HomeMy Public PortalAboutExhibit MSD 89B - Bissell Air PermitExhibit MSD 896
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Missouri Department of dnr.mo.gov
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Michael L. Parson, Governor
FEB 2 0 2019
Ms. Rebecca Coyle
MSD — Bissell Point Wastewater Treatment Plant
10 East Grand Avenue
St. Louis, MO 63147
Re: MSD - Bissell Point Wastewater Treatment Plant, 510-0053
Permit Number: OP2019-005
Carol 5. Comer, Director
Dear Ms. Coyle:
Enclosed with this Ietter is your Part 70 operating permit. Please review this document carefully.
Operation of your installation in accordance with the rules and regulations cited in this document is
necessary for continued compliance. It is very important that you read and understand the
requirements contained in your permit.
This permit may include requirements with which you may not be familiar. If you would like the
department to meet with you to discuss how to understand and satisfy the requirements contained in
this permit, an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with
you. To request a CAV, please contact your local regional office or fill out an online request. The
regional office contact information can be found at http://dnr.mo.gov/regions/. The online CAV
request can be found at http://dnr.mo.gov/cav/compliance.htm.
You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557,
Jefferson City, MO 65102, as provided in RSMo 643.078.16 and 621.250.3. If you choose to appeal,
you must file a petition with the AHC within thirty days after the date this decision was mailed or the
date it was delivered, whichever date was earlier. if any such petition is sent by registered mail or
certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than
registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.
If you have any questions or need additional information regarding this permit, please do not
hesitate to contact Berhanu Getahun at the St. Louis Regional Office, 7545 S. Lindbergh, Suite
210, St. Louis, MO 63125, or by telephone at (314) 416-2960. You may also contact me with
the Department's Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102, or by
telephone at (573) 751-4817.
Sincerely,
AIR POLLUTION CONTROL PROGRAM
Michael J. Stansfield, P.
Operating Permit Unit Chief
MJS:bgj
Enclosures
c: PAMS File: 2007-06-088
0
Recycled paper
MISSOURI
DEPARTMENT OF
NATURAL RESOURCES
Air Pollution Control Program
IPA ] .Y
k ERI—WET OFEAnf iE
Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to operate the air
contaminant source(s) described below, in accordance with the laws, rules, and conditions set forth herein.
Operating Permit Number: OP Z 0
19-005
Expiration Date:FEB 2024
Installation ID: 510-0053
Project Number: 2007-06-088
Iu:stallatior Name and Address
MSD - Bissell Point
Wastewater Treatment Plant
10 East Grand Avenue
St. Louis, MO 63147
City of St. Louis
1Parensf Cc11Bapanv's Name and Address
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
Installation Description:
The Bissell Point Plant treats wastewater and sewage from the St. Louis area. The plant
incinerates the sludge produced during the treatment process. The installation is located in an
ozone non -attainment area and is a major source for nitrogen oxides and carbon monoxide.
FEB 2 0 2099
Effective Date Director or ]f signee
Department of Natural Resources
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 2
Installation ID: 510-0053 Project No. 2007-06-088
Table of Contents
4
EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS 5
H. PLANT WIDE EMISSION LIMITATIONS 6
III. EMISSION UNIT SPECIFIC EMMISSION LIMITATIONS 7
EPO3 THROUGH EPO6 — INCINERATORS 7
Permit Condition (EPO3 through EP06) - 001 7
10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants 7
40 CFR Part 61 Subpart C National Emission Standard for Beryllium 7
Permit Condition (EPO3 through EP06) - 002 8
10 CSR 10-6.060 Construction Permits Required 8
Construction Permit No. 95-05-068, Issued August 16, 1995 8
Permit Condition (EPO3 through EP06) - 003 9
10 CSR 10-6.060 Construction Permits Required 9
Construction Permit No. 95-05-068, Issued August 16, 1995 9
New Source Review Permit Amendment - Permit Number: 95-05-068A, Issued December 29, 2014 9
Control Device Requirement— Scrubbers 9
Permit Condition (EPO3 through EP06) - 004 10
10 CSR 10-6.191 Sewage Sludge Incinerators 10
10 CSR 10-6.191(3)(b) Operator Training and Qualifications — 40 CFR §§60.5130 through 60.5I60 10
Permit Condition (EPO3 through EP06) - 005 12
10 CSR 10-6.191 Sewage Sludge Incinerators 12
10 CSR 10-6.191(3)(C) Emission Limits, Emission Standards, Operating Limits, and Requirements — 40 CFR
§§60.5165 through 60.5181 12
Permit Condition (EPO3 through EP06) - 006 15
10 CSR 10-6.191 Sewage Sludge Incinerators 15
10 CSR 10-6.191(3)(D) Initial Compliance Requirements — 40 CFR §§60.5185 through 60.5200 15
10 CSR 10-6.191(3)(D) Continuous Compliance Requirements — 40 CFR §§60.5205 through 60.5215 15
Permit Condition (EPO3 through EP06) - 007 18
10 CSR 10-6.191 Sewage Sludge Incinerators 18
10 CSR 10-6.191(3XF) Performance Testing, Monitoring, and Calibration Requirements — 40 CFR §§60.5220
through 60.5225 18
Permit Condition (EPO3 through EP06) - 008 21
10 CSR 10-6.191 Sewage Sludge Incinerators 21
10 CSR 10-6.191(4) Reporting and Record Keeping— 40 CFR §§60.5230 through 60.5235 21
EPOS - ASH HANDLING SYSTEM 28
Permit Condition (EP09) - 001 28
10 CSR 10-6.191 Sewage Sludge Incinerators 28
40 CFR Part 60 Subpart MMMM Emission Guidelines and Compliance Times for Existing Sewage Sludge
Incineration Units. 28
Permit Condition (EP09) - 002 29
10 CSR 10-6.400 Restriction of Emission of Particulate Matter from Industrial Processes 29
40 CFR Part 64 Compliance Assurance Monitoring (CAM) 29
EP10—UNDERGROUND GASOLINE STORAGE TANK 32
Permit Condition (EP10) - 001 32
10 CSR 10-5.220 Control of Petroleum Liquid Storage, Loading and Transfer. 32
Permit Condition (EP10) - 002 32
10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 32
L INSTALLATION EQUIPMENT LISTING 4
EMISSION UNITS WITH LIMITATIONS
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 3
Installation ID: 510-0053 Project No. 2007-06-088
40 CPR Part 63 Subpart CCCCCC National Emission Standards for Hazardous Air Pollutants for Source
Category: Gasoline Dispensing Facilities 32
EP14 THROUGH EP16 — SLUDGE BUILDING BOILERS 33
Permit Condition (EP14 through EP16) - 001 33
10 CSR 10-6.060 Construction Permits Required 33
Construction Permit No. 95-05-029A, Issued November 4, 1997 33
Permit Condition (EP14 through EP16) - 002 34
10 CSR 10-6.070 New Source Performance Regulations 34
40 CFR Part 60 Subpart Dc 34
Standards of Performance for Small Industrial=Commercial-kistitutional Steam Generating Units 34
EP18 — PUMP STATION BOILERS 34
34
EP19 — PRIMARY CONTROL BUILDING BOILER 34
EP20 —ADMINISTRATIVE BUILDING BOILERS 34
EP22 — TRICKLING FILTER PUMP STATION BOILERS
Permit Condition (EP18 through EP20) - 001 and Permit Condition (EP22) - 001 34
,10 CSR 10-6.060 Construction Permits Required 34
Construction Permit No. 95-05-029A, Issued November 4, 1997 34
EP23 — BIOFILTER 35
Permit Condition (EP23) - 001 35
10 CSR 10-6.060 Construction Permits Required 35
Construction Permit No. 95-05-069, Issued March 1, 1996 35
IV. CORE PERMIT REQUIREMENTS 36
V. GENERAL PERMIT REQUIREMENTS 42
47
VI. ATTACHMENTS
Attachment A -
Attachment B -
Attachment C -
Attaclunent D
Attachrent E:
Attachment F -
Representative Operating Conditions Metrics 48
Fugitive Emission Observations 49
Method 22 Visible Emissions Observations 50
- Method 9 Opacity Emissions Observations 51
Compliance Assurance Monitoring Plan (CAM) 52
Inspection/Maintenance/Repair/Malfunction Log 53
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 4
Installation ID: 510-0053 Project No. 2007-06-088
I. Installation Equipment Listing
EIVIISSION UNITS WITH LIMITATIONS
The following list provides a description of the equipment at this installation that emits air pollutants and that
are identified as having unit -specific emission limitations.
Emission
Unit #
Description of Emission Unit
EPOS Incinerator #2
EPO4 Incinerator #3
EPOS Incinerator #4
EPO6 Incinerator #5
EPOS Wet Ash Conveying
EP 10 1000 Gallon Underground Gasoline Storage Tank
EP14 Sludge Building Boiler #1
EP 15 Sludge Building Boiler #2
EP 16 Sludge Building Boiler #3
EP 1 E Pump Station Boilers (2)
EP 19 Primary Control Building Boiler
EP20 Two Administration Building Boilers (2)
EP22 Trickling Filter Pump Station Boiler
EP23 Biofilter
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 5
Project No. 2007-06-088
EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS
The following list provides a description of the equipment that does not have unit specific limitations at the time
of permit issuance.
Emission
Unit # Descri tion of Emission Unit
EPO1 Wastewater Treatment includes:
Influent Pump station, 6 Grit Removal Tanks, 7 Comminutors, 8 Primary Settling
Tanks, 2 Sludge Holding Tams, 2 Ash Settling Basins, 1Trickling Filter Pump
Station, 6 Trickling Filters, 6 Aeration Tanks, 12 Final Clarifiers, Disinfection,
Effluent Pum Station
EP1.1 . p
EF21 Prep Buildings One 500-Gallon Underground`Diesel Storage
__—.--.----__.._._..._____...-._.__...............
B 'ldin s Space Heaters —4 lair ct Fired 3.4 MMBtu/hr (total heat input) Space
Heaters, Natural Gas Fired
EP24 Natural Gas Fired Water Heaters: Environmental Compliance 3 , Primary Control
Pump _ _ ._Maintenance Buildin.(1)
rsualc�ir�g1),.., Pum W Station ...... — — ... _ --
Small Parts Spray Booth
Parts Washer - (only aqueous cleaner used)
Sand Blasters (2 units)
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 6
Project No. 2007-06-088
II. Plant Wide Emission Limitations
The installation shall comply with each of the following emission limitations. Consult the appropriate sections
in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the
applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that
this permit is issued. The plant wide conditions apply to all emission units at this installation. All emission
units are listed in Section 1 under Emission Units with Limitations or Emission Units without Limitations.
None
MSD - Bissell Point Wastewater Treatment Plant
Installation I.D: 510-0053
Part 70 Operating Permit 7
Project No. 2007-06-088
III. Emission Unit Specific Emission Limitations
The installation shall comply with each of the following emission limitations. Consult the appropriate sections
in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the
applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that
this permit is issued.
