points - F-110 EU 040 Coal Storage Bldg Exhaust What to do EMISSION LIMITS Fugitive PM: Apply chemical binding agent during unloading and conveying of coal to stockpile. This limit applies to each unit individually. Total Particulate Matter: less than or equal to grains/dry standard cubic foot. This limit applies to each unit individually. Opacity: less than or equal to 20 percent opacity. This limit applies to each unit individually. POLLUTION CONTROL EQUIPMENT Operate and maintain low temperature fabric filters (CE023-CE028) at all times that any emission unit controlled by the fabric filters is in operation in accordance with the requirements of GP007. The Permittee shall document periods of non-operation of the control equipment. Why to do it Minn. R , subp. G, H Minn. R , subp. G(1) Minn. R , subp. G(2) Minn. R , subp. 2 and 14

90 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 010 Miscellaneous material handling operations A-19 01/02/ Associated Items: CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 031 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 032 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 036 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 037 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 023 SE Plant Limestone Bin - F-202 EU 024 SE Plant Sand Bin - F-203 EU 025 SE Plant Lime Silo EU 026 SE Plant New Ash Silo - F-106 EU 027 SE Plant New Ash Silo Vent - F-108 EU 028 SE Plant Ash Silo EU 029 SE Plant Ash Silo Breather Vent EU 030 St. Paul Plant Ash Silo EU 031 St. Paul Plant Ash Silo Breather Vent What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot if not required to meet the less stringent limit of either Minn. R or Minn. R Applies to each emissions unit individually. Opacity: less than or equal to 20 percent opacity. Applies to each emission unit individually. OPERATING LIMITS Operate and maintain low temperature fabric filters (CE029-CE037) at all times that any emission unit controlled by the fabric filters is in operation in accordance with the requirements of GP007. The Permittee shall document periods of non-operation of the control equipment. Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) Minn. R , subp. 2 and 14

91 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 011 Peaking Unit Generators: Pre-PSD (EU ) A-20 01/02/ Associated Items: EU GEN001 - Moos Tower-Reciprocating IC Engine EU GEN002 - Moos Tower-Reciprocating IC Engine EU GEN003 - Moos Tower-Reciprocating IC Engine What to do OPERATIONAL LIMITS Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. This limit applies to each unit individually. EMISSION LIMITS Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. This limit applies to each unit individually. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input. This limit applies to each unit individually. RECORDKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Why to do it Minn. R , subp. 2 Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 5

92 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 012 Peaking Unit Generators: Annual Limits to Avoid PSD A-21 01/02/ Associated Items: EU GEN003 - Phillips-Wang Bldg-Reciprocating IC Engine EU GEN002 - Washington Ave Ramp-Reciprocating IC Engine EU GEN001 - EE/Comp Sci Bldg-Reciprocating IC Engine EU GEN001 - Basic Science-Reciprocating IC Engine EU GEN002 - Basic Science-Reciprocating IC Engine EU GEN002-4th Street Switch-Reciprocating IC Engine EU GEN003-4th Street Switch-Reciprocating IC Engine EU GEN002 - Phillips-Wang Bldg-Reciprocating IC Engine What to do OPERATIONAL LIMITS Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. This limit applies to each unit individually. EMISSION LIMITS Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. This limit applies to each unit individually. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input. This limit applies to each unit individually. RECORDKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 1 Minn. R , subp. 2 Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subps. 4 & 5

93 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 013 Emergency Generators: Part of Netting A-22 01/02/ Associated Items: EU GEN001 - RR Weis Art Museum-Reciprocating IC Engine EU GEN001 - Aquaculture-Reciprocating IC Engine EU GEN001 - Williams Arena EU GEN001 - Lions Research Center-Reciprocating IC Engine EU GEN001 - Hockey Arena-Reciprocating IC Engine EU GEN001 - IWMF-Reciprocating IC Engine EU GEN001 - Magnetic Resonance Facility-Reciprocating IC Engine EU GEN001 - Middlebrook Hall-Reciprocating IC Engine EU GEN001-19th Ave Parking Ramp-Reciprocating IC Engine EU GEN001 - Carlson School-Reciprocating IC Engine EU GEN002 - Cancer Center-Reciprocating IC Engine What to do EMISSION LIMITS Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. This limit applies to each unit individually. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input. This limit applies to each unit individually. OPERATING CONDITIONS Fuel type: Natural gas/propane/no. 2 fuel oil only. Use a fuel type limit if you are basing compliance with the SO2 standards on the sulfur content of the fuel. Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. Applies to each unit individually. RECORDINGKEEPING REQUIREMENTS Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Why to do it Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 35a TItle I Condition: Limit to avoid classification as a major modification under 40 CFR Section and 40 CFR Section 51, Appenidix S; Minn. R , subp. 5 Minn. R , subps. 4 & 5

94 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 014 Boilers: Part of Netting A-23 01/02/ Associated Items: EU BO Magnetic Resonance Boiler EU BO Magnetic Resonance Boiler EU BO Ag Chemical Building-Boiler EU BO Ag Chemical Building-Boiler EU BO Magnetic Resonance Boiler EU BO IWMF-Boiler EU BO IWMF-Boiler EU BO Lions Research Center-Boiler EU BO Lions Research Center-Boiler EU BO Lions Research Center-Boiler What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input. This limit applies to each unit individually. Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input. This limit applies to each unit individually. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies to each unit individually. OPERATING CONDITIONS Fuel type: Natural gas only Operating Hours: less than or equal to 5840 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. RECORDINGKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Why to do it Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 35a TItle I Condition: Limit to avoid classification as a major modification under 40 CFR Section and 40 CFR Section 51, Appenidix S; Minn. R , subp. 5 Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R

95 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 015 Emergency Generators A-24 01/02/ Associated Items: EU GEN001 - MCB-Reciprocating IC Engine EU GEN002 - Translation Research-Reciprocating IC Engine EU GEN001 - Walter Library-Reciprocating IC Engine EU GEN001 - East River Ramp-Reciprocating IC Engine EU GEN001 - Phillips-Wang Bldg-Reciprocating IC Engine EU GEN002 - Phillips-Wang Bldg-Reciprocating IC Engine EU GEN001 - East River Ramp-Reciprocating IC Engine EU GEN001 - Archive EU GEN001 - MLAC EU GEN001 - MALG Facility EU GEN001 - Cargill Building - Microbial & Plant Genomics EU GEN001 - Plant Growth EU 146 Hanson Hall Generator-Reciprocating IC Engine EU 147 New 717 Delaware Generator-Reciprocating IC Engine EU 148 Existing 717 Delaware Generator-Reciprocating IC Engine EU 149 Northrop Auditorium Generator-Reciprocating IC Engine EU 150 TCF Stadium Generator-Reciprocating IC Engine EU 151 MBB Generator-Reciprocating IC Engine EU kw Portable Generator-Reciprocating IC Engine EU 153 STSS Center Generator-Reciprocating IC Engine EU 154 Cancer/Cardio Emergency Generator 1-Reciprocating IC Engine EU 158 Ambulatory Care Clinic Generator 1-Reciprocating IC Engine EU 159 Amublatory Care Clinic Generator 2-Reciprotcating IC Engine EU 160 MRF Generator-Reciprocating IC Engine EU 163 Main Plant Reciprocating IC Engine What to do Why to do it These requirements apply separately to each unit listed in GP 015 unless otherwise noted. Emergency generators modified or reconstructed after July 11, 2005, or 40 CFR Section (a)(2) & (3); Minn. R. manufactured after April 1, 2006 are subject to 40 CFR pt. 60, subp. IIII. These additional requirements are listed in GP 016, GP 017, and EU 163 depending on the specifications and model year of the emergency generator. Emergency generators located at an area source of HAPS are subject to 40 CFR 40 CFR Section ; Minn. R pt. 63, subp. ZZZZ. These additional requirements are listed in GP 016 and GP 017 depending on the specifications and model year of the emergency generator. EMISSION LIMITS Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input heat input. Minn. R , subp. 2 OPERATING LIMITS Fuel type: Natural gas or No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section (c) only. Sulfur Content of Fuel: less than or equal to 15 parts per million for NR diesel fuel. Cetane index or aromatic content: (i) a minimum cetane index of 40, or (ii) a maximum aromatic content of 35 volume percent. RECORDKEEPING REQUIREMENTS Minn. R , subp. 35a 40 CFR Section (c); Minn. R , subp. 35a

96 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Hours of Operation: The Permittee shall maintain documentation on site that the Minn. R , subps. 4 & 5 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. The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R , subp. 5 A-25 01/02/15 096

97 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 016 Emergency Generators: model year 2011 or later, Tier II A-26 01/02/ Associated Items: EU 153 STSS Center Generator-Reciprocating IC Engine EU 154 Cancer/Cardio Emergency Generator 1-Reciprocating IC Engine EU 158 Ambulatory Care Clinic Generator 1-Reciprocating IC Engine EU 159 Amublatory Care Clinic Generator 2-Reciprotcating IC Engine EU 160 MRF Generator-Reciprocating IC Engine What to do Why to do it These requirements apply to each unit listed in GP 016 unless otherwise noted. 40 CFR PT. 63, SUBP. ZZZZ REQUIREMENTS EU 153, EU 154, EU 158, EU 159, and EU 160 are new affected sources as 40 CFR Section (c); Minn. R defined under 40 CFR pt. 63, subp. ZZZZ, and the facility is an area source as defined at 40 CFR Section 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 EU 153, EU 154, EU 158, EU 159, and EU CFR PT. 60, SUBP. IIII REQUIREMENTS EMISSION LIMITS Exhaust opacity from compression-ignition nonroad engines for which this subpart is applicable must not exceed: (1) 20 percent during the acceleration mode; (2) 15 percent during the lugging mode; and (3) 50 percent during the peaks in either the acceleration or lugging modes. Carbon Monoxide: less than or equal to 3.5 grams/kilowatt-hour NMHC+NOx: less than or equal to 6.4 grams/kilowatt-hour Total Particulate Matter: less than or equal to 0.20 grams/kilowatt-hour Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieves these emission standards over the entire life of the engine. OPERATING LIMITS Sulfur Content of Fuel: less than or equal to 15 parts per million for NR deisel fuel. Cetane index or aromatic content: (i) a minimum cetane index of 40, or (ii) a maximum aromatic content of 35 volume percent. The Permittee must operate and maintain the engine 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 may only change those settings that are permitted by the manufacturer. The Permittee must also meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable. Compliance Demonstration: The Permittee must demonstrate compliance by purchasing an engine certified to conform with the emission standards listed in the emission limits above for the same model year and maximum engine power. The engine must be installed and configured according to manufacturer's specifications. 40 CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (b); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (c); 40 CFR Section (c); Minn. R ; Minn. R

98 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-27 01/02/ The Permittee must operate the emergency stationary ICE according to the requirements in 40 CFR Section (f)(2) through (3). In order for the engine to be considered an emergency stationary ICE under this 40 CFR pt. 60, subp. IIII, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section (f)(2) through (3), is prohibited. If the Permittee does not operate the engine according to the requirements in 40 CFR Section (f)(2) through (3), the engine will not be considered an emergency engine under 40 CFR pt. 60, subp. IIII and must meet all requirements for non-emergency engines. Operating Hours: less than or equal to 100 hours/year for any combination of the purposes specified in paragraphs 40 CFR Section (f)(2)(i) through (iii). Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) counts as part of the 100 hours per calendar year allowed by 40 CFR Section (f)(2). Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Operating Hours: less than or equal to 50 hours/year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2). Except as provided in 40 CFR Section (f)(3)(i), the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A. The engine is dispatched by the local balancing authority or local transmission and distribution system operator; B. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. C. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D. The power is provided only to the facility itself or to support the local transmission and distribution system. (continued below) (continued from above) E. Permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the Permittee. MONITORING REQUIREMENTS The engine shall contain a non-resettable hour meter prior to startup of engine. RECORDKEEPING REQUIREMENTS The Permittee shall maintain records of the operation of the engine in emergency service that is recorded through the non-resettable hour meter. The record must include the time of operation and the reason the generator was in operation during that time. 40 CFR Section (f); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(ii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(iii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (c); Minn. R ; Minn. R

99 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-28 01/02/ GENERAL PROVISIONS FOR NSPS IIII The Permittee shall comply with the General Provisions in 40 CFR Section 60.1 through 60.19, as applicable. General Provisions for 60.7(a)(4) and 60.7(b) are specified below. 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. NOTIFICATIONS (GENERAL PROVISIONS) 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. RECORDKEEPING (GENERAL PROVISIONS) 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. 40 CFR Section ; 40 CFR Pt. 60 Subp. IIII; 40 CFR Section (c); Minn. R ; Minn. R CFR Section 60.12; Minn. R CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(b); Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp. 1

100 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 017 Emergency Generators: model year after April 1, 2006 and before 2011, Tier II A-29 01/02/ Associated Items: EU 146 Hanson Hall Generator-Reciprocating IC Engine EU 147 New 717 Delaware Generator-Reciprocating IC Engine EU 150 TCF Stadium Generator-Reciprocating IC Engine EU 151 MBB Generator-Reciprocating IC Engine What to do Why to do it These requirements apply to each unit listed in GP 017 unless otherwise noted. 40 CFR PT. 63, SUBP. ZZZZ REQUIREMENTS EU 146, EU 147, EU 150, and EU 151 are new affected sources as defined under 40 CFR Section (c); Minn. R CFR pt. 63, subp. ZZZZ, and the facility is an area source as defined at 40 CFR Section 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 EU 146, EU 147, EU 150, and EU CFR PT. 63, SUBP. IIII REQUIREMENTS EMISSION LIMITS Exhaust opacity from compression-ignition nonroad engines for which this subpart is applicable must not exceed: (1) 20 percent during the acceleration mode; (2) 15 percent during the lugging mode; and (3) 50 percent during the peaks in either the acceleration or lugging modes. Carbon Monoxide: less than or equal to 3.5 grams/kilowatt-hour NMHC+NOx: less than or equal to 6.4 grams/kilowatt-hour Total Particulate Matter: less than or equal to 0.20 grams/kilowatt-hour Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieves these emission standards over the entire life of the engine. OPERATING LIMITS Sulfur Content of Fuel: less than or equal to 15 parts per million for NR deisel fuel. Cetane index or aromatic content: (i) a minimum cetane index of 40, or (ii) a maximum aromatic content of 35 volume percent. The Permittee must operate and maintain the engine 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 may only change those settings that are permitted by the manufacturer. The Permittee must also meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable. Compliance Demonstration: The Permittee must demonstrate compliance by purchasing an engine certified to conform with the emission standards listed in the emission limits above for the same model year and maximum engine power. The engine must be installed and configured according to manufacturer's specifications. The Permittee must operate the emergency stationary ICE according to the requirements in 40 CFR Section (f)(1) through (3). In order for the engine to be considered an emergency stationary ICE under this 40 CFR pt. 60, subp. IIII, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section (f)(1) through (3), is prohibited. If the Permittee does not operate the engine according to the requirements in 40 CFR Section (f)(1) through (3), the engine will not be considered an emergency engine under 40 CFR pt. 60, subp. IIII and must meet all requirements for non-emergency engines. 40 CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (b); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (c); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f); 40 CFR Section (c); Minn. R ; Minn. R

101 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-30 01/02/ There is no time limit on the use of emergency stationary ICE in emergency situations. Operating Hours: less than or equal to 100 hours/year for any combination of the purposes specified in paragraphs 40 CFR Section (f)(2)(i) through (iii). Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) counts as part of the 100 hours per calendar year allowed by 40 CFR Section (f)(3). Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Operating Hours: less than or equal to 50 hours/year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2). Except as provided in 40 CFR Section (f)(3)(i), the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A. The engine is dispatched by the local balancing authority or local transmission and distribution system operator; B. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. C. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D. The power is provided only to the facility itself or to support the local transmission and distribution system. (continued below) (continued from above) E. Permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the Permittee. MONITORING REQUIREMENTS The engine shall contain a non-resettable hour meter prior to startup of engine. GENERAL PROVISIONS FOR NSPS IIII The Permittee shall comply with the General Provisions in 40 CFR Section 60.1 through 60.19, as applicable. General Provisions for 60.7(a)(4) and 60.7(b) are specified below. 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. NOTIFICATIONS (GENERAL PROVISIONS) 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 Section (f)(1); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(ii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(iii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Pt. 60 Subp. IIII 40 CFR Section (c); Minn. R ; Minn. R CFR Section 60.12; Minn. R CFR Section 60.7(a)(4); Minn. R , subp. 1

102 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-31 01/02/ RECORDKEEPING REQUIREMENTS (GENERAL PROVISIONS) 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. 40 CFR Section 60.7(b); Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp. 1

103 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP CEMS Monitoring Requirements A-32 01/02/ Associated Items: CE 044 SCR (Selective Catalytic Reduction) CE 045 Catalytic Converter EU 161 Main Plant CHP Turbine EU 162 Main Plant CHP Duct Burner SV 093 Main Plant CHP What to do All continuous monitoring systems (CMS) required shall be subject to the provisions of performance specifications for CMS under 40 CFR pt. 60, Appendix B and, if the CMS is used to demonstrate compliance with emission limits on a continuous basis, 40 CFR pt. 60, Appendix F, unless otherwise specified in an applicable subpart or by the Administrator. All continuous monitoring systems and monitoring devices shall be installed and operational prior to conducting performance tests under 40 CFR Section Verification of operational staus shall, as a minimum, include completion of the manufacturer's written requirements or recommendations for installation, operation and calibration. Except as provided in 40 CFR Section 60.13(c)(1), the Permittee shall furnish the Administrator within 60 days of completion two or, upon request, more copies of a written report of the results of the performance evaluation. The Permittee must check the zero (or low level value between 0 and 20% of span value) and span (50 to 100% of span value) calibration drifts at least once daily in accordance with a written procedure. The zero and span must, as a minimum, be adjusted whenever either the 24-hour zero drift or the 24-hour span drift exceeds two times the limit of the applicable performance specification in 40 CFR pt. 60, Appendix B. The system must allow the amount of excess zero and span drift to be recorded and quantified whenever specified. Except for system breakdowns, repairs, calibration checks and zero and span adjustments required under 40 CFR Section 60.13(d), all continuous monitoring systems shall be in continuous operation and shall meet minimum frequency of operation requirements as follows: All CMS referenced by 40 CFR Section 60.13(c) for measuring emissions, except opacity, shall complete a minimum of one cycle of operation (sampling, analyzing and data recording) for each successive 15-minute period. All continuous monitoring systems or monitoring devices shall be installed such that representative measurements of emissions or process parameters from the affected facility are obtained. Additional procedures for location of continuous monitoring systems contained in the applicable Performance Specifications of 40 CFR pt. 60, Appendix B shall be used. i) Except as provided under 40 CFR Section 60.13(h)(2)(iii), for a full operating hour (any clock hour with 60 minutes of unit operation), at least four valid data points are required to calculate the hourly average, i.e. one data point in each of the 15-minute quadrants of the hour. ii) Except as provided under 40 CFR Section 60.13(h)(2)(iii), for a partial operating hour (any clock hour with less than 60 minutes of unit operation), at least one valid data point in each 15-minute quadrant of the hour in which the unit operates is required to calculate the hourly average. iii) For any operating hour in which required maintenance or quality assurance activities are performed: A) If the unit operates in two or more quadrants of the hour, a minimum of two valid data points, separated by at least 15 minutes, is required to calculate the hourly average, or B) if the unit operates in only one quadrant of the hour, at least one valid data point is required to calculate the hourly average. Why to do it 40 CFR Section 60.13(a); Minn. R CFR Section 60.13(b); Minn. R CFR Section 60.13(c)(2); Minn. R CFR Section 60.13(d)(1); Minn. R CFR Section 60.13(e); Minn. R CFR Section 60.13(f); Minn. R CFR Section 60.13(h)(2)(i)-(iii); Minn. R

104 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-33 01/02/ iv) If a daily calibration error check is failed during any operating hour, all data for that hour shall be invalidated, unless a subsequent calibration error test is passed in the same hour and the requirements of 40 CFR Section 60.13(h)(2)(iii) are met, based solely on valid data recorded after the successful calibration. v) For each full or partial operating hour, all valid data points shall be used to calculate the hourly average. vi) Except as provided under 40 CFR Section 60.13(h)(2)(vii), data recorded during periods of continuous monitoring system breakdown, repair, calibration checks and zero and span adjustments shall not be included in the data averages computed under this paragraph. vii) Permittee complying with the requirements of 40 CFR Section 60.7(f)(1) or (2) must include any data recorded during periods of monitor breakdown or malfunction in the data averages. viii) When specified in an applicable subpart, hourly averages for certain partial operating hours shall not be computed or included in the emission averages (e.g. hours with < 30 minutes of unit operation under 40 CFR Section 60.47b(d)). ix) Either arithmetic or integrated averaging of all data may be used to calculate the hourly averages. The data may be recorded in reduced or nonreduced form (e.g. ppm pollutant and percent O2 or ng/j of pollutant). All excess emissions shall be converted into units of the standard using the applicable conversion procedures specified in the applicable subpart. After conversion into units of the standard, the data may be rounded to the same number of significant digits used in the applicable subpart to specify the emission limit. 40 CFR Section 60.13(h)(2)(iv) -(vii); Minn. R CFR Section 60.13(h)(2)(viii) -(ix); Minn. R CFR Section 60.13(h)(3); Minn. R

