Air Individual Permit Moderate Amendment 01700011-101 to ...Vaporizer EQUI 2: LNG Vaporizer sends to...

Air Individual Permit Moderate Amendment

01700011-101 Permittee: Northern Natural Gas Co - Wrenshall LNG

Facility name: Northern Natural Gas Co - Wrenshall LNG 2301 County Road 1 Wrenshall, MN 55797-8759 Carlton County

Operating permit issuance date: October 26, 2011 Expiration date: October 26, 2016 * All Title I Conditions do not expire Moderate Amendment: September 19, 2017 Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR *The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received April 12, 2016.) 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. 01700011-005 and authorizes the Permittee to construct and operate new units at the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. 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 § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Signature: Carolina Espejel-Schutt This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 4. Summary of subject items ........................................................................................................................................... 6 5. Limits and other requirements .................................................................................................................................... 7 6. Submittal/action requirements ................................................................................................................................. 25 7. Appendices ................................................................................................................................................................. 27

Appendix A. Insignificant Activities and General Applicable Requirements ............................................................ 27 Appendix B. Units Authorized for Construction and Operation .............................................................................. 28 Appendix C. Turbine Stack Parameters for National Ambient Air Quality Standards (NAAQS) Compliance .......... 29 Appendix D. Carbon Dioxide Equivalent Calculation Equations .............................................................................. 30

Permit issued: September 19, 2017 01700011-101 Permit expires: October 26, 2016 Page 3 of 31

1. Permit applications table

Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 04/05/2010 01700011- 005 Moderate Amendment 12/20/2016 01700011-101


2. Where to send submittals

Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, 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. 20460

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term

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

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)

mailto:[email protected]:[email protected]://www.pca.state.mn.us/nwqh472


3. Facility description

The Northern Natural Gas Co - Wrenshall LNG (Facility) is located at 2301 County Road 1 in Wrenshall, Carlton County, Minnesota. The facility is a natural gas plant that is used to liquefy and store natural gas for later vaporization and distribution into underground pipelines. The facility emission sources consist of two natural gas-fired turbines, three natural gas-fired vaporizers, a 26,460,000 gallon LNG storage tank, a 11,700 gallon ethylene storage tank, a 5,900 gallon pentane storage tank, a 2,000 gallon butane storage tank, a 4,050 gallon propane storage tank, natural gas flares which combust excess gases from each tank, and a diesel fire pump. The primary emissions are nitrogen oxides (NOx), carbon monoxide (CO), and greenhouse gases (CO2e) from the turbines, flares, vaporizers, and fire pump. The facility also has equipment that qualifies as insignificant activities under Minn. R. 7007.1300. The facility assumes a limit on CO2e to remain a synthetic minor source under New Source Review/Prevention of Significant Deterioration (NSR/PSD). The facility is a major source under Part 70 (Title V) regulations and an area source under the federal National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR pt. 63). Amendment Description

This permit action is a moderate amendment that authorizes construction and operation of a cold-box separator and associated heat exchangers. Included in this project is construction and operation of a liquid “heavies” knockout storage tank (EQUI 17), a natural gas-fired flare (TREA 4) to control tank off-gas emissions, and a stack/vent (STRU 8). Emission increases associated with this project is mainly from combustion of the Cold Box flare and, to a lesser extent, the emissions from the tank. No emissions are associated with the cold-box separator or heat exchanger. The anticipated emissions increases are such that the facility remains below NSR/PSD thresholds.


4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

TFAC 1: Northern Natural Gas Co - Wrenshall LNG

ACTV 1: All IAs COMG 1: Natural gas-fired Vaporizers

has members

EQUI 1, EQUI 2, EQUI 3

EQUI 1: LNG Vaporizer sends to STRU 4: LNG Vaporizer



EQUI 4: LNG sends to STRU 5: Storage Tank Flare

EQUI 4: LNG is controlled by

TREA 2: Storage Tank Flare

EQUI 5: Butane is controlled by


EQUI 6: Natural Gas-Fired Turbine (ASP-021), 08/01/66

sends to STRU 6: Natural Gas-Fired Turbine

EQUI 7: Natural Gas-Fired Turbine (ASP-339), 11/01/73

sends to STRU 7: Natural Gas-Fired Turbine

EQUI 8: Diesel Fire Pump

sends to STRU 1: Emergency Fire Pump

EQUI 9: Propane is TREA 2:

SI ID: Description

Relationship Type

Related SI ID: Description

controlled by

Storage Tank Flare

EQUI 10: Ethylene is controlled by


EQUI 11: Pentane is controlled by


EQUI 17: Cold Box Knockout Tank

sends to STRU 8: Cold Box Flare

EQUI 17: Cold Box Knockout Tank

is controlled by

TREA 4: Cold Box Flare

STRU 1: Emergency Fire Pump

STRU 2: LNG Vaporizer STRU 3: LNG Vaporizer STRU 4: LNG Vaporizer STRU 5: Storage Tank Flare

STRU 6: Natural Gas-Fired Turbine

STRU 7: Natural Gas-Fired Turbine

STRU 8: Cold Box Flare TREA 2: Storage Tank Flare

TREA 4: Cold Box Flare

Permit Issued: September 19, 2017 01700011-101 Permit Expires: October 26, 2016 Page 7 of 31

5. Limits and other requirements

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 1 01700011 Northern Natural

Gas Co - Wrenshall LNG

5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the following: Appendix A: Insignificant Activities and General Applicable Requirements; Appendix B: Units Authorized for Construction and Operation; Appendix C: Turbine Stack Parameters for NAAQS Compliance; and Appendix D: Carbon Dioxide Equivalent Calculation Equations. [Minn. R. 7007.0800, subp. 2]

5.1.2 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

5.1.3 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.4 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

5.1.5 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

5.1.6 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

5.1.7 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

5.1.8 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. 7011.0150. [Minn. R. 7011.0150]

5.1.9 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010-7030.0080]

5.1.10 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

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

5.1.12 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]

5.1.13 Performance Test Notifications and Submittals: Performance Test Notification and 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 The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

5.1.14 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

5.1.15 Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]

5.1.16 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

5.1.17 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

5.1.18 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.19 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