EP03 through EP06 - Incinerators
Emission Unit , I
EP03
EP04
EP0S
EPO6
Incinerator #2 — Multiple Hearth Sewage Sludge Incinerator (SSI)
(constructed 1967)
Air Pollution Control — Venturi Scrubber (CD 15) and
Impingement Tray Scrubber (CD 16)
Incinerator #3 — Multiple Hearth Sewage Sludge Incinerator (SSI)
(constructed 1967)
Air Pollution Control — Venturi Scrubber (CD17) and
Impingement Tray Scrubber (CD 18)
Incinerator #4 — Multiple Hearth Sewage Sludge Incinerator (SSI)
(constructed 1967)
Air Pollution Control — Venturi Scrubber (CD19) and
Impingement Tray Scrubber (CD20)
Incinerator #5 — Multiple Hearth Sewage Sludge Incinerator (SSI)
(constructed 1967)
Air Pollution Control — Venturi Scrubber (CD21) and
Impingement Tray Scrubber (CD22)
Nichols Herreshoff
Nichols Herreshoff
Nichols Herreshoff
Nichols Herreshoff
Permit Condition (EPO3 through EP06) a 001
10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants
40 CFR Part 61 Subpart C National Emission Standard for Beryllium
Emission Limitation:
The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart C for any activities
occurring at this installation which would be subject to the provisions of 40 CFR Part 61, Subpart C, National
Emission Standard for Beryllium. Emissions to the atmosphere from the incinerators shall not exceed 10 grams
of beryllium over a 24-hour period. [40 CFR 61.32(a)]
Manitorisw
MSD shall perform stack sampling and testing at least every six (6) years as required by Construction Permit
No. 95-05-068, issued on August 16, 1995, by the City of St. Louis Air Pollution Control Program.
[Permit #95-05-068, Section III G]
Recordkeeving
1) The permittee shall retain copies of emission test results. Any other data needed to determine total emissions
shall be retained as specified in 40 CFR §61.33(e). [40 CFR §61.33].
2) Recordkeeping shall be accomplished in accordance with the requirements of 10 CSR 10-6.065(6)(C)1.0
General Recordkeeping and Reporting Requirements, as stated in Section V of this permit.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 8
Project No. 2007-06-088
Reporting:
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.O.
Box 176, Jefferson City, Missouri 65102 or AirComplianceRepordng@dnr.mo.gov, no later than ten days after
any exceedance of any of the terms imposed by this regulation. Any deviations from this permit condition shall
also be reported in the semi-annual monitoring report and annual compliance certification, as required by
Section V of this permit.
Permit Condition (EPO3 through EP06) - 002
10 CSR 10-6.060 Construction Permits Required
Construction Permit No. 95-05-068, Issued August 16, 1995
Emission Limitation
The permittee shall not cause, permit or allow the emissions rate of total hydrocarbon (THC) to exceed one
hundred parts per mullion by volume (100 ppmv) based on a monthly average and corrected for zero percent
(0%) moisture and seven percent (7%) oxygen when using the instrument required by 40 CFR Part 503.45.
[Permit #95-05-068, Section II F.]
1Mdonitorin2:
1) The permittee shall install, calibrate, operate, and maintain an instrument for each sewage sludge incinerator
that measures and records the total hydrocarbons concentration in the sewage sludge incinerator stack exit
gas continuously, as specified by the permitting authority. [40 CFR 503.45(a)(1)]
2) The total hydrocarbons instrument shall employ a flame ionization detector; shall have a heated sampling
line maintained at a temperature of 150 degrees Celsius or higher at all times; and shall be calibrated at least
once every 24-hour operating period using propane. [40 CFR 503.45(a)(2)1
3) The permittee shall install, calibrate, operate, and maintain an instrument for each sewage sludge incinerator
that measures and records the oxygen concentration in the sewage sludge incinerator stack.
[40 CFR 503.45(b)]
4) The incinerator must be retested at least every six (6) years to meet the most stringent performance
requirements in effect at the time of retesting. Pretest forms stating testing methods and dates shall be
completed and approved prior to testing.
5) The permittee shall install, calibrate, operate, and maintain an instrument for each sewage sludge incinerator
that measures and records information used to determine the moisture content in the sewage sludge
incinerator stack exit gas continuously. [40 CFR 503.45(c)]
Recordkeepinp:
The permittee shall keep records of
1) The measured total hydrocarbon (THC) for stack exist gases. [Permit #95-05-068, Section VI A.9.]
2) The measured oxygen content of the exhaust gases from the incinerators.
[Permit #95-05-068, Section VI A.2.]
3) The monitored moisture content of stack exist gases. [Permit #95-05-068, Section VI A.8.]
Reporting:
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.O.
Box 176, Jefferson City, Missouri 65102 or A.irComplianceReporting@dnr.mo.gov, no later than ten days after
any exceedance of any of the terms imposed by this regulation. Any deviations from this permit condition shall
also be reported in the semi-annual monitoring report and annual compliance certification, as required by
Section V of this permit.
MSI3 - ;Bissell;BissellPaint Wastewater Treatment Plant Part 70 Operating Permit 9project No. 2007-06-088
Installation 1D: 510-0053 � _
Permit Condition (EPO3 through EP06) - 003
10 CSR 10-6.060 Construction Permits Required
Construction Permit No. 95-05-068, issued August 16, 1995
New Source Review Permit Amendment - Permit Number: 95-05-068A, Issued December 29, 2014
Control Device Requirement — Scrubbers
Operational Limitation/Equipment Specification:
1) The permittee shall control emissions from the equipment listed in Table 1 below using venturi scrubbers
and impingement tray scrubbers (CD-15 through CD-22) as specified in the permit application.
Table 1: Project Equipment
Emitsion'€IsiltIDew_
Unit
EP-03
EP-04
EP-05
EP-06
Sewage Sludge Incinerator #2
Sewage Sludge Incinerator #3
Sewage Sludge Incinerator #4
Sewage Sludge Incinerator #5
Venturi Scrubber (CD15) and
Impingement Tray Scrubber (CD16)
Venturi Scrubber (CD 17) and
Impingement Tray Scrubber (CD18)
Venturi Scrubber (CD19) and
Impingement Tray Scrubber (CD20)
Venturi Scrubber (CD21) and
Impingement Tray Scrubber (CD22)
2) The permittee shall charge no more than an average, on an annual basis, of 68.88 tons per day of dry solid
sludge to each incinerator. However, no more than an average, on an annual basis, of 203.75 tons per day of
combined dry sewage sludge may be charged into the four operational incinerators at the installation.
Therefore, the total amount of combined sewage sludge that may be burned at this installation shall not
exceed 74,369 tons per year.
3) The permittee shall operate and maintain the scrubbers in accordance with the manufacturer's specifications.
Each scrubber shall be equipped with a gauge or meter, which indicates the pressure drop across the control
device. Each scrubber shall be equipped with a flow meter that indicates the liquid flow rate through the
scrubber. These gauges or meters shall be located such that MoDNR's employees may easily observe them.
Mon itorinvlR ecordkeepinv
1) The permittee shall maintain a copy of the scrubber manufacturer's performance warranty containing the
design conditions on site.
2) The permittee shall monitor and record the liquid flow rate through each scrubber continuously as stated in
Operating Limits and Requirements of Permit Condition (EP03 through EPO6) - 005. The flow rate shall be
maintained within the design conditions specified in the manufacturer's performance warranty.
3) The pernnittee shall maintain an operating and maintenance log for the scrubbers which shall include the
following:
a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and corrective
actions; and
b) Maintenance activities, including inspection schedules, repair actions, and replacements made.
4) The Permittee shall maintain records of the sewage sludge feed rate to the incinerators.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit
10
Project No. 2007-06-088
Permit Condition (EPO3 through EP06) - 004
10 CSR 10-6.191 Sewage Sludge Incinerators
, 10 CSR 10-6.191(3)(b) Operator Training and Qualifications — 40 CFR §§60.5130 through 60.5160
®aerator Training and Qualification Requirements: [40 CFR §60.5130]
1) The permittee shall not operate the SSI unit unless a fully trained and qualified SSI unit operator is
accessible, either at the facility or can be at the facility within 1 hour. The trained and qualified SSI unit
operator may operate the SSI unit directly or be the direct supervisor of one or more other plant personnel
who operate the unit. If all qualified SSI unit operators are temporarily not accessible, the permittee must
follow the procedures in 40 CFR §60.5155. [40 CFR §60.5130(a)]
2) The permittee shall obtain operator training and qualification through a state -approved program or by
completing the requirements included in 40 CFR §60.5130(c) (described in 3) below).
[40 CFR §60,5130(b)]
3) Training must be obtained by completing an incinerator operator training course that includes, at a
minimum, the three elements described in 40 CFR §60.5130(c)(1) through (c)(3) (listed below).
[40 CFR §60.5130(c)]
a) Training on the 10 subjects listed in 40 CFR §60.5130(c)(1)(i) through (c)(1)(x) (listed below).
[40 CFR §60.5130(c)(1)]
i) Environmental concerns, including types of emissions. [40 CFR §60.5130(c)(1)(i)]
li) Basic combustion principles, including products of combustion.
[40 CFR §60.5130(c)(1)(ii)]
iii) Operation of the specific type of incinerator to be used by the operator, including proper startup,
sewage sludge feeding, and shutdown procedures. [40 CFR §60.5130(c) (1)(iii)]
iv) Combustion controls and monitoring. [40 CFR §60.5130(c)(1)(iv)]
v) Operation of air pollution control equipment and factors affecting performance (if applicable). [40
CFR §60.5130(c)(1)(v)]
vi) Inspection and maintenance of the incinerator and air pollution control devices.
[§60.5130(c)(1)(vi)]
vii) Actions to prevent malfunctions or to prevent conditions that may lead to malfunctions.
[40 CFR §60.5130(c) (1)(vii)]
viii) Bottom and fly ash characteristics and handling procedures. [40 CFR §60.5130(c)(1)(viii)]
ix) Applicable Federal, State, and local regulations, including Occupational Safety and Health
Administration workplace standards. [40 CFR §60.5130(c)(lxix)]
x) Pollution prevention. [40 CFR §60.5130(c)(1)(x)]
b) An examination designed and administered by the state -approved program.
[40 CFR §60.5130(c)(2)]
c) Written material covering the training course topics that may serve as reference material following
completion of the course. [40 CFR §60.5130(c)(3)]
Operator Training Coarse_ [40 CFR §60.5135]
The Permittee shall complete the operator training course as required by §60.5135.
°aerator Qualification: [40 CFR §§60.5140 through 5155]
1) The permittee must obtain operator qualification by completing a training course that satisfies the criteria
under 40 CFR §60.5130(b). [40 CFR §60,5140(a)]
2) Qualification is valid from the date on which the training course is completed and the operator successfully
passes the examination required under 40 CFR §60.5130(c)(2). [40 CFR §60.5140(b)]
i
MSD -Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 11
Project No. 2007-06-088
3) To maintain qualification, the permittee must complete an annual review or refresher course covering, at a
minimum, the five topics described in 40 CFR §60.5145 (a) through (e).