105 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 019 Main CHP Turbine and Duct Burner A-34 01/02/ Associated Items: CE 044 SCR (Selective Catalytic Reduction) CE 045 Catalytic Converter EU 161 Main Plant CHP Turbine EU 162 Main Plant CHP Duct Burner MR 004 Main CHP Fuel Flow Meter SV 093 Main Plant CHP What to do A. EMISSION LIMITS Nitrogen Oxides: less than or equal to 35.0 tons/year using 12-month Rolling Sum. For the first 12 months, after initial certification of the NOx CEMs, NOx emissions are limited as determined by the following equation: Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R E = 35.0 x [ (N/12)] where E = NOx emissions in total tons N = number of months after the limit is effective Nitrogen Oxides: less than or equal to 25 parts per million at 15 percent O2 or 150 ng/j of useful output (1.2 lb/mwh) while combusting natural gas. Nitrogen Oxides: less than or equal to 74 parts per million at 15 percent O2 or 460 ng/j of useful output (3.6 lb/mwh) while combusting ULSD oil. Nitrogen Oxides: less than or equal to 4.0 parts per million at 15 percent O2 while combusting natural gas. This limit does not apply during startup, shutdown or malfunctions. Nitrogen Oxides: less than or equal to 9.0 parts per million at 15 percent O2 while combusting ULSD oil. This applies to the turbine (EU161) when the duct burner (EU162) is not in operation. This limit does not apply during startup, shutdown or malfunctions. Nitrogen Oxides: less than or equal to 6.0 parts per million at 15 percent O2 while combusting ULSD oil. This applies when both the turbine (EU161) and the duct burner (EU162) are in operation. This limit does not apply during startup, shutdown or malfunctions. Carbon Monoxide: less than or equal to 90.0 tons/year using 12-month Rolling Sum. For the first 12 months, after initial certification of the CO CEMs, CO emissions are limited as determined by the following equation: 40 CFR Section (a) and 40 CFR pt. 60, subp. KKKK, Table 1 40 CFR Section (a) and 40 CFR pt. 60, subp. KKKK, Table 1 Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R E = 90.0 x [ (N/12)] where E = CO emissions in total tons N = number of months after the limit is effective Carbon Monoxide: less than or equal to 20.0 parts per million at 15 percent O2. This limit does not apply during startup, shutdown or malfunctions. Sulfur Dioxide: less than or equal to lbs/million Btu heat input at 15 percent oxygen Ammonia: less than or equal to 5.0 parts per million at 15 percent O2. This limit does not apply during startup, shutdown or malfunctions. B. OTHER LIMITS AND REQUIREMENTS Permitted Fuel Types: Pipeline natural gas, as defined in 40 CFR Section 72.2, except that total sulfur content shall not exceed 20 grains/100 scf, or ultra-low sulfur distillate oil (ULSD) with a maximum total sulfur content not to exceed 15 parts per million, by weight. Recordkeeping - NOx Emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of NOx emitted during the previous calendar month, and the tons of NOx emitted during the previous 12-month period. Separate monthly and 12-month rolling sum records shall be maintained. Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R CFR Section (a)(2) Title I Condition: to avoid classifiation as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R

106 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-35 01/02/ Recordkeeping - CO Emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of CO emitted during the previous calendar month, and the tons of CO emitted during the previous 12-month period. Separate monthly and 12-month rolling sum records shall be maintained. Recordkeeeping: The Permittee shall shall maintain records verifying the use of pipeline natural gas, as defined in 40 CFR Section Normal business records may be utilized for this purpose. Fuel Usage: less than or equal to gallons/year using 12-month Rolling Sum of ultra-low sulfur distillate oil. Recordkeeping - Fuel Oil Usage: By the end of the following operating day, the Permittee shall calculate and record the number of gallons that the turbine (EU161) and duct burner (EU162) combusted, during the previous calendar day. Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R By the 15th day of each month, the Permittee shall calculate and record the total fuel oil usage (in gallons) for the turbine (EU161) and duct burner (EU162), for the previous calendar month and previous 12-month period. Separate daily, monthly and 12-month recordkeeping shall be maintained on-site. Control Equipment Operation: After completion of the EU161/162 startup, the Permittee shall control NOx with selective catalytic reduction (CE 044) and the CO with a catalytic oxidizer (CE 045). The Permittee shall operate and maintain the turbine, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown, and malfunction. C. CEMS REQUIREMENTS FOR CO AND NOx Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R CFR Section See additional, applicable CEMS Requirements in GP 005. Emissions Monitoring: The Permittee shall install, calibrate, operate and maintain NOx and O2 continuous emissions monitoring system (CEMS) in accordance with 40 CFR pt. 60, Appendix B and Appendix F. Emissions Monitoring: The Permittee shall install, calibrate, operate and maintain CO and O2 continuous emissions monitoring system (CEMS) in accordance with 40 CFR pt. 60, Appendix B and Appendix F. Calculation: The Permittee shall calculate valid hourly average emissions from CEMS. CO and NOx Emission Monitoring: The Permittee shall use a CO CEMS and NOx CEMS to measure CO and NOx emissions from SV 093. D. CMS REQUIREMENT Fuel Flowrate: The Permittee shall calibrate, operate, and maintain a continuous monitoring system (CMS) that records the fuel flowrate at each fuel combustion device (EU161 and EU162). CMS QA/QC: The Permittee shall follow manufacturer recommendations for preventative maintenance and periodic monitoring to ensure CMS reliability, including but not limited to annual calibrations for fuel gas flow meters. E. O2 MONITOR REQUIREMENTS QA Plan: Develop and implement a written quality assurance plan that covers the O2 Monitor. 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 pt. 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. The Commissioner may approve requested exclusions if the Commissioner determines that it is not reasonable to keep a specific part on-site after consideration of the consequences of a malfunction of the part, the likelihood of a malfunction, the time required to obtain the part, and other pertinent factors. O2 QA/QC: The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain the O2 monitor 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. Title I Condition: To avoid classification as a major modification under 40 CFR Section and Minn. R ; 40 CFR Section (b)(1); Minn. R Title I Condition: To avoid classification as a major modification under 40 CFR Section and Minn. R ; Minn. R Minn. R , subps. 1, 2 & 3 Minn. R Title I Condition: to avoid classification as a major modification under 40 CFR Section and Minn. R Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 4

107 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-36 01/02/ F. MONITORING REQUIREMENTS See additional, applicable Monitoring Requirements in GP 005 and GP 018. Certification test procedure: The CO CEMS must be certified according to the appropriate performance specifications listed in Code of Federal Regulations, title 40, part 60, Appendix B. The certification test shall also be conducted in accordance with the certification test plan approved by the Commissioner. Minn. R , subp. 1 The Permittee shall conduct and complete certification testing within 90 days after the due date of the first excess emissions report required for the NOx and CO CEMS. Each NOx diluent CEMS must be installed and certified according to Performance Specification 2 (PS 2) in 40 CFR pt. 60, Appendix B, except the 7-day calibration drift is based on unit operating days, not calendar days. With state approval, Procedure 1 in 40 CFR pt. 60, Appendix F is not required. Alternatively, a NOx diluent CEMS that is installed and certified according to 40 CFR pt. 75, Appendix A is acceptable for use. The relative accuracy test audit (RATA) of the CEMS shall be performed on a lb/mmbtu basis. As specified in 40 CFR Section 60.13(e)(2), during each full unit operating hour, both the NOx monitor and the diluent monitor must complete a minimum of one cycle of operation (sampling, analyzing and data recording) for each 15-minute quadrant of the hour, to validate the hour. For partial unit operating hours, at least one valid data point must be obtained with each monitor for each quadrant of the hour in which the unit operates. For unit operating hours in which required quality assurance and maintenance activities are performed on the CEMS, a minimum of two valid data points (one in each of two quadrants) are required for each monitor to validate the NOx emission rate for the hour. Each fuel flowmeter shall be installed, calibrated, maintained, and operated according to the manufacturer's instructions. Alternatively, with state approval, fuel flowmeters that meet the installation, certification and quality assurance requirements of 40 CFR pt. 75, Appendix D are acceptable for use. Each watt meter, steam flow meter and pressure or temperature measurement device shall be installed, calibrated, maintained and operated according to the manufacturer's instructions. The ammonia measurement device shall be installed, calibrated, maintained and operated according to the manufacturer's instructions. The ammonia measurement device shall be installed, calibrated, maintained and operated according to the manufacturer's instructions. The Permittee shall develop and keep on-site a quality assurance (QA) plan for all of the continuous monitoring equipment described in 40 CFR Section (a), (c) and (d). For the CEMS and fuel flow meters, the Permittee may, with state approval, satisfy the requirements of 40 CFR Section (e) by implementing the QA program and plan described in section 1 of 40 CFR pt. 75, Appendix B. The Permittee shall use the calculated hourly average emission rates from 40 CFR Section (f) to assess excess emissions on a 30 unit operating day rolling average basis. A "30-day rolling average NOx emissions rate" is the arithmetic average of all hourly NOx emission data in ppm or ng/j measured by the continuous emission monitoring equipment for a given day and the twenty-nine unit operating days immediately preceding that unit operating day. A new 30-day average is calculated each unit operating day as the average of all hourly NOx emissions rates for the preceding 30 unit operating days if a valid NOx emission rate is obtained for at least 75 percent of all operating hours. The Permittee shall demonstrate with a current, valid purchase contract, tariff sheet or transportation contract for the fuel that the maximum total sulfur content is less than or equal to weight percent (15 ppmw) for ultra-low sulfur distillate oil. The Permittee shall demonstrate with a current, valid purchase contract, tariff sheet or transportation contract for the fuel that the maximum total sulfur content is either: 1) less than or equal to 0.05 weight percent (500 ppmw) for oil, or 2) less than or equal to 20 grains of sulfur per 100 standard cubic feet for natural gas. G. PERFORMANCE TESTING REQUIREMENTS Minn. R , subp CFR Section (a) 40 CFR Section (b) 40 CFR Section (c) 40 CFR Section (d) Minn. R , subps. 4 & 5 Minn. R CFR Section (e) 40 CFR Section (h); 40 CFR Section (b)(1) Minn. R , subp CFR Section

108 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-37 01/02/ Within 60 days after achieving the maximum production rate, but not later than 180 days after initial startup, the initial NOx performance test required under 40 CFR Section 60.8 may be performed in the following alternative manner: a) Perform a minimum of nine RATA reference method runs, with a minimum time per run of 21 minutes, at a single load level, within plus or minus 25% of 100% peak load. The ambient temperature must be greater than 0 degree F during the RATA runs. b) For each RATA run, concurrently measure the heat input to the unit using a fuel flow meter (or flow meters) and measure the electrical and thermal output from the unit. Continued 40 CFR Section ; 40 CFR Section 60.8(a) 40 CFR Section c) Use the test data both to demonstrate compliance with the applicable NOx emisson limit and to provide the required reference method data for the RATA of the CEMS described under 40 CFR Section d) Compliance with the applicable emission limit is achieved if the arithmetic average of all of the NOx emission rates for the RATA runs, expressed in ppm or lb/mwh, does not exceed the emission limit. H. REPORTING REQUIREMENTS The Permittee must submit reports of excess emissions and monitor downtime, in accordance with 40 CFR Section 60.7(c). Excess emissions must be reported for all periods of unit operation, including start-up, shutdown and malfunction. The Permittee shall submit a notification of any physical or operational change which increases the emission rate: due 60 days (or as soon as practical) before the change is commenced. The Permittee 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 (CMS) or monitoring device is inoperative. The Permittee shall submit excess emissions and monitoring systems performance report and/or summary form to the Administrator semiannually except when: more frequent reporting is required by an applicable subpart; or the Administrator on a case-by-case basis, determines that more frequent reporting is necessary. All reports shall be postmarked by the 30th day following the end of each six-month period and shall include the information in 40 CFR Section 60.7(c)(1) through (4). The summary report form shall contain the information in figure 1 of 40 CFR Section One summary report form shall be submitted for each pollutant monitored at each affected facility. If the total duration of excess emissions is less than 1% of the total operating time and CMS downtime is less than 5% of the total operating time, only the summary report form shall be submitted. 40 CFR Section CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(b); Minn. R , subp CFR Section 60.7(c); 40 CFR Section ; Minn. R , subp CFR Section 60.7(d); Minn. R , subp. 1 If the total duration of excess emissions is 1% or greater of the total operating time or CMS downtime is 5% or greater of the total operating time, the summary report form and the excess emission report described in 40 CFR Section 60.7(c) shall both be submitted. The Permittee shall 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. The file shall be retained for at least two years following the date of such measurements, maintenance, reports and records except as described in paragraphs (1) and (2) of 40 CFR Section 60.7(f). If notification substantially similar to that in 40 CFR Section 60.7(a) is required by any other State or local agency, sending the Administrator a copy of that notification will satisfy the requirements of 40 CFR Section 60.7(a). Individual subparts of 40 CFR pt. 60 may include specific provisions which clarify or make inapplicable the provisions set forth in this section. At all times, including periods of startup, shutdown and malfunction, the Permittee shall, to the extent possible, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether aceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures and inspection of the source. 40 CFR Section 60.7(f); Minn. R , subp CFR Section 60.7(g); Minn. R , subp CFR Section 60.7(h); Minn. R , subp CFR Section 60.11(d); Minn. R

109 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. A CFR Section 60.11(g); Minn. R /02/15 109

110 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: GP 020 Limited Use Boilers A-39 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler EU 005 SE4 - Spreader Stoker Boiler EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler EU 009 SP5 - Spreader Stoker Boiler EU 010 SP6 - Spreader Stoker Boiler APPLICABILITY What to do Why to do it 40 CFR Section (b) Requirements under 40 CFR pt. 63, Subpart JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers Area Sources Enforcement not delegated to MPCA. OPERATIONAL REQUIREMENTS At all times, the Permittee must operate and maintain affected boilers, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. 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. The Permittee must have a one-time energy assessment performed by a qualified energy assessor in accordance with 40 CFR Section (b). The energy assessment must include: 1) A visual inspection of the boiler system; 2) An evaluation of operating characteristics of the boiler systems, specifications of energy using systems, O&M procedures, and unusual operating constraints; 3) An inventory of major energy use systems consuming energy from affected boiler(s) which are under control of the Permittee; 4) A review of available plans, facility operation and maintenance procedures and logs, and fuel usage; 5) A list of major energy conservation measures that are within the facility's control; 6) A list of the energy savings potential of the energy conservation measures identified; and 7) A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. The Permittee shall conduct an initial tune-up by March 21, 2014 by following the procedures described in 40 CFR Section (b). The Permittee must conduct a tune-up for each boiler every 5 years as specified in 40 CFR Sections and and keep records as required in 40 CFR Section (c) to demonstrate continuous compliance. The tune-up must be conducted while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. The Permittee must conduct a tune-up of the boiler every 5 years no more than 61 months after the previous tune-up, to demonstrate continuous compliance as specified in (1) through (7) as follows: (1)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, not to exceed 72 months from the previous inspection). (2)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. (continued below) 40 CFR Section (a) 40 CFR Section (b); 40 CFR Section 63, subp. JJJJJJ, Table 2 40 CFR Section ; 40 CFR pt. 63, subp. JJJJJJ, Table 2 40 CFR Section (b); 40 CFR Section (a); 40 CFR Section 63, subp. JJJJJJ, Table 2 40 CFR Section (b) and (c)

111 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-40 01/02/ (continued from above) 40 CFR Section (b) (3)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, not to exceed 72 months from the previous inspection). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 72 months from the previous inspection. (4)Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. (continued below) (continued from above) 40 CFR Section (b) (5)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. (6)Maintain on-site and submit, if requested by the Administrator, a report containing the information in (i) through (iii) as follows: (i)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. (ii)a description of any corrective actions taken as a part of the tune-up of the boiler. (continued below) (continued from above) (iii)the type and amount of fuel used over the 12 months prior to the tune-up of the boiler, 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 use by each unit. (7)If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. The standards in 40 CFR Section apply at all times the affected boilers are operating, except during periods of startup and shutdown as defined in 40 CFR Section , during which time the Permittee must comply only with 40 CFR pt. 63, subp. JJJJJJ, Table 2. The Permittee must comply with the General Provisions as applicable in Table 8 of 40 CFR pt. 63, subp. JJJJJJ. RECORDKEEPING The Permittee must maintain the following records: (1)A copy of each notification and report that was submitted to comply with 40 CFR pt. 63, subp. JJJJJJ, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted, as required by 40 CFR Section 63.10(b)(2)(xiv); (2)Records to document conformance with 40 CFR Sections and as specified as follows: (i)records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. (iii)for each boiler required to conduct an energy assessment, the Permittee must keep a copy of the energy assessment report. (vi) The Permittee must keep a copy of the federally enforceable permit that limits the annual capacity factor to less than or equal to 10 percent and records of fuel use for the days the boiler is operating. (continued below) (continued from above) 40 CFR Section (b) 40 CFR Section (d) 40 CFR Section ; 40 CFR pt. 63 subp. JJJJJJ, Table 8 40 CFR Section (c) 40 CFR Section (c) (4)Records of the occurrence and duration of each malfunction of each boiler or of the associated air pollution control and monitoring equipment. (5)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), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. (continued below)

112 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-41 01/02/ Records must be in a form suitable and readily available for expeditious review. The Permittee must keep each record for 5 years following the date of each recorded action. The Permittee must keep each record on-site or be accessible from a central location by computer or other means that instantly provide access at the site for at least 2 years after the date of each recorded action. The Permittee may keep the records off site for the remaining 3 years. REPORTING AND NOTIFICATION REQUIREMENTS Initial Notification: due within 120 days after the source becomes subject to 40 CFR pt. 63, subp. JJJJJJ. The Permittee must prepare by March 1, and submit to the Administrator upon request, a 5 year compliance certification report for the previous 5 year period containing the information described below. The Permittee must submit the compliance report by March 15 if the Permittee had any instance described by item 3 below. (1)Company name and address (2)Statement by a responsible official, with the official's name, title, phone number, address, and signature, certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of 40 CFR pt. 63, subp. JJJJJJ. The notification must include the following certifications of compliance, as applicable, and signed by a responsible official: (i)"this facility complies with the requirements in 40 CFR Section to conduct a 5 year tune-up, as applicable, of each boiler." (continued below) (continued from above) 40 CFR Section (d) 40 CFR Section (a)(2) 40 CFR Section (b) 40 CFR Section (b) (ii) "This facility complies with the requirement in 40 CFR Section (d) to minimize the boiler's time spent during startup and shutdown and to conduct startups and shutdowns according to the manufacturer's recommended procedures or procedures specified for a boiler of similar design if manufacturer's recommended procedures are not available." Notification of compliance status: due 120 days after March 21, The notification must include the following certifications of compliance, as applicable and signed by a responsible official: (i)the Permittee must submit the information required in 40 CFR Section 63.9(h)(2), except the information listed in 40 CFR Section 63.9(h)(2)(i)(B), (D), (E) and (F). (continued below) (continued from above) (ii)"this facility complies with the requirements in 40 CFR Section to conduct an initial tune-up of the boiler." (iii)"this facility has had an energy assessment performed according to 40 CFR Section (c)." (vi)the notification must be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX). However, if the reporting form specific to 40 CFR pt. 63, subp. JJJJJJ is not available in CEDRI at the time that the report is due, the written Notification of Compliance Status must be submitted to the Administrator at the appropriate address listed in 40 CFR Section The Permittee must conduct a performance tune-up according to 40 CFR Section (b) and submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the boiler. The Permittee must submit all of the notifications in 40 CFR Sections 63.7(b); 63.8(e) and (f); 63.9(b) through (e), (g) and (h) that apply by the dates specified in those sections except as specified in 40 CFR Section (a)(2) and (4). Subpart A General Provisions Prohibited activities: 40 CFR Section (a)(4); 40 CFR (c) 40 CFR Section (a)(4); 40 CFR (c) 40 CFR Section (b) 40 CFR Section (a)(1) 40 CFR Section 63.4(a); Minn. R (1) No owner or operator subject to the provisions of 40 CFR pt. 63 shall operate any affected source in violation of the requirements of 40 CFR pt. 63. (2) No owner or operator subject to the provisions of this part shall fail to keep records, notify, report, or revise reports as required under this part.

113 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Circumvention. No owner or operator subject to the provisions of 40 CFR pt. 63 shall 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; A CFR Section 63.4(b); Minn. R /02/ (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. Fragmentation after November 15, 1990 which divides ownership of an operation, within the same facility among various owners where there is no real change in control, will not affect applicability. The owner and operator must not use fragmentation or phasing of reconstruction activities (i.e., intentionally dividing reconstruction into multiple parts for purposes of avoiding new source requirements) to avoid becoming subject to new source requirements. 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 Section 63.4(c); Minn. R CFR Section 63.10(b)(1) ; Minn. R

114 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 001 SG201 - CFB Boiler A-43 01/02/ Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler GP 001 New and modified boilers (annual limits to avoid mod) GP 003 Db Boilers - General and CEMS/COMS requirements What to do EMISSION LIMITS Carbon Monoxide: less than or equal to lbs/million Btu heat input and less than or equal to lb/hr as a 1-hr average. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Sulfur Dioxide: less than or equal to 0.38 lbs/million Btu heat input and less than or equal to 96.1 lb/hr as determined by a CEMS as a 1-hour average when combusting coal. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Nitrogen Oxides: less than or equal to lbs/million Btu heat input and less than or equal to lb/hr as determined by a CEMS as a 30-day rolling average. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 08/21/2003 (next test on or before 8/21/08) to verify emission factors for PM, PM10, CO and VOC emissions within GP001. Also, to verify compliance with CO limit set within SV001. PERFORMANCE TESTING - OAT HULLS Oat Hull Performance Test: due 60 days after achieving the maximum oat hull firing rate, but no later than 180 days after initial startup of the biomass truck unloading station, biomass storage silo, and biomass transfer system to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Oat Hull Performance Test Notification and Submittals; Performance Test Notification (written): due 30 days before Performance Test Performance Test Plan: due 30 days before Performance Test Performance Test Pre-Test Meeting: due 7 day before Performance Test Performance Test Report: due 45 days after Performance Test Performance Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Revised PSD Analysis based on Oat Hull Performance Test: Within 60 days of submitting the Oat Hull Performance Test Report, the Permittee shall perform a revised PSD analysis based on the results of the performance test. If the results of the analysis continue to demonstrate that projected actual emission do not exceed baseline actual emissions for any regulated NSR pollutant by a significant amount, the Permittee may burn oat hulls up to the tested rate and shall maintain records of the revised PSD analysis. If the results of the analysis demonstrate that a significant emissions increase would occur, the Permittee may not operate the biomass truck unloading station, biomass storage silo, and biomass transfer system without obtaining a permit amendment in compliance with Minn. R through Minn. R ALTERNATIVE BOIMASS FUEL TESTING AND SUBMITTALS Alternative Biomass Fuel Testing Authorization: The Permittee is authorized to conduct test burns of the following alternative biomass fuels: agricultural crops; herbs, nuts, by-products or waste; vegetable oils, by-products or waste; crop field residue or field processing by-products; shells, husks, seed, dust, screenings and other agricultural by-products; cultivated grasses or grass by-products; wood, wood waste including wood processing by-products; and leaves. Acceptable biomass fuels do not include peat, wood that has been painted, stained or pressure treated, waste oil, farm chemicals, pesticide containers, demolition waste except for wood, waste from farms from an open dump, tire derived fuels, non-agricultural industrial process wastes, animal manures and wastes, or any material meeting the definition of a hazardous waste. Alternative Biomass Fuel Testing Restrictions: Test burns for any potential biomass fuel shall be limited to 4,000 tons, no more than 45 days of operation using the fuel, and a test period not to exceed 180 days. 6 Minn. R Minn. R Minn. R Why to do it Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2 Title I Condition: Limit to avoid major modification under 40 CFR Section 52.21; Minn. R through Minn. R Minn R , subp. 2 Minn R , subp. 2