5.1.20 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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 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. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

5.1.21 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. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

5.1.22 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

5.1.23 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

5.1.24 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

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

5.1.26 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.27 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

5.1.28 The parameters used in NOx modeling for Permit No. 01700011-005 are listed in Appendix C of this permit. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.29 Modeling Triggers: For changes that do not require a permit amendment and affect any modeled parameter documented in Appendix C, or are an addition to the information documented in Appendix C, a Remodeling Submittal requirement is not triggered at the time of the change. The Permittee shall keep updated records on site of all parameters and emission rates. The Permittee shall submit any changes to parameters and emission rates with the next required Remodeling Submittal. For changes that require a minor, moderate, or major permit amendment and affect any modeled parameter documented in Appendix C, or are an addition to the information documented in Appendix C, a Remodeling Submittal requirement is triggered. The Permittee shall include previously made changes to parameters and emission rates that did not trigger a Remodeling Submittal. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.30 Remodeling Submittal: The Permittee must submit to the Commissioner for approval changes meeting the above criteria and must wait for a written approval before making such changes. For minor amendments, written approval of the modeling may be given before permit issuance; however, this approval applies only to the modeling and not to any other changes. The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature,


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. The plume dispersion characteristics due to the revisions of the information must be equivalent to or better than the dispersion characteristics modeled dated 3/14/2003. The Permittee shall demonstrate this equivalency in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must submit full remodeling. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.31 Modeling at Reissuance: The Permittee shall submit an assessment with the reissuance application (due as stated elsewhere in this permit) that addresses any changes made during the permit term that did not require a permit amendment but that affected any modeled parameter or emission rate (including adding sources beyond those documented in Appendix C) and were not assessed in a later modeling submittal. The information in this submittal shall be the same as listed in the requirement entitled "Remodeling Submittal". [Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 1, Minn. Stat. 116.07, subd. 4a, Minn. R. 7007.0100, subp. 7(M), Minn. Stat. 116.07, subd. 9, Minn. R. 7009.0010-0080, Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0800, subp. 2]

COMG 1 GP001 Natural gas-fired

Vaporizers

5.2.1 Carbon Dioxide Equivalent


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.2.4 Monthly Recordkeeping: By the 15th day of each month, calculate and record the 12-month rolling sum of carbon dioxide equivalent emissions calculated during each of the previous 12 months. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.2.5 Fuel Allowed: Natural gas only. [Minn. R. 7007.0800, subp. 2] EQUI 1 EU004 LNG Vaporizer 5.3.1 The Permittee shall limit Particulate Matter


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 6 EU005 Natural Gas-Fired

Turbine (ASP-021), 08/01/66

5.8.1 The Permittee shall limit Opacity


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.8.7 Fuel Monitoring: The Permittee shall follow the applicable fuel

sulfur content monitoring requirements in 40 CFR Section 60.334(h) and shall monitor at the frequency specified in 40 CFR Section 60.334(i). 40 CFR Section 60.334(h)(3) allows the Permittee to not monitor total sulfur content of gaseous fuel if the fuel is shown to meet the definition of natural gas as defined in 40 CFR Section 60.331(u). [40 CFR 60.334(h)-(i), Minn. R. 7011.2350]

5.8.8 The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

5.8.9 Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

5.8.10 Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

5.8.11 No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

5.8.12 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 specified in 40 CFR Section 60.7(f)(1)-(3). [40 CFR 60.7(f), Minn. R. 7019.0100, subp. 1]

5.8.13 Turbine Component Replacement Recordkeeping: The Permittee shall record the date and nature of each component replacement no later than 5 business days after completion of each replacement. The Permittee shall also record the total cost of the component replacement compared to the cost of an entirely new stationary gas turbine (as defined at 40 CFR Section 60.4420). This record shall be made at least 30 days before a NOx test is conducted on the gas turbine (as a result of the component replacement), but no later than 180 days after each component replacement. [Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.0800, subp. 5]

EQUI 7 EU006 Natural Gas-Fired

Turbine (ASP-339), 11/01/73



Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.9.7 Fuel Monitoring: The Permittee shall follow the applicable fuel

sulfur content monitoring requirements in 40 CFR Section 60.334(h) and shall monitor at the frequency specified in 40 CFR Section 60.334(i). 40 CFR Section 60.334(h)(3) allows the Permittee to not monitor total sulfur content of gaseous fuel if the fuel is shown to meet the definition of natural gas as defined in 40 CFR Section 60.331(u). [40 CFR 60.334(h)-(i), Minn. R. 7011.2350]

5.9.8 The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

5.9.9 Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

5.9.10 Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

5.9.11 No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

5.9.12 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 specified in 40 CFR Section 60.7(f)(1)-(3). [40 CFR 60.7(f), Minn. R. 7019.0100, subp. 1]

5.9.13 Turbine Component Replacement Recordkeeping: The Permittee shall record the date and nature of each component replacement no later than 5 business days after completion of each replacement. The Permittee shall also record the total cost of the component replacement compared to the cost of an entirely new stationary gas turbine (as defined at 40 CFR Section 60.4420). This record shall be made at least 30 days before a NOx test is conducted on the gas turbine (as a result of the component replacement), but no later than 180 days after each component replacement. [Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.0800, subp. 5]

EQUI 8 EU007 Diesel Fire Pump 5.10.1 The Permittee shall limit Opacity


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Section 63.6640(f). Any operation other than emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1)(i) through (iii) of 40 CFR Section 63.6640(f), is prohibited. If the engine is not operated according to the requirements in (1)(i) through (iii) of 40 CFR Section 63.6640(f), the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines. The requirements in (f)(1)(i) through (iii) are as follows: (i)There is no time limit on the use of emergency stationary RICE in emergency situations; (ii) The emergency stationary RICE may be operated for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. 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 owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per year; and (iii) The emergency stationary RICE may be operated up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing. The 50 hours per year for non-emergency situations cannot be used for peak shaving or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. The Permittee may operate the emergency engine for a maximum of 15 hours per year as part of a demand response program if the regional transmission organization or equivalent balancing authority and transmission operator has determined there are emergency conditions that could lead to a potential electrical blackout, such as unusually low frequency, equipment overload, capacity or energy deficiency, or unacceptable voltage level. The engine may not be operated for more than 30 minutes prior to the time when the emergency condition is expected to occur, and the engine operation must be terminated immediately after the facility is notified that the emergency condition is no longer imminent. The 15 hours per year of demand response operation are counted as part of the 50 hours of operation per year provided for non-emergency situations. The supply of emergency power to another entity or entities pursuant to financial arrangement is not limited by 40 CFR Section 63.6640(f)(1)(iii), as long as the power provided by the financial arrangement is limited to emergency power. [40 CFR