[40 CFR §60.5145]
a) Update of regulations. [40 CFR §60.5145(a)]
b) incinerator operation, including startup and shutdown procedures, sewage sludge feeding, and ash
handling. [40 CFR §60.5145(b)]
c) inspection and maintenance. [40 CFR §60.5 I45(c)]
d) Prevention of malfunctions or conditions that may lead to malfunction. [40 CFR §60.5145(d)]
e) Discussion of operating problems encountered by attendees. [40 CFR §60.5145(e)]
4) The permittee must renew a lapsed operator qualification before the permittee begins operation of a SSI unit
by one of the two methods specified in 40 CFR §60.5150(a) and (b). [40 CFR §60.5150]
a) For a lapse of less than 3 years, the permittee must complete a standard annual refresher course
described in 40 CFR §60.5145. [40 CFR §60.5150(a)]
b) For a lapse of 3 years or more, the permittee must repeat the initial qualification requirements in 40 CFR
§60.5140(a). [40 CFR §60.5150(b)]
5) if a qualified operator is not at the facility and cannot be at the facility within 1 hour, the permittee must
meet the criteria specified in either paragraphs (a) or (b) of 40 CFR §60.5155 (listed below), depending on
the length of time that a qualified operator is not accessible. [40 CFR §60.5155]
a) When a qualified operator is not accessible for more than 8 hours, the SSI unit may be operated for less
than 2 weeks by other plant personnel who are familiar with the operation of the SSI unit and who have
completed a review of the information specified in 40 CFR §60.5160 within the past 12 months.
However, the permittee must record the period when a qualified operator was not accessible and include
this deviation in the annual ccessible for 2 weeks oras specified under 40 FR more�the pe(d). rmittee0mustRtakD the two actions
b) When a qualified operator is
s
that are described in 40 CFR §60.5155 (b)(1) and (b)(2) (listed below).
[40 CFR §60.5155(b)]
i) The permittee shall notify the Director of this deviation in writing within 10 days• In the notice, state
what caused this deviation, what the permittee is doing to ensure that a qualified operator is
accessible, and when the permittee anticipates that a qualified operator will be accessible.
[40 CFR §60.5155(b)(1)1
ii) The permittee shall submit a status report to the Director every 4 weeks outlining what the permittee
is doing to ensure that a qualified operator is accessible, stating when the permittee anticipates that a
qualified operator will be accessible, and requesting approval from the Director to continue
operation of the SSI unit. The permittee must submit the first status report 4 weeks after the
permittee notifies the Director of the deviation under 40 CFR §60.5155(b)(1).
[40 CFR §60.5155(b)(2)]
(1) If the Director notifies the permittee that the permittee's request to continue operation of the SSI
unit is disapproved, the SSI unit may continue operation for 30 days, and then must cease
operation. [40 CFR §60.5155(b)(2)(i)1
(2) Operation of the unit may resume if a qualified operator is accessible as required under 40 CFR
§60.5130(a). The permittee must notify the Director within 5 days of having resumed operations
and of having a qualified operator accessible. [40 CFR §60.5155(b)(2)(i)]
Site Specific Documentation: [40 CFR §60.5160]
1) The permittee must maintain at the facility the documentation of the operator training procedures specified
under 40 CFR §60.5230(c)(1) and make the documentation readily accessible to all SSI unit operators.
[40 CFR §60.5160(a)]
2) The permittee must establish a program for reviewing the information listed in 40 CFR §60.5230(c)(1) with
each qualified incinerator operator and other plant personnel who may operate the unit according to the
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 12
Installation ID: 510-0053 Project No. 2007-06-088
provisions of 40 CFR §60.5155(a), according to the following schedule:
[40 CFR §60.5160(b)]
a) The initial review of the information listed in 40 CFR §60.5230(c)(1) must be conducted within 6
months prior to an employee's assumption of responsibilities for operation of the SSI unit.
[40 CFR §60.5160(b)(1)]
b) Subsequent annual reviews of the information listed in 40 CFR §60.5230(c)(1) must be conducted no
later than 12 months following the previous review. [40 CFR §60.5160(b)(2)]
Permit Condition (EPO3 through EP06) - 005
10 CSR 10-6.191 Sewage Sludge Incinerators
10 CSR 10-6.191(3)(C) Emission Limits, Emission Standards, Operating Limits, and Requirements — 40
CFR §§60.5165 through 60.5181
Emission Limitation and Standards:
1) The emission limits and standards specified in Table 3 to Subpart MMMM of 40 CFR Part 60apply to
emissions from a bypass stack or vent while sewage sludge is in the combustion chamber (i.e., until the
sewage sludge feed to the combustor has been cut off for a period of time not less than the sewage sludge
incineration residence time). [40 CFR §60.5165]
Table 3 to Subpart MMMM of 40 CFR Part 60 —Emission Limits and Standards for Existing Multiple
Hearth Sewage Sludge Incineration Units
For the air
pollutant
Particulate matter
The permittee must
meet this emission limit'
80 milligrams per dry
standard cubic meter
Using these averaging methods and minimum
sampling volumes or durations
3-run average (collect a minimum volume of
0.75 dry standard cubic meters per run)
And determine compliance
using this method
Performance test (Method 5 at
40 CFR part 60, appendix A-3;
Method 26A or Method 29 at 40
CFR Part 60, Appendix A-8).
Hydrogen
chloride
Carbon monoxide
Dioxins/furans
(total mass basis)
Dioxins/furans
(toxic equivalency
basis)b
1.2 parts per million by
dry volume
3,800 parts per million by
dry volume
5.0 nanograms per dry
standard cubic meter; or
0.32 nanograms per dry
standard cubic meter
3-run average (For Method 26, collect a
minimum volume of 200 liters per run. For
Method 26A, collect a minimum volume of 1
dry standard cubic meters per run)
3-run average (collect sample for a minimum
.duration of one hour per run)
p-run average (collect a minimum volume of 1
dry standard cubic meters per run)
Performance test (Method 26 or
26A at 40 CFR Part 60,
Appendix A-8).
Performance test (Method 10,
10A, or 10B at 40 CFR Part 60,
Appendix A-4).
Performance test(Method 23 at
40 CFR Part 60, Appendix A-7).
Mercury
0.28 milligrams per dry
standard cubic meter
3-run average (For Method 29 and ASTM
D6784-02 (Reapproved 2008),c collect a
minimum volume of I dry standard cubic meters
per run. For Method 30B, collect a minimum
Performance test (Method 29 at
40 CFR part 60, appendix A-8;
Method 30B at 40 CFR Part 60,
Appendix A-8; or ASTM
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 510-0053
For the air
pollutant
Oxides of
nitrogen
The permittee must
meet this emission limit'
220 parts per million by
dry volume
Sulfur dioxide
26 parts per million by
dry volume
Cadmium
Lead
0.095 milligrams per dry
standard cubic meter
0.30 milligrams per dry
standard cubic meter
13
Project No. 2007-05-08 8
Using these averaging methods and minimum
sampling volumes or duratiaua
sample as specified in Method 30B at 40 CFR
part 60, appendix A-8)
3-run average (Collect sample for a minimum
duration of one hour per run)
And determine compliance
using this method
D6784-02 (Reapproved 2008)).`
3-run average (For Method 6, collect a minimum
volume of 200 liters per run. For Method 6C,
collect sample for a minimum duration of one
hour per run)
3-run average (collect a minimum volume of 1
dry standard cubic meters per run)
Performance test (Method 7 or
7E at 40 CFR Part 60, Appendix
A-4).
Performance test (Method 6 or
6C at 40 CFR part 40, Appendix
A-4; or ANS1/ASME PTC
19.10-1981).`
Performance test (Method 29 at
40 CFR part 60, Appendix A-8).
3-run average (collect a minimum volume of 1 Performance test (Method 29 at
dry standard cubic meters per run) y40 CFR Part 60, Appendix A-8).
a All emission limits are measured at 7 percent oxygen, dry basis at standard condi
b
The permittee has the option to comply with either the dioxinlfuran emission lim
dioxin/furan emission limit on a toxic equivalency basis.
Incorporated by reference, see 40 CFR §60.17.
2) The emission limits and standards apply at all times and during periods of malfunction.
[40 CFR 00.5180]
Operating Limits and Requirements:
The permittee must meet the operating limits and requirements specified in 40 CFR §60.5170(a), (b), (e), (f) and
(g) (listed below), according to the schedule specified in 40 CFR §60.5170 (e). The operating parameters for
which the permittee will establish operating limits for a wet scrubber, are listed in Table 4 to Subpart MMMM
of 40 CFR Part 60. The permittee must comply with the operating requirements in 40 CFR §60.5170 (f) and the
requirements in 40 CFR §60.5170 (g) for meeting any new operating limits, re-established in 40 CFR §60.5210.
The operating limits apply at all times that sewage sludge is in the combustion chamber (i.e., until the sewage
sludge feed to the combustor has been cut off for a period of time not less than the sewage sludge incineration
residence time). [40 CFR §60.5170]
tions.
it on a total mass basis or the
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 510-0053
14
Project No. 2007-06-088
Table 4 to Subpart MINIM of 40 C1 R Part 60—Operating Parameters for Existing Sewage Sludge Incineration
Units'
For these operating parameters
Combustion chamber operating
temperature (not required if afterburner
temperature is monitored)
Pressure drop across each wet scrubber
Scrubber liquid flow rate
Scrubber liquid pH
The permittee must establish
these operating limits
Minimum combustion chamber
or afterburner operating
temperature
Minimum pressure drop
Minimum flow rate
Minimum pH
And monitor using these minimum frequencies
Data
measurement
Continuous
Continuous
Continuous
Continuous
Data
recording"
Every 15
minutes
Every 15
minutes
Every 15
minutes
Every 15
minutes
Data averaging
period for
compliance
12-hour block.
I2-hour block.
12-hour block,
3-hour block.
a As specified in 40 CFR §60.5190, the permit may use a continuous emissions monitoring system or continuous
automated sampling system in lieu of establishing certain operating limits.
b
This recording time refers to the minimum frequency that the continuous monitor or other measuring device initially
records data. For all data recorded every 15 minutes, the permittee must calculate hourly arithmetic averages. For all
parameters, the permittee uses hourly averages to calculate the 12-hour or 3-hour block average specified in this table
for demonstrating compliance. The permittee maintains records of 1-hour averages.
1) The permittee must meet the site -specific minimum combustion chamber operating temperature or
afterburner operating temperature established in 40 CFR §60.5190. The minimum combustion chamber
operating temperature or afterburner operating temperature shall be equal to the lowest 4-hour average
combustion chamber operating temperature or afterburner operating temperature measured during the most
recent performance test demonstrating compliance with all applicable emission limits.
[40 CFR §60.5170(a) and 40 CFR §60.5190(e)]
2) The permittee must meet the site specific operating limits for the wet scrubbers established according to 40
CFR §60.5190 (described below). [40 CFR §60.5I70(b)]
a) The minimum pressure drop across each wet scrubber used to meet the particulate matter, lead, and
cadmium emission limits in Table 3 to Subpart MMMM of 40 CFR Part 60, shall be equal to the lowest
4-hour average pressure drop across each such wet scrubber measured during the most recent
performance test demonstrating compliance with the particulate matter, lead, and cadmium emission
limits. [40 CFR §60.5190(b)]
b) Minimum scrubber liquid flow rate (measured at the inlet to each wet scrubber), shall be equal to the
lowest 4-hour average liquid flow rate measured during the most recent performance test demonstrating
compliance with all applicable emission limits. [40 CFR §60.5190(c)]
c) The minimum scrubber liquid pH for each wet scrubber used to meet the sulfur dioxide or hydrogen
chloride emission limits in Table 3 to Subpart MMMM of 40 CFR Part 60, equal to the lowest 1-hour
average scrubber liquid pH measured during the most recent performance test demonstrating compliance
with the sulfur dioxide and hydrogen chloride emission limits.