115 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-44 01/02/ Alternative Biomass Fuel Testing Requirements: Test burns shall be conducted to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Alternative Biomass Fuel Testing Submittals: 30 days prior to testing of a biomass fuel, the Permittee shall submit a written performance test notification and test plan. The test plan shall meet the requirements of Minn. R and shall also include the type(s) and estimated amount of biomass to be tested, 2) operating parameters and anticipated fuel mixes during testing for the boiler to be tested, 3) air pollutants that will be monitored and measured during testing, and 4) a testing schedule. Alternative Biomass Fuel Testing Notification and Submittals; Pre-Test Meeting: due 7 day before Performance Test Test Report: due 45 days after Performance Test Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Minn R , subp. 2 Minn. R , subp. 1-4; Minn. R Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2

116 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 002 SG202/SG203 - Med/High Pressure Package Boilers A-45 01/02/ Associated Items: EU 002 SG202 - Medium Pressure Package Boiler EU 003 SG203 - High Pressure Package Boiler GP 001 New and modified boilers (annual limits to avoid mod) GP 003 Db Boilers - General and CEMS/COMS requirements What to do Why to do it EMISSION LIMITS Sulfur Dioxide: less than or equal to lbs/hour using 3-hour Block Average as Minn. R determined by fuel oil vendor certification. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. This limit applies to simultaneous operation of boilers EU002 and EU003. Nitrogen Oxides: less than or equal to lbs/million Btu heat input using 30-day Minn. R ; most stringent limit, meets Rolling Average for simultaneous operation of both boilers and less than or equal to requirements of 40 CFR Section 60.44b(a) lb/hr for EU002 and less than or equal to lb/hr for EU003 for all fuels and fuel combinations as determined by CEMS (NOx CEMS required under EU002 and EU003). Carbon Monoxide: less than or equal to lbs/million Btu heat input using Minn. R Hour Average for simultaneous operation of both boilers and less than or equal to lb/hr for EU002 and less than or equal to lb/hr for EU003 for all fuels and fuel combinations. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. PERFORMANCE TESTING/TESTING FREQUENCY Performance Test: due before end of each calendar 60 months starting 02/03/2004 (on or before 2/3/09) to verify compliance with hourly CO limit for EU002. Performance Test: due before end of each calendar 60 months starting 02/04/2004 (on or before 2/4/09) to verify compliance with hourly CO limit for EU003. Performance Test: due before end of each calendar 60 months starting 02/03/2004 (on or before 02/03/09) for CO, VOC, PM and PM10 to verify emission factors within GP001 for EU002. Performance Test: due before end of each calendar 60 months starting 02/04/2004 (on or before 2/4/09) for CO, VOC, PM and PM10 to verify emission factors within GP001 for EU003. OTHER REQUIREMENTS Compliance with Sulfur Dioxide limit: See requirements under GP001, EU002 and EU003 that address retaining fuel oil receipts, natural gas emission factors, daily records of fuel type usage and calculation methods. Minn. R , subp. 1 Minn. R , subp. 1 MInn. R , subp. 1 Minn. R , subp. 1 Recordkeeping for Minn. R

117 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 003 SE3 - Pulverized Coal Boiler A-46 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler GP 001 New and modified boilers (annual limits to avoid mod) GP 005 CEMS req'd by state rule GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers What to do EMISSION LIMITS Sulfur Dioxide: less than or equal to 0.34 lbs/million Btu heat input and less than or equal to lb/hr, as a 1-hr average when combusting coal or No. 2 fuel oil or both as determined by CEMS. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Nitrogen Oxides: less than or equal to lbs/million Btu heat input and less than or equal to lb/hr. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Carbon Monoxide: less than or equal to lbs/million Btu heat input and less than or equal to 5.75 lb/hr. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 01/26/2005 (next test on or before 1/26/10) to verify emission factors for PM, PM10, NOx, CO and VOC within GP001. Why to do it Minn. R Minn. R Minn. R Minn. R , subp. 1

118 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 004 SE4 - Spreader Stoker Boiler A-47 01/02/ Associated Items: EU 005 SE4 - Spreader Stoker Boiler GP 001 New and modified boilers (annual limits to avoid mod) GP 005 CEMS req'd by state rule GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers What to do EMISSION LIMITS Sulfur Dioxide: less than or equal to 0.34 lbs/million Btu heat input and less than or equal to lb/hr, as a 1-hr average when combusting coal or No. 2 fuel oil or both with or without approved biomass as determined by CEMS. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Nitrogen Oxides: less than or equal to 0.78 lbs/million Btu heat input and less than or equal to lb/hr. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Carbon Monoxide: less than or equal to 0.28 lbs/million Btu heat input and less than or equal to lb/hr. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 11/16/2004 (next test on or before 11/16/09 to verify emission factors for PM, PM10, NOx, and VOC within GP001. Performance Test: due before end of each calendar 60 months starting 11/25/2003 (next test on or before 11/25/08) to verify emission factors for CO within GP001. Why to do it *Minn. R Minn. R Minn. R Minn. R , subp. 1 Minn. R , subp. 1

119 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 005 SG231 - Med. pressure package boiler (new St. Paul boiler) A-48 01/02/ Associated Items: EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) GP 001 New and modified boilers (annual limits to avoid mod) GP 003 Db Boilers - General and CEMS/COMS requirements What to do EMISSION LIMITS Nitrogen Oxides: less than or equal to lbs/million Btu heat input and less than or equal to lb/br as determined by CEMS as a 30-day rolling average. Carbon Monoxide: less than or equal to lbs/million Btu heat input and less than or equal to lb/hr. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 04/08/2004 (next test on or before 4/8/09) to verify emission factors for PM, PM10, CO and VOC emissions within GP001. Why to do it Minn. R ; most stringent limit, meets requirements of 40 CFR Section 60.44b(a); Minn. R Minn. R Minn. R , subp. 1

120 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers A-49 01/02/ Associated Items: EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler EU 009 SP5 - Spreader Stoker Boiler EU 010 SP6 - Spreader Stoker Boiler GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers What to do Why to do it EMISSION LIMITS Particulate Matter less than 10 microns - Ambient Air Impact Analysis based on Minn. R Performance Test: If the Performance Test demonstrates an emission rate greater than either 0.1 lb/mmbtu or 25.8 lb/hr PM10 for all boilers operating simultaneously, the Permittees shall submit a protocol for an ambient air impact dispersion model using the measured emission rate. The protocol shall be submitted by 60 days after the last performance test reports for SV006 has been received and accepted by the MPCA. The results of the dispersion model using the measured emission rate shall be submitted as specified in the protocol as approved by the MCPA. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Nitrogen Oxides: less than or equal to 0.63 lbs/million Btu heat input and less than Minn. R or equal to lb/hr when emission units EU007, EU008, EU009, and EU010 are all operating at the maximum continuous rating; less than or equal to lb/mmbtu when only EU007 and/or EU008 are operating; less than or equal to lb/mmbtu when only EU009 and/or EU010 are operating. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Sulfur Dioxide: less than or equal to 1.15 lbs/million Btu heat input and less than or Minn. R ; most stringent, meets limits set by equal to lb/hr as determined by fuel sampling and analysis. This is a Minn. R , subp. 1 state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Carbon Monoxide: less than or equal to 0.14 lbs/million Btu heat input and less Minn. R than or equal to 36.2 lb/hr when all 4 boilers are operating; less than or equal to 0.04 lb/mmbtu when only EU007 and/or EU008 are operating; less than or equal to lb/mmbtu when only EU009 and/or EU010 are operating. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. OPERATIONAL LIMITS Opacity CEMS: Maintain and operate a Continuous Opacity Monitoring System (COMS). Sulfur Dioxide: See EU007, EU008, EU009, EU010 for required coal sampling and analysis requirement. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 01/15/2002 (next test on or before 1/15/07) for PM10 (to verify emission factor used in modeling analysis), NOx and CO for EU007. Performance Test: due before end of each calendar 36 months starting 12/04/2003 (next test on or before 12/04/06) for NOx and CO for EU008. Performance Test: due before end of each calendar 60 months starting 12/04/2003 (next test on or before 12/04/08) for PM10 (to verify emission factor used in modeling analysis) for EU008. Performance Test: due before end of each calendar 36 months starting 01/16/2002 (next test on or before 1/16/07) for PM10 (to verify emission factor used in modeling analysis) for EU009. Performance Test: due before end of each calendar 36 months starting 12/01/2004 (next test on or before 12/1/07) for NOx for EU009. Performance Test: due before end of each calendar 60 months starting 12/03/2003 (next test on or before 12/3/08) for CO for EU009. Performance Test: due before end of each calendar 36 months starting 12/02/2003 (next test on or before 12/02/06) for NOx for EU010. Performance Test: due before end of each calendar 60 months starting 01/17/2002 (next test on or before 1/17/07) for PM10 (to verify emission factor used in modeling analysis) for EU010. Minn. R , subp. 1 Minn. R ; Minn. R Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1

121 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-50 01/02/ Performance Test: due before end of each calendar 60 months starting 12/02/2003 (next test on or before 12/02/08) for CO for EU010. Minn. R , subp. 1

122 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: SV 007 SP7 - Oil/Gas Package Boiler A-51 01/02/ Associated Items: EU 011 SP7 - Oil/Gas Package Boiler GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers What to do EMISSION LIMITS Particulate Matter less than 10 microns - Ambient Air Impact Analysis based on Performance Test: If the Performance Test demonstrates an emission rate greater than either lb/mmbtu or 5.54 lb/hr PM10, the Permittees shall submit a protocol for an ambient air impact dispersion model using the measured emission rate. The protocol shall be submitted by 60 days after the last performance test reports for SV007 has been received and accepted by the MPCA. The results of the dispersion model using the measured emission rate shall be submitted as specified in the protocol as approved by the MCPA. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. Nitrogen Oxides: less than or equal to lbs/million Btu heat input and less than or equal to lb/hr. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Carbon Monoxide: less than or equal to 0.04 lbs/million Btu heat input and less than or equal to 3.56 lb/hr. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. PERFORMANCE TESTING Performance Test: due before end of each calendar 60 months starting 12/05/2003 (next test on or before 12/5/08) for PM10 and CO emissions. Performance Test: due before end of each calendar 36 months starting 12/05/2005 (next test on or before 12/5/08) for NOx emissions. Why to do it Minn. R Minn. R Minn. R Minn. R , subp. 1 Minn. R , subp. 1

123 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 001 SG201 - Circulating Fluidized Bed Boiler A-52 01/02/ Associated Items: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 020 Dry Limestone Injection GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 003 Db Boilers - General and CEMS/COMS requirements GP 008 Boilers subject to coal sampling and analysis SV 001 SG201 - CFB Boiler What to do SULFUR DIOXIDE Sulfur Dioxide: less than or equal to 10% of the potential sulfur dioxide emission rate according to the following formula: Why to do it 40 CFR Section 60.42b(a); Minn. R Es = (KaHa + KbHb)/(Ha+Hb) where: Es = sulfur dioxide emission limit, in lb/million Btu heat input Ka = 1.2 lb/million Btu Kb = 0.80 lb/million Btu Ha = heat input from the combustion of coal (million Btu) Hb = heat input from the combustion of oil (million Btu) Annual Capacity Factor for Fuels Other Than Coal: greater than 10%. Annual Capacity Factor shall be calculated as defined in 40 CFR pt. 60, subp. Db. Fuel oil sulfur limits and/or percent reduction requirements under this section are determined on a 30-day rolling average. Sulfur Dioxide: The Sulfur Dioxide emission limits and percent reduction requirements apply at all times, including periods of startup, shutdown and malfunction, except that percent reduction requirements do not apply when only very low sulfur fuel oil or natural gas is combusted, and further, except that the percent reduction requirement does not apply during startup, shutdown, or malfunction when the fluidized bed temperature is below normal operating level. Sulfur Dioxide: The Permittee shall obtain and maintain at the facility fuel receipts from the fuel supplier which certify that the fuel oil contains less than or equal to 0.5% sulfur by weight. Sulfur Dioxide Monitoring: Determine the average SO2 emissions and percent reduction by collecting coal/biomass samples in as as-fired condition at the inlet to the steam generating unit and analyzing them for sulfur and heating value according to Method 19 and the procedure specified within GP008 and measuring SO2 in stack SV001 by the SO2 CEMS. PARTICULATE MATTER Total Particulate Matter: less than or equal to 0.10 lbs/million Btu heat input for all fuels and fuel combinations. Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one 6-minute period per hour of not more than 27 opacity. Opacity Compliance: Demonstrate compliance with opacity standards using COMS data results. The PM and opacity standards apply at all times, except during periods of startup, shutdown or malfunction. NITROGEN OXIDES Nitrogen Oxides: less than or equal to lbs/million Btu heat input using 30-day Rolling Average (which is equivalent to lb/hr at manufacturer's rated capacity) when combusting only natural gas or only fuel oil. 40 CFR Section 60.43b(a)(2) and 40 CFR Section 60.41b; Minn. R CFR Section 60.42b(e); Minn. R CFR Section 60.42b(g) and 40 CFR Section 60.42b(j); Minn. R CFR Section 60.49b(r); Minn. R CFR Section 60.47b(b); Minn. R CFR Section 60.43b(a)(2); Minn. R CFR Section 60.43b(f); Minn. R CFR Section 60.11(e)(5); Minn. R , subp. 2(B); Minn. R CFR Section 60.43b(g); Minn. R CFR Section 60.44b(a)(1); 40 CFR Section 60.44b(a)(2); Minn. R

124 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-53 01/02/ Nitrogen Oxides: less than or equal to the amount allowed by the following formula when the facility simultaneously combusts coal, oil and/or natural gas or if the facility simultaneously combusts coal or oil, or a mixture of these fuels with natural gas and approved biomass: 40 CFR Section 60.44b(b); 40 CFR Section 60.44b(c); Minn. R En = [(ELgo x Hgo)+(ELc x Hc)] / (Hgo+Hc) where: En = the NOx emission limit in lb/mmbtu ELgo = the emission lmit for natural gas or fuel oil, lb/mmbtu Hgo = the total heat input from natural gas or fuel oil, MMBtu/hr ELc = the emission limit for coal in lb/mmbtu Hc = the total heat input from coal, MMBtu/hr Nitrogen Oxides: The nitrogen oxides standards apply at all times including periods of startup, shutdown and malfunction. Nitrogen Oxides: emission rate shall be determined by the NOx CEMS as a 30-day rolling average. OPERATIONAL LIMITS Startup Fuel: Natural gas only except that No. 2 fuel oil may be used when natural gas is curtailed. No. 2 fuel oil may be used up to 15% of the maximum heat input (40 MMBtu/hr) for startup only. Fuel type: Bituminious and Subbituminous Coal, approved biomass, approved biomass mixed with coal, approved biomass mixed with natural gas, and natural gas. No. 2 fuel oil for startup only as stated above. Approved Biomass: Approved biomass includes wood (as limited below) and oat hulls. Alternative biomass may be fired during test burns in compliance with all permit conditions. Treated wood and wood waste materials prohibited as fuel: No wood or wood waste which meets the definition of hazardous waste may be used as fuel. 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. PERFORMANCE TESTING 40 CFR Section 60.44b(h); Minn. R CFR Section 60.43b(i); Minn. R Minn. R Minn. R , subp. 35a Title I Condition: Limit to avoid major modification under 40 CFR Section Minn. R , subp CFR Section 60.12; Minn. R See SV001 requirements. Minn. R , subp. 1 CEMS REQUIREMENTS Opacity CEMS: The owner or operator shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS). Subpart Db COMS requirements are contained in GP003 of the permit. Sulfur Dioxide CEMS: The Permittee shall install, calibrate, maintain and operate continuous emission monitoring systems (CEMS) for measuring SO2 concentrations and either Oxygen (2) or Carbon Dioxide (CO2) concentrations. Subp. Db CEMS requirements are contained in GP003 of this permit. Nitrogen Oxide CEMS: The Permittee shall install, calibrate, maintain and operate a continuous monitoring system for measuring NOx. Subpart Db CEMS requirements are contained in GP003 of this permit. POLLUTION CONTROL EQUIPMENT Operate the associated baghouse fabric filter (CE001) whenever unit is operational according to the requirements in CE CFR Section 60.48b(a) 40 CFR Section 60.47b(a) 40 CFR Section 60.48b(b) Minn. R , subp. 2 and 14 RECORDKEEPING Recordkeeping: For each emission unit, maintain records of the type and amount of fuel combusted each day; calculate the annual capacity factor for each fuel for each calendar quarter. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 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. NOTIFICATIONS 40 CFR Section 60.49b(d); Minn. R CFR Section 60.7(f); Minn. R , subp CFR Section 60.7(b); Minn. R , subp. 1

125 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-54 01/02/ Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced, unless specifically exempted under an applicable subpart or in section 60.14(e). OAT HULL INFORMATION Oat Hull Performance Test: due 60 days after achieving the maximum oat hull firing rate, but no later than 180 days after initial startup of the biomass truck unloading station, biomass storage silo, and biomass transfer system to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Oat Hull Performance Test Notification and Submittals; Performance Test Notification (written): due 30 days before Performance Test Performance Test Plan: due 30 days before Performance Test Performance Test Pre-Test Meeting: due 7 day before Performance Test Performance Test Report: due 45 days after Performance Test Performance Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Revised PSD Analysis based on Oat Hull Performance Test: Within 60 days of submitting the Oat Hull Performance Test Report, the Permittee shall perform a revised PSD analysis based on the results of the performance test. If the results of the analysis continue to demonstrate that projected actual emission do not exceed baseline actual emissions for any regulated NSR pollutant by a significant amount, the Permittee may burn oat hulls up to the tested rate and shall maintain records of the revised PSD analysis. If the results of the analysis demonstrate that a significant emissions increase would occur, the Permittee may not operate the biomass truck unloading station, biomass storage silo, and biomass transfer system without obtaining a permit amendment in compliance with Minn. R through Minn. R Alternative Biomass Fuel Testing Authorization: The Permittee is authorized to conduct test burns of the following alternative biomass fuels: agricultural crops; herbs, nuts, by-products or waste; vegetable oils, by-products or waste; crop field residue or field processing by-products; shells, husks, seed, dust, screenings and other agricultural by-products; cultivated grasses or grass by-products; wood, wood waste including wood processing by-products; and leaves. Acceptable biomass fuels do not include peat, wood that has been painted, stained or pressure treated, waste oil, farm chemicals, pesticide containers, demolition waste except for wood, waste from farms from an open dump, tire derived fuels, non-agricultural industrial process wastes, animal manures and wastes, or any material meeting the definition of a hazardous waste. Alternative Biomass Fuel Testing Restrictions: Test burns for any potential biomass fuel shall be limited to 4,000 tons, no more than 45 days of operation using the fuel, and a test period not to exceed 180 days. Alternative Biomass Fuel Testing Requirements: Test burns shall be conducted to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Alternative Biomass Fuel Testing Submittals: 30 days prior to testing of a biomass fuel, the Permittee shall submit a written performance test notification and test plan. The test plan shall meet the requirements of Minn. R and shall also include the type(s) and estimated amount of biomass to be tested, 2) operating parameters and anticipated fuel mixes during testing for the boiler to be tested, 3) air pollutants that will be monitored and measured during testing, and 4) a testing schedule. Alternative Biomass Fuel Testing Notification and Submittals; Pre-Test Meeting: due 7 day before Performance Test Test Report: due 45 days after Performance Test Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2 Title I Condition: Limit to avoid major modification under 40 CFR Section 52.21; Minn. R through Minn. R Minn R , subp. 2 Minn R , subp. 2 Minn R , subp. 2 Minn. R , subp. 1-4; Minn. R Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2

126 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 002 SG202 - Medium Pressure Package Boiler A-55 01/02/ Associated Items: GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 003 Db Boilers - General and CEMS/COMS requirements SV 002 SG202/SG203 - Med/High Pressure Package Boilers What to do EMISSION LIMITS Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one 6-minute period per hour of not more than 27 opacity. Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 30-day Rolling Average as determined by CEMS. Please note the NOx limit at SV002 for EU002 and EU003 which is more restrictive. OPERATIONAL LIMITS Fuel type: Natural gas or No. 2 fuel oil only. Sulfur Dioxide: less than or equal to 0.5 percent by weight sulfur in fuel oil; percent reduction requirement of 40 CFR Section 60.42b(a) does not apply to this emission unit. Sulfur Dioxide: The Permittee shall obtain and maintain at the facility fuel receipts from the fuel supplier for each shipment which certify that the fuel oil contains less than or equal to 0.5% sulfur by weight. The opacity standards apply at all times, except during periods of startup, shutdown or malfunction. Opacity CEMS: The owner or operator shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS). Opacity Compliance: Demonstrate compliance with opacity standards using COMS data results. Nitrogen Oxides CEMS: The owner or operator shall install, calibrate, maintain, and operate a continous monitoring system for NOx. Nitrogen Oxides: The NOx standards apply at all times including periods of startup, shutdown, and malfuntion. Nitrogen Oxides: emission rate shall be determined by the NOx CEMS as a 30-day rolling average. RECORDKEEPING Recordkeeping: For each emission unit, maintain records of the type and amount of fuel combusted each day; calculate the annual capacity factor for each fuel for each calendar quarter. 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. NOTIFICATIONS Notification of Anticipated Date for Conducting Opacity Observations: due 30 days prior to observation date Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced, unless specifically exempted under an applicable subpart or in section 60.14(e). 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. PERFORMANCE TESTING 40 CFR Section 60.43b(f) Why to do it 40 CFR Section 60.44b(a); Minn. R Minn. R , subp. 35a 40 CFR Section 60.42b(j); most stringent, meets limit set by 40 CFR Section 60.42b(a) for fuel oil 40 CFR Section 60.49b(r); Minn. R CFR Section 60.43b(g) 40 CFR Section 60.48b(a) 40 CFR Section 60.11(e)(5); Minn. R , subp. 2(B) 40 CFR Section 60.48b(b) 40 CFR Section 60.44b(h) 40 CFR Section 60.43b(i); Minn. R CFR Section 60.49b(d); Minn. R CFR Section 60.7(b); Minn. R , subp CFR Section 60.7(f); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.12; Minn. R See SV002 requirements. Minn. R , subp. 1