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 63.6640(f)(1), Minn. R. 7011.8150]

5.10.9 The Permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR 63.6625(f), Minn. R. 7011.8150]

5.10.10 The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change every 500 hours of operation or annually, whichever comes first. The oil analysis must be performed at the same frequency specified for changing the oil. The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If none of these condemning limits are exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. [40 CFR 63.6625(j), Minn. R. 7011.8150]

5.10.11 The Permittee shall demonstrate continuous compliance with each emission limitation and operating limitation that applies according to methods specified below. The Permittee shall demonstrate compliance with the Work or Management Practices as follows: 1) Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or 2) Develop and follow the Permittee's own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. [40 CFR 63.6640(a), Minn. R. 7011.8150]

5.10.12 The Permittee shall be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply at all times. The Permittee shall also keep the following records: 1) A copy of each notification and report that was submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted, according to the requirement in 40 CFR Section 63.10(b)(2)(xiv); 2) Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation monitoring equipment; 3) Records of all required maintenance performed on the air pollution control and monitoring equipment; and 4) Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.6605, 40 CFR 63.6655(a), Minn. R. 7011.8150]

5.10.13 The Permittee shall keep records of the Work or Management Practices required in Table 6 of 40 CFR pt. 63, subp. ZZZZ to show continuous compliance with each operating requirement that applies. [40 CFR 63.6655(d), Minn. R. 7011.8150]

5.10.14 The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that operation and maintenance of the stationary RICE and after-treatment control device (if any) was done according to the Permittee's own maintenance plan. [40 CFR 63.6655(e)(3), Minn. R. 7011.8150]

5.10.15 The Permittee shall keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engines are used for demand response operation, the owner or operator must keep records of the notification of the emergency situation, and the time the engine was operated as part of demand response. [40 CFR 63.6655(f)(1), Minn. R. 7011.8150]

5.10.16 The Permittee shall report each instance in which each operating requirement that applies was not met. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in 40 CFR Section 63.6650. [40 CFR 63.6640(b), Minn. R. 7011.8150]

5.10.17 Each affected source that has obtained a Title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR Sections 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). [40 CFR 63.6650(f), Minn. R. 7011.81550]

5.10.18 Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), 40 CFR 63.6660, Minn. R. 7019.0100, subp. 2(B)]

5.10.19 Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation standard. Such concealment includes, but is not limited to: (1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

5.10.20 Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3)& Minn. R. 7011.7000]

5.10.21 The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard. [40 CFR 63.5(b)(4), Minn. R. 7011.7000]

5.10.22 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major-emitting or reconstructs an affected source that is not major-emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b). [40 CFR 63.5(b)(4)& Minn. R. 7011.7000]

5.10.23 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b), Minn. R. 7011.7000]

5.10.24 Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). The Permittee may use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii). [40 CFR 63.6(f)(2) & Minn. R. 7011.7000]

5.10.25 Finding of compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard. [40 CFR 63.6(f)(3) & Minn. R. 7011.7000]

5.10.26 Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Commissioner or the Administrator, shall submit a site-specific test plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). [40 CFR 63.7(c)(2) & Minn. R. 7017.2015]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.10.27 Approval of site-specific test plan. The Administrator will notify the

Permittee of approval or intention to deny approval of the site-specific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. [40 CFR 63.7(c)(3) & Minn. R. 7017.2015]

5.10.28 Performance testing facilities. The Permittee, at the request of the Commissioner or the Administrator, shall provide performance-testing facilities as specified in 40 CFR Section 63.7(d). [40 CFR 63.7(d), Minn. R. 7017.2015]

5.10.29 Conduct of performance tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). [40 CFR 63.7(e)(2) & Minn. R. 7017.2015]

5.10.30 Unless otherwise specified in a relevant standard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). [40 CFR 63.7(e)(3) & Minn. R. 7017.2015]

5.10.31 Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwise approved by the Commissioner or Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The Permittee shall report the results of the performance test to the Commissioner or Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. [40 CFR 63.7(g), Minn. R. 7017.2015]

5.10.32 Waiver of performance tests. Until a waiver of a performance testing requirement has been granted by the Commissioner or the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). [40 CFR 63.7(h), Minn. R. 7017.2015]

5.10.33 Notification of Change. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(g), Minn. R. 7019.0100]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.10.34 The Permittee shall submit reports to the Commissioner and shall

send a copy of each report to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]

5.10.35 Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in the relevant standard. [40 CFR 63.10(d)(1) & Minn. R. 7019.0100]

5.10.36 Reporting results of performance tests. The Permittee shall report the results of any performance test under 40 CFR Section 63.7 to the Administrator. The Permittee shall report the results of the performance test to the Administrator (or the State with an approved permit program) before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing by the Administrator. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h). [40 CFR 63.10(d)(2)& Minn. R. 7019.0100]

5.10.37 Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. [40 CFR 63.10(d)(4)& Minn. R. 7019.0100]

EQUI 9 TK005 Propane 5.11.1 The Permittee shall equip the storage vessel with a permanent

submerged fill pipe or shall comply with the requirements of Minn. R. 7011.1505, subp. 3(C). [Minn. R. 7011.1505, subp. 3(B)]

EQUI 10 TK002 Ethylene 5.12.1 The Permittee shall equip the storage vessel with a permanent


EQUI 11 TK003 Pentane 5.13.1 The Permittee shall equip the storage vessel with a permanent