[40 CFR §60.5190(d)]
3) The permittee must monitor the feed rate and moisture content of the sewage sludge fed to the sewage
sludge incinerator, as specified in 40 CFR §60.5170 (f)(1) and (f)(2). [40 CFR §60.5170(f)]
MSD -Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 15
Project No. 2007-06-088
Installation ID: 510-0053
a) The permittee must continuously monitor the sewage sludge feed rate and calculate a daily average for
all hours of operation during each 24-hour period. Keep a record of thedaily average feed rate, as
specified in 40 CFR §60.5230(f)(3)(ii) (described in Permit Condition(EPO3 through EP06) — 008) .
[40 CFR §60.5170(f)(1)]
b) The permittee must take at least one grab sample per day of the sewage sludge fed to the sewage sludge
incinerator. If the permittee takes more than one grab sample in a day, calculate the daily average for the
grab samples. Keep a record of the daily average moisture content, as specified in §60.5230(f)(3)(ii).
[40 CFR §60.5170(f)(2)]
4) For the operating limits and requirements specified in 40 CFR §60.5170(a), (b), and (d), the permittee must
meet any new operating limits and requirements, re-established according to 40 CFR §60.5210(d).
[40 CFR §60.5170(g)]
Permit Condidou (1EPO3 through EP06) - 006
10 CSR 10-6.191 Sewage Sludge Incinerators
10 CSR 10-6.191(3)(D) Initial Compliance Requirements — 40 CFR §§60.5185 through 60.5200
10 CSR 10-6.191(3)(D) Continuous Compliance Requirements — 40 CFR §§60.5205 through 60.5215
Ith Comoliance Rea uirrements:
1) To demonstrate initial compliance with the emission limits and standards in Table 3 to Subpart MMMM of
40 CFR Part 60 (Permit Condition (EP-03 through EP-06) — 005), the permittee shall use the procedures
specified in 40 CFR §60.5185(a). The permittee must meet the requirements of 40 CFR §60.5185(a) and
(e), according to the performance testing, monitoring, and calibration requirements in 40 CFR §60.5220(a).
[40 CFR §60.5185]
a) The permittee shall demonstrate initial compliance using the performance test required in 40 CFR §60.8.
The permittee must demonstrate that the SSI unit meets the emission limits and standards specified in
Table 3 to Subpart MMMM of 40 CFR Part 60 for particulate matter, hydrogen chloride, carbon
monoxide, dioxins/furans (total mass basis or toxic equivalency basis), mercury, nitrogen oxides, sulfur
dioxide, cadmium, lead, and fugitive emissions from ash handling using the performance test. The initial
performance test must be conducted using the test methods, averaging methods, and minimum sampling
volumes or durations specified in Table 3 to this subpart (Permit Condition (EP-03 through EP-06) —
005) and according to the testing, monitoring, and calibration requirements specified in 40 CFR
§60.5220(a). [40 CFR 40 CFR §60.5185(a)]
i) Except as provided in 40 CFR §60.5185(e), the permittee must demonstrate that the SSI unit meets
the emission limits and standards specified in Table 3 to Subpart MMMM of 40 CFR Part 60 by the
permittee's final compliance date (see Table 1 to this Subpart MMMM of 40 CFR Part 60 ).
[40 CFR §60.5185(a)(1)]
ii) The permittee may use the results from a performance test conducted within the 2 previous years that
was conducted under the same conditions and demonstrated compliance with the emission limits and
standards in Table 3 to this subpart (Permit Condition (EP-03 through EP-06) — 005), provided no
process changes have been made since the permittee conducted that performance test. However, the
permittee must continue to meet the operating limits established during the most recent performance
test that demonstrated compliance with the emission limits and standards in Table 3 to Subpart
MMMM of 40 CFR Part 60 (Permit Condition (EP-03 through EP-06) — 005). The performance test
must have used the test methods specified in Table 3 to Subpart MMMM of 40 CFR Part 60.
[40 CFR §60.5185(a)(2)]
b) If a force majeure is about to occur, occurs, or has occurred for which the permittee intend to assert a
claim of force majeure, the permittee must notify the Director in writing as specified in 40 CFR
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 16
Project No. 2007-06-088
§60.5235(g). The permittee must conduct the initial performance test as soon as practicable after the
force majeure occurs. The Director will determine whether or not to grant the extension to the initial
performance test deadline, and will notify the permittee in writing of approval or disapproval of the
request for an extension as soon as practicable. Until an extension of the performance test deadline has
been approved by the Director, the permittee remains strictly subject to the requirements of this subpart.
[40 CFR §60.5185(e)]
2) Air Pollution Control Device Inspection: [40 CFR §60.5195]
a) The permittee must conduct an air pollution control device inspection according to 40 CFR §60.5220(c)
by the final compliance date under the approved state plan, Federal plan, or delegation, as applicable.
For air pollution control devices installed after the final compliance date, the permittee must conduct the
air pollution control device inspection within 60 days after installation of the control device. [40 CFR
§60.5195(a)]
b) Within 10 operating days following the air pollution control device inspection under 40 CFR
§60.5195(a), all necessary repairs must be completed unless the permittee obtains written approval from
the Director establishing a date whereby all necessary repairs of the SSI unit must be completed. [40
CFR §60.5195(b)]
3) The permittee cltall develop, submit and update a site specific monitoring plan for each continuous
parametric monitoring and ash handling system and shall conduct an initial performance evaluation of the
continuous parametric monitoring systems as specified in 40 CFR §60.5200.
[40 CFR §60.5200]
Contiguous Compliance Requirements:
1) Continuous compliance with the emission limits and standards:
To demonstrate continuous compliance with the emission limits and standards specified. in Table 3 to
Subpart MMMM of 40 CFR Part 60 (Permit Condition (EP-03 through EP-06) — 005), the permittee must
use the procedures specified in 40 CFR §60.5205(a). The permittee must meet the requirements of 40 CFR
§60.5205(a) and (e), according to the performance testing, monitoring, and calibration requirements in 40
CFR §60.5220(a) and (b). The permittee may also petition the Director for alternative monitoring
parameters as specified in 40 CFR §60.5205. [40 CFR §60.5205]
a) The permittee shall demonstrate continuous compliance using a performance test. Except as provided in
40 CFR §60.5205(a)(3) and (e), following the date that the initial performance test for each pollutant in
Table 3 to Subpart MMMM of 40 CFR Part 60 is completed, the permittee must conduct a performance
test for each such pollutant on an annual basis (between 11 and 13 calendar months following the
previous performance test). The performance test must be conducted using the test methods, averaging
methods, and minimum sampling volumes or durations specified in Table 3 to Subpart MMMM of 40
CFR Part 60 and according to the testing, monitoring, and calibration requirements specified in 40 CFR
§60.5220(a).
[40 CFR §60.5205(a)]
i) The permittee may conduct a repeat performance test at any time to establish new values for the
operating limits to apply from that point forward. The Director may request a repeat performance
test at any time. [40 CFR §60.5205(a)(l)]
ii) The permittee must repeat the performance test within 60 days of a process change, as defined in 40
CFR §60.5250. [40 CFR §60.5205(a)(2)]
iii) Except as specified in 40 CFR §60.5205 (a)(1) and (2), the permittee can conduct performance tests
less often for a given pollutant, as specified in 40 CFR §60.5205 (a)(3)(i) through (iii).
[40 CFR §60.5205(a)(3)]
(1) The penmittee can conduct performance tests less often if the permittee's performance tests for
the pollutant for at least 2 consecutive years show that the emissions are at or below 75 percent
of the emission limit specified in Table 3 to Subpart MMMM of 40 CFR Part 60 (Permit
!VISE) - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 17
Project No. 2007-06-088
Condition (EP-03 through EP-06) — 005), and there are no changes in the operation of the
affected source or air pollution control equipment that could increase emissions. In this case, the
permittee does not have to conduct a performance test for that pollutant for the next 2 years. The
permittee must conduct a performance test during the third year and no more than 37 months
after the previous performance test. [40 CFR §60.5205(a)(3)(i)]
(2) If the permittee's SSI unit continues to meet the emission limit for the pollutant, the permittee
may choose to conduct performance tests for the pollutant every third year if the emissions are at
or below 75 percent of the emission limit, and if there are no changes in the operation of the
affected source or air pollution control equipment that could increase emissions, but each such
performance test must be conducted no more than 37 months after the previous performance test.
[40 CFR §60.5205(a)(3)(ii)]
(3) If a performance test shows emissions exceeded 75 percent of the emission limit for a pollutant,
the permittee must conduct annual performance tests for that pollutant until all performance tests
over 2 consecutive years show compliance. [40 CFR §60.5205(a)(3)(iii)]
b) The permittee must submit an annual compliance report as specified in 40 CFR §60.5235(c).
[40 CFR §60.5205(d) j
c) If a force majeure is about to occur, occurs, or has occurred for which the permittee intends to assert a
claim of force majeure, the permittee must notify the Director in writing as specified in 40 CFR
§60.5235(g). The permittee must conduct the performance test as soon as practicable after the force
majeure occurs. The Director will determine whether or not to grant the extension to the performance
test deadline, and will notify the permittee in writing of approval or disapproval of the request for an
extension as soon as practicable. Until an extension of the perfonnance test deadline has been approved
by the Director, the permittee remains strictly subject to the requirements of Subpart MMMM of 40
CFR Part 60. [40 CFR §60.5205(e)]
d) After any initial requests in 40 CFR §60.5200 for alternative monitoring requirements for initial
compliance, the permittee may subsequently petition the Director for alternative monitoring parameters
as specified in 40 CFR §§60.13(i) and 60.5200(e). [40 CFR §60.5205(f)1
2) Continuous compliance with operating limits:
The permittee must continuously monitor the operating parameters as specified in 40 CFR §60.5210(a) and
meet the requirements of 40 CFR §60.5210(b) and (c), according to the monitoring and calibration
requirements in 40 CFR §60.5225. The permittee must confirm and re-establish the permittee's operating
limits as specified in 40 CFR §60.5210(d). [40 CFR §60.5210] a) The permittee must continuously monitor the operating parameters specified in 40 CFR §60.5210 ( a)( 1)
using the continuous monitoring equipment and according to the procedures specified in 40 CFR
§60.5225 or established in 40 CFR §60.5175. To determine compliance, the permittee must use the data
averaging period specified in Table 4 to Subpart MMMM of 40 CFR Part 60 unless a different
averaging period is established under 40 CFR §60.5175. [40 CFR §60.5210(a)]
i) The permittee must demonstrate that the SSI unit meets the operating limits established according to
40 CFR §§60.5175 and 60.5190 and 40 CFR §60.5210(d) for each applicable operating parameter.
[40 CFR §60.5210(a)(1)]
b) Operation above the established maximum, below the established minimum, or outside the allowable
range of the operating limits specified in 40 CFR §60.5210(a) constitutes a deviation from the
permittee's operating limits established under this subpart, except during performance tests conducted to
determine compliance with the emission and operating limits or to establish new operating limits. The
permittee must submit the deviation report specified in 40 CFR §60.5235(d) for each instance that the
perrnittee did not meet one of the permittee's operating limits established under this subpart.