127 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 003 SG203 - High Pressure Package Boiler A-56 01/02/ Associated Items: GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 003 Db Boilers - General and CEMS/COMS requirements SV 002 SG202/SG203 - Med/High Pressure Package Boilers What to do EMISSION LIMITS Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one 6-minute period per hour of not more than 27 opacity. Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 30-day Rolling Average as determined by CEMS. Please note the NOx limit at SV002 for EU002 and EU003 which is more restrictive. OPERATIONAL LIMITS Fuel type: Natural gas or No. 2 fuel oil only. Sulfur Dioxide: less than or equal to 0.5 percent by weight sulfur in fuel oil; percent reduction requirement of 40 CFR Section 60.42b(a) does not apply to this emission unit. Sulfur Dioxide: The Permittee shall obtain and maintain at the facility fuel receipts from the fuel supplier for each shipment which certify that the fuel oil contains less than or equal to 0.5% sulfur by weight. The opacity standards apply at all times, except during periods of startup, shutdown or malfunction. Opacity CEMS: The owner or operator shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS). Opacity Compliance: Demonstrate compliance with opacity standards using COMS data results. Nitrogen Oxides CEMS: The owner or operator shall install, calibrate, maintain, and operate a continous monitoring system for NOx. Nitrogen Oxides: The NOx standards apply at all times including periods of startup, shutdown, and malfuntion. Nitrogen Oxides: emission rate shall be determined by the NOx CEMS as a 30-day rolling average. RECORDKEEPING Recordkeeping: For each emission unit, maintain records of the type and amount of fuel combusted each day; calculate the annual capacity factor for each fuel for each calendar quarter. 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. NOTIFICATIONS Notification of Anticipated Date for Conducting Opacity Observations: due 30 days prior to observation date Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced, unless specifically exempted under an applicable subpart or in section 60.14(e). 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. PERFORMANCE TESTING 40 CFR Section 60.43b(f) Why to do it 40 CFR Section 60.44b(a); Minn. R Minn. R , subp. 35a 40 CFR Section 60.42b(j); most stringent, meets limit set by 40 CFR Section 60.42b(a) for fuel oil 40 CFR Section 60.49b(r); Minn. R CFR Section 60.43b(g) 40 CFR Section 60.48b(a) 40 CFR Section 60.11(e)(5); Minn. R , subp. 2(B) 40 CFR Section 60.48b(b) 40 CFR Section 60.44b(h) 40 CFR Section 60.43b(i); Minn. R CFR Section 60.49b(d); Minn. R CFR Section 60.7(b); Minn. R , subp CFR Section 60.7(f); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.12; Minn. R See SV002 requirements. Minn. R , subp. 1

128 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 004 SE3 - Pulverized Coal Boiler A-57 01/02/ Associated Items: CE 002 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F CE 003 Gas Scrubber (General, Not Classified) GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 005 CEMS req'd by state rule GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 003 SE3 - Pulverized Coal Boiler What to do EMISSION LIMITS Sulfur Dioxide: less than or equal to 3.0 lbs/million Btu heat input when combusting solid fuels only. See next requirement for SO2 limit when simultaneously combusting solid and liquid fuels. Sulfur Dioxide: less than or equal to the amount allowed by the following formula when the facility simultaneously combusts coal and/or oil: Why to do it Minn. R , subp. 1 Minn. R , subp. 1 Ex = [(ELo x Ho)+(ELc x Hc)] / (Ho+Hc) where: Es = the SO2 emission limit in lb/mmbtu ELo = the emission limit for fuel oil Ho = the total heat input from fuel oil, MMBtu/hr ELc = the emission limit for coal Hc = the total heat input from coal Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input when combusting liquid fuels only. Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input Opacity: less than or equal to 20 percent opacity, except for one six-minute period per hour of not more than 33% opacity. OPERATIONAL LIMITS Upon the commencement of commercial operation of the Main Plant Combined Heating Plant's turbine and duct burner, EU 004 shall be retired. Fuel type: Subbituminous and bituminous coal, No. 2 fuel oil and natural gas only. Boiler annual capacity: less than or equal to 148,044 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Opacity CEMS: The owner or operator shall maintain and operate a COMS to measure opacity emissions from the emission unit. Sulfur Dioxide CEMS: Maintain and operate CEMS for SO2 and diluent oxygen after the dry scrubber. POLLUTION CONTROL EQUIPMENT Operate CE002 (med. temp fabric filter) and CE003 (gas scrubber). The Permittee shall operate and maintain the fabric filter and the gas scrubber at all times that any emission unit controlled by the fabric filter and the gas scrubber is in operation in accordance with the requirements of CE002 and CE003, respectively. PERFORMANCE TESTING Minn. R , subp. 1 Minn. R , subp. 2, more stringent than Minn. R , subp. 1, referencing Minn. R Minn. R , subp. 2, more stringent than Minn. R , subp. 1, referencing Minn. R Minn. R , subp. 2 Minn. R , subp. 35a Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. R Minn. R Minn. R , subp. 2 and 14 See SV003 requirements. Minn. R , subp. 1 RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi)

129 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-58 01/02/ Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subp. 5

130 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 005 SE4 - Spreader Stoker Boiler A-59 01/02/ Associated Items: CE 004 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F CE 005 Gas Scrubber (General, Not Classified) GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 005 CEMS req'd by state rule GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 004 SE4 - Spreader Stoker Boiler What to do EMISSION LIMITS Sulfur Dioxide: less than or equal to 3.0 lbs/million Btu heat input when combusting solid fuels only. See next requirement for SO2 limit when simultaneously combusting solid and liquid fuels. Sulfur Dioxide: less than or equal to the amount allowed by the following formula when the facility simultaneously combusts coal and/or oil (with or without approved biomass): Why to do it Minn. R , subp. 1 Minn. R , subp. 1 Ex = [(ELo x Ho)+(ELc x Hc)] / (Ho+Hc) where: Es = the SO2 emission limit in lb/mmbtu ELo = the emission limit for fuel oil Ho = the total heat input from fuel oil, MMBtu/hr ELc = the emission limit for coal Hc = the total heat input from coal Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input when combusting liquid fuels only. Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input Opacity: less than or equal to 20 percent opacity, except for one six-minute period per hour of not more than 33% opacity. OPERATIONAL LIMITS Upon the commencement of commercial operation of the Main Plant Combined Heating Plant's turbine and duct burner, EU 005 shall be retired. Fuel type: Subbituminous and Bituminous Coal, No. 2 fuel oil, natural gas and approved biomass mixed with coal only. Approved biomass is defined below. Approved Biomass: Approved biomass includes oat hulls. Alternative biomass may be fired during test burns in compliance with all permit conditions. Boiler annual capacity: less than or equal to 163,812 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Opacity CEMS: The owner or operator shall maintain and operate a COMS to measure opacity emissions from the emission unit. Sulfur Dioxide CEMS: Maintain and operate CEMS for SO2 and diluent oxygen after the dry scrubber. POLLUTION CONTROL EQUIPMENT Operate CE004 (med. temp fabric filter) and CE005 (gas scrubber). The Permittee shall operate and maintain the fabric filter and the gas scrubber at all times that any emission unit controlled by the fabric filter and the gas scrubber is in operation in accordance with the requirements of CE004 and CE005, respectively. PERFORMANCE TESTING Minn. R , subp. 1 Minn. R , subp. 2, more stringent than Minn. R , subp. 1, referencing Minn. R Minn. R , subp. 2, more stringent than Minn. R , subp. 1, referencing Minn. R Minn. R subp. 2 Minn. R , subp. 35a *Title I Condition: Limit to avoid major modification under 40 CFR Section Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. R Minn. R Minn. R , subp. 2 and 14 See SV004 requirements. Minn. R , subp. 1 OAT HULL INFORMATION

131 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-60 01/02/ Oat Hull Performance Test: due 60 days after achieving the maximum oat hull firing rate, but no later than 180 days after initial startup of the biomass truck unloading station, biomass storage silo, and biomass transfer system to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Oat Hull Performance Test Notification and Submittals; Performance Test Notification (written): due 30 days before Performance Test Performance Test Plan: due 30 days before Performance Test Performance Test Pre-Test Meeting: due 7 day before Performance Test Performance Test Report: due 45 days after Performance Test Performance Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Revised PSD Analysis based on Oat Hull Performance Test: Within 60 days of submitting the Oat Hull Performance Test Report, the Permittee shall perform a revised PSD analysis based on the results of the performance test. If the results of the analysis continue to demonstrate that projected actual emission do not exceed baseline actual emissions for any regulated NSR pollutant by a significant amount, the Permittee may burn oat hulls up to the tested rate and shall maintain records of the revised PSD analysis. If the results of the analysis demonstrate that a significant emissions increase would occur, the Permittee may not operate the biomass truck unloading station, biomass storage silo, and biomass transfer system without obtaining a permit amendment in compliance with Minn. R through Minn. R Alternative Biomass Fuel Testing Authorization: The Permittee is authorized to conduct test burns of the following alternative biomass fuels: agricultural crops; herbs, nuts, by-products or waste; vegetable oils, by-products or waste; crop field residue or field processing by-products; shells, husks, seed, dust, screenings and other agricultural by-products; cultivated grasses or grass by-products; wood, wood waste including wood processing by-products; and leaves. Acceptable biomass fuels do not include peat, wood that has been painted, stained or pressure treated, waste oil, farm chemicals, pesticide containers, demolition waste except for wood, waste from farms from an open dump, tire derived fuels, non-agricultural industrial process wastes, animal manures and wastes, or any material meeting the definition of a hazardous waste. Alternative Biomass Fuel Testing Restrictions: Test burns for any potential biomass fuel shall be limited to 4,000 tons, no more than 45 days of operation using the fuel, and a test period not to exceed 180 days. Alternative Biomass Fuel Testing Requirements: Test burns shall be conducted to measure CO, PM, PM10, VOC, HCl, and hexane emissions, to monitor NOx and SO2 emissions, and to determine fuel chlorine content for calculating HCl control efficiency. Alternative Biomass Fuel Testing Submittals: 30 days prior to testing of a biomass fuel, the Permittee shall submit a written performance test notification and test plan. The test plan shall meet the requirements of Minn. R and shall also include the type(s) and estimated amount of biomass to be tested, 2) operating parameters and anticipated fuel mixes during testing for the boiler to be tested, 3) air pollutants that will be monitored and measured during testing, and 4) a testing schedule. Alternative Biomass Fuel Testing Notification and Submittals; Pre-Test Meeting: due 7 day before Performance Test Test Report: due 45 days after Performance Test Test Report - Microfiche Copy or CD: due 105 days after Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subp. 1 Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2 Title I Condition: Limit to avoid major modification under 40 CFR Section 52.21; Minn. R through Minn. R Minn R , subp. 2 Minn R , subp. 2 Minn R , subp. 2 Minn. R , subp. 1-4; Minn. R Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2 Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi) Minn. R , subp. 5

132 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 006 SG231 - Medium Pressure Package Boiler (new St. Paul boiler) A-61 01/02/ Associated Items: GP 001 New and modified boilers (annual limits to avoid mod) GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 003 Db Boilers - General and CEMS/COMS requirements GP 004 Boilers SG231 and SP7 - fuel oil usage limit SV 005 SG231 - Med. pressure package boiler (new St. Paul boiler) What to do EMISSION LIMITS Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one 6-minute period per hour of not more than 27 percent opacity. Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 30-day Rolling Average as determined by CEMS. Please note the NOx limit at SV005 for EU006 which is more restrictive. OPERATIONAL LIMITS Sulfur Dioxide: less than or equal to 0.5 percent by weight sulfur in fuel oil; percent reduction requirement of 40 CFR Section 60.42b(a) does not apply to this emission unit. The opacity standard applies at all times, except during periods of startup, shutdown or malfunction. Opacity CEMS: The owner or operator shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS). Opacity Compliance: Demonstrate compliance with opacity standards using Reference Method 9. Nitrogen Oxides: emission rate shall be determined by the NOx CEMS as a 30-day rolling average. Nitrogen Oxides: The NOx standards apply at all times including periods of startup, shutdown, and malfuntion. Nitrogen Oxides CEMS: The owner or operator shall install, calibrate, maintain,and operate a continous monitoring system for NOx. Fuel type: No. 2 fuel oil and natural gas only. RECORDKEEPING AND REPORTING Recordkeeping: For each emission unit, maintain records of the type and amount of fuel combusted each day; calculate the annual capacity factor for each fuel for each calendar quarter. Recordkeeping for Sulfur Dioxide: The Permittee shall obtain and maintain at the facility fuel receipts from the fuel supplier which certifiy that fuel oil meets the definition of very low sulfur fuel oil (less than or equal to 0.5% sulfur by weight). 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. NOTIFICATIONS Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced, unless specifically exempted under an applicable subpart or in section 60.14(e). 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. PERFORMANCE TESTING 40 CFR Section 60.43b(f) Why to do it 40 CFR Section 60.44b(a); Minn. R CFR Section 60.42b(j); most stringent, meets limit set by 40 CFR Section 60.42b(a) for fuel oil 40 CFR Section 60.43b(g) 40 CFR Section 60.48b(a) 40 CFR Section 60.11; Minn. R , subp. 2(B) 40 CFR Section 60.43b(i); Minn. R CFR Section 60.44b(h) 40 CFR Section 60.48b(b) Minn. R , subp. 35a 40 CFR Section 60.49b(d); Minn. R ; Minn. R , subp CFR Section 60.49b(r); Minn. R CFR Section 60.7(b); Minn. R , subp CFR Section 60.7(f); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.12; Minn. R See SV005 requirements. Minn. R , subp. 1

133 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 007 SP1 - Pulverized Coal Boiler A-62 01/02/ Associated Items: CE 006 Centrifugal Collector - Medium Efficiency CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity, except for one six-minute period Minn. R , subp. 2 per hour of not more than 60% opacity. Sulfur Dioxide: less than or equal to the amount allowed by the following formula Minn. R , subp. 3 when different fuels are burned simultaneously in any combination: W= (Y x A + Z x B) / (X + Y + Z) where: W = the maximum allowable emissions of SO2 in lb/mmbtu X = percentage of total heat input from gaseous fossil fuel Y = percentage of total heat input from liquid fossil fuel Z = percentage of total heat input from solid fossil fuel A = the allowable SO2 standard for liquid fossil fuels B = the allowable SO2 standard for solid fossil fuels (less stringent than SO2 limit found under SV006, met by equipment design) OPERATIONAL LIMITS Fuel type: Bituminous and Subbituminous Coal, No. 2 fuel oil, and natural gas. Boiler annual capacity: less than or equal to 38,554 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Combustion of on-specification and off-specification used oil is authorized provided the Permittee meets the requirements of Minn. R. ch The Permittee must keep a daily record of the amount of used oil combusted. Opacity CEMS: The owner or operator shall maintain and operate a COMS on SV006 to measure opacity emissions from the emission unit. Sulfur Dioxide: Determine the average SO2 emissions by collecting coal samples in an as-fired condition at the inlet to the steam-generating unit using the coal sampling procedures specified in GP008 of this permit. Analyze them for sulfur content and heating value, and maintain fuel oil supplier receipts according to the procedures specified in this permit. POLLUTION CONTROL EQUIPMENT Operate and maintain CE007 (high temp. fabric filter) and CE006 (med. efficiency centrifugal collector) at all times that any emission unit controlled by the fabric filter is in operation. The fabric filter shall be operated in accordance with the requirements of CE007. PERFORMANCE TESTING Minn. R , subp. 35a Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. Stat. Section , subd. 4a; Minn. R , subp. 2, Minn. R , subp. 100a; ; and Minn. R Minn. R Minn. R , subp. 2 and 14 See SV006 requirements. Minn. R , subp. 1 RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi) Minn. R , subp. 5

134 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 008 SP2 - Pulverized Coal Boiler A-63 01/02/ Associated Items: CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 041 Centrifugal Collector - Medium Efficiency GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity, except for one six-minute period Minn. R , subp. 2 per hour of not more than 60% opacity. Sulfur Dioxide: less than or equal to the amount allowed by the following formula Minn. R , subp. 3 when different fuels are burned simultaneously in any combination: W= (Y x A + Z x B) / (X + Y + Z) where: W = the maximum allowable emissions of SO2 in lb/mmbtu X = percentage of total heat input from gaseous fossil fuel Y = percentage of total heat input from liquid fossil fuel Z = percentage of total heat input from solid fossil fuel A = the allowable SO2 standard for liquid fossil fuels B = the allowable SO2 standard for solid fossil fuels (less stringent than SO2 limit found under SV006, met by equipment design) OPERATIONAL LIMITS Fuel type: Bituminous and Subbituminous Coal, No. 2 fuel oil, and natural gas. Boiler annual capacity: less than or equal to 38,554 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Combustion of on-specification and off-specification used oil is authorized provided the Permittee meets the requirements of Minn. R. ch The Permittee must keep a daily record of the amount of used oil combusted. Opacity CEMS: The owner or operator shall maintain and operate a COMS on SV006 to measure opacity emissions from the emission unit. Sulfur Dioxide: Determine the average SO2 emissions by collecting coal samples in an as-fired condition at the inlet to the steam-generating unit using the coal sampling procedures specified in GP008 of this permit. Analyze them for sulfur content and heating value, and maintain fuel oil supplier receipts according to the procedures specified in this permit. POLLUTION CONTROL EQUIPMENT Operate and maintain CE007 (high temp. fabric filter) and CE006 (med. efficiency centrifugal collector) at all times that any emission unit controlled by the fabric filter is in operation. The fabric filter shall be operated in accordance with the requirements of CE007. PERFORMANCE TESTING Minn. R , subp. 35a Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. Stat. Section , subd. 4a; Minn. R , subp. 2, Minn. R , subp. 100a; ; and Minn. R Minn. R Minn. R , subp. 2 and 14 See SV006 requirements. Minn. R , subp. 1 RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi) Minn. R , subp. 5

135 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 009 SP5 - Spreader Stoker Boiler A-64 01/02/ Associated Items: CE 021 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 042 Centrifugal Collector - Medium Efficiency GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity, except for one six-minute period Minn. R , subp. 2 per hour of not more than 60% opacity. Sulfur Dioxide: less than or equal to the amount allowed by the following formula Minn. R , subp. 3 when different fuels are burned simultaneously in any combination: W= (Y x A + Z x B) / (X + Y + Z) where: W = the maximum allowable emissions of SO2 in lb/mmbtu X = percentage of total heat input from gaseous fossil fuel Y = percentage of total heat input from liquid fossil fuel Z = percentage of total heat input from solid fossil fuel A = the allowable SO2 standard for liquid fossil fuels B = the allowable SO2 standard for solid fossil fuels (less stringent than SO2 limit found under SV006, met by equipment design) OPERATIONAL LIMITS Fuel type: Bituminous and Subbituminous Coal, No. 2 fuel oil, and natural gas. Boiler annual capacity: less than or equal to 74,460 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Combustion of on-specification and off-specification used oil is authorized provided the Permittee meets the requirements of Minn. R. ch The Permittee must keep a daily record of the amount of used oil combusted. Opacity CEMS: The owner or operator shall maintain and operate a COMS on SV006 to measure opacity emissions from the emission unit. Sulfur Dioxide: Determine the average SO2 emissions by collecting coal samples in an as-fired condition at the inlet to the steam-generating unit using the coal sampling procedures specified in GP008 of this permit. Analyze them for sulfur content and heating value, and maintain fuel oil supplier receipts according to the procedures specified in this permit. POLLUTION CONTROL EQUIPMENT Operate and maintain CE021 (high temp. fabric filter) and CE006 (med. efficiency centrifugal scrubber) at all times that any emission unit controlled by the fabric filter is in operation. The fabric filter shall be operated in accordance with the requirements of CE021. PERFORMANCE TESTING Minn. R , subp. 35a Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. Stat. Section , subd. 4a; Minn. R , subp. 2, Minn. R , subp. 100a; ; and Minn. R Minn. R Minn. R , subp. 2 and 14 See SV006 requirements. Minn. R , subp. 1 RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi) Minn. R , subp. 5

136 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 010 SP6 - Spreader Stoker Boiler A-65 01/02/ Associated Items: CE 022 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 043 Centrifugal Collector - Medium Efficiency GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers GP 008 Boilers subject to coal sampling and analysis GP 020 Limited Use Boilers SV 006 SP1/SP2/SP5/SP6 Pulverized coal and spreader stoker boilers What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity, except for one six-minute period Minn. R , subp. 2 per hour of not more than 60% opacity. Sulfur Dioxide: less than or equal to the amount allowed by the following formula Minn. R , subp. 3 when different fuels are burned simultaneously in any combination: W= (Y x A + Z x B) / (X + Y + Z) where: W = the maximum allowable emissions of SO2 in lb/mmbtu X = percentage of total heat input from gaseous fossil fuel Y = percentage of total heat input from liquid fossil fuel Z = percentage of total heat input from solid fossil fuel A = the allowable SO2 standard for liquid fossil fuels B = the allowable SO2 standard for solid fossil fuels (less stringent than SO2 limit found under SV006, met by equipment design) OPERATIONAL LIMITS Fuel type: Bituminous and Subbituminous Coal, No. 2 fuel oil, and natural gas. Boiler annual capacity: less than or equal to 74,460 MMBtu/year using a 12-month rolling sum, to be calculated by the 15th of each month for the previous 12 month period. Combustion of on-specification and off-specification used oil is authorized provided the Permittee meets the requirements of Minn. R. ch The Permittee must keep a daily record of the amount of used oil combusted. Opacity CEMS: The owner or operator shall maintain and operate a COMS on SV006 to measure opacity emissions from the stack. Sulfur Dioxide: Determine the average SO2 emissions by collecting coal samples in an as-fired condition at the inlet to the steam-generating unit using the coal sampling procedures specified in GP008 of this permit. Analyze them for sulfur content and heating value, and maintain fuel oil supplier receipts according to the procedures specified in this permit. POLLUTION CONTROL EQUIPMENT Operate and maintain CE022 (high temp. fabric filter) and CE006 (med. efficiency centrifugal collector) at all times that any emission unit controlled by the fabric filter is in operation. The fabric filter shall be operated in accordance with the requirements of CE022. PERFORMANCE TESTING Minn. R , subp. 35a Minn. R , subp. 2; 40 CFR (c)(2)(vi) Minn. Stat. Section , subd. 4a; Minn. R , subp. 2, Minn. R , subp. 100a; ; and Minn. R Minn. R Minn. R , subp. 2 and 14 See SV006 requirements. Minn. R , subp. 1 RECORDKEEPING Daily Recordkeeping: The Permittee shall record the daily amount of fuel combusted in the boiler and heating value of the fuel for the previous operating day. Daily Recordkeeping: The Permittee shall calculate and record the daily total heat input (MMBtu) using the higher heating value and the quantity of each fuel combusted for the previous operating day. Minn. R , subps. 4 and 5; 40 CFR (c)(2)(vi) Minn. R , subp. 5