EQUI 17 Cold Box

Knockout Tank

5.14.1 The Permittee shall equip the storage vessel with a permanent submerged fill pipe or shall comply with the requirements of Minn. R. 7011.1505, subp. 3(C). [Minn. R. 7011.1505, subp. 3(B)]

5.14.2 The Permittee is authorized to construct and operate EQUI 17 as


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation defined by the emissions unit information in Appendix B of this permit within 5 years of issuance of Air Emissions Permit No. 01700011-101. The unit shall meet all the requirements of this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 2 CE001 Storage Tank

Flare



Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation stating no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

6.1.3 The Permittee shall submit a compliance certification: Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R. 7007.0800, subp. 6(C)]

EQUI 17 Cold Box

Knockout Tank

6.2.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800, subp. 16(L)]

6.2.2 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a. [Minn. R. 7007.0800, subp. 16(L)]

TREA 4 Cold Box Flare 6.3.1 The Permittee shall submit a notification of the date construction

began: Due 30 calendar days after Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800, subp. 16(L)]

6.3.2 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a. [Minn. R. 7007.0800, subp. 16(L)]


7. Appendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. Rule description of the activity General applicable requirement Minn. R. 7007.1300, subp. 3(A) Fuel Use: space heaters fueled by

kerosene, natural gas, or propane, less than 420,000 Btu/hr Natural gas-fired space heaters with a total rated heat input of 0.040 MMBtu/hour.

PM


Appendix B. Units authorized for construction and operation The table below summarizes which units are authorized to be constructed and operated as a result of this permit action. New, modified, or reconstructed affected sources will require notification of construction and startup per Minn. R. 7007.0800, subp. 16(L) and are subject to the standards in the permit. Table 1: New units authorized for construction and operation under Permit No. 01700011-101 Subject Item Description Manufacturer Model Capacity EQUI 17 Cold Box Knockout Tank N/A N/A 5,999 gallons

TREA 4 Cold Box Flare Zeeco Vari Jet 145 MMBtu/hr


Appendix C: Turbine Stack Parameters for National Ambient Air Quality Standards (NAAQS) Compliance

Source ID Stack/Vent ID Stack Height (ft) Stack Temp (°F) Flow Rate (acfm) Stack Diameter (ft) EQUI 6 STRU 6 55.0 750.0 81,500 3.3 x 4 EQUI 7 STRU 7 55.0 750.0 81,500 3.3 x 4


Appendix D: Carbon Dioxide Equivalent (CO2e) Calculation Equations The Permittee shall use the following equations to calculate Carbon Dioxide Equivalent (CO2e) emissions for compliance with the COMG 1 CO2e limit. Note: Global warming potentials (GWPs) for methane and nitrous oxide have changed since issuance of Permit No 01700011-005. CO2e = [CH4 (NG) x GWPCH4] + [N2O (NG) x GWPN2O] + CO2 (NG) CO2e (12) = sum of the values of CO2e calculated over the previous 12 calendar months (12- month rolling sum) CH4 (NG) = QNG x EFCH4-NG ÷ 2000 N2O (NG) = QNG x EFN2O-NG ÷ 2000 CO2 (NG) = QNG x EFCO2-NG ÷ 2000 Where: CO2e = quantity of CO2e emitted during the previous calendar month (tons) CH4 (NG) = quantity of methane generated by combustion of natural gas during the previous month (tons) N2O (NG) = quantity of nitrous oxide generated by combustion of natural gas during the previous month (tons) QNG = quantity of natural gas combusted during the previous calendar month (MMcf) EFCH4-NG = MPCA-approved emission factor for calculating methane emissions from combustion of natural gas. At the time of permit issuance, the MPCA-approved emission factor is 2.27 lb/MMcf.1 If testing is done, and use of the tested values would result in a higher CH4 emission factor, the higher emission factor should be used. If testing results in a lower CH4 emission factor, the emission factor in the permit (the higher factor) should be used until a permit amendment is issued authorizing use of the lower emission factor. If Table C-2 of Subpart C to 40 CFR Part 98 is changed to reflect a different emission factor, the revised emission factor should be used in the derivation of the emission factor used herein. EFN2O-NG = MPCA-approved emission factor for calculating nitrous oxide emissions from combustion of natural gas. At the time of permit issuance, the MPCA-approved emission factor is 0.227 lb/MMcf.2 If testing is done, and use of the tested values would result in a higher N2O emission factor, the higher emission factor should be used. If testing results in a lower N2O emission factor, the emission factor in the permit (the higher factor) should be used until a permit amendment is issued authorizing use of the lower emission factor. If Table C-2 of Subpart C to 40 CFR Part 98 is changed to reflect a different emission factor, the revised emission factor should be used in the derivation of the emission factor used herein. EFCO2-NG = MPCA-approved emission factor for calculating carbon dioxide emissions from combustion of natural gas. At the time of permit issuance, the MPCA-approved emission factor is 120161.8 lb/MMcf.2 If testing is done, and use of the tested values would result in a higher CO2 emission factor, the higher emission factor should be used. If testing results in a lower CO2 emission factor, the emission factor in the permit (the higher factor) should be used until a permit amendment is issued authorizing use of the lower emission factor. If Table C-1 of Subpart C to 40 CFR Part 98 is changed to reflect a different emission factor, the revised emission factor should be used in the derivation of the emission factor used herein. 1 Converted from the value provided in Table C-2 of Subpart C to 40 CFR Part 98 (0.001 kg/MMBtu), using conversion factors of 0.001028 MMBtu/ft3 and 2.20462 kg/lb 2 Converted from the value provided in Table C-1 of Subpart C to 40 CFR Part 98 (0.001 kg/MMBtu), using conversion factors of 0.001028 MMBtu/ft3 and 2.20462 kg/lb 3, 4 Table A-1 from 40 CFR pt. 98, subp. A


GWPCH4 = global warming potential of methane (unit less). At the time of permit issuance, the GWP of methane is 25. 3 If Subpart A of 40 CFR Part 98 is changed to reflect a different GWP, the revised GWP should be used. GWPN2O = global warming potential of nitrous oxide (unit less). At the time of permit issuance, the GWP of nitrous oxide is 2984. If Subpart A of 40 CFR Part 98 is changed to reflect a different GWP, the revised GWP should be used.