[40 CFR §60.5210(b))
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 18
Project No. 2007-06-088
c) The permittee must submit the annual compliance report specified in 40 CFR §60.5235(c) to
demonstrate continuous compliance. . [40 CFR §60.5210(c))
3) The permittee must confirm the permittee's operating limits according to 40 CFR §60.52I 0(d)(1) or re-
establish operating limits according to 40 CFR §60.5210(d)(2). The permittee's operating limits must be
established so as to assure ongoing compliance with the emission limits. These requirements also apply to
the permittee's operating requirements in the permittee's fugitive emissions monitoring plan specified in 40
CFR §60.5170(d). [40 CFR §60.5210(d)]
a) The permittee's operating limits must be based on operating data recorded during any performance test
required in 40 CFR §60.5205(a). [40 CFR §60.5210(d)(1)]
b) The permittee may conduct a repeat performance test at any time to establish new values for the
operating limits to apply from that point forward. [40 CFR §60.5210(d)(2)]
4) Annual air pollution control device inspections and necessary repairs: [40 CFR §60.5215]
a) The permittee must conduct an annual inspection of each air pollution control device used to comply
with the emission limits, according to 40 CFR §60.5220(c), no later than 12 months following the
previous annual air pollution control device inspection. [40 CFR §60.5215(a)]
b) Within 10 operating days following an air pollution control device inspection, all necessary repairs must
be completed unless the permittee obtains written approval from the Director establishing a date
whereby all necessary repairs of the affected SSI unit must be completed. [40 CFR §60.5215(b)]
Permit Condition (EP03 through EP06) - 007
10 CSR 10-6.191 Sewage Sludge Incinerators
10 CSR 10-6.191(3)(F) Performance Testing, Monitoring, and Calibration Requirements — 40 CFR
§ §60.5220 through 60.5225
Performance Testae$ Requirements:
1) All performance tests must consist of a minimum of three test runs conducted under conditions
representative of normal operations, as specified in 40 CFR §60.8(c). Emissions in excess of the emission
limits or standards during periods of startup, shutdown, and malfunction are considered deviations from the
applicable emission limits or standards. [40 CFR §60.5220(a)(1)]
2) The permittee must document that the dry sludge burned during the performance test is representative of the
sludge burned under normal operating conditions by: [40 CFR §60.5220(a)(2)]
a) Maintaining a log of the quantity of sewage sludge burned during the performance test by continuously
monitoring and recording the average hourly rate that sewage sludge is fed to the incinerator.
[40 CFR §60.5220(a)(2)(i)]
b) Maintaining a Iog of the moisture content of the sewage sludge burned during the performance test by
taking grab samples of the sewage sludge fed to the incinerator for each 8 hour period that testing is
conducted. [40 CFR §60.5220(a)(2)(ii)]
3) Ail performance tests must be conducted using the test methods, minimum sampling volume, observation
period, and averaging method specified in Table 3 to this subpart. [40 CFR §60.5220(a)(3)1
4) Method 1 at 40 CFR Part 60, Appendix A must be used to select the sampling location and number of
traverse points. [40 CFR §60.5220(ax4)]
5) Method 3A or 3B at 40 CFR Part 60, Appendix A-2 must be used for gas composition analysis, including
measurement of oxygen concentration. Method 3A or 3B at 40 CFR Part 60, Appendix A-2 must be used
simultaneously with each method. [40 CFR §60.5220(a)(5)1
6) AB pollutant concentrations must be adjusted to 7 percent oxygen using the following equation (Equation 1
of 40 CFR §60.5220): [40 CFR §60.5220(a)(6)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 19
Project No. 2007-06-088
c
�, I (20.9 -- 7)me (Equation 1)
Where: i
Cali = Pollutant concentration adjusted to 7 percent oxygen.
Cme = Pollutant concentration measured on a dry basis.
(20.9 — 7) = 20,9 percent oxygen — 7 percent oxygen (defined oxygen correction basis).
20.9 = Oxygen concentration in air, percent.
%02 = Oxygen concentration measured on a dry basis, percent.
7) Performance tests must be conducted and data reduced in accordance with the test methods and procedures
contained in Subpart MMMM of 40 CFR Part 60 unless the Director does one of the following:
[40 CFR §60.5220(a)(7)]
a) Specifies or approves, in specific cases, the use of a method with minor changes in methodology.
[40 CFR §60.5220(a)(7)(i)]
b) Approves the use of an equivalent method. [40 CFR §60.5220(a)(7)(ii)]
c) Approves the use of an alteiiiativc method the results of which he has determined to be adequate for
indicating whether a specific source is in compliance. [40 CFR §60.5220(a)(7)(iii)]
d) Waives the requirement for performance tests because the perrnittee has demonstrated by other means to
the Director's satisfaction that the affected SSI unit is in compliance with the standard.
[40 CFR §60.5220(a)(7)(iv)]
e) Approves shorter sampling times and smaller sample volumes when necessitated by process variables or
other factors, Nothing in this paragraph is construed to abrogate the Director's authority to require
testing under section 114 of the Clean Air Act. [40 CFR §60.5220(a)(7)(v)]
8) The permittee must provide the Director at least 30 days prior notice of any performance test, except as
specified under other subparts, to afford the Director the opportunity to have an observer present. If after 30
days notice for an initially scheduled performance test, there is a delay (due to operational problems, etc.) in
conducting the scheduled performance test, the permittee must notify the Director as soon as possible of any
delay in the original test date, either by providing at least 7 days prior notice of the rescheduled date of the
performance test, or by arranging a rescheduled date with the Director by mutual agreement.
[40 CFR §60.5220(a)(8)]
9) The permittee must provide, or cause to be provided, performance testing facilities as follows:
[40 CFR §60.5220(a)(9)]
a) Sampling ports adequate for the test methods applicable to the SSI unit, as follows:
[40 CFR §60.5220(a)(9)(i)]
i) Constructing the air pollution control system such that volumetric flow rates and pollutant emission
rates can be accurately determined by applicable test methods and procedures.
[40 CFR §60.5220(a)(9)(i)(A)]
ii) Providing a stack or duct free of cyclonic flow during performance tests, as demonstrated by
applicable test methods and procedures. [40 CFR §60,5220(a)(9)(i)(E)]
b) Safe sampling platform(s). [40 CFR §60.5220(a)(9)(ii)]
c) Safe access to sampling platform(s). [40 CFR §60.5220(a)(9)(iii)]
d)Utilities for sampling and testingequipment.[40 CFR 60.5220 a 9 iv
p g� p § ()( )
10) Unless otherwise specified in this subpart, each performance test must consist of three separate runs using
the applicable test method. Each run must be conducted for the time and under the conditions specified in
the applicable standard. Compliance with each emission limit must be determined by calculating the
arithmetic mean of the three runs. In the event that a sample is accidentally lost or conditions occur in which
one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of
the sample train, extreme meteorological conditions, or other circumstances, beyond the permittee's control,
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 20
Project No. 2007-06-088
compliance may, upon the Director's approval, be determined using the arithmetic mean of the results of the
two other runs. [40 CFR §60.5220(a)(10)]
11) In lieu of the operating requirements of 40 CFR §60.5220(a)(11), the permittee may use the metrics defined
in Attachment A to serve as a platform for evaluating operating conditions of each incinerator during each
test run specified in 40 CFR §60.5220(a)(1). The metrics should be meaningful and proportionate, and
modified as necessary to achieve its purpose. Therefore, when data is considered, the Program and
Installation should consider its meaning and how it relates to the objective. If metrics data indicate a
condition of deviation, the permittee shall provide an account of the conditions surrounding the performance
test event and submit it with the performance test report for that test event.
12) Bypass stack. Use of the bypass stack at any time that sewage sludge is being charged to the SSI unit is an
emissions standards deviation for all pollutants listed in Table 3 to Subpart MMMM of 40 CFR Part 60. The
use of the bypass stack during a performance test invalidates the performance test.
[40 CFR §60.5220(d)]
Air Pollution Control Device Inspections:
The permittee must conduct air pollution control device inspections that include, at a minimum, the following:
[40 CFR §60.5220(c)]
1) Inspect air pollution control device(s) for proper operation. [40 CFR §60.5220(c)(1)]
2) Generally observe that the equipment is maintained in good operating condition.
[40 CFR §60.5220(c)(2)]
3) Develop a site -specific monitoring plan according to the requirements in 40 CFR §60.5200. This
requirement also applies to the permittee if the permittee petitions the EPA Administrator for alternative
monitoring parameters under 40 CFR §60.13(i). [40 CFR §60.5220(c)(3)]
AlonitorinR and Calibration Reuirements for Compliance with Operating limits:
1) The permittee must install, operate, calibrate, and maintain the continuous parameter monitoring systems
according to the requirements in 40 CFR §60.5225 (a)(1) and (2). [40 CFR §60.5225(a)]
a) The permittee must meet the following general requirements for flow, pressure, pH, and operating
temperature measurement devices: [40 CFR §60.5225(a)(1)]
i) The permittee must collect data using the continuous monitoring system at all times the affected SSI
unit is operating and at the intervals specified in 40 CFR §60.5225(a)(1)(ii), except for periods of
monitoring system malfunctions that occur during periods specifically defined in 40 CFR
§60.5200(a)(7)(i), repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments). Any such periods that the permittee does not collect data using
the continuous monitoring system constitute a deviation from the monitoring requirements and must
be reported in a deviation report. [40 CFR §60.5225(a)(1)(i)]
ii) The permittee must collect continuous parameter monitoring system data in accordance with 40 CFR
§60.13(e)(2). [40 CFR §60.5225(a)(1)(ii)]
iii) Any data collected during monitoring system malfunctions, repairs associated with monitoring
system malfunctions, or required monitoring system quality assurance or control activities must not
be included in calculations used to report emissions or operating levels. Any such periods must be
reported in the permittee's annual deviation report. [40 CFR §60.5225(a)(1)(iii)]
iv) Any data collected during periods when the monitoring system is out of control as specified in 40
CFR §60.5200(a)(7)(i) must not be included in calculations used to report emissions or operating
levels. Any such periods that do not coincide with a monitoring system malfunction, as defined in 40
CFR §60.5250, constitute a deviation from the monitoring requirements and must be reported in a
deviation report. [40 CFR §60.5225 (a)(1)(iv)]
MSD - Bissell Point Wastewater Treatment Plant
Installation 1D: 510-0053
Part 70 Operating Permit 21
Project No. 2007-06-088
v) The permittee must use all the data collected during all periods except those periods specified in
paragraphs 40 CFR §60.5225(a)(1)(iii) and (a)(1)(iv) in assessing the operation of the control device
and associated control system. [40 CFR §60.5225 (a)(1)(v)]
vi) Record the results of each inspection, calibration, and validation check.
[40 CFR §60.5225(a)(1)(vi)]
b) The permittee must operate and maintain the continuous monitoring system according to the monitoring
plan required under 40 CFR §60.4880. [40 CFR §60.5225(a)(2)]
2) The permittee must operate and maintain the continuous parameter monitoring systems specified in 40 CFR
§60.5225(a) and (b) in continuous operation according to the permittee's monitoring plan required under 40
CFR §60.4880. [40 CFR §60.5225(c)]
3) If the permittee's SSE unit has a bypass stack, the permittee must install, calibrate (to manufacturers'
specifications), maintain, and operate a device or method for measuring the use of the bypass stack
including date, time, and duration. [40 CFR §60.5225(d)1
Permit Condition (EPO3 through EP06) 0 008
10 CSR 10-6.191 Sewage Sludge incinerators
110 CSR 10-6.191(4) Reporting and Record Keeping — 40 CFR §§60.5230 through 60.5235
Reco?dke nira':
The permittee must maintain the items (as applicable) specified 40 CFR §60.5230(a) through (n) (listed below)
for a period of at least 5 years. All records must be available on site in either paper copy or computer -readable
format that can be printed upon request, unless an alternative format is approved by the Director. [40 CFR
§60.5230]
1) Date. Calendar date of each record. [40 CFR §60.5230(a)]
2) Increments of progress. Copies of the final control plan and any additional notifications, reported under 40
CFR §60.5235. [40 CFR §60.5230(b)]
3) Operator Training. Documentation of the operator training procedures and records specified in 40 CFR
§60.5230(c)(1) through (c)(4). The permittee must make available and readily accessible at the facility at all
times for all SSl unit operators the following documentation specified in 40 CFR §60.5230(c)(1). [40 CFR
§60.5230(c)]
a) Documentation of the following operator training procedures and information:
[40 CFR §60.5230(c)(1)]
i) Summary of the applicable standards under Subpart MMMM of 40 CFR Part 60.