137 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 011 SP7 - Oil/Gas Package Boiler A-66 01/02/ Associated Items: GP 002 All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits) GP 004 Boilers SG231 and SP7 - fuel oil usage limit GP 006 COMS req'd by state rule: St. Paul Plant Boilers and SE Plant Boilers SV 007 SP7 - Oil/Gas Package Boiler What to do EMISSION LIMITS Opacity: less than or equal to 20 percent opacity (six-minute average) when combusting oil; except for one (1) six-minute period per hour of not more than 27% opacity. The opacity standard applies at all times, except during periods of startup, shutdown or malfunction. OPERATIONAL LIMITS Fuel type: Distillate fuel oil (No. 2 fuel oil), and natural gas. Fuel Heat Input: less than or equal to 99 million Btu/hour Maximum Distillate Oil Fuel Usage: less than or equal to gallons/year using 12-month Rolling Sum Maximum Natural Gas Fuel Usage: less than or equal to 563 million cubic feet/year using 12-month Rolling Sum Fuel Usage: less than or equal to gallons/year using 12-month Rolling Sum for distillate oil and less than or equal to million cubic feet using a 12-month rolling period for natural gas. For every 1000 gallons distillate oil used in excess of the limit above, the limit on natural gas is reduced by million cubic feet. For every 1 million cubic feet natural gas used in excess of the limit above, the limit on distillate oil use is reduced by 7300 gallons. Why to do it 40 CFR Section 60.43c(c); Minn. R CFR Section 60.43c(d); Minn. R Minn. R , subp. 35a Title I Condition: limit to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: limit to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: limit to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: limit to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Sulfur Dioxide: less than or equal to 0.5 percent by weight sulfur in fuel oil. 40 CFR Section 60.42c(d); Minn. R Sulfur Dioxide: The SO2 standard applies at all times including startup, shutdown or malfunction. CONTINUOUS OPACITY MONITORING SYSTEM (COMS) Emissions Monitoring: The owner or operator shall use a COMS to measure opacity emissions from SV007 (See requirements for COMS under GP006). RECORDKEEPING Maintain records of the type and amount of each fuel combusted each day. Calculate the 12-month rolling sum each calendar month for each fuel type. Recordkeeping: maintain records of the type and amount of each fuel combusted each day. Calculate the 12-month rolling sum each calendar month for each fuel type. Sulfur Dioxide: The Permittees shall obtain and maintain at the facility records of fuel supplier certifications. The certifications shall include the following information: 1. The name of the fuel supplier; 2. A statement from the supplier that the fuel oil meets the definition of distillate oil in 40 CFR Section 60.41c. PERFORMANCE TESTING 40 CFR Section 60.42c(i); Minn. R Minn. R , subp CFR Section 60.48c(g); Minn. R CFR Section 60.48c(g); Minn. R CFR Section 60.48c(f)(1); 40 CFR Section 60.44c(h); Minn. R See SV007 requirements. Minn. R , subp. 1

138 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 014 Diesel rpm Generator; 6 Cylinder in Line; 4 Cycles, Turbo St. Paul Plant A-67 01/02/ Associated Items: SV 010 Diesel rpm GEN Turbo SP Plant What to do OPERATIONAL LIMITS Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. EMISSION LIMITS Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 RECORDKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subps. 4 & 5

139 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 015 Diesel rpm Generator; 8 Cylinder V; 4 Cycles, Turbo A-68 01/02/ Associated Items: SV 011 Diesel rpm GEN Turbo What to do OPERATIONAL LIMITS Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. EMISSION LIMITS Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 RECORDKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subps. 4 & 5

140 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 016 Diesel rpm; 6 Cylinder in Line; 4 Cycles SE Fire Pump A-69 01/02/ Associated Items: SV 012 Diesel rpm GEN Fire pump What to do OPERATIONAL LIMITS Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. EMISSION LIMITS Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input as determined by vendor certification of fuel oil sulfur content. RECORDKEEPING REQUIREMENTS Maintain records of the hours of operation for each calendar month and a record of the 12-month rolling sum of hours of operation. Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Why to do it Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 1 Minn. R , subp. 2 Title I Condition: to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subps. 4 & 5

141 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU GEN002-4th Street Switch-Reciprocating IC Engine A-70 01/02/ Associated Items: GP 012 Peaking Unit Generators: Annual Limits to Avoid PSD SV GEN002-4th Street Switch What to do Intercooler Temperature: less than 195 degrees Fahrenheit at all times during emission unit operation. Recordkeeping: Maintain records of intercooler temperatures for a period of five years from the date of measurement. Refer to GP012 for further requirements. Why to do it Title I Condition: limit to avoid classification as a major modification under 40 CFR Section Title I Condition: recordkeeping for limit to avoid classification as a major modification under 40 CFR Section 52.21

142 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU GEN003-4th Street Switch-Reciprocating IC Engine A-71 01/02/ Associated Items: GP 012 Peaking Unit Generators: Annual Limits to Avoid PSD SV GEN003-4th Street Switch What to do Intercooler Temperature: less than 195 degrees Fahrenheit at all times during emission unit operation. Recordkeeping: Maintain records of intercooler temperatures for a period of five years from the date of measurement. Refer to GP012 for further requirements. Why to do it Title I Condition: limit to avoid classification as a major modification under 40 CFR Section Title I Condition: recordkeeping for limit to avoid classification as a major modification under 40 CFR Section 52.21

143 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU BO-005 Art Building A-72 01/02/ What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period Minn. R , subp. 2 per hour of not more than 60 percent opacity. OPERATING CONDITIONS Fuel type: Natural gas only. Minn. R , subp. 35a

144 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU BO Bierman Field Ath A-73 01/02/ What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period Minn. R , subp. 2 per hour of not more than 60 percent opacity. OPERATING CONDITIONS Fuel type: Natural gas/propane/no. 2 fuel oil only. Minn. R , subp. 35a RECORDINGKEEPING REQUIREMENTS Fuel Oil Sulfur Content Certification: Obtain and maintain at the facility fuel receipts from the fuel supplier which certify the sulfur content of the fuel does not exceed 0.5% by weight. Records shall be maintained for 5 years. Fuel type: Natural gas only. Minn. R , subps. 4 & 5 Minn. R , subp. 35a

145 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU BO Bierman Field Ath A-74 01/02/ What to do Why to do it EMISSION LIMITS Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 1.6 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period Minn. R , subp. 2 per hour of not more than 60 percent opacity. OPERATING CONDITIONS Fuel type: Natural gas only. Minn. R , subp. 35a

146 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 143 SE Mpls biomass truck unloading A-75 01/02/ Associated Items: CE 039 Fabric Filter - Low Temperature, i.e., T<180 Degrees F What to do EMISSION LIMITS Opacity: less than or equal to 5% opacity from truck unloading stations, railcar unloading stations, railcar loading stations, and handling operation fugitive emissions. Opacity: less than or equal to 10 percent opacity discharged from control equipment. Total Particulate Matter: greater than or equal to 80% collection efficiency. PM < 10 micron: greater than or equal to 89.1 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 89.1 percent. This limit applies to each unit individually. Total Particulate Matter: greater than or equal to 89.1 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 89.1percent. This limit applies to each unit individually. OPERATING LIMITS The Permittee shall clean up commodities (i.e., biomass) spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). Visible Emissions: The Permittee shall check the fabric filter for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 inches of water column, unless a new range is required to be 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 Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. 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. REPORTING AND RECORDKEEPING Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed. NOTIFICATIONS Notification of Commence Construction Date and Initial Startup Date: due 30 days after initial startup. The Permittee shall submit the following information with the notification: stack/vent, control equipment, and emissions unit information using the latest MPCA application forms. Why to do it Minn. R , subp. 3(A) Minn. R , subp. 3(D) Minn. R , subp. 3(E) Minn. R , subp. 2 and 14 Minn. R , subp. 2 and 14 Minn. R , subp. 1(A) Minn. R , subp. 4 and 5 Minn. R , subp. 4 and 5 Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4 and 5 Minn. R , subp. 2

147 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 144 SE Mpls biomass silo and biomass transfer to CFB A-76 01/02/ Associated Items: CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F What to do EMISSION LIMITS Opacity: less than or equal to 5% opacity from truck unloading stations, railcar unloading stations, railcar loading stations, and handling operation fugitive emissions. Opacity: less than or equal to 10 percent opacity discharged from control equipment. Total Particulate Matter: greater than or equal to 80% collection efficiency. PM < 10 micron: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 99 percent. This limit applies to each unit individually. Total Particulate Matter: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 99 percent. This limit applies to each unit individually. OPERATING LIMITS The Permittee shall clean up commodities (i.e., biomass) spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). Visible Emissions: The Permittee shall check the fabric filter for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 inches of water column, unless a new range is required to be 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 Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. 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. REPORTING AND RECORDKEEPING Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed. NOTIFICATIONS Notification of Commence Construction Date and Initial Startup Date: due 30 days after initial startup. The Permittee shall submit the following information with the notification: stack/vent, control equipment, and emissions unit information using the latest MPCA application forms. Why to do it Minn. R , subp. 3(A) Minn. R , subp. 3(D) Minn. R , subp. 3(E) Minn. R , subp. 2 and 14 Minn. R , subp. 2 and 14 Minn. R , subp. 1(A) Minn. R , subp. 4 and 5 Minn. R , subp. 4 and 5 Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4 and 5 Minn. R , subp. 2

148 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 156 Cancer/Cardio Boiler 1 Associated Items: SV 088 Cancer/Cardio Boiler 1 A-77 01/02/ What to do Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. Why to do it 40 CFR Section 60.48c(g); Minn. R

149 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 157 Cancer/Cardio Boiler 2 Associated Items: SV 089 Cancer/Cardio Boiler 2 A-78 01/02/ What to do Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. Why to do it 40 CFR Section 60.48c(g); Minn. R

150 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: EU 163 Main Plant Reciprocating IC Engine A-79 01/02/ Associated Items: CE 045 Catalytic Converter GP 015 Emergency Generators SV 094 Main Plant Reciprocating IC Engine What to do Why to do it 40 CFR PT. 63, SUBP. ZZZZ REQUIREMENTS EU 163 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, and 40 CFR Section (c); Minn. R the facility is an area source as defined at 40 CFR Section 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 EU CFR PT. 60, SUBP. IIII REQUIREMENTS EMISSION LIMITS Exhaust opacity shall not exceed: (1) 20 percent during the acceleration mode; (2) 15 percent during the lugging mode; and (3) 50 percent during the peaks in either the acceleration or lugging modes. Carbon Monoxide: less than or equal to 3.5 grams/kilowatt-hour NMHC+NOx: less than or equal to 4.0 grams/kilowatt-hour Total Particulate Matter: less than or equal to 0.20 grams/kilowatt-hour The Permittee shall operate and maintain EU 163 so that it achieves these emission standards over the entire life of the engine. OPERATING LIMITS Sulfur Content of Fuel: less than or equal to 15 parts per million for diesel fuel. Cetane index or aromatic content: (i) a minimum cetane index of 40, or (ii) a maximum aromatic content of 35 volume percent. The Permittee must operate and maintain the engine 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 may only change those settings that are permitted by the manufacturer. The Permittee must also meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable. Operating Hours: less than or equal to 300 hours/year using 12-month Rolling Sum.By the 15th day of each month, the Permittee shall record the hours of operation during the previous calendar month, and the operating hours during the previous 12-month period. This is a total of all operatoring hours, regardless of purpose of usage. Compliance Demonstration: The Permittee must demonstrate compliance by purchasing an engine certified to conform with the emission standards listed in the emission limits above for the same model year and maximum engine power. The engine must be installed and configured according to manufacturer's specifications. The Permittee must operate the emergency stationary ICE according to the requirements in 40 CFR Section (f)(2) through (3). In order for the engine to be considered an emergency stationary ICE under this 40 CFR pt. 60, subp. IIII, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section (f)(2) through (3), is prohibited. If the Permittee does not operate the engine according to the requirements in 40 CFR Section (f)(2) through (3), the engine will not be considered an emergency engine under 40 CFR pt. 60, subp. IIII and must meet all requirements for non-emergency engines. 40 CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (b); 40 CFR Section (b); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R Title I Condition: To avoid classification as a major modification under 40 CFR Section and Minn. R CFR Section (c); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f); 40 CFR Section (c); Minn. R ; Minn. R

151 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-80 01/02/ Operating Hours: less than or equal to 100 hours/year for any combination of the purposes specified in paragraphs 40 CFR Section (f)(2)(i) through (iii). Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) counts as part of the 100 hours per calendar year allowed by 40 CFR Section (f)(3). Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Operating Hours: less than or equal to 50 hours/year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2). Except as provided in 40 CFR Section (f)(3)(i), the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A. The engine is dispatched by the local balancing authority or local transmission and distribution system operator; B. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. C. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D. The power is provided only to the facility itself or to support the local transmission and distribution system. (continued below) (continued from above) E. Permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the Permittee. MONITORING REQUIREMENTS The engine shall contain a non-resettable hour meter prior to startup of engine. RECORDKEEPING REQUIREMENTS The Permittee shall maintain records of the operation of the engine. The record must include the time of operation and the reason the generator was in operation during that time. GENERAL PROVISIONS FOR NSPS IIII The Permittee shall comply with the General Provisions in 40 CFR Section 60.1 through 60.19, as applicable. General Provisions for 60.7(a)(4) and 60.7(b) are specified below. 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 Section (f)(2); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(ii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(2)(iii); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (f)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R Title I Condition: To avoid classification as a major modification under 40 CFR Section and Minn. R ; 40 CFR Section (b); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Pt. 60 Subp. IIII; 40 CFR Section (c); Minn. R ; Minn. R CFR Section 60.12; Minn. R

152 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: University of MN - Twin Cities Permit Number: A-81 01/02/ NOTIFICATIONS (GENERAL PROVISIONS) 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. RECORDKEEPING REQUIREMENTS (GENERAL PROVISIONS) 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. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. 40 CFR Section 60.7(a)(4); Minn. R , subp CFR Section 60.7(b); Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp. 1

153 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F A-82 01/02/ Associated Items: EU 001 SG201 - Circulating Fluidized Bed Boiler What to do Total Particulate Matter: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 99 percent. PM < 10 micron: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 99 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration and any action resultng from the calibration. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Why to do it Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 2 and 14 Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 2 and 14 Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

154 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 002 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F A-83 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler What to do Why to do it Total Particulate Matter: greater than or equal to 96 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 96 percent. PM < 10 micron: greater than or equal to 96 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 96 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration Minn. R , subp. 2 and 14 and any action resultng from the calibration. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if Minn. R , subp. 4, 5, and 14 any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

155 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 003 Gas Scrubber (General, Not Classified) A-84 01/02/ Associated Items: EU 004 SE3 - Pulverized Coal Boiler What to do Sulfur Dioxide: greater than or equal to 70 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for SO2 of 70 percent. Operational requirement: The Permittee is required to operate the scrubber whenever EU004 is in operation. Why to do it Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Pressure Drop: less than or equal to 2 inches of water column Title I Condition: Monitoring for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Monitoring and Recordkeeping: The Permittee shall operate the scrubber per Minn. R , subp. 4 and 5 manufacturers specifications and the pressure drop range as specified in the Operation and Maintenance (O & M) manual, unless a new pressure drop range is set pursuant to MInn. R , supb. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The Permittee shall record the pressure drop rate once every 24 hours when in operation.

156 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 004 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F A-85 01/02/ Associated Items: EU 005 SE4 - Spreader Stoker Boiler What to do Why to do it Total Particulate Matter: greater than or equal to 97 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 97percent. PM < 10 micron: greater than or equal to 99 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 99 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration Minn. R , subp. 2 and 14 and any action resultng from the calibration. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if Minn. R , subp. 4, 5, and 14 any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

157 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 005 Gas Scrubber (General, Not Classified) A-86 01/02/ Associated Items: EU 005 SE4 - Spreader Stoker Boiler What to do Sulfur Dioxide: greater than or equal to 70 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for SO2 of 70 percent. Operational requirement: The Permittee is required to operate the scrubber whenever EU004 is in operation. Why to do it Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Pressure Drop: less than or equal to 2 inches of water column Title I Condition: Monitoring for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Monitoring and Recordkeeping: The Permittee shall operate the scrubber per Minn. R , subp. 4 and 5 manufacturers specifications and the pressure drop range as specified in the Operation and Maintenance (O & M) manual, unless a new pressure drop range is set pursuant to MInn. R , supb. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The Permittee shall record the pressure drop once every 24 hours when in operation.

158 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F A-87 01/02/ Associated Items: EU 007 SP1 - Pulverized Coal Boiler EU 008 SP2 - Pulverized Coal Boiler What to do Why to do it Total Particulate Matter: greater than or equal to 96 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 96 percent. PM < 10 micron: greater than or equal to 96 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 96 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration Minn. R , subp. 2 and 14 and any action resultng from the calibration. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Monitoring for Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 4 and 5 Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

159 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 021 Fabric Filter - High Temperature, i.e., T>250 Degrees F A-88 01/02/ Associated Items: EU 009 SP5 - Spreader Stoker Boiler What to do Why to do it Total Particulate Matter: greater than or equal to 97 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 97 percent. PM < 10 micron: greater than or equal to 97 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 97 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration Minn. R , subp. 2 and 14 and any action resultng from the calibration. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if Minn. R , subp. 4, 5, and 14 any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Recordkeeping for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Monitoring for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

160 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 022 Fabric Filter - High Temperature, i.e., T>250 Degrees F A-89 01/02/ Associated Items: EU 010 SP6 - Spreader Stoker Boiler What to do Why to do it Total Particulate Matter: greater than or equal to 97 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM of 97 percent. PM < 10 micron: greater than or equal to 97 percent control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM10 of 97 percent. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 6 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. Calibrate pressure gauge annually and maintain a written record of the calibration Minn. R , subp. 2 and 14 and any action resultng from the calibration. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if Minn. R , subp. 4, 5, and 14 any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 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. The Permittee shall operate and maintain the fabric filter 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. Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Recordkeeping for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Title I Condition: Monitoring for limit taken to avoid classification as a major modification under 40 CFR Section 52.21; Minn. R Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

161 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 039 Fabric Filter - Low Temperature, i.e., T<180 Degrees F A-90 01/02/ Associated Items: EU 143 SE Mpls biomass truck unloading What to do The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation in accordance with the requirements located within EU143. Why to do it Minn. R , subp. 2 and 14

162 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F A-91 01/02/ Associated Items: EU 144 SE Mpls biomass silo and biomass transfer to CFB What to do The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation in accordance with the requirements located within EU144. Why to do it Minn. R , subp. 2 and 14

163 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: University of MN - Twin Cities Subject Item: FS 001 Southeast Coal and Biomass Bunker A-92 01/02/ Associated Items: CE 038 Fabric Filter - Low Temperature, i.e., T<180 Degrees F GP 007 Low-temperature Fabric Filters (GP009, GP010, FS001) What to do OPERATIONAL LIMITS Fugitive PM: Maintain shape of pile and apply water to minimize fugitive dust. Why to do it Minn. R , subp. C and F

164 TABLE B: SUBMITTALS Facility Name: University of MN - Twin Cities Permit Number: Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. B-1 01/02/ 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 parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. 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 Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. 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

165 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: University of MN - Twin Cities Permit Number: B-2 01/02/ What to send When to send Portion of Facility Affected CEM Certification Test Report due 45 days after CEM Certification Test EU160, GP019 Computer Dispersion Modeling Information due 1216 days after 05/16/2006. Submit modeling data as specified in MPCA guidance for Modeling Information Requests (for PM10, SO2 and NOx). This modeling information is for data collection purposes, no modeling analysis is required at this time. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Total Facility The Modeling Information was submtitted to the MPCA on September 14, Notification of the Date Construction Began due 30 days after Start Of Construction. This notification shall include the information specified by 40 CFR 60.48c(a)(1)-(3). Notification due 15 days after Startup (actual date) of EU 161. Notification due 30 days after Start Of Construction of EU 161. A notification of the date of construction of EU 161 commenced postmarked no later than 30 days after such date. Notification of start of construction is required by 40 CFR Section 60.7(a)(1). Notification due 30 days before Startup of the continuous monitoring system (CMS) in accordance with 40 CFR Section 60.13(c). Relative Accuracy Test Audit (RATA) Notification due 30 days before CEMS Relative Accuracy Test Audit (RATA) EU156, EU157 GP019 GP019 GP019 GP005

166 TABLE B: RECURRENT SUBMITTALS Facility Name: University of MN - Twin Cities Permit Number: B-3 01/02/ What to send When to send Portion of Facility Affected Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendar GP005 quarter following end of the calendar quarter in which the Audit was performed Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar GP006 quarter following Initial Startup of the Monitor Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar GP005 quarter following Initial Startup of the Monitor (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. Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year starting 05/16/2006. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occured, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year starting 05/16/2006 (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Total Facility

167 167 APPENDIX MATERIAL Facility Name: University of MN Twin Cities Permit Number: APPENDIX A Insignificant Activities and Applicable Requirements The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements. Under Minn. R , subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R , subp.2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Permittee is somewhat likely to add and their associated applicable requirements. Minn. R , subpart 3(A) 3(B) 3(C) 3(D) 3(E) 3(F) 3(G) Rule Description of the Activity Fuel use: space heaters fueled by, kerosene, natural gas, or propane. Must be less than or equal to 420,000 Btu/hr combined total capacity. Furnaces, boilers, and incinerators: - Infrared electric ovens Fabrication operations: equipment used exclusively for forging, pressing, drawing, spinning, or extruding hot metals. Processing operations: - open tumblers with a batch capacity of 1,000 pounds or less Storage tanks: 1. Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and 2. Non-hazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of non-hazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. Cleaning operations: commercial laundries, not including dry cleaners and industrial launderers. Emissions from a laboratory, as defined in the subpart. Animal Waste Treatment Facility Crops Services Building Process Kaufert Forestry Products Research Mechanical Engineering Electric Arcing Research University Laboratories Applicable Requirement Minn. R /0515 Minn. R /0110 Minn. R /0715 Minn. R /0715 Minn. R /0715 OR Minn. R , subp. 2(B)/3(B) or Minn. R /0110 (if not associated with industrial process per the IPE definition) Minn. R /0110 Minn. R ; Minn. R /0515; Minn. R ; Minn. R /0715