Technical Support Document, Permit Number: 01700011-101 Page 1 of 6

Technical Support Document For

Air Emission Permit No. 01700011-101 This technical support document (TSD) is intended for all parties interested in the 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. 7007.0850, 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 determination to issue the permit. 1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 4922 - Natural Gas Transmission)

Northern Natural Gas Co 1111 S 103rd St Omaha, Nebraska 68124-1072

Northern Natural Gas Co - Wrenshall LNG Plant 2301 County Road 1 Wrenshall, MN 55797-8759 Carlton County

Contact: Kelly Henry Phone: 651-456-1712

1.2 Facility description

The facility is a natural gas plant that is used to liquefy and store natural gas for later vaporization and distribution into underground pipelines. The facility emission sources consist of two natural gas-fired turbines, three natural gas-fired vaporizers, a 26,460,000 gallon LNG storage tank, a 11,700 gallon ethylene storage tank, a 5,900 gallon pentane storage tank, a 2,000 gallon butane storage tank, a 4,050 gallon propane storage tank, natural gas flares which combust excess gases from each tank, and a diesel fire pump. The primary emissions are nitrogen oxides (NOx), carbon monoxide (CO), and greenhouse gases (CO2e) from the turbines, flares, vaporizers, and fire pump. The facility also has equipment that qualifies as insignificant activities under Minn. R. 7007.1300. The facility assumes a limit on CO2e to remain a synthetic minor source under New Source Review/Prevention of Significant Deterioration (NSR/PSD). The facility is a major source under Part 70 (Title V) regulations and an area source under the federal National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR pt. 63).

1.3 Description of the activities allowed by this permit action This permit action is a moderate amendment that authorizes the construction and operation of a cold box separator, a storage tank for liquid “heavies” collection (EQUI 17), a natural gas-fired flare (TREA 4) to control emissions from the tank, and heat exchangers. This addition to the process assists in removal of unwanted, condensable contaminates (“heavies”) from the natural gas prior to storage and transfer. In addition, allowable SO2 emissions from the facility were reduced due to the reduction in allowable sulfur content in diesel fuel required by rule. Because this is not part of the project but rather a regulatory update, this is not reflected in the emission totals in Table 3 and 4 below. Regardless, the anticipated emissions increases are such that the facility remains below NSR/PSD thresholds. The MPCA has a combined operating and construction-permitting program under Minn. R. ch. 7007 and Minn. R. 7007.0800. Under that authority, this permit action authorizes construction.


1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action

Date received Application/notification type and description 12/19/2016 Moderate Amendment (IND20160002)

1.5 Facility emissions Table 3. Title I emissions summary

Pollutant

Unlimited potential emissions from the modification (tpy)

Limited potential emissions from the modification (tpy)

NSR/112(g) threshold for new major source (tpy)

NSR/112(g) review required? (yes/no)

PM 4.73 4.73 250 No PM10 4.73 4.73 250 No PM2.5 4.73 4.73 250 No NOX 62.28 62.28 250 No SO2 0.37 0.37 250 No CO 52.32 52.32 250 No Ozone (VOC) 3.43 3.43 250 No Lead 0.00031 0.00031 250 No Total HAP 7.03 7.03 25 No Single HAP 1.93 1.93 10 No CO2e* 67,884.95 67,884.95 100,000 No

*Carbon dioxide equivalents as defined in Minn. R. 7007.0100. Table 4. Non-Title I emissions increase summary

Pollutant

After change (lb/hr)

Before change (lb/hr)

Net change* (lb/hr)

Insignificant modification thresholds (lb/hr )

Type of amendment (minor or moderate)

PM10 1.08 0 1.08 0.855 3.42 Minor NOx 14.22 0 14.22 2.28 9.13 Moderate SO2 0.8 0 0.8 2.28 9.13 N/A CO 11.94 0 11.94 5.70 22.80 Minor VOC 0.78 0 0.78 2.28 9.13 N/A Lead 0 0.000071 0.000071 0.025 0.11 N/A

*The term ‘Net Change’ is not equivalent to ‘Net Emissions Increase’ as defined at 40 CFR Section 52.21(b)(3).

Table 5. Facility classification

Classification Major Synthetic minor/area Minor/area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to permit

∑ The permit has been updated to reflect current MPCA templates and standard citation formatting; ∑ Permit conditions migrated from Delta database into the MPCA’s current Tempo database;


∑ The new emission unit to be constructed and operated (EQUI 17), associated control equipment (TREA 4), and stack/vent (STRU 8) were added to the permit with applicable requirements;

∑ Added requirements for notification of construction and initial start-up; ∑ Control equipment (CE001, TREA 2) that migrated as an emission unit was deleted and PTE data entered

at the TREA level; ∑ Fuel sulfur content limit with an effective date of June 1, 2012 is specified in EQUI 8 requirements; ∑ Applicable NSPS and NESHAP general provisions (Subpart A) were specified in the permit; and ∑ Some requirements have been reordered to help with clarity (i.e. limits specific to several units are

grouped and/or requirements that do not apply to all group members were removed). 2. Regulatory and/or statutory basis

2.1 New source review (NSR) The permit carries forward limits on the facility such that it remains a synthetic minor source under New Source Review regulations. No changes are authorized by this permit.

2.2 Part 70 permit program The facility is a major source under the Part 70 permit program.

2.3 New source performance standards (NSPS) The Permittee has stated that portions of the facility are subject to 40 CFR pt. 60, subp. GG - Standards of Performance for Stationary Gas Turbines. No new NSPS standards apply as a result of this modification.

2.4 National emission standards for hazardous air pollutants (NESHAP)

The facility is an area source of HAPs and is subject to 40 CFR pt. 63, subp. ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. No new NESHAP standards apply as a result of this modification.