[40 CFR §60.5230(c)(1)(i)]
ii) Procedures for receiving, handling, and feeding sewage sludge. [40 CFR §60.5230(c)(1)(ii)]
iii) Incinerator startup, shutdown, and malfunction preventative and corrective procedures.
[§ 60.523 0(c)(1)(iii)]
iv) Procedures for maintaining proper combustion air supply levels.
[40 CFR §60.5230(c)(1)(iv)]
v) Procedures for operating the incinerator and associated air pollution control systems within the
standards established under this subpart. 140 CFR §60.5230(c)(1)(v)]
vi) Monitoring procedures for demonstrating compliance with the incinerator operating limits. [40 CFR
§60.5230(c)(1)(vi)]
vii) Reporting and recordkeeping procedures. [40 CFR §60.5230(c)(1)(vii)]
viii) Procedures for handling ash. [40 CFR §60.5230(c)(1)(viii)]
ix) A list of the materials burned during the performance test, if any in addition to sewage sludge.
[40 CFR § 60.523 0(c)(1)(ix)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 22
Project No. 2007-06-088
x) For each qualified operator and other plant personnel who may operate the unit according to the
provisions of 40 CFR §60.5155(a), the phone and/or pager number at which they can be reached
during operating hours. [40 CFR §60.5230(c)(1)(x)]
b) Records showing the names of SSI unit operators and other plant personnel who may operate the unit
according to the provisions of 40 CFR §60.5155(a), as follows: [40 CFR §60.5230(c)(2)]
i) Records showing the names of SSI unit operators and other plant personnel who have completed
review of the information in 40 CFR §60.5230(c)(1) as required by 40 CFR §60.5160(b), including
the date of the initial review and all subsequent annual reviews. [40 CFR §60.5230(c)(2)(i)]
ii) Records showing the names of the SSI operators who have completed the operator training
requirements under 40 CFR §60.5130, met the criteria for qualification under §60.5140, and
maintained or renewed their qualification under 40 CFR §60.5145 or §60.5150. Records must
include documentation of training, including the dates of their initial qualification and all subsequent
renewals of such qualifications. [40 CFR §60.5230(c)(2)(ii)]
c) Records showing the periods when no qualified operators were accessible for more than 8 hours, but less
than 2 weeks, as required in 40 CFR §60.5155(a). [40 CFR §60.5230(c)(3)]
d) Records showing the periods when no qualified operators were accessible for 2 weeks or more along
with copies of reports submitted as required in 40 CFR §60.5155(b). [40 CFR §60.5230(c)(4)]
4) Air pollution control device inspections. Records of the results of initial and annual air pollution control
device inspections conducted as specified in 40 CFR §§60.5195 and 60.5220(c), including any required
maintenance and any repairs not completed within 10 days of an inspection or the timeframe established by
the Director. [40 CFR §60.5230(d)]
5) Performance test reports. [40 CFR §60.5230(e)]
a) The results of the initial, annual, and any subsequent performance tests conducted to determine
compliance with the emission limits and standards and/or to establish operating limits, as applicable.
[40 CFR §60.5230(e)(1)]
b) Retain a copy of the complete performance test report, including calculations.
[40 CFR §60.5230(e)(2)]
c) Keep a record of the hourly dry sludge feed rate measured during performance test runs as specified in
40 CFR §60.5220(a)(2)(i). [40 CFR §60.5230(e)(3)]
d) Keep any necessary records to demonstrate that the performance test was conducted under conditions
representative of normal operations, including a record of the moisture content measured as required in
40 CFR §60.5220(a)(2)(ii) for each grab sample taken of the sewage sludge burned during the
performance test. [40 CFR §60.5230(e)(4)]
6) Continuous monitoring data. Records of the following data, as applicable: [40 CFR §60.5230(f)]
a) For continuous parameter monitoring systems: [40 CFR §60.5230(f)(3)]
i) All 1-hour average values recorded for the following operating parameters, as applicable:
[40 CFR §60.5230(f)(3)(i)]
(1) Combustion chamber operating temperature. [40 CFR §60.5230(f)(3)(i)(A)]
(2) Pressure drop across each wet scrubber system and liquid flow rate to each wet scrubber used to
comply with the emission limit in Table 3 to Subpart MMMM of 40 CFR Part 60 for particulate
matter, cadmium, or lead, and scrubber liquid flow rate and scrubber liquid pH for each wet
scrubber used to comply with an emission limit in Table 3 to this subpart for sulfur dioxide or
hydrogen chloride. [40 CFR §60.5230(f)(3)(i)(B)]
ii) All daily average values recorded for the feed rate and moisture content of the sewage sludge fed to
the sewage sludge incinerator, monitored and calculated as specified in 40 CFR §60.5170(f).
[40 CFR §60.5230(f)(3)(ii)]
7) Deviation Reports. Records of any deviation reports submitted under 40 CFR §60.5235(e) and (f).
[40 CFR §60.5230(h)]
MSD - Bissell Point Wastewater Treatment Plant
installation ID: 510-0053
Part 70 Operating Permit 23
Project No. 2007-06-088
8) Equipment specifications and operation and maintenance requirements. Equipment specifications and
related operation and maintenance requirements received from vendors for the incinerator, emission
controls, and monitoring equipment. [40 CFR §60.5230(i)]
9) Inspections, calibrations, and validation checks of monitoring devices. Records of inspections, calibration,
and validation checks of any monitoring devices as required under 40 CFR §§60.5220 and 60.5225.
[40 CFR §60.5230U)]
10) Monitoring plan and performance evaluations for continuous monitoring systems. Records of the
monitoring plans required under 40 CFR §60.5200. [40 CFR §60.5230(k)]
11) Less frequent testing. If, consistent with 40 CFR §5205(a)(3), the permittee elects to conduct performance
tests less frequently than annually, the permittee must keep annual records that document that the permittee's
emissions in the two previous consecutive years were at or below 75 percent of the applicable emission limit
in Table 1 or 2 to Subpart MMMM of 40 CFR Part 60, and document that there were no changes in source
operations or air pollution control equipment that would cause emissions of the relevant pollutant to
increase within the past 2 years. [40 CFR §60.5230(l)]
12) Use of bypass stack. Records indicating use of the bypass stack, including dates, times, and durations as
required under 40 CFR §60.5225(d). [40 CFR §60.5230(m)]
13) If a malfunction occurs, the permittee must keep a record of the information submitted in the permittee's
annual report in 40 CFR §60.5235(c)(16). [40 CFR §60.5230(n)]
Reporting: See Table 6 to Subpart
The permittee must submit the reports specified in 40 CFR §60.5235 (a) through (i). p
MMMM of 40 CFR Part 60 for a summary cf these reports.
1) Annual compliance report. The permittee must submit an annual compliance report that includes the items
listed in 40 CFR §60.5235(c)(1) through (c)(16) (listed below) for the reporting period specified in 40 CFR
§60.5235(c)(3). The permittee must submit the first annual compliance report no later than 12 months
following the submission of the initial compliance report in 40 CFR §60.5235(b). The permittee must
submit subsequent annual compliance reports no more than 12 months following the previous annual
compliance report. (The permittee may be required to submit these reports (or additional compliance
information) more frequently by the title V operating permit required in 40 CFR §60.5240.)
[40 CFR §60.5235(c)]
a) Company name, physical address, and mailing address. [40 CFR §60.5235(c)(1)]
b) Statement by a responsible official, with that official's name, title, and signature, certifying the accuracy
of the content of the report. [40 CFR §60.5235(c)(2)]
c) Date of report and beginning and ending dates of the reporting period. [40 CFR §60.5235(c)(3)]
d) If a performance test was conducted during the reporting period, the results of that performance test.
[40 CFR §60.5235(c)(4)]
i) If operating limits were established during the performance test, include the value for each operating
limit and, as applicable, the method used to establish each operating limit, including calculations.
[40 CFR §60.5235(c)(4)(i)]
ii) If activated carbon is used during the performance test, include the type of activated carbon used.
[40 CFR §60.5235(c)(4)(ii)]
e) For each pollutant and operating parameter recorded using a continuous monitoring system, the highest
average value and lowest average value recorded during the reporting period, as follows:
[40 CFR §60.5235(c)(5)]
i) For continuous parameter monitoring systems, report the following values:
[40 CFR §60.5235(c)(5)(ii)]
(1) For all operating parameters except scrubber liquid pH, the highest and lowest 12-hour average
values. [40 CFR §60.5235(c)(5)(ii)(A)]
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 24
Installation ID: 510-0053
Project No_ 2007-06-088
(2) For scrubber liquid pH, the highest and lowest 3-hour average values.
[40 CFR §60.5235(c)(5)(ii)(B)]
f) If there are no deviations during the reporting period from any emission limit, emission standard, or
operating limit that applies to the permittee, a statement that there were no deviations from the emission
limits, emission standard, or operating limits. [40 CFR §60.5235(c)(6)]
g) If a performance evaluation of a continuous monitoring system was conducted, the results of that
performance evaluation. If new operating limits were established during the performance evaluation,
include the permittee's calculations for establishing those operating limits.
[40 CFR §60.5235(c)(8)]
h) If the permittee elects to conduct performance tests less frequently as allowed in 40 CFR §60.5205(a)(3)
and did not conduct a performance test during the reporting period, the permittee must include the dates
of the last two performance tests, a comparison of the emission level the permittee achieved in the last
two performance tests to the 75 percent emission limit threshold specified in 40 CFR §60.5205(a)(3),
and a statement as to whether there have been any process changes and whether the process change
resulted in an increase in emissions. [40 CFR §60.5235(c)(9)]
i) Documentation of periods when all qualified sewage sludge incineration unit operators were unavailable
for more than 8 hours, but less than 2 weeks. [40 CFR §60.5235(c)(10)]
j) Results of annual air pollution control device inspections recorded under 40 CFR §60.5230(d) for the
reporting period, including a description of repairs. [40 CFR §60.5235(c)(11)]
k) If there were no periods during the reporting period when the permittee's continuous monitoring systems
had a malfunction, a statement that there were no periods during which the permittee's continuous
monitoring systems had a malfunction. [40 CFR §60.5235(c)(12)]
1) If there were no periods during the reporting period when a continuous monitoring system was out of
control, a statement that there were no periods during which the permittee's continuous monitoring
systems were out of control. [40 CFR §60.5235(c)(13)]
m) If there were no operator training deviations, a statement that there were no such deviations during the
reporting period. [40 CFR §60.5235(c)(14)]
n) If the permittee did not make revisions to the permittee's site -specific monitoring plan during the
reporting period, a statement that the permittee did not make any revisions to the permittee's site -
specific monitoring plan during the reporting period. If the permittee made revisions to the permittee's
site -specific monitoring plan during the reporting period, a copy of the revised plan.