168 168 Minn. R , subpart 3(H) 3(I) 3(I) Rule Description of the Activity Miscellaneous: 1. Equipment used exclusively for packaging lubricants or greases; 2. Equipment used for hydraulic or hydrostatic testing; 3. Brazing, soldering or welding equipment; Rarig Theatre MIG Welder Rarig Theater Gas Welder Tedd Mann Concert Hall MIG Welder 4. Blueprint copiers and photographic processes; Three Coffman Studio Photo Developing Rooms 5. Equipment used exclusively for melting or application of wax; Art Department Wax Melting 6. Nonasbestos equipment used exclusively for bonding lining to brake shoes; and 7. Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners. Applicable Requirement Minn. R /0110; Minn. R /0515; Minn. R ; Minn. R /0715 Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone and 3. 1,000 tons per year of CO 2 e.. Blegen and Mayo Building Fire Pumps Minn. R Coal drop onto storage pile (100 ton/hr) Minn. R FURNACES AND KILNS Minn. R Art Depart. Gas Blast Furnace No. 1 (240-BF-001) Art Depart. Gas Blast Furnace No. 2 (240-BF-002) Art Depart. Gas Blast Furnace No. 3 (240-BF-003) Art Depart. Gas Burn-Out Kiln (240-BK-001) Art Depart. Gas Indoor Kiln No. 1 (240-IK-001) Art Depart. Gas Indoor Kiln No. 2 (240-IK-002) Art Depart. Gas Indoor Kiln No. 3 (240-IK-003) Art Depart. Gas Indoor Kiln No. 4 (240-IK-004) Art Depart. Gas Indoor Kiln No. 5 (240-IK-005) Art Depart. Gas Outdoor Kiln No. 1 (240-OK-001) Art Depart. Gas Outdoor Kiln No. 2 (240-OK-002) Art Depart. Gas Outdoor Kiln No. 3 (240-OK-003) Art Depart. Gas Outdoor Kiln No. 4 (240-OK-004) DEGREASERS Minn. R /0715 Three wet ash truck loading operations (Old and New at SE Plant and St. Paul Plant), each 20 ton/hr capacity and 27% moisture (from AP-42) Degreaser Coffman Facilities Degreaser Physics Machine Shop Degreaser Civil Mineral Engineering Degreaser Civ/Min Pavement Lab Degreaser FM Zone 1 Degreaser FM Zone 3 Degreaser Fleet Service (Holman) Degreaser Fleet Service (Farm and Grounds) Degreaser Physics-Eric Ganz s Lab Degreaser Studio Arts Degreaser Mechanical Engineering Degreaser Machine Shop

169 169 Minn. R , subpart 3(I) Rule Description of the Activity NATURAL GAS EMERGENCY GENERATORS 020GEN001 - Elliot Hall (50 kw) 028GEN001 - Sanford Hall (25 kw) 037GEN001 - Appleby Hall (10 kw) 042GEN001 - Walter Library (30 kw) 044GEN001 - Shops Building (50 kw) 049GEN001 - Tate Lab of Physics (45 kw) 053GEN001 - Northrop Auditorium (75 kw) 060GEN001 - Vincent Hall (15 kw) 066GEN001 - Amundson Hall (30 kw) 107GEN001 - Masonic Cancer Center (80 kw) 122GEN001 - Kolthoff Hall (75 kw) 125GEN001 - Shepard Labs (50 kw) 139GEN001 - Bierman Field Ath. (25 kw) 158GEN001 - Harvard St. Ramp (55 kw) 207GEN001 - Willey Hall (70 kw) 208GEN002 - Middlebrook Hall (25 kw) 209GEN001 - Rarig Center (45 kw) 215GEN001 - Ferguson Hall (55 kw) 322GEN001 - Coffey Hall (15 kw) 338GEN001 - McNeal Hall (50 kw) 350GEN001 - Haecker Hall (25 kw) 357GEN001 - Green Hall (33 kw) 371GEN001 - Vet. Teaching Hospital (75 kw) 372GEN001 - Peters Hall (25 kw) 373GEN001 - St. Paul Central Lib. (75 kw) 394GEN001 - Alderman Hall (15 kw) 396GEN001 - Christensen Hall (25 kw) 412GEN001 - COB (15 kw) 455GEN001 - Swine Res. Fac. (55 kw) 463GEN001 - Poultry Teaching (75 kw) DIESEL EMERGENCY GENERATORS 093GEN University Ave. (75 kw) 160GEN001 4th Street Switch (50 kw) 205GEN001 Anderson Hall (30 kw) 370GEN001 Greenhouse (50 kw) 383GEN001 Bailey Hall (20 kw) Minn. R Minn. R Applicable Requirement

170 170 Minn. R , subpart Rule Description of the Activity DIESEL STORAGE TANKS 250 gal diesel tank Horticul. Res gal diesel tank Church St. Garage 550 gal diesel tank Mgmt/Econ Bldg 300 gal diesel tank Transport. Safety 300 gal diesel tank Transport. Safety 200 gal diesel tank 19 th Ave Ramp 500 gal diesel tank 21 st Ave Ramp 400 gal diesel tank Middlebrook 200 gal diesel tank Comstock 550 gal diesel tank YMCA 280 gal diesel Law Utility 300 gal diesel tank HHH 300 gal diesel tank Anderson Hall 300 gal diesel tank CME 600 gal diesel tank CME 1000 gal diesel tank Elec Engineering 15,000 gal fuel oil tank Gould Building 3000 gal diesel tank PWB-Unit A (B/C) 3000 gal diesel tank PWB-Moos Tower (B/C) 500 gal diesel tank Millard-JOML Complex 265 gal diesel tank Williamson Hall 505,000 gal fuel oil 1&2 tank MPLS Htg Plant-Main 225,000 gal fuel oil 1&2 tank MPLS Htg Plant-Main 10,000 gal fuel oil 1&2 tank MPLS Htg Plant-S.E. 20,000 gal diesel tank Basic Sciences 6000 gal diesel tank Telecom. Bldg 510 gal diesel tank IWMF 2000 gal diesel tank Naval Satellite 2500 gal diesel tank MCT Facility 500 gal diesel tank Ag Engineering 160 gal diesel tank Eng. & Fisheries Lab 265 gal diesel tank Student Center 300 gal diesel tank Golf Course Tool H 35,000 gal #2 fuel oil tank St. Paul Htg Plant 35,000 gal #2 fuel oil tank St. Paul Htg Plant 280 gal diesel tank Earl Brown Cent 1500 gal diesel tank Biol Sci Center 265 gal diesel tank Bailey Hall 7500 gal #2 fuel oil tank Bruce Publshg 6000 gal diesel tank Farm & Grnds Main 520,000 gal fuel oil 1&2 tank St. Paul Htg Plant 1000 gal diesel tank Vet Teach Hospt 1000 gal diesel tank Lewis Hosp-Animals Diesel and fuel oil transfer operations GASOLINE STORAGE TANKS 560 gal gasoline tank and transfer Naval Satellite 1000 gal gasoline tank and transfer Golf Course Tool H AMMONIA STORAGE TANK 10,000 gal Ammonia tank Main CHP Applicable Requirement Minn. R /0110 or Minn. R /0715 Minn. R and Minn. R no requirements apply under these rules Minn. R /0110 or Minn. R /0715

171 171 Minn. R , subpart 3(I) Rule Description of the Activity NATURAL GAS BOILERS 87-BO E. River Road (0.3 MM Btu/hr) 88-BO-001 Torture Treat. Ctr. (0.225 MM Btu/hr) 92-BO Ontario (1 MM Btu/hr) 141-BO-001 Oak St. Ramp (1.2 MM Btu/hr) 159-BO-001 Football Complex (1.438 MM Btu/hr) 159-BO-002 Football Complex (1.438 MM Btu/hr) 160-BO-001 4th Street Switch (0.472 MM Btu/hr) 160-BO-002 4th Street Switch Unit Heater (0.131 MM Btu/hr) 160-BO-003 4th Street Switch Unit Heater (0.131 MM Btu/hr) 160-BO-004 4th Street Switch Unit Heater (0.131 MM Btu/hr) 160-BO-005 4th Street Switch Unit Heater (0.131 MM Btu/hr) 184-BO-001 Network/Telecom (1.043 MM Btu/hr) 240-BO-001 Art Building (0.5 MM Btu/hr) 240-BO-002 Art Building (0.4 MM Btu/hr) 240-BO-003 Art Building (0.4 MM Btu/hr) 240-BO-004 Art Building (0.165 MM Btu/hr) 349-BO-001 Golf Maintenance (0.15 MM Btu/hr) 353-BO-001 KOUM Transmitter (0.248 MM Btu/hr) 354-BO-001 Golf Club House (1 MM Btu/hr) 384-BO-001 Commonwealth #1 (0.167 MM Btu/hr) 384-BO-002 Commonwealth #2 (0.167 MM Btu/hr) 384-BO-003 Commonwealth #3 (0.167 MM Btu/hr) 384-BO-004 Commonwealth #4 (0.167 MM Btu/hr) 384-BO-005 Commonwealth #5 (0.167 MM Btu/hr) 384-BO-006 Commonwealth #6 (0.167 MM Btu/hr) 384-BO-007 Commonwealth #7 (0.167 MM Btu/hr) 384-BO-008 Commonwealth #8 (0.167 MM Btu/hr) 384-BO-009 Commonwealth #9 (0.167 MM Btu/hr) 384-BO-010 Commonwealth #25 (0.167 MM Btu/hr) 384-BO-011 Commonwealth #26 (0.167 MM Btu/hr) 384-BO-012 Commonwealth #27 (0.167 MM Btu/hr) 384-BO-013 Commonwealth #28 (0.167 MM Btu/hr) 384-BO-014 Commonwealth #29 (0.167 MM Btu/hr) 384-BO-015 Commonwealth #30 (0.167 MM Btu/hr) 384-BO-016 Commonwealth #45 (0.167 MM Btu/hr) 384-BO-017 Commonwealth #46 (0.167 MM Btu/hr) 384-BO-018 Commonwealth #47 (0.167 MM Btu/hr) 384-BO-019 Commonwealth #48 (0.167 MM Btu/hr) 384-BO-020 Commonwealth #49 (0.167 MM Btu/hr) 384-BO-021 Commonwealth #10 (0.91 MM Btu/hr) 384-BO-022 Commonwealth #16 (0.91 MM Btu/hr) 384-BO-023 Commonwealth #17 (0.91 MM Btu/hr) 384-BO-024 Commonwealth #22 (0.91 MM Btu/hr) 384-BO-025 Commonwealth #24 (0.91 MM Btu/hr) 384-BO-026 Commonwealth #31 (0.91 MM Btu/hr) 384-BO-027 Commonwealth #32 (0.91 MM Btu/hr) 384-BO-028 Commonwealth #35 (0.91 MM Btu/hr) 384-BO-029 Commonwealth #37 (0.91 MM Btu/hr) 384-BO-030 Commonwealth #39 (0.91 MM Btu/hr) 384-BO-031 Commonwealth #42 (0.91 MM Btu/hr) 384-BO-032 Commonwealth #44 (0.91 MM Btu/hr) 384-BO-033 Commonwealth #50 (0.91 MM Btu/hr) 384-BO-034 Commonwealth #57 (0.91 MM Btu/hr) 384-BO-035 Commonwealth #57 (0.91 MM Btu/hr) 384-BO-036 Commonwealth #13 (0.78 MM Btu/hr) 384-BO-037 Commonwealth #20 (0.78 MM Btu/hr) 384-BO-038 Commonwealth #55 (0.167 MM Btu/hr) 384-BO-039 Commonwealth #55 (0.167 MM Btu/hr) 384-BO-040 Commonwealth #52,51 (1.56 MM Btu/hr) 384-BO-041 Commonwealth #18 (0.125 MM Btu/hr) Applicable Requirement Minn. R /0515

172 172 Minn. R , Rule Description of the Activity Applicable Requirement subpart 3(J) Fugitive Emissions from roads and parking lots. Minn. R (K) - Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment. - St. Paul Paint Shop Minn. R /0715 Insignificant Activities Required to Be Listed for Part 70 sources Minn. R , Rule Description of the Activity subpart 4 Individual emissions units at a stationary source, each of which has: A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide; B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and C. For hazardous air pollutants, emissions units with: 1. Potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in subp. 5; or 2. Combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart gal IWMF waste solvent storage tank No gal IWMF waste solvent storage tank No gal IWMF waste solvent storage tank No. 3 IWMF Distillation Walk-in Hood IWMF Distillation Bench Top Hood IWMF Transfer Operations Rarig Theatre Spray Painting Tedd Mann Concert Hall Spray Gun Coffman Studio Screen Printing Operation 10,000 gal gasoline tank and transfer Holman Bldg 6000 gal gasoline tank and transfer Farm & Grnds Main Applicable Requirement Minn. R /0715 Minn. R

173 173 Minn. R , subpart Rule Description of the Activity SMALL ENGINE DIESEL EMERGENCY GENERATORS (EU074-EU103) 063GEN001 Comstock Hall (200 kw) 064GEN001 Coffman (400 kw) 079GEN001 Lyon Labs (200 kw) 144GEN001 Phillips-Wang. Bldg. (250 kw) 144GEN090 Phillips-Wang. Bldg. (250 kw) 152GEN001 Williamson Hall (180 kw) 156GEN001 Civ. And Min. Eng. Blg (300 kw) 161GEN090 Telecomm. Building (375 kw) 161GEN091 Telecomm. Building Portable Generator (80 kw) 161GEN092 Telecomm. Building Portable Generator (80 kw) 161GEN093 Telecomm. Building Portable Generator (80 kw) 163GEN001 Church St. Garage (125 kw) 167GEN001 Aquatic Center (230 kw) 181GEN001 Ridder Arena (150 kw) 188GEN001 University Ramp (Gateway) (130 kw) 201GEN001 Management and Econ. (125 kw) 211GEN001 Law Building (200 kw) 214GEN001 West Bank Ramp (125 kw) 216GEN001 Humphrey Center (100 kw) 241GEN001 Art Building (150 kw) 334GEN001 Ag. Eng. Bldg. (180 kw) 376GEN001 Student Center (75 kw) 411GEN001 Biol. Sciences (& FP) (375 kw) 420GEN001 Brown Cont. Ed. Ctr (90 kw) 427GEN001 Vet. Teaching Hospital (350 kw) 438GEN001 Ecology Building (300 kw) 483GEN001 Gortner Avenue Ramp (100 kw) ELECGEN003 Portable Generator (250 kw) ELECGEN004 Portable Generator (115 kw) ELECGEN005 Portable Generator (55 kw) Applicable Requirement Minn. R ; Minn. R , subp. 2; Minn. R , subp. 5 (annual hours of operation recorded and available upon request)

174 174 Minn. R , Rule Description of the Activity subpart 4 NATURAL GAS EMERGENCY GENERATORS (EU114-EU138) 035GEN001 Smith Hall (190 kw) 052GEN001 Pioneer Hall (75 kw) 068GEN001 Centennial Hall (115 kw) 069GEN001 Variety Club Res. Ctr (150 kw) 070GEN001 Boynton Health Serv. (130 kw) 074GEN001 Mayo & Add. (B10) (170 kw) 074GEN002 Mayo & Add. (B155) (100 kw) 074GEN003 Mayo & Add. (L350) (170 kw) 074GEN004 Mayo & Add. (B700-C) (355 kw) 074GEN005 Mayo & Add. (B700-B) (170 kw) 074GEN006 Mayo & Add. (b700-a) (170 kw) 074GEN007 Mayo & Add. (G265) (250 kw) 074GEN090 Mayo & Add. (250 kw) 110GEN001 Frontier Hall (80 kw) 115GEN001 Children's Rehab Center (170 kw) 141GEN001 Oak St. Ramp (150 kw) 202GEN001 Social Science (250 kw) 204GEN001 Wilson Library (200 kw) 208GEN003 Middlebrook Hall (85 kw) 265GEN002 Mechanical Engineering (255 kw) 385AGEN001 Vet. Med. Diagnostic (100 kw) 393GEN001 Hodson Hall (115 kw) 413GEN001 Andrew Boss Lab (100 kw) 416GEN001 Animal Sci./Vet. Med. (250 kw) 426GEN001 Voc. and Tech. Ed. (170 kw) NATURAL GAS BOILERS (EU , EU ) 240-BO-005 Art Building (2.86 MM Btu/hr) 139-BO-001 Bierman Field Ath. (9.8 MM Btu/hr) 139-BO-002 Bierman Field Ath. (9.8 MM Btu/hr) EU 156 Cancer Cardio Boiler 1 (11 MM Btu/hr) EU 157 Cancer Cardio Boiler 2 (11 MM Btu/hr) INTEGRATED WASTE MANAGEMENT FACILITY 177-EF-14 Transfer Operation Applicable Requirement Minn. R ; Minn. R , subp. 2; Minn. R , subp. 5 (annual hours of operation recorded and available upon request) Minn. R ; Minn. R /0515; Minn. R , subp. 2; Minn. R , subp. 5 (annual hours of operation recorded and available upon request) Minn. R ; Minn. R /0715 (carbon tetrachloride lab packed and, therefore, not processed in IWMF) Conditionally Insignificant Activities Minn. R Rule Description of the Activity Emissions from equipment venting particulate matter (PM) or particulate matter less than 10 microns (PM-10) inside a building, provided that emissions from the equipment are: a). filtered through an air cleaning system; and b). vented inside of the building 100% of the time. Art Department Woodworking Architecture Woodworking Shop Weisman Woodworking Applicable Requirement Minn. R /0715

175 175 APPENDIX B Parameters Used in Air Dispersion Modeling Analysis Facility Name: University of MN Twin Cities Permit Number: SUMMARY OF STACK PARAMETERS FOR MODELING INPUT [from Second Supplement to AEPA, Table V-15, p.5-30, Record 013] (and based on FW Memo to MPCA dated 5/5/98 as part of revised modeling for PM10) Base Elevation Stack Height Stack Temp Exit Velocity Stack Diameter Source ID EU # Stack UTM coordinates East (m) West (m) (m) (m) (K) (m/sec) (m) SV001 (ST#101) EU SV002 (ST#102) EU 002, EU SV003 (ST#103) EU SV004 (ST#104) EU SV005 (ST#301) EU SV006 (STPB#1) EU 007-EU SV007 (STPB#7) EU SUMMARY OF WORST CASE OPERATING SCENARIOS-NEW UNITS [from Second Supplement to AEPA, Table V-16, p.5-33, Record 013] Pollutant Unit Stack Number Fuel Load Emission Rate (g/sec) Lb/hr (x ) SO2 EU001 EU002, EU003 EU006 SV001 SV002 SV005 Coal Distillate Oil Distillate Oil 100% 100% NA TSP/PM10 CO g/s [lb/hr] NOx EU001 EU002, EU003 EU006 EU001 EU002, EU003 EU006 EU001 EU002, EU003 EU006 SV001 SV002 SV005 SV001 SV002 SV005 SV001 SV002 SV005 Coal Distillate Oil Distillate Oil Wood Distillate Oil Distillate Oil Wood Distillate Oil Distillate Oil 100% 100% NA 100% 100% 100% 100% 100% 100% [70.75]* 2.62 [20.810]* 1.37 [10.88]* SUMMARY OF WORST CASE OPERATING SCENARIOS-EXISTING UNITS [from Second Supplement to AEPA, Table V-17, p.5-34, Record 013] Pollutant Unit Stack Number Emission Rate (g/sec) Lb/hr (x ) SO2 EU004 EU005, EU EU011 SV003 SV004, SV006 SV , , TSP PM10 CO EU004 EU005, EU EU011 EU004 EU005, EU EU011 EU004 EU005, EU EU011 SV003 SV004, SV006 SV007 SV003 SV004, SV006 SV007 SV003 SV004, SV006 SV , , [5.72]* 6.60 [52.40], 4.37 [34.70]* 0.45 [3.57]* , ,

176 176 NOx EU004 EU005, EU EU011 SV003 SV004, SV006 SV , , * Numbers in brackets [] were penciled into the tables by previous permit engineer.