2.5 Minnesota state rules

Portions of the facility are subject to the following Minnesota Standards of Performance: ∑ Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment ∑ Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment ∑ Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment ∑ Minn. R. 7011.1505 Standards of Performance for Storage Vessels ∑ Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines ∑ Minn. R. 7011.2350 Standards of Performance for New Stationary Gas Turbines ∑ Minn. R. 7011.8150 Emission Standards for Hazardous Air Pollutants: Stationary Reciprocating

Internal Combustion Engines Table 6. Regulatory overview of units affected by the modification/permit amendment

Subject item* Applicable regulations Rationale EQUI 17 (Cold Box Knockout Tank)

Minn. R. 7011.1505, subp. 3(B) Standards of Performance for Storage Vessels. Determination of applicable limit from rule: ∑ the unit was constructed in 2017; and ∑ the capacity is greater than 2000 gallons but less than 40,000

gallons. TREA 4 (Cold Box Flare)

Minn. R. 7011.0610, subps. 1(A)(1) and 1(A)(2)

Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment. Flares reduce VOC and HAPs emissions but generate emissions of their own; therefore, this rule applies.


*Location of the requirement in the permit (e.g., EQUI 1, COMG 1, etc.). 3. Technical information

This permit action authorizes construction and operation of new equipment that increases facility emissions. The new flare that controls the gaseous emissions from the new liquid “heavies” knockout storage tank contributes to that increase. Originally, control equipment that had emissions as a result of its operation (flares, afterburners, etc.) were entered into the database as both an emission unit and control equipment. This was due to Delta (old database) not being able to catalog PTE data at the control equipment level. The new database (Tempo) is able to accommodate this, so the flare that migrated as an emission unit (Storage Tank Flare) was deleted and all PTE data and unit details were entered at the migrated TREA level. 3.1 Calculations of emissions increase analysis

The majority of the emissions as a result of this amendment are derived from the natural gas-fired flare. The flare consists of two pilot burners with a combined capacity of 145 MMBtu/hr (0.142 MMcf/hr). The flare was oversized to accommodate any emergency situation in which storage tank contents would have to be off-gassed. Emission factors were taken from EPA AP-42 Chapter 1.4, Tables 1.4-1 and 1.4-2 assuming a heating value of 1,020 Btu/scf for natural gas. Emissions calculations for the liquid knockout tank were done using TANKS software.

Attachment 1 to this TSD contains the Title I and non-Title I emissions increase calculations for this modification. These demonstrate that this modification is not a major modification under PSD and that the modification qualifies for a moderate amendment under Minn. R. 7007.1450.

3.2 Dispersion modeling The permit contains conditions that require the Permittee to conduct dispersion modeling for NOx if there are modifications to natural gas-fired turbines (EQUI 6 and EQUI 7) or the turbine stack parameters in Appendix C. Since this permit action does not contain modifications to the turbines or any associated stack parameter (stack height, exit temperature, etc.), this project does not trigger a NOx modeling resubmittal.

3.3 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. ∑ The kind of monitoring found on similar units elsewhere.

The table below summarizes the monitoring requirements associated with this amendment.


Table 7. Monitoring

Subject item* Requirement (rule basis)

What is the monitoring Why is this monitoring adequate?

TREA 4 (Liquid Knockout Tank Flare)

PM ≤ 0.30 gr/dscf Opacity ≤ 20 percent with exceptions [Minn. R. 7011.0610, subps. 1(A)(1) and 1(A)(2)]

None Fuel use for the flare is limited to natural gas only. Due to allowable fuels and equipment design, it is unlikely that either limit will be violated.

*Location of the requirement in the permit (e.g., EQUI 1, COMG 1, etc.).

3.4 Insignificant activities Northern Natural Gas Co - Wrenshall LNG Plant has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. No new insignificant activities are authorized by the permit action and existing units designated as insignificant activities remain unaffected.

3.5 Permit organization

In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo 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 the Requirements table in Tempo. 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 (Appendix D) for specific calculation procedures to calculate CO2e. These procedures are too complex to enter into Tempo and must go in an appendix.

3.6 Comments received

Due to this permit action being defined as a moderate amendment under Minn. R. 7007.1450, a public comment period is not required; however, an EPA review period is required and must be on review for the full 45-day period. EPA Review Period: July 17, 2017 – August 31, 2017 No comments were received by the MPCA from the EPA during the above 45-day review period.

4. Permit fee assessment Attachment 3 to this TSD contains 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. 7002.0019. This action does not include any new standards. The NSPS and NESHAP standards that apply are existing standards that already applied to the facility; therefore, they are not chargeable activities (i.e., the standard was not triggered by the changes requested in the permit applications).

5. Conclusion

Based on the information provided by Northern Natural Gas Co - Wrenshall LNG Plant, the MPCA has reasonable assurance that the operation of the emission facility, as described in the Air Emission Permit No. 01700011-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.


Staff members on permit team: Jacobe Timler (permit engineer) Adriane Lenshek (peer reviewer)

Mark Severin (performance testing) Steve Palzkill (enforcement)

Michaela Leach (permit writing assistant) Laurie O'Brien (administrative support)

TEMPO360 Activities: Moderate Amendment (IND20160002)

Attachments: 1. Emissions increase calculation spreadsheets

2. Requirements development report and subject item inventory/details 3. Points calculator

ATTACHMENT 1 EMISSIONS INCREASE CALCULATION SPREADSHEETS

(Available Electronically in Tempo Central File)

Title I and non-Title I Emissions Increase AnalysisNorthern Natural Gas - Wrenshall LNG PlantCombined PTE for Flare (TREA 4) and KO Tank (EQUI 17)

Fuel rate = 0.1422 MMcf/hrHeat input = 145.044 MMBtu/hr

Pollutant

Emission Factor (lb/MMcf)

Emission Rate (lb/hr)

Uncontrolled PTE (tpy)

Limited PTE (tpy)

NSR Threshold

NSR Review Required?

Insignificant Modification Threshold (< lb/hr)

Minor Amendment Threshold (< lb/hr)

Moderate Amendment Threshold (≥ lb/hr)

Insignificant/Minor/Moderate?