[40 CFR §60.5235(c)(15)]
o) If the permittee had a malfunction during the reporting period, the compliance report must include the
number, duration, and a brief description for each type of malfunction that occurred during the reporting
period and that caused or may have caused any applicable emission limitation to be exceeded. The
report must also include a description of actions taken by the permittee during a malfunction of an
affected source to minimize emissions in accordance with 40 CFR §60.11(d), including actions taken to
correct a malfunction. [40 CFR §60.5235(c)(16)}
2) Deviation reports. [40 CFR §60.5235(d)]
a) The permittee must submit a deviation report if: [40 CFR §60.5235(d)(I)]
i) Any recorded operating parameter level, based on the averaging time specified in Table 4 to Subpart
MMMM of 40 CFR Part 60, is above the maximum operating limit or below the minimum operating
limit established under this subpart. [40 CFR §60.5235(d)(1)(i)]
ii) There are visible emissions of combustion ash from an ash conveying system for more than 5
percent of the hourly observation period. [40 CFR §60.5235(d)(1)(iv)]
iii) A performance test was conducted that deviated from any emission limit in Table 3 to Subpart
MMMM of 40 CFR Part 60. [40 CFR §60.5235(d)(1)(v)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 25
Project No. 2007-06-088
iv) The permittee had a malfunction that caused or may have caused any applicable emission limit to be
exceeded. [40 CFR §60.5235(d)(1)(vii)]
b) The deviation report must be submitted by August 1 of that year for data collected during the first half of
the calendar year (January 1 to June 30), and by February 1 of the following year for data the permittee
collected during the second half of the calendar year (July 1 to December 31). [40 CFR §60.5235(d)(2)]
c) For each deviation where the permittee is using a continuous monitoring system to comply with the
operating limit, report the items described in 40 CFR §60.5235 (d)(3)(i) through (d)(3)(viii) (listed
below). [40 CFR §60.5235(d)(3)1
i) Company name, physical address, and mailing address. [40 CFR §60.5235(d)(3)(i)]
ii) Statement by a responsible official, with that official's name, title, and signature, certifying the
accuracy of the content of the report. [40 CFR §60.5235(d)(3)(ii)]
iii) The calendar dates and times the permittee's unit deviated from the emission limits, emission
standards, or operating limits requirements. [40 CFR §60.5235(d)(3)(iii)]
iv) The averaged and recorded data for those dates. [40 CFR §60.5235(d)(3)(iv)]
v) Duration and cause of each deviation from the following: [40 CFR §60.5235(d)(3)(v)]
(1) Emission limits, emission standards, operating limits, and the permittee's corrective actions.
[40 CFR §60.5235(d)(3)(v)(A)1
(2) Bypass events and the permittee's corrective actions. [40 CFR §60.5235(d)(3)(v)(B)]
vi) Dates, times, and causes for monitor downtime incidents. [40 CFR §60.5235(d)(3)(vi)]
vii) A copy of the operating parameter monitoring data during each deviation and any test report that
documents the emission levels. [40 CFR §60.5235(d)(3)(vii)]
viii) If there were periods during which the continuous monitoring system malfunctioned or was out of
control, the permittee must include the following information for each deviation from an emission
limit or operating limit: [40 CFR §60.5235(d)(3)(viii)]
(1) The date and time that each malfunction started and stopped.
[40 CFR §60.5235(d)(3)(viii)(A)1
(2) The date, time, and duration that each continuous monitoring system was inoperative, except for
zero (low-level) and high-level checks. [40 CFR §60.5235(d)(3)(viii)(B)]
(3) The date, time, and duration that each continuous monitoring system was out of control,
including start and end dates and hours and descriptions of corrective actions taken.
[40 CFR §60.5235(d)(3)(viii)(C)]
(4) The date and time that each deviation started and stopped, and whether each deviation occurred
during a period of malfunction, during a period when the system as out of control, or during
another period. [40 CFR §60.5235(d)(3)(viii)(D)]
(5) A summary of the total duration of the deviation during the reporting period, and the total
duration as a percent of the total source operating time during that reporting period.
[40 CFR §60.5235(d)(3)(viii)(E)]
(6) A breakdown of the total duration of the deviations during the reporting period into those that
are.due to control equipment problems, process problems, other known causes, and other
unknown causes. [40 CFR §60.5235(d)(3)(viii)(F)]
(7) A summary of the total duration of continuous monitoring system downtime during the
reporting period, and the total duration of continuous monitoring system downtime as a percent
of the total operating time of the SSI unit at which the continuous monitoring system downtime
occurred during that reporting period. [40 CFR §60.5235(d)(3)(viii)(G)]
(8) An identification of each parameter and pollutant that was monitored at the SSI unit.
[§ 60.5235 (d)(3)(viii)(3H)]
(9) A brief description of the SSi unit. [40 CFR §60.5235(d)(3)(viii)(I)]
(10) A brief description of the continuous monitoring system. [40 CFR §60.5235(d)(3)(viii)(J)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 26
Project No. 2007-06-088
(11) The date of the latest continuous monitoring system certification or audit.
[40 CFR §60.5235(d)(3)(viii)(K)]
(12) A description of any changes in continuous monitoring system, processes, or controls since the
last reporting period. [40 CFR §60.5235(d)(3)(viii)(L)]
d) For each deviation where the permittee is not using a continuous monitoring system to comply with the
associated emission limit or operating limit, report the following items: [40 CFR §60.5235(d)(4)]
i) Company name, physical address, and mailing address. [40 CFR §60.5235(d)(4)(i)]
ii) Statement by a responsible official, with that official's name, title, and signature, certifying the
accuracy of the content of the report. [40 CFR §60.5235(d)(4)(ii]
iii) The total operating time of each affected source during the reporting period.
[40 CFR §60.5235(d)(4)(iii)]
iv) The calendar dates and times the permittee's unit deviated from the emission limits, emission
standards, or operating limits requirements. [40 CFR §60.5235(d)(4)(iv)]
v) The averaged and recorded data for those dates. [40 CFR §60.5235(d)(4(v))]
vi) Duration and cause of each deviation from the following: [40 CFR §60.5235(d)(4)(vi)]
(1) Emission limits, emission standards, operating limits, and the permittee's corrective actions.
[40 CFR §60.5235(d)(4)(vi)(A)]
(2) Bypass events and the permittee's corrective actions. [40 CFR §60.5235(d)(4)(vi)(B)]
vii) A copy of any performance test report that showed a deviation from the emission limits or
standards. [40 CFR §60.5235(d)(4)(vii)]
viii) A brief description of any malfunction reported in 40 CFR §60.5235(d)(1)(vii), including a
description of actions taken during the malfunction to minimize emissions in accordance with 40
CFR §60.11(d) and to correct the malfunction. [40 CFR §60.5235(d)(4)(viii)]
3) Qualified operator deviation. [40 CFR §60.5235(e)]
a) If all qualified operators are not accessible for 2 weeks or more, the permittee must take the two actions
in 40 CFR §60.5235(e)(1Xi) and (e)(I)(ii) (listed below). [40 CFR §60.5235(e)(1)]
i) Submit a notification of the deviation within 10 days that includes the three items in 40 CFR
§60.5235 (e)(I)(i)(A) through (e)(1)(i)(C) (listed below). [40 CFR §60.5235(e)(1)(i)]
(1) A statement of what caused the deviation. [40 CFR §60.5235(e)(1)(i)(A)]
(2) A description of actions taken to ensure that a qualified operator is accessible.
[40 CFR §60.5235(e)(1)(i)(B)j
(3) The date when the permittee anticipates that a qualified operator will be available.
[40 CFR §60.5235(e)(1)(i)(C)]
ii) Submit a status report to the Director every 4 weeks that includes the three items in 40 CFR
§60.5235 (e)(1)(i.i)(A) through (e)(1)(ii)(C) (listed below). [40 CFR §60.5235(e)(1)(ii)1
(1) A description of actions taken to ensure that a qualified operator is accessible.
[40 CFR §60.5235(e)(1)(ii)(A)]
(2) The date when the permittee anticipates that a qualified operator will be accessible.
[40 CFR §60.5235(e)(1)(ii)(B)]
(3) Request for approval from the Director to continue operation of the SSI unit.
[40 CFR §60.5235(eX1Xii)(C)]
b) If the permittee's unit was shut down by the Director, under the provisions of 40 CFR §60.5155(b)(2)(i),
due to a failure to provide an accessible qualified operator, the permittee must notify the Director within
five days of meeting 40 CFR §60.5155(b)(2)(ii) that the permittee is resuming operation.
[40 CFR §60.5235(e)(2)]
4) Not(cation of a force majeure. If a force majeure is about to occur, occurs, or has occurred for which the
permittee intends to assert a claim of force majeure: [40 CFR §60.5235(f)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 27
Project No. 2007-06-088
a) The pennittee must notify the Director, in writing as soon as practicable following the date the permittee
first knew, or through due diligence, should have known that the event may cause or caused a delay in
conducting a performance test beyond the regulatory deadline, but the notification must occur before the
performance test deadline unless the initial force majeure or a subsequent force majeure event delays the
notice, and in such cases, the notification must occur as soon as practicable. [40 CFR §60.5235(f)(1)1
b) The permittee must provide to the Director a written description of the force majeure event and a
rationale for attributing the delay in conducting the perforrrtance test beyond the regulatory deadline to
the force majeure; describe the measures taken or to be taken to minimize the delay; and identify a date
by which the permittee proposes to conduct the performance test. [40 CFR §60.5235(1)(2)]
5) Other notifications and reports required. The permittee must submit other notifications as provided by 40
CFR §60.7 and as follows: [40 CFR §60.5235(g)]
a) The permittee must notify the Director 1 month before starting or stopping use of a continuous
monitoring system for determining compliance with any emission limit. [40 CFR §60.5235(g)(1)]
b) The permittee must notify the Director at least 30 days prior to any performance test conducted to
comply with the provisions of this subpart, to afford the Director the opportunity to have an observer
present, [40 CFR §60.5235(g)(2)]
c) As specified in 40 CFR §60.5220(a)(8), the permittee must notify the Director at least 7 days prior to the
date of a rescheduled performance test for which notification was previously made in 40 CFR
§60.5235(g)(2). [40 CFR §60.5235(g)(3)]
6) Report submission form. [40 CFR §60.5235(h)]
a) The permittee must submit initial, annual, and deviation reports electronically or in paper format,
postmarked on or before the submittal due dates. [40 CFR §60.5235(h)(1)]
b) As of January 1, 2012 and within 60 days after the date of completing each performance test, as defined
in 40 CFR §63.2, conducted to demonstrate compliance with Subpart IVMMMM of 40 CFR Part 60, the
permittee must submit relative accuracy test audit (i.e., reference method) data and performance test
(i.e., compliance test) data, except opacity data, electronically to EPA's Central Data Exchange (CDX)
by using the Electronic Reporting Tool (ERT) (see http://www.epa.gov/ttn/chief/ert/ert tool.html/) or
other compatible electronic spreadsheet. Only data collected using test methods compatible with ERT
are subject to this requirement to be submitted electronically into EPA's WebFIRE database.