177 ATTACHMENT TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft/proposed permit. 1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address Stationary Source/Address Applicant/Address (SIC Code: 8221) University of Minnesota Board of Regents 202 Morrill Hall, Minneapolis, Hennepin County, Minnesota Contact: Mike Austin Phone: Facility Description University of MN - Twin Cities W140 Boynton Health Service Minneapolis, Hennepin County, Minnesota The University of Minnesota is a teaching and research institution with two campuses in the Twin Cities: the Minneapolis campus and the St. Paul campus. The two campuses are approximately three miles apart and are connected by a transitway 80 feet wide owned by the University. The Facility covers an area of approximately 1154 acres and contains approximately 22,000,000 gross square feet of buildings overall. The Facility employs approximately 15,000 people and serves a population of 40,000 full time and 11,000 part time students. The Facility owns and operates, or contracts with other parties who operate, a variety of facilities that support its teaching and research functions. The Minneapolis Campus consists of the East and West Bank locations adjacent to the industrial downtown Minneapolis stretch of the Mississippi River. The campus has a variety of teaching and research facilities in the areas of engineering, liberal arts, business, health sciences, and athletics. The Minneapolis Campus provides dormitory and other facilities that are operated by the Facility. A central steam plant (Southeast Plant), which directly provides steam for heating and cooling to the Minneapolis Campus, is located on the East Bank. The Southeast Plant is owned by the Facility, but is currently operated by Veolia Energy Solutions, LLC (Veolia). The Southeast Plant provides steam to most oncampus buildings and to several off-campus customers through the University system. The St. Paul Campus is generally located east of Cleveland Avenue, south of Larpenteur Avenue, west of the Minnesota State Fairgrounds, and north of Como Avenue in St. Paul. The campus has its primary teaching and research emphasis in agricultural studies. Prominent facilities include a veterinary medicine teaching and research facility, biological sciences complex, agricultural engineering building, agronomy and plant research facilities, and animal husbandry facilities. Technical Support Document, Permit Action Number: Page 1 of 25

178 Description of the Activities Allowed by this Permit Action This permit action is for a major amendment. This permit action will authorize the construction of the proposed Main Plant Combined Heat & Power (CHP) system. The CHP system includes a 22.8 MW combustion turbine generator (EU 161) in series with a 210 MMBtu/hr duct burner (EU 162). Exhaust gases will be used to produce up to 270,000 pounds of steam per hour for the Minneapolis campus steam distribution system. The CHP system can operate under a number of scenarios: - Full or partial combustion turbine generator (CTG) operation with no supplemental duct burner firing. Steam is produced from only the CTG exhaust gas. - Full CTG operation with full or partial duct burner operation. The system will use natural gas as primary fuel and ultra-low sulfur distillate oil (ULSD) when gas is curtailed or physically unavailable. The CHP system includes an oxidation catalyst to reduce CO. In addition, the CTG will use a stage, dry low NOx combustor as well as an aqueous ammonia-based selective catalytic reduction system to control NOx. The CHP is subject to 40 CFR pt. 60, subp. KKKK. 40 CFR pt. 63, subp. YYYY applies to major HAP sources. The University of Minnesota facility is an area source, hence subp. YYYY does not apply. A 500 kw diesel emergency generator will also be installed. The generator is subject to 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ. Six existing coal-fired boilers will be designated as limited use boilers under the provisions of 40 CFR pt. 63, subp. JJJJJJ. To do so, annual capacity limits of 10% were added to EU004, EU005, EU Upon the commencement of commercial operation of the Main Plant Combined Heating Plant's turbine and duct burner, two coal fired boilers (EU 004 and EU 005) will be retired. In addition, the following are other authorized changes to the permit: The new emergency generator (EU163) is associated to GP015. GP018 was created to house 40 CFR Section CEM general provision requirements. GP019 was created to house the new CHP requirements. The proposed Main CHP was also associated with existing GP002 and GP005. GP020 was created to house the 40 CFR pt. 63, subp. JJJJJJ (NESHAP for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources). The following permit condition was removed from the coal-fired boilers: Combustion of EDTAtype boiler cleaning agents is authorized provided the cleaning agents are generated on site and provide less than 5% of heat input to the emission unit per hour. This was removed from EU004, EU005, EU007 EU010. The permit has been updated to reflect current MPCA templates and standard citation formatting. Technical Support Document, Permit Action Number: Page 2 of 25

179 Facility Emissions: The CTG (turbine) performance is presented in Table 2. Data is shown for a range of ambient temperatures and humidity, for both fuel types and with the duct burner firing at full load or not in operation. Gross Thermal Output is the heat content of the steam produced in the HRSG for each given condition. CTG operating performance data was used to determine worst-case pollutant emission rates. A similar analysis of the CHP operating performance data was also used to determine worst-case pollutant emission rates. Both analyses concluded that the low ambient operating scenario was the worst case for emission calculations. Table 2 Controlled Operating Conditions Conditions Fuel Dry/Wet Bulb Title Load Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas 59 F/51 F 91.0 F/73.5 F F 59 F/51 F 59 F/51 F Base High Ambient Low Ambient Reduced Load Reduced Load 100% Load 100% Load 100% Load 75% Load 50% Load Net Heat Rate (Btu/kwh) Gross Power (kw) Net Power (kw) (MMBtu/hr LHV) 9,949 21,270 21, ,869 19,182 19, ,485 22,279 22, ,044 15,963 15, ,762 10,648 10, (MMBtu/hr HHV) Conditions Fuel Dry/Wet Bulb Title Load Distillate Oil Distillate Oil Distillate Oil Distillate Oil Distillate Oil 59 F/51 F 91.0 F/73.5 F F 59 F/51 F 59 F/51 F Base High Ambient Low Ambient Reduced Load Reduced Load 100% Load 100% Load 100% Load 75% Load 50% Load Net Heat Rate (Btu/kwh) Gross Power Net Power Fuel (MMBtu/hr LHV) 10,083 20,751 20, ,073 18,411 18, ,061 21,561 21, ,185 15,491 15, ,055 10,211 9, (MMBtu/hr HHV) Technical Support Document, Permit Action Number: Page 3 of 25

180 180 Table 3. Title I Emissions Summary Limited NSR/112(g) Emissions Emissions Significant Increase from Increase from Thresholds the the for Major Modification Modification Sources (tpy) (tpy) (tpy) NSR/ 112(g) Review Required? (Yes/No) Pollutant PM No PM No PM No NO x No SO No CO No Ozone (VOC) No Lead No CO 2 e** 312, ,092 75,000 No (see subsequent discussion of July 24, 2014 EPA memo) n-hexane No formaldehyde No *Based on 90/10 natural gas/ulsd fuel oil ** Data at low Ambient Temperature (worst case) *** Includes projected startup and shutdown emissions **** n-hexane and formaldehyde account for 80% of total HAPs ***** Because of the existing GP001 HCl limit, the limits of 10% for the annual boiler capacity for GP020 do not have an impact on PTE for this permit action Table 4. Total Facility Actual Summary PM tpy PM 10 tpy PM 2.5 tpy SO 2 tpy NO x tpy CO Tpy CO 2 e tpy VOC tpy Single HAP tpy Total Facility Actual Emissions (2013) * * Not reported in MN emission inventory. All HAPs tpy Table 5. Facility Classification Classification Major Synthetic Minor/Area Minor/Area PSD x Part 70 Permit Program x Part 63 NESHAP x Technical Support Document, Permit Action Number: Page 4 of 25

181 Regulatory and/or Statutory Basis New Source Review The facility is an existing major source under New Source Review regulations. The changes authorized by this permit do not trigger PSD modification thresholds as indicated in Table 3. (See information about GHG in the Technical Information section below.) Part 70 Permit Program The facility is a major source under the Part 70 permit program. This permit action does not change this status. New Source Performance Standards (NSPS) The new CHP (EU161, EU162) is subject to 40 CFR pt. 60, subp. KKKK, NSPS for Stationary Combustion Turbines. The NSPS NOx limits are, however, less stringent than the Synthetic Minor emission limits proposed by the Permittee. The new emergency generator (EU 163) is subject to NSPS, 40 CFR pt. 60, Subp. IIII, NSPS for Stationary Compression Ignition Internal Combustion Engines. National Emission Standards for Hazardous Air Pollutants (NESHAP) Existing HAP limits will be maintained. This will keep the facility classified as an area source for HAPs. The new emergency generator (EU163) is subject to 40 CFR pt. 63, subp. ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE). By maintaining compliance with NSPS subp. IIII, the new generator will be in compliance with NESHAP subp. ZZZZ. (40 CFR (c)(1)) Six existing boilers (EU004, EU005, EU ) are already subject to 40 CFR pt. 63, subp. JJJJJJ, NESHAP for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. Subp. JJJJJJ requirements were added to this permit action. Compliance Assurance Monitoring (CAM) CAM applies to the modification allowed in this permit amendment, since the unit is an other pollutant specific emission unit (PSEU). However, the Permittee is not required to submit the monitoring plan required under 40 CFR 64.4 until their next application for permit renewal because the unit is not a large PSEU. Environmental Review & Air Emissions Risk Analysis (AERA) A mandatory EAW is triggered for this project. Minn. R , subp. 15.B Air Pollution (Greenhouse Gases). Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for Stationary Internal Combustion Engines Minn. R Standards of Performance Stationary Combustion Turbines Minn. R Stationary Reciprocating Internal Combustion Engines Technical Support Document, Permit Action Number: Page 5 of 25

182 182 Minn. R Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Table 6. Regulatory Overview of Units Affected by the Modification/Permit Amendment Subject Item* Applicable Regulations Rationale EU163 (Diesel Emergency Generator) EU163 (Diesel Emergency Generator) Minn. R ; Minn. R CFR pt. 63, subp. ZZZZ; 40 CFR pt. 60, subp. IIII; Minn. R ; Minn. R Minnesota Standards of Performance for Stationary Internal Combustion Engines. The unit is a Stationary Internal Combustion Engine National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE). Determination of applicable limits from the rule: The unit is located at an area source of HAPs Owner or operators of each unit commenced construction after June 12, 2006 The unit is a stationary Compression Ignition (CI) Engine Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. Determination of applicable limits from rule: Owner or operators of each unit commenced construction after July 11, 2005 The unit was manufactured on or after January 1, 2011 The unit is an emergency stationary internal combustion engine The unit is not a fire pump engine The unit was manufactured as a Tier III engine GP002 (All steam service steam boilers & CHP turbine/duct burner (HAP and heat input limits)) GP005 (CEMS required by State rule) GP018 (Section CEM general provision requirements) Limits to be an area source for HAPs Minn. R. pt CHP (EU161, EU162) emissions included in the existing limit to remain an area source of HAPs. CHP (EU161, EU162) CEMS subject to these requirements. 40 CFR Section CHP (EU161, EU162) CEMS subject to these requirements. Technical Support Document, Permit Action Number: Page 6 of 25

183 183 Subject Item* Applicable Regulations Rationale GP019 (Turbine/Duct Burner) 40 CFR pt ; Minn. R ; Prevention of Significant Deterioration. Emission limits taken to keep the potential emissions increase of CO and NO x from the CHP to less than significant as defined by 40 CFR (Limit set on NOx and CO emissions from CHP to avoid major modification classification under 40 CFR Part ) 40 CFR pt. 60, subp. KKKK New Source Performance Standards for Stationary Combustion Turbines. Determination of applicable limits from the rule: The unit is a stationary combustion turbine The heat input of the turbine is greater than 10 MMBtu/hr Construction will commence after Feb. 18, 2005 GP020 (Limited Use Boilers) 40 CFR pt. 63, subp. JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. Determination of applicable limits from the rule: The unit is located at an area source of HAPs Owner or operators of each unit commenced construction on or before June 4, 2010 Each unit is a boiler *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 2. Technical Information 2.1(i) Additional Air Quality Regulatory Applicability Documentation Major PSD Amendment for Combined Heat and Power Cogeneration Facility The combined heat and power (CHP) cogeneration facility will generate electricity and steam. The proposed project will also include an emergency generator. The project does not involve the modification of any existing emission units. The emissions increase analysis for Prevention of Significant Deterioration (PSD) applicability includes only new emission units constructed with this project. The Main CHP project is a Synthetic Minor NSR Modification for CO and NOx. Emission rates lower than required by federal New Source Performance Standards (NSPS) are included as proposed permit conditions to allow the plant to operate at full annual capacity on natural gas without any operating hour limits. (Distillate oil use will be limited to 10% of annual capacity.) CHP Facility Description This permit action authorizes the construction of a combined-cycle natural gas facility consisting of a General Electric LM2500 combustion turbine (EU161), a heat recovery steam generator (HRSG) with duct burners (EU162), a steam turbine and an air-cooled condenser. The total generating capacity will be 22.8 megawatts (MW) in series with a 210 MMBtu/hr duct burner. Exhaust gases will be used to produce up to 270,000 pounds of steam per hour for the campus steam distribution system (depending on operating scenario). Exhaust gases will be emitted through exhaust stack SV093. The system will use Technical Support Document, Permit Action Number: Page 7 of 25

184 184 natural gas as primary fuel and ultra-low sulfur distillate oil (ULSD) when gas is curtailed or physically unavailable. The CHP system can operate under a number of scenarios: - Full or partial CTG operation with no supplemental duct burner firing. Steam is produced from only the CTG exhaust gas. - Full CTG operation with full or partial duct burner operation. The combustion turbine (EU161) will be fueled by natural gas supplied by a pipeline system to a delivery point. Piping will carry the gas from the delivery point to the CHP cogeneration facility. The turbine can also combust diesel fuel. EU161 will be equipped with low-no X burners. The duct burner is incapable of running independently from the turbine. The HRSG will have natural gas-fired or diesel fuel duct burners (EU162) for supplementary heat input. The duct burner is incapable of running independently from the turbine. Following the duct burner will be an oxidation catalyst (CE045) for reducing CO, as well as an aqueous ammonia based selective catalytic reduction (SCR) system (CE044) for reducing NO X. Aqueous ammonia (19%) for the SCR system will be delivered to the CHP cogeneration site and stored in a 10,000 gallon tank. The aqueous ammonia will then be injected into the ammonia grid upstream of the SCR catalyst. This project will also include an emergency engine (EU 163). The Permittee intends to use existing generators located at 4 th Street Switch Station to provide power when the CTG needs to black start. The 4 th Street engine/generators are already permitted. Construction is anticipated to begin in December The Permittee anticipates an in-service date sometime during third quarter PSD Regulatory Applicability Analysis Because the CHP cogeneration facility contains only new emission units, the actual-to-potential test specified in 40 CFR Section 52.21(a)(2)(iv)(d) will be used: Actual-to-potential test for projects that only involve construction of a new emission unit(s). A significant emissions increase of a regulated NSR pollutant is projected to occur if the sum of the difference between the potential to emit (as defined in paragraph (b)(4) of this section) from each new emissions unit following completion of the project and the baseline actual emissions (as defined in paragraph (b)(48)(iii) of this section) of these units before the project equals or exceeds the significant amount for that pollutant (as defined in paragraph (b)(23) of this section.) The terms new emission unit, potential to emit and baseline actual emissions have specific meanings ascribed by the applicable rules. A new emission unit includes any part of a stationary source that will emit a regulated NSR pollutant and be newly constructed. The baseline actual emissions for a new emission unit is zero prior to initial operation. Potential to emit (PTE) is defined as: [t]he maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. The PTE for an emission unit yet to be constructed is calculated as the product of its hourly maximum throughput or heat input capacity and an uncontrolled emission factor taken from AP-42, a manufacturer s performance guarantee, existing regulatory standards or other information sources. Enforceable emission limitations on the capacity of the source to emit a pollutant (e.g., air pollution control equipment, restrictions on hours of operation) may be taken to reduce the unit s PTE. Technical Support Document, Permit Action Number: Page 8 of 25

185 185 New Combustion Turbine (EU161) The LM2500 combustion turbine (EU161) will be fired with pipeline natural gas as well as ULSD fuel oil. It will be equipped with low-no X technology and SCR (CE044) to maintain low NO X emissions as well as a catalytic oxidizer (CE045) to control CO. The vendor has provided performance guarantees of: lb/hr for PM10 when the entire CHP is operating; lb/hr for PM10 when only the turbine is operating; - 4 ppm for NOx combusting natural gas when the entire CHP is operating; - 6 ppm for NOx combusting ULSD fuel oil when the entire CHP is operating; - 9 ppm for NOx combusting USLD fuel oil when only the turbine is operating; and, - 20 ppm for CO combusting either natural gas or ULSD fuel oil when the entire CHP is operating. The vendor also provided a 2.0 ppm VOC emission factor while combusting natural gas and a 1.0 ppm emission factor while combusting ULSD oil. The ammonia emission factor was also provided by the vendor. PM2.5 has been assumed to be 80% of PM10. Calculations for other PSD pollutants are based on emission factors for natural gas or distillate oil from AP-42 chapter 3.1 as well as WebFire. PTE of combustion turbines varies greatly based on ambient conditions. They are highest during cold ambient temperatures due to colder air being denser allowing for higher mass flow and fuel input rates in the turbine. PTE calculations are based on an ambient temperature of o F, corresponding to the turbine s MMBtu/hr rated capacity based on a higher heating value (HHV) basis. The worst case ambient condition was used in all of the calculations. (See Table 2 above.) For most pollutants, the maximum emission rates occur at 100 percent load. However, CO and NO X emissions are greatest when the turbine is starting up or shutting down. CO and NO X startup emissions are calculated using startup emission curves provided by the manufacturer. Annual PSD PTE calculations account for 100 hours of each startup and shutdown operation, each with an average duration of 30 minutes. This is a conservative assumption as the Permittee expects to operate the Main CHP facility continuously, as baseload for 11 months per year. As the baseload steam generator for the Minneapolis campus, the CTG will be operating more than 95 percent of the time, in either full or partial load. The Permittee will take synthetic minor limits for CO and NO X to avoid a major modification under 40 CFR Section CO and NO X emissions will be monitored by the use of continuous emissions monitoring systems (CEMS). The proposed CHP project has a CO 2e PTE of 235,092 tons per year. This exceeds the 75,000 CO 2e PSD significant emission rate (SER). In addition, the remaining NSR regulated pollutants proposed project emissions are either subject to limits that are less than the SERs for NSR (40 CFR 52.21(b)(1)) or do not exceed the SERs because they are true minor increases. At the time of processing this permit action there is an issue of whether this increase of CO 2e emissions would be subject to PSD. At this time, EPA has provided the following guidance in its July 24, 2014 memorandum entitled Next Steps and Preliminary Views on the Application of Clean Air Act Permitting Programs to Greenhouse Gases Following the Supreme Court's Decision in Utility Air Regulatory Group v. Environmental Protection Agency. In the July 24 EPA GHG memorandum provides, in part: Technical Support Document, Permit Action Number: Page 9 of 25

186 186 In summary, in order to act consistently with its understanding of the Supreme Court" s decision pending judicial action to effectuate the final decision, the EPA will not apply or enforce the following regulatory requirements: Federal regulations or the EPA-approved PSD SIP provisions that require a stationary source to obtain a PSD permit if GHG are the only pollutant (i) that the source emits or has the potential to emit above the major source thresholds, or (ii) for which there is a significant emissions increase and a significant net emissions increase from a modification (e.g., 40 CFR (b)(49)(v)). Hence, the proposed CHP project is not considered a major modification for NSR. 40 CFR pt New Duct Burners (EU162) The duct burners (EU162) will be fired with pipeline natural gas as well as ULSD fuel oil. The duct burner will not be operating independently from the CTG. In other words, the CTG exhaust will flow through the duct burner. From the duct burner, the exhaust will continue though the same catalytic oxidizer (CE 045) and same SCR (CE 044). The vendor provided emission guarantees for either the CTG operating alone or the CTG operating in series with the duct burner. Calculations were done separately for the CTG and the duct burner, then combined for the total CHP. Emissions were based on the above vendor guarantees or from AP-42 chapters 1.3 and 1.4 as well as WebFire. The rated heat input capacity of EU162 is MMBtu/hr on a HHV basis. The duct burners (EU162) will operate only when the combustion turbine (EU161) is at or near full load, at which time the HRSG will already be heated. The startup and shutdown of the duct burners will not result in higher emissions. The maximum emission rates occur when the duct burners are operating at 100 percent load. 2.1(ii) Additional Air Quality Regulatory Applicability Documentation 40 CFR pt. 60: New Source Performance Standards Subpart KKKK applies to stationary combustion turbines that commence construction after February 18, 2005 and have a maximum heat input at peak load equal to or greater than 10 MMBtu/hr based on HHV of the fuel. Since the heat input of the combustion turbine (EU161) is greater than 10 MMBtu/hr, subpart KKKK is applicable. Also, as specified at 40 CFR Section (a), subpart KKKK applies to the associated HRSG and duct burners (EU162). Subpart KKKK establishes standards for NO X and SO 2. The emission standards may be met on either a concentration or output basis. For SO 2 the emission standard may be met on either an output or fuel content basis. The NSPS NOx limits are less stringent than the Synthetic Minor emission limits proposed by the Permittee. Under 40 CFR , the Permittee has elected not to monitor the total sulfur content. 40 CFR provides, in part: You may elect not to monitor the total sulfur content of the fuel combusted in the turbine, if the fuel is demonstrated not to exceed potential sulfur emissions of 26 ng SO 2 /J (0.060 lb SO 2 /MMBtu) heat input for units located in continental areas.... You Technical Support Document, Permit Action Number: Page 10 of 25

187 187 must use one of the following sources of information to make the required demonstration: (a) The fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, specifying that the maximum total sulfur content for oil use in continental areas is 0.05 weight percent (500 ppmw) or less and 0.4 weight percent... the total sulfur content for natural gas use in continental areas is 20 grains of sulfur or less per 100 standard cubic feet..., has potential sulfur emissions of less than less than 26 ng SO 2 /J (0.060 lb SO 2 /MMBtu) heat input for continental areas.... In addition, stationary combustion turbines regulated under 40 CFR Section are exempt from 40 CFR pt. 60, subpart GG. Heat recovery steam generators and duct burners regulated under 40 CFR Section (Subpart KKKK) are exempted from 40 CFR pt. 60, subparts Da, Db, and Dc. 40 CFR pt. 60, subp. IIII applies to stationary compression ignition internal combustion engines. Since the proposed emergency generator is a 2007 or later model, 40 CFR pt. 60, subp. IIII is applicable to the 500 kw Main plant emergency generator (EU163). Subpart IIII establishes standards for NOx, CO, and PM. EU163 is a Tier III engine. 2.1(iii) Additional Air Quality Regulatory Applicability Documentation National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility has previously accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. These limits remain in-place. Thus, no major source NESHAPs apply. Accordingly, the new turbine is not subject to 40 CFR pt. 63, subp. YYYY for Stationary Combustion Turbines. The new emergency generator, as a result of this modification, is subject to 40 CFR pt. 63, subp. ZZZZ, for Stationary Reciprocating Internal Combustion Engines (RICE) at area sources. HAP emissions are a function of fuel type and combustion method. Hexane is the primary HAP from natural gas combustion, while formaldehyde is the primary ULSD fuel oil HAP. The Main CHP will become the baseload steam source for the University. Consequently, emissions from the Main CHP will replace a large portion of the existing Southeast steam plant HAP emissions. The existing permit already had in place requirements to not exceed 15 tons per year of total HAPs and 7 tons per year of hexane for the steam plants. These limits will remain in place in GP002. In addition, the Main CHP turbine/duct burner HAPs emissions will be included in GP002. In addition, the other largest HAP emission for the Main CHP is formaldehyde with a 0.15 tpy PTE. With the additional 0.15 tpy, the overall facility formaldehyde PTE will remain less than 10 tpy. 2.1(iv) Additional Air Quality Regulatory Applicability Documentation 40 CFR pt. 64: Compliance Assurance Monitoring The combustion turbine (EU161) and duct burner (EU162) are subject to emission limits or standards and include new control devices (CE044 and CE045). The emissions from both units were combined for purposes of comparing them to CAM applicability. Pre-control PTE is above 100 tpy for NO X and CO. The post control PTE is below 100 tpy. Thus, the CHP facility project emission units qualify as other PSEU for NO X and CO in accordance with 40 CFR Section 64.5(b). Currently, no CAM plan is required until the next Title V permit renewal application. The CHP facility will use NO X and CO CEMS to meet the Technical Support Document, Permit Action Number: Page 11 of 25

188 188 requirements of 40 CFR Section 64.3(d)(1). As part of the Title V reissuance, the CAM plan will be required. At that time, operating parameters for the catalytic oxidizer (CE 045) and same SCR (CE 044) will be added to the permit. 2.1(v) Additional Air Quality Regulatory Applicability Documentation Turbine Startup/Shutdown As a synthetic minor PSD Modification, the University is not required to conduct air dispersion modeling as part of the permitting process. However, the University has conducted screening modeling, for the EAW, to ensure that the project will not significantly affect human health or the environment in the community surrounding the facility. The hourly emissions modeling was based on the facility combusting ULSD fuel (which is backup to natural gas). Analyses were conducted on PM10, PM2.5, NO2, SO2, H2S, and CO. For the criteria pollutants, the Significant Impact Level (SIL) was not exceeded. Hence, no cumulative modeling was deemed necessary. In addition to reviewing the impacts from the facility combusting ULSD fuel oil, the emissions from startup/shutdown were considered. Startup and shutdown is expected to be between 8 10 minutes. For startup, it takes an additional 20 minutes for the controls to be fully operational. Hence, the entire startup/shutdown duration is expected to be about 30 minutes. The frequency and timing of the startup/shutdowns was reviewed. It was conservatively estimated that there would be about 12 planned shutdown per year as well as about 13 unplanned shutdowns per year. The unplanned shutdowns would be at random times of the overall year and not controllable. It is noted that 40 CFR Section has a requirement addressing start/shutdown emissions. The requirement provides that the Permittee will minimize emissions by operating the facility with good air pollution control practice. This includes trying to minimize the frequency of planned shutdowns. During permit review, MPCA staff also considered if turbine emissions during startup/shutdown events would significantly contribute to high ozone days. After reviewing eleven years of forecast and actual AQI data from the Blaine ozone monitor, staff found that there was an average of fewer than two days per year with an actual AQI exceeding 90. Since there are likely to be only a couple of days per month when a startup/shutdown event occur, there is a very small chance that an event will occur on a day with an AQI above 90. Based on this information, staff determined that no additional permit terms would be included in this permit action. 2.1(vi) Additional Air Quality Regulatory Applicability Documentation Environmental Justice: Environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. By incorporating environmental justice principles into its permitting and other functions, the MPCA strives to ensure that pollution does not have a disproportionate negative impact on any group of people and that all Minnesotans have the same opportunity to participate in environmental decisions that have the potential to impact them. Technical Support Document, Permit Action Number: Page 12 of 25