PM2.5 7.6 1.08 4.73 4.73 250 No N/A N/A N/A N/APM10 7.6 1.08 4.73 4.73 250 No 0.855 3.42 3.42 MinorSOx 0.6 0.09 0.37 0.37 250 No 2.28 9.13 9.13 Insignificant ModNOx 100 14.22 62.28 62.28 250 No 2.28 9.13 9.13 Moderate**VOC* 5.5 0.78 3.43 3.43 250 No 2.28 9.13 9.13 Insignificant ModLead 0.0005 7.11E-05 3.11E-04 0.00 250 No 0.025 0.11 0.11 Insignificant ModCO 84 11.94 52.32 52.32 250 No 5.7 22.8 22.8 MinorSingle HAP* N/A 0.44 1.94 1.94 10 No N/A N/A N/A N/ATotal HAP* N/A 1.61 7.04 7.04 25 No N/A N/A N/A N/A

*Includes emissions from KO tank**Moderate amendment required based on emissions increase

Hazardous Air Pollutants

Pollutant




Limited PTE (tpy)

2-Methylnaphthalene 2.40E-05 3.41E-06 1.49E-05 1.49E-053-Methylchloranthrene 1.80E-06 2.56E-07 1.12E-06 1.12E-067,12- Dimethylbenz(a)anthracene 1.60E-05 2.28E-06 9.97E-06 9.97E-06Acenaphthene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Acenaphthylene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Anthracene 2.40E-06 3.41E-07 1.49E-06 1.49E-06Benz(a)anthracene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Benzene 2.10E-03 2.99E-04 1.31E-03 1.31E-03Benzo(a)pyrene 1.20E-06 1.71E-07 7.47E-07 7.47E-07Benzo(b)fluoranthene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Benzo(g,h,i)perylene 1.20E-06 1.71E-07 7.47E-07 7.47E-07Benzo(k)fluoranthene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Butane 2.10E+00 2.99E-01 1.31E+00 1.31E+00Chrysene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Dibenzo(a,h)anthracene 1.20E-06 1.71E-07 7.47E-07 7.47E-07Dichlorobenzene 1.20E-03 1.71E-04 7.47E-04 7.47E-04Ethane 3.10E+00 4.41E-01 1.93E+00 1.93E+00Fluoranthene 3.00E-06 4.27E-07 1.87E-06 1.87E-06Fluorene 2.80E-06 3.98E-07 1.74E-06 1.74E-06Formaldehyde 7.50E-02 1.07E-02 4.67E-02 4.67E-02Hexane 1.80E+00 2.56E-01 1.12E+00 1.12E+00Indeno(1,2,3-cd)pyrene 1.80E-06 2.56E-07 1.12E-06 1.12E-06Naphthalene 6.10E-04 8.67E-05 3.80E-04 3.80E-04Pentane 2.60E+00 3.70E-01 1.62E+00 1.62E+00Phenanathrene 1.70E-05 2.42E-06 1.06E-05 1.06E-05Propane 1.60E+00 2.28E-01 9.97E-01 9.97E-01Pyrene 5.00E-06 7.11E-07 3.11E-06 3.11E-06Toluene 3.40E-03 4.83E-04 2.12E-03 2.12E-03

Emissions from the natural gas flare pilot burner.Northern Natural Gas - Wrenshall LNG PlantCombined PTE for Flare (TREA 4) and KO Tank (EQUI 17)

71.1 Mcf/hr natural gas per pilot 0.1422 MMcf/hr natural gas both pilots

Emission factors source: AP-42, Chapter 1.4, Tables 1 and 2

Flare

(assume continous operation) 0.0711 MMcf ng/hr 622.836 annual MMcf

72.522 MMBtu/hrEF PTE

PM2.5 7.6 lb/MMcf 2.37 tpy 0.54 lb/hrPM10 7.6 lb/MMcf 2.37 tpy 0.54 lb/hrSOx 0.6 lb/MMcf 0.19 tpy 0.04 lb/hrNOx 100 lb/MMcf 31.14 tpy 7.11 lb/hrVOC 5.5 lb/MMcf 1.71 tpy 0.39 lb/hrCO 84 lb/MMcf 26.16 tpy 5.97 lb/hrSingle HAP 0.0005 lb/MMcf 0.97 tpy 0.22 lb/hrTotal HAP 0.0005 lb/MMcf 3.51 tpy 0.80 lb/hr

Project PTE based on total pilot throughput: 1245.67 MMcf/rolling 12-mo periodtpy lb/hr

PM2.5 4.73 1.08PM10 4.73 1.08SOx 0.37 0.09NOx 62.28 14.22VOC 3.43 (VOC total also includes knock out tan 0.78CO 52.32 11.94Single HAP 1.94 (HAP total also includes knock out tan 0.442Total HAP 7.03 (HAP total also includes knock out tan 1.606

HAPs (both pilots)

Pollutant




2-Methylnaphthalene 2.40E-05 3.41E-06 1.49E-053-Methylchloranthrene 1.80E-06 2.56E-07 1.12E-067,12- Dimethylbenz(a)anthracene 1.60E-05 2.28E-06 9.97E-06Acenaphthene 1.80E-06 2.56E-07 1.12E-06Acenaphthylene 1.80E-06 2.56E-07 1.12E-06Anthracene 2.40E-06 3.41E-07 1.49E-06Benz(a)anthracene 1.80E-06 2.56E-07 1.12E-06Benzene 2.10E-03 2.99E-04 1.31E-03Benzo(a)pyrene 1.20E-06 1.71E-07 7.47E-07Benzo(b)fluoranthene 1.80E-06 2.56E-07 1.12E-06Benzo(g,h,i)perylene 1.20E-06 1.71E-07 7.47E-07Benzo(k)fluoranthene 1.80E-06 2.56E-07 1.12E-06Butane 2.10E+00 2.99E-01 1.31E+00Chrysene 1.80E-06 2.56E-07 1.12E-06Dibenzo(a,h)anthracene 1.20E-06 1.71E-07 7.47E-07Dichlorobenzene 1.20E-03 1.71E-04 7.47E-04Ethane 3.10E+00 4.41E-01 1.93E+00Fluoranthene 3.00E-06 4.27E-07 1.87E-06Fluorene 2.80E-06 3.98E-07 1.74E-06Formaldehyde 7.50E-02 1.07E-02 4.67E-02Hexane 1.80E+00 2.56E-01 1.12E+00Indeno(1,2,3-cd)pyrene 1.80E-06 2.56E-07 1.12E-06Naphthalene 6.10E-04 8.67E-05 3.80E-04Pentane 2.60E+00 3.70E-01 1.62E+00Phenanathrene 1.70E-05 2.42E-06 1.06E-05Propane 1.60E+00 2.28E-01 9.97E-01Pyrene 5.00E-06 7.11E-07 3.11E-06Toluene 3.40E-03 4.83E-04 2.12E-03