189 189 As part of the permitting process and in consultation with the U.S. EPA, the MPCA has evaluated available socio-economic information about residents in the area around the facility to evaluate the potential for environmental justice concerns. In the case of University of Minnesota s Combined Heat and Power facility, the EPA and MPCA have identified possible concerns for environmental justice based on information about income and ethnicity of area residents. To address these concerns the University of Minnesota conducted enhanced outreach to area residents to facilitate their awareness of and involvement in the decision-making process. Beginning in 2011 and continuing throughout the permitting process, this included outreach on multiple occasions to local community groups, informal communication and community information meetings. With the removal of two coal burning boilers at the Southeast Plant, this permit action will result in an overall low risk in pollutants of concern for health issues, the MPCA did not recommend additional actions to further address emissions. 2.1(vii) Additional Air Quality Regulatory Applicability Documentation Limited Use Designation for 6 Existing Coal Fired Boilers The facility is an area source under 40 CFR pt. 63. In addition, 40 CFR pt. 63, subp. JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources) applies to six existing coal-fired boilers at the facility. The Permittee has proposed to voluntarily limit the operating capacity of six existing coal-fired boilers. By accepting an annual limit of no more than 10% of maximum annual capacity, the units will comply with the definition of Limited Use, thereby reducing requirements associated with the rule. Limiteduse boiler means any boiler that burns any amount of solid or liquid fuels and has a federally enforceable average annual capacity factor of no more than 10 percent. 40 CFR Section The six affected boilers (EU004, EU005 and EU007 EU010) serve as backup units in case of boiler outages or natural gas curtailment during the peak heating season. These units are rarely used and have not reached 10 percent of annual capacity in the past decade. The following table presents that annual maximum heat input and the proposed annual maximum heat input limit for the six affected boilers. Technical Support Document, Permit Action Number: Page 13 of 25

190 190 Table 7 - Existing and Proposed Annual Maximum Heat Inputs Heat Input Capacity (MMBtu/hr) Annual Maximum Heat Input (MMBtu/Year) Proposed Annual Maximum Heat Input Limit (MMBtu/Year) EU ID Description 004 Southeast Boiler No. 3 - Pulverized Coal Boiler 169 1,480, , Southeast Boiler No. 4 - Spreader Stoker Coal Boiler 187 1,638, , St. Paul Boiler No. 1 - Pulverized Coal Boiler ,440 38, St. Paul Boiler No. 2 - Pulverized Coal Boiler ,440 38, St. Paul Boiler No. 5 Spreader Stoker Boiler ,600 74, St. Paul Boiler No. 6 Spreader Stoker Boiler ,600 74,460 5,378, ,864 For the six affected boilers, the 40 CFR pt. 60, subp. JJJJJJ compliance date was March 21, On the March 21, 2014 compliance date, the six affected boilers were required to demonstrate initial compliance through the following items: Conduct a one-time energy assessment performed by a qualified energy assessor as specified in 40 CFR Conduct an initial tune-up as specified in The Permittee has provided that each of these items was completed by the effective date of March 21, The University has not operated any of the six affected boilers since the March 21, 2014 compliance date and will not operate the units until the federally enforceable permit limits are included in the permit with this action. Because the boilers have not operated, they have not been required to demonstrate initial emission limit compliance through performance testing. 40 CFR pt. 60, subp. JJJJJJ provides that emission limit performance tests are not due until 180 days after the boiler restart. In the current permit application, the Permittee proposes to accept an annual limit of no more than 10% of maximum annual capacity. Hence, the six affected units will comply with the definition of Limited Use. This limit will reduce the requirements associated with the rule. Under 40 CFR (f), limited-use boilers are not subject to the emission limits in Table 1, the energy assessment requirements in Table 2, or the operating limits in Table 3. It is noted that energy assessment has already been completed. Technical Support Document, Permit Action Number: Page 14 of 25

191 191 All permitted heating plant boilers, included in GP002 in the permit, are presently subject to seven ton per year annual emission cap for hydrochloric acid (HCl). The six boilers subject to this action have relatively high HCl emission rates which already limit annual operation. They cannot, as a group, operate more than four percent of annual capacity without exceeding the HCl limit for the entire facility. To illustrate, 1. The Limited-Use Boilers (EUs 004,005, and ) are subject to the existing GP002 Emission Cap for Hydrochloric Acid 7 tons per year. 2. The limited-use boilers emit 7 tons HCl per year at about 4.4% of annual capacity factor. The Limited Use clause limits these boilers to 10% annual capacity. 3. There is no change in PTE, from designating the six affected boilers as limited use boilers because they are already capped by GP002 at PTE that is less than that of the 10% for limited use designation. Since these boilers are already effectively limited, this proposed amendment has no impact on allowable annual emissions for the Total Facility. Table 8 Annual Maximum Heat Input (MMBtu/Year) HCl Emission Factor (lb/mmbtu) Annual Maximum HCl Emissions (Tons/Year) ID Description EU004 Southeast Boiler No. 3 - Pulverized Coal Boiler 1,480, EU005 Southeast Boiler No. 4 - Spreader Stoker Coal Boiler 1,638, EU007 St. Paul Boiler No. 1 - Pulverized Coal Boiler 385, EU008 St. Paul Boiler No. 2 - Pulverized Coal Boiler 385, EU009 St. Paul Boiler No. 5 Spreader Stoker Boiler 744, EU010 St. Paul Boiler No. 6 Spreader Stoker Boiler 744, GP018 Existing HCl Unlimited Annual Emissions 5,378, GP018 Proposed Limited Use Annual Emissions 537, GP018 Existing (Average) HCl Limited Annual Emissions 103,863 7 Technical Support Document, Permit Action Number: Page 15 of 25

192 192 As for permit structure, the requirements that limits the annual capacity factor to less than or equal to 10 percent are located at the emission unit level for the 6 affected boilers. The 40 CFR pt. 63, subp. JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources) applicable requirements that apply to the 6 affected boilers are found in GP Regulatory Information 3.1 Calculations of Potential to Emit The calculation spreadsheets are available in the Central files of Delta. The spreadsheets contain detailed calculations and supporting information prepared by the Permittee and reviewed by the MPCA. 3.2 Dispersion Modeling EPA has established ambient air quality standards for criteria pollutants other than GHG (NAAQS). The standards protect public health and the environment. Compliance is determined through a monitoring network operated by the MPCA. Changes at existing facilities must undertake air dispersion modeling if they are defined as Major PSD Modification for any criteria pollutant other than GHG. Model results are compared to PSD Significant Impact Levels (SILs) for each criteria pollutant. Each SIL is set by EPA at a small fraction of the NAAQS (typically less than five percent of the standard). As a Minor PSD Modification, the University is not required to conduct air dispersion modeling as part of the permitting process. However, the University has conducted screening modeling to ensure that the project will not significantly affect human health or the environment in the community surrounding the facility. Modeling was conducted following an MPCA-approved protocol. The AERSCREEN dispersion model was used. Worst-case hourly emissions (ULSD as fuel, cold-weather operation) and stack temperature (226 F) were input to the model, along with actual local geography. Neighboring building dimensions were also input to the model. The modeling run was performed assuming a generic emission rate of one pound per hour. The resulting maximum one-hour ambient air quality concentration was then used as a Unit Impact Multiplier ( ug/m3 air pollution / 1 lb/hr pollutant). The Unit Impact Multiplier was multiplied by each pollutant s worst-case one-hour emission rate to determine each pollutant s maximum ambient air quality impact. MPCA-approved Conversion Factors were also used to convert the one-hour results to estimate longer-term ambient air quality impacts. Results indicate that the proposed plant will not significantly affect local ambient air quality (Table 7). The maximum one-hour ambient air pollutant concentration was located 100 degrees from north and 128 meters from the stack, or at East River Road. Worst-case one hour concentrations are significantly lower at other distances from the facility. Technical Support Document, Permit Action Number: Page 16 of 25

193 193 Modeling results can be considered environmentally conservative because they do not take into account: 1. The retirement of two coal-fired boilers at the neighboring Southeast Plant. 2. Reduced operation of the remaining Southeast boilers due to baseload operation of the Main CHP Plant. Pollutant Table 9. Air Dispersion Screening Model Summary Results (Worst-Case Operating Conditions) Air Quality Averagin g Time NO 2 /NO x Ratio Emission Rate (lb/hr) Max Concentration (µg/m 3 ) SIL (µg/m 3 ) Standard(µg/ m 3 ) NO 2 1-hr Annual *1 ppm NO 2 = 1,880 µg/m 3 Pollutant Averaging Time Emission Rate (lb/hr) Conversion Factor Unit Impact Multiplier (µg/m 3 ) Max Concentration (µg/m 3 ) SIL (µg/m 3 ) Air Quality Standard (µg/m 3 ) CO 1-hr ,000 8-hr ,000 PM hr Annual PM hr Annual SO 2 1-hr hr hr Annual Technical Support Document, Permit Action Number: Page 17 of 25

194 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. The table below summarizes the monitoring requirements associated with this amendment. Subject Item* GP 015 (Diesel Emergency Generator) Table 10. Monitoring Requirement (rule basis) Monitoring Discussion SO 2 : < 0.5 Recordkeeping: All units are for emergency use. Proper maintenance lb/mmbtu Maintain records of and operation of the units will ensure compliance Opacity: < 20% fuel type usage on a with opacity standards. Use of fuel oil with sulfur monthly basis. content below % by weight will ensure (Minn. R. compliance with SO 2 limit ) Sulfur Content of Fuel: < % by weight (Minn. R ) Obtain Fuel Oil Supplier Certification for each shipment of fuel. Technical Support Document, Permit Action Number: Page 18 of 25

195 195 Subject Item* EU 163 (Main Plant RICE) Requirement (rule basis) Monitoring Discussion Operating Hours: 300 hr/yr total Operating Hours: 100 hr/yr for maintenance, testing, & emergency demand response Recordkeeping: Install on a non-resettable hour meter. Maintain records of the operation of the engine in emergency service including time and reason the generator was in operation. Monitoring requirements of NSPS IIII are considered adequate to demonstrate compliance with the limits. No additional monitoring is needed. By maintaining compliance with NSPS IIII, the unit is also in compliance with NESHAP ZZZZ. (40 CFR (c)(1)) Operating Hours: 50 hr/yr for non emergency situations CO 3.5 g/kw hr PM 0.20 g/kwhr NMHC + NOX 4.0 g/kw hr (NSPS Subpart IIII) Technical Support Document, Permit Action Number: Page 19 of 25

196 196 Subject Item* GP019 (Main CHP) Requirement (rule basis) Monitoring Discussion NO X : < 35.0 tpy NO X /CO: Monitor NO X, using 12 month CO & O 2 CEM to rolling sum continuously measure CO: < 90.0 tpy NO X & CO emissions, using 12 month also calculate and rolling sum record 12 month (Title I Condition: rolling sum of to avoid major emissions modification under 40 CFR & Minn. R ) NO X, CO & O 2 CEMS to comply with NO X & CO limits along with recordkeeping. NO X, CO & O 2 CEMS to comply with NO X & CO limits along with recordkeeping. NO X : < 4.0 ppm at 15 % O 2 (EU161/EU162) while combusting Nat. gas NO X : < 9.0 ppm at 15 % O 2 (EU161 only) while combusting ULSD fuel oil NO X : < 6.0 ppm at 15 % O 2 (EU161/EU162) while combusting ULSD fuel oil CO: < 20.0 ppm at 15 % O 2 (EU161/EU162) (Title I Condition: to avoid major modification under 40 CFR & Minn. R ) NO X /CO: Monitor NO X, CO & O 2 CEM to continuously measure NO X & CO emissions Technical Support Document, Permit Action Number: Page 20 of 25

197 197 Subject Item* GP019 (Main CHP) Requirement (rule basis) Monitoring Discussion NO X : < 25 ppm at NO X : Monitor NO X & 15% O 2 O 2 CEM to (EU161/162) continuously measure while combusting NO X emissions nat. gas NO X : < 74 ppm at 15% O 2 (EU161/162) while combusting ULSD fuel oil Purchase records Monitoring of NO X & SO 2 limits from NSPS subp. KKKK are included in the standard. Demonstrate with current, valid purchase contract, tariff sheet, or transportation contract for fuel SO 2 : < lbs/mmbtu (40 CFR pt. 60, subp. KKKK) Pipeline Nat. gas < 20 gr/100 scf sulfur content or ULSD fuel oil < 15 ppm sulfur content (Title I Condition: to avoid major modification under 40 CFR & Minn. R ) Purchase records Calibrate, operate, maintain a CMS to record fuel flow to EU161 and EU162. Demonstrate with current, valid purchase contract, tariff sheet, or transportation contract for fuel Calibrate, operate, maintain a CMS to record fuel flow to EU161 and EU162. Fuel usage, 2,720,247 gal/yr of ULSD fuel oil (Title I Condition: to avoid major modification under 40 CFR & Minn. R ) Fuel: operate CMS to record fuel flow rate Technical Support Document, Permit Action Number: Page 21 of 25

198 198 Subject Item* GP020 (limited use boilers) EU004, EU005, EU Requirement (rule basis) Monitoring Discussion Boiler tune-ups Recordkeeping Tune-up and recordkeeping requirements from 40 CFR pt. 63, subp. JJJJJJ are in the permit. Annual boiler capacity Recordkeeping: Maintain records of fuel quantity combusted on a daily basis *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 3.4 Insignificant Activities These are limited use boilers. The annual boiler capacity is restricted to 10%. University of MN - Twin Cities has several operations which are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix A to the permit. There is one new insignificant activities as a result of this project. That is a 10,000 gallon ammonia tank. 3.5 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. This permit uses an appendix for specific calculation procedures from 40 CFR pt. 60, subp. TT. These procedures are too complex to enter into Delta and must go in an appendix. Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit and where no testing or tracking specific to a unit is in the permit (thereby reducing the likelihood that there where will be further unit-specific requirements later). This is the case for the requirements at GP018 (CEM general provisions), GP 019 (Main CHP), and GP020 (boilers subject to 40 CFR pt. 63, subp. JJJJJJ). 3.6 Comments Received Public Notice Period: October 31, 2014 December 1, 2014 EPA 45-day Review Period: October 31, 2014 December 16, 2014 During the air permit public notice, the MPCA received 3 comment letters. In general, the 3 comment letters were concerned about the local air quality impacts from the project and asked for a public informational meeting. The comments received are found in the Board Packet labeled as Appx A to Attch 2 Permit List of Comment. The response to comments are found in the Board Packet labeled as Appx B to Attch 2 Permit Response to Comments. A public notice for the public information Technical Support Document, Permit Action Number: Page 22 of 25

199 199 meeting was placed in the Star Tribune on December 22, The public information meeting will be conducted on January 22, Changes to the permit were not made as a result of the comments. 4. Permit Fee Assessment In the Central files is found the MPCA s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R The permit action includes one permit application, received after the effective date of the rule (July 1, 2009). The action includes an administrative amendment and a major amendment. The administrative amendment (DQ 4826) is a name change of the steam plant operator. The major amendment contains limits to avoid PSD (CO and NOx) (10 pts.), NSPS IIII, NSPS KKKK, NESHAP JJJJJJ, and NESHAP ZZZZ review (40 pts.) and an EAW triggered by exceeding the GHG threshold (subp. 15B) (70 pts.). This is for DQ It is noted that this permit action is the resubmittal of DQ 4572 which was returned as incomplete. 5. Conclusion Based on the information provided by the University of Minnesota Twin Cities, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Bruce Braaten (permit engineer) Brent Rohne (enforcement) Marc Severin (compliance) Tarik Hanafy (peer reviewer) Beckie Olson (permit writing assistant) Laurie O Brien (administrative support) AQ File No. 86TC; DQ 4897 Attachments: 1. PTE Summary and Calculation Spreadsheets 2. Facility Description and CD-01 Forms 3. Environmental Justice i. EPA ii. University of Minnesota Outreach Memorandum Technical Support Document, Permit Action Number: Page 23 of 25

200 200 Attachment 1 PTE Summary and Emissions Increase Calculation Spreadsheets Available Electronically in the Central File of Delta Attachment 2 - Facility Description and CD-01 Forms Available electronically in the Facility Description of Delta CD-01 Forms available electronically in the Central File of Delta, within the permit action Attachment 3 Environmental Justice From: Rineheart, Rachel [mailto:rineheart.rachel@epa.gov] Sent: Tuesday, August 19, :01 PM To: Olson, Beckie (MPCA); Darrow, Jennifer Subject: RE: Environmental Justice - Hennepin County, MN There may be EJ concerns in this area. From: Olson, Beckie (MPCA) [mailto:beckie.olson@state.mn.us] Sent: Tuesday, August 19, :51 AM To: Rineheart, Rachel; Darrow, Jennifer Subject: Environmental Justice - Hennepin County, MN Hello. The MPCA intends to begin work on issuing a Major Modification for the Part 70 Air Emissions Permit to University of MN - Twin Cities located at 202 Morrill Hall Minneapolis, MN (Hennepin County). Is this an area where environmental justice might be an issue to consider? If you have an interest in this proposed project, please contact the assigned permit engineer, Bruce Braaten, either by phone at or by at bruce.braaten@state.mn.us Thank you, Beckie Olson State Programs Administrator Technology Specialist St. Paul Office beckie.olson@state.mn.us

201 201 September 22, 2014 TO: FROM: RE: Mike Austin Jan Morlock Outreach to date related to Combined Heat and Power facility December, 2010: first climate action plan published for the Twin Cities Campus, a roadmap for UMTC to reduce carbon footprint by half, by 2020; and to reach climate neutrality by Spring, 2011: proposal developed for a Combined Heat and Power Facility on the site of the Old Main steamplant. June, 2011: an outreach plan is developed, and informal and one-on-one outreach about the project begins. Includes legislative, city, neighborhood community, and interest group contacts. (See Draft Communications and Action Plan. ) Community organizations were invited to let us know if they would like a visit at a meeting of their organization. July 6, 2011: Board of Regents reviews preliminary 2012 capital request, which includes Combined Heat and Power Facility. July, 2011: local community and general public is invited to two community information meetings about the project. Outreach list includes neighborhood community contacts in the West Bank and three Southeast Minneapolis neighborhoods; City of Minneapolis; Hennepin County; potentially interested local, regional, state agencies and MNRRA; environmental interest groups; and state legislators for this area. Meeting notices were sent to neighborhood and business associations, and community lists, asking that they post and share. August 10 and August 18, 2011: community information meetings were held in the evening at Sanford Hall dining room, adjacent to the site for the proposed Combined Heat and Power facility. Events included presentation, discussion and Q&A, and a walking tour to view the site. Eighteen people attended the first meeting, twelve of whom had no affiliation with the project; Fourteen attended the second meeting, six of whom were not affiliated with UMN or the project. Those in attendance included neighborhood, environmental organization, public agency representatives, media, and elected officials. November, 2013: Ancillary site work began in the area around the Old Main site. Neighborhood organizations were contacted by to advise them of the activity. September, 2014: Permit amendment application has been accepted by MPCA, and a new round of community engagement begins.

202 202

203 ATTACHMENT This map shows the underground steam distribution system. Also shown is the location of the existing SE Steam Plant and the Old Main Plant (proposed project).

204 204

205 ATTACHMENT Combined Heat and Power Plant Fact Sheet The University s ability to deliver on our mission of research and discovery, teaching and learning, and public service and outreach depends on reliable and efficient facilities. To that end, the University is revitalizing a century old utility building to house a Combined Heat and Power Plant (CHP) to provide the campus with dependable sources of power and steam, in a cost-effective and sustainable manner. In 2011 the University developed a climate action plan for the Twin Cities Campus (z.umn.edu/cap). This plan is a roadmap to reduce campus emissions in half by 2020 and to reach climate neutrality by A steppingstone toward these goals is the addition of CHP, a highly efficient facility that uses natural gas to generate electricity and steam simultaneously ( cogeneration ) for the Twin Cities Campus. Steam is used to heat and cool buildings as well as to sterilize lab and medical equipment. The University s Southeast Steam Plant, presently the primary source of steam for the East and West Bank campuses and the University of Minnesota Medical Center, will become the secondary source of steam, as a back-up to the CHP facility. The circulating fluidized bed (CFB) boiler at the Southeast Steam Plant, designed to burn a variety of fuels, will no longer be the primary utility. Two other aging coal-fired boilers at the Southeast Steam Plant will be eliminated. CHP will be installed in an existing utility building, called Project Site the Old Main Steam Plant, just west of the Dinkytown Bikeway Bridge and the Education Sciences Building. The Project Build a modern and highly efficient Combined Heat and Power Plant in the Old Main building by adding a 25 megawatt combustion turbine with heat recovery steam generator to both produce steam to heat campus and electricity to power campus. Stabilize the Old Main Building with the installation of a new roof and windows, tuck-pointing, and the removal of hazardous materials. The Benefits Reliability Meets current and projected campus heating (through steam) needs until Improves reliability of steam for Minneapolis campus by having production ability in two locations instead of one. Replaces inefficient and unreliable 1940s-era coal burners. Cost-effective Reduces overall University utility costs by up to $2 million per year.

206 Delivers a 30 year Lifecycle Savings vs. the cost of traditional boiler of up to $170 million. Hedges against future electrical cost increases. 206 Sustainability Moves the University toward its long-term climate action plan goals of reducing the campus carbon footprint by half by 2020, and reaching climate neutrality by Reduces the University s net carbon footprint by an estimated 65,000 metric tons of CO 2 by efficiently using waste heat created from generating electricity. Restores Old Main, a 100 year old building that has sat largely vacant for more than a decade. Additional Information Rendering of Finished Exterior Project schedule and progress updates at Information on the air permit at Information on the Environmental Assessment Worksheet at For more project information please contact: Jan Morlock Director of Community Relations jam@umn.edu Michael Berthelsen Associate Vice President, Facilities Management berth004@umn.edu Page 2 of