Knockout Tank PTENorthern Natural Gas - Wrenshall LNG PlantEQUI 17

Review mass liquid loading of constituents:

Mol wt.Nitrogen 28.01 not VOCCO2 44.01 not VOCMethane 16.04 not VOCEthylene 28.05 VOCEthane 30.07 not VOCPropane 44.1 VOCi-Butane 58.12 VOCn-Butane 58.12 VOCi-Pentane 72.15 VOCn-Pentane 72.15 VOCn-Hexane 86.18 VOCBenzene 78.11 VOCH2O 18.02 not VOC

Conservatively run TANKS assuming single component tank contents of n-Hexane.Per DES, tank characteristics are 25.33' L; 6.5' D; capacity of 5,999 gallons.

Per B&V Flaring and Trucking Information, maximum throughput is 0.3 gpmPotential continuous operation of 8760 hrs/yr, throughput is 157,680 galAssume total maximum turnovers of 26 based on 5,999 gal capacity of the tank.

TANKS result:Standing losses: 175.25 lbsWorking losses: 355.1448 lbsTotal losses: 530.3948 lbs

0.265197 tons, uncontrolled

These emissions would be routed to the 98% efficient flare under normal circumstances.Resulting controlled emissions would be: 0.005304 tons 0.001211 lb/hr

Facility Name: Facility ID: Subject Item ID

Fuel Type Annual ThroughputDefault High Heat

Value

Coal and Coke tons MMBtu/ton lb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)CO2e (metric

tons)Anthracite 25.09 228.60 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Bituminous 24.93 205.65 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Subbituminous 17.25 214.22 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Lignite 14.21 215.44 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Coal Coke 24.80 250.60 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Mixed (Commercial sector) 21.39 207.83 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Mixed (Industrial coking) 26.28 207.01 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Mixed (Industrial sector) 22.35 208.71 0.024 0.0035 0.00 0.00 0.00 0.00 0.00Mixed (Electric Power Sector) 19.73 210.59 0.024 0.0035 0.00 0.00 0.00 0.00 0.00

Natural Gas standard cubic feet (scf) MMBtu/scflb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)

CO2e (metric tons)

(Weighted US Average) 1,245,672,000.00 0.001026 116.98 0.0022 0.00022 74,753.70 1.41 0.14 74,830.74 67884.95

Petroleum Products gallons MMBtu/gallon lb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)CO2e (metric

tons)Distillate Oil No. 1 0.139 161.49 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Distillate Oil No. 2 0.138 163.05 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Distillate Oil No. 4 0.146 165.43 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Residual Fuel Oil No. 5 0.140 160.78 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Residual Fuel Oil No. 6 0.150 165.57 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Used Oil 0.138 163.14 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Kerosene 0.135 165.79 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Liquefied Petroleum Gases 0.092 136.05 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Propane 0.091 138.60 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Propylene 0.091 149.41 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Ethane 0.068 131.40 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Ethanol 0.084 150.88 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Ethylene 0.058 145.42 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Isobutane 0.099 143.17 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Isobutylene 0.103 151.81 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Butane 0.103 142.79 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Butylene 0.105 151.50 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Naptha (401 deg F) 0.139 168.04 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Pentates Plus 0.110 154.37 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Petrochemical Feedstocks 0.125 156.57 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Petroleum Coke 0.143 225.78 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Special Naptha 0.125 159.48 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Unfinished Oils 0.139 164.33 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Heavy Gas Oils 0.148 165.17 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Lubricants 0.144 163.74 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Motor Gasoline 0.125 154.81 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Aviation Gasoline 0.120 152.67 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Kerosene-Type Jet Fuel 0.135 159.22 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Asphalt and Road Oil 0.158 166.14 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00Crude Oil 0.138 164.33 0.0066 0.0013 0.00 0.00 0.00 0.00 0.00

Other Fuels - Solid tons MMBtu/ton lb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)CO2e (metric

tons)Municipal Solid Waste 9.95 200.11 0.071 0.0013 0.00 0.00 0.00 0.00 0.00Tires 28.00 189.53 0.071 0.0093 0.00 0.00 0.00 0.00 0.00Plastics 38.00 165.35 NA NA 0.00 0.00 0.00 0.00 0.00Petroleum Coke 30.00 225.78 NA NA 0.00 0.00 0.00 0.00 0.00

Other Fuels - Gaseous standard cubic feet (scf) MMBtu/scflb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)

CO2e (metric tons)

Blast Furnace Gas 0.000092 604.77 0.000049 0.00022 0.00 0.00 0.00 0.00 0.00Coke Oven Gas 0.00599 103.29 0.0011 0.00022 0.00 0.00 0.00 0.00 0.00Propane Gas 0.002516 135.50 NA NA 0.00 0.00 0.00 0.00 0.00Fuel Gas 0.001388 130.07 NA NA 0.00 0.00 0.00 0.00 0.00

Biomass Fuels - Solid tons MMBtu/ton lb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)CO2e (metric

tons)Wood and Wood Residuals (dry basis) 17.48 206.79 0.016 0.0079 0.00 0.00 0.00 0.00 0.00

Agricultural Byproducts 8.25 260.52 0.071 0.0093 0.00 0.00 0.00 0.00 0.00Peat 8.00 246.56 0.071 0.0093 0.00 0.00 0.00 0.00 0.00Solid Byproducts 10.39 232.61 0.071 0.0093 0.00 0.00 0.00 0.00 0.00

Biomass Fuels - Gaseous standard cubic feet (scf) MMBtu/scflb CO2/MMBtu lb CH4/MMBtu lb N2O/MMBtu CO2 (tons) CH4 (tons) N2O (tons) CO2e (tons)

CO2e (metric tons)

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