[40 CFR §60.5235(h)(2)]
7) Changing report dates. If the Director agrees, the permittee may change the semiannual or annual reporting
dates. See 40 CFR §60.19(c) for procedures to seek approval to change the permittee's reporting date.
[40 CFR §60.5235(i)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit
28
Project No. 2007-06-088
ln:
unit ....
EP09
EP09 - Ash Handling System
Wet Ash Conveying (constructed 1967)
Air Pollution Control — Venturi Scrubber and Mist Eliminator
(CD29 and CD30)
Model.
United Conveyor
Permit Condition (EP09) - 001
10 CSR 10-6.191 Sewage Sludge Incinerators
40 CFR Part 60 Subpart MMMM Emission Guidelines and Compliance Times for Existing Sewage Sludge
Incineration Units.
Emission Limitation and Standards:
Pursuant to 40 CFR §60.5165, the permittee must meet the emission limits and standards specified in Table 3 to
40 CFR Part 60, Subpart MMMM for ash handling system by the final compliance date under the approved
state plan, Federal plan, or delegation, as applicable. The emission limits and standards apply at all times the ash
handling system is operating and during periods of malfunction. [40 CFR §60.5170]
Table 3 to Subpart MMMM of 40 CFR Part 60 —Emission Limits and Standards
For the air
pollutant
Fugitive emissions
from ash handling
The permittee must
meet this emission limit
Visible emissions of
combustion ash from an
ash conveying system
(including conveyor
transfer points) for no
more than 5 percent of the
hourly observation period
Using these averaging methods and minimum
sampling volumes or durations
Three 1-hour observation periods
And determine compliance
using this method
Visible emission test (Method
2 of Appendix A-7 of 40 CFR
Part 60).
2
Oi'eratin, Limits and Requirements:
The permittee must meet the operating limits and requirements specified in 40 CFR §60.5170 (d) (listed below),
according to the schedule specified in 40 CFR §60.5170 (e). The permittee must comply with the requirements
in 40 CFR §60.5170 (g) for meeting any new operating limits, re-established in 40 CFR §60.5210. The
operating limits apply at all times that sewage sludge is in the combustion chamber (i.e., until the sewage sludge
feed to the combustor has been cut off for a period of time not less than the sewage sludge incineration
residence time). [40 CFR §60.5170]
MSD - Bissell Point Wastewater Treatment Plant Part 70 operating Permit 29
Installation ID: 510-0053 Project No. 2007-06-088
Table 4 to Subpart MMMM of 40 CFR Part 60—Operating Parameters for Existing Sewage Sludge Incineration
Units'
For these operating
parameters
Fugitive emissions from
ash handling
The permittee must establish these
operating limits
Site -specific operating requirements
And monitor using these minimum frequencies
Data
measurement
Not applicable
Data recording
Not applicable
Data averaging period
for compliance
Not applicable.
1) The permittee must meet the operating requirements in the permittee's site -specific fugitive emission
monitoring plan, submitted as specified in 40 CFR §60.5200(d) to ensure that the ash handling system will
meet the emission standard for fugitive emissions from ash handling. [40 CFR §60.5170(d)]
2) The permittee must meet the operating limits and requirements specified in 40 CFR §60.5170(d) by the final
compliance date under the approved state plan, Federal plan, or delegation, as applicable.
[40 CFR §60,5i70(e)]
3) For the operating limits and requirements specified in 40 CFR §60.5170 (d), the permittee must meet any
new operating limits and requirements, re-established according to 40 CFR §60.5210(d).
[40 CFR §60.5170(g)]
Permit Condition (EP09) - 002
10 CSR 10-6.400 Restriction of Emission of Particulate Matter from Industrial Processes
40 CFR Part 64 Compliance Assurance Monitoring (CAM)
Emission Limitation:
1) The permittee shall not emit particulate matter in excess of 25.2 lbs/br from EP09.
2) The permittee shall not cause, allow or permit the emission of particulate matter from any source in a
concentration in excess of 0.30 grain per standard cubic foot of exhaust gases.
Monitorinj(:
1) The permittee is subject to the CAM plan contained in Attachment E.
2) CAM Compliance Indicators: The following CAM Indicators shall be used to monitor the control device
(Venturi Scrubber with Mist Eliminator):
a) Visible Emissions
i) Visible emissions from the scrubber stack exhaust shall be monitored using the procedures contained
in U.S. EPA Test Method 22 on a daily basis to ensure no visible emissions during the operation of
this unit. The permittee is only required to take readings when the emission unit is operating and
when the weather conditions allow.
b) Pressure Drop
i) The permittee shall check and document the Venturi scrubber/Mist Eliminator pressure drop daily.
The pressure drop across the Venturi scrubber/Mist Eliminator shall be maintained within the range
of 1.0 to 10.0 inches of water (H20).
3) CAM Compliance Indicator Range: An excursion is defined as either the presence of visible emissions or as
a pressure drop less than 1.0 inch H2O or a pressure drop greater than 10.0 inches H20. An excursion of
either indicator constitutes an excursion. If visible emissions are present when the pressure drop is within
its specified indicator range and no Venturi Scrubber/Mist Eliminator problems are identified as the cause,
the pressure drop indicator range shall be re-evaluated by MSD. Excursions trigger an inspection,
corrective action, and need to be reported in the next Semiannual Monitoring Report; if an excursion results
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 30
Project No. 2007-06-088
in excess emissions exceeding one hour, MSD may elect to file a startup, shutdown, and malfunction
assertion under 10 CSR 10-6.050 if appropriate to the situation.
4) Continued operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required
quality assurance or control activities, the permittee shall collect data at all required intervals when the
emission unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required
quality assurance or control activities shall not be used for purposes of 40 CFR Part 64. The permittee shall
use all the data collected during all other periods in assessing the operation of the control device and
associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable
failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor
maintenance or careless operation are not malfunctions. [40 CFR §64.7(c)]
5) Response to exceedances: [40 CFR §64.7(d)]
a) Upon detecting an exceedance, the permittee shall restore operation of the emission unit (including the
control device and associated capture system) to its normal or usual manner of operation as
expeditiously as practicable in accordance with good air pollution control practices for minimizing
emissions. The response shall include minimizing the period of any startup, shutdown or malfunction
and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence
of the cause of an exceedance (other than those caused by excused startup or shutdown conditions).
Such actions may include initial inspection and evaluation, recording that operations returned to normal
without operator action (such as through response by a computerized distribution control system), or any
necessary follow-up actions to return operation to within the indicator range, designated condition, or
below the applicable emission limitation or standard, as applicable. [40 CFR §64.7(d)(1)]
b) Determination of whether the permittee has used acceptable procedures in response to an excursion or
exceedance will be based on information available, which may include but is not limited to, monitoring
results, review of operation and maintenance procedures and records, and inspection of the control
device, associated capture system, and the process. [40 CFR §64.7(d)(2)]
Recor keevinR:
1) General Recordkeeping Requirements:
a) The permittee shall comply with the recordkeeping requirements specified in 40 CFR §70.6(a)(3)(ii).
The permittee shall maintain records of monitoring data, monitor performance data, corrective actions
taken, any written quality improvement plan required pursuant to 40 CFR §64.8 and any activities
undertaken to implement a quality improvement plan, and other supporting information required to be
maintained under 40 CFR Part 64 (such as data used to document the adequacy of monitoring, or records
of monitoring maintenance or corrective actions). [40 CFR §64.9(b)(1)]
b) Instead of paper records, the permittee may maintain records on alternative media, such as microfilm,
computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media
allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping
requirements. [40 CFR §64.9(b)(2)]
2) All records shall be maintained for five years.
3) These records shall be made available immediately for inspection to the Department of Natural Resources'
personnel upon their verbal request and presentation of identification.
Renorthez:
1) General Reporting Requirements: The permittee shall submit semi-annual monitoring certified by a
responsible official using the semi-annual monitoring report and annual compliance certification to the Air
Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO
65102, as required by 10 CSR 10-6.065(6)(C)1. C.(III). The report shall include, at a minimum, the
following information, as applicable: [40 CFR §64.9(a)(1) & (2)]
a) All instances of deviations from perrnit requirements must be clearly identified;
MSD - Bissell Point Wastewater Treatment Plant
Installation 1D: 510-0053
Part 70 Operating Permit 31
Project No. 2007-06-088
b) Prompt reporting of deviations from permit requirements, including those attributable to upset
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or
preventive measures taken;
c) Summary information on the number, duration and cause (including unknown cause, if applicable) of
excursions or exceedances, as applicable, and the corrective actions taken;
[40 CFR §64.9(a)(2)(i)]
d) Summary information on the number, duration and cause (including unknown cause, if applicable) for
monitor downtime incidents (other than downtime associated with zero and span or other daily
calibration checks, if applicable); and [40 CFR §54.9(a)(2)01)]
e) A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR
§64.8. Upon completion of a QIP, the permittee shall include in the next summary report documentation
that the implementation of the plan has been completed and reduced the likelihood of similar levels of
excursions or exceedances occurring. [40 CFR §64.9(a)(2)(iii)].
2) Documentation of need for improved monitoring: If the permittee identifies a failure to achieve compliance
with this permit condition for which the approved monitoring did not provide an indication of an
exceedance while providing valid data, or the results of compliance or performance testing document a need
to modify the existing indicator ranges or designated conditions, the permittee shall promptly notify the Air
Pollution Control Program and, if necessary, submit a proposed modification to the 40 CFR Part 70 permit
to address the necessary monitoring changes. Such a modification may include, but is not limited to,
reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring
and collecting data, or the monitoring of additional parameters. [40 CFR §64.7(e)]
3) The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.
O. Box 176, Jefferson City, MO 65102 or AirComplianceReporting@dnr.mo.gov no later than ten (10) days
after any deviations/exceedance of the Emission Limitation.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit
32
Project No. 2007-06-088
EP- I O
EP10 — Underground Gasoline Storage Tank
1,000 Gallon Underground Gasoline Storage Tank
Permit Condition (EP10) - 001
10 CSR 10-5.220 Control of Petroleum Liquid Storage, Loading and Transfer.
Operational Limitation/Eauipmment Specifications:
The permittee shall not cause or permit the transfer of gasoline from a delivery vessel into a gasoline storage
tank with a capacity greater than five hundred (500) gallons and less than or equal to one thousand (1,000)
gallons unless — [10 CSR 10-5.220(3)(C)1.]
I) The gasoline storage tank is equipped with a submerged fill pipe extending unrestricted to within six inches
(6") of the bottom of the tank, and not touching the bottom of the tank, or the storage tank is equipped with
a system that allows a bottom fill condition; [10 CSR 10-5.220(3)(C)1.A.]
2) All storage tank caps and fittings are vapor -tight when gasoline transfer is not taking place; and [10 CSR 10-
5.220(3)(C)1.B.]
3) The storage tank is vented via a conduit that is — [10 CSR 10-5.220(3)(C)1.C.]
a) At least two inches (2") inside diameter; [10 CSR 10-5.220(3)(C)1.C.(I)]
b) At least twelve feet (12') in height above grade; and [10 CSR 10-5.220(3)(C)1.C.(II)]
c) Equipped with a pressure/vacuum valve that is CARB certified at three inches water column
pressure/eight inches water column vacuum (3"wcp/8"wcv) except when the permittee provides
documentation that the vapor recovery is CARB certified for a different valve and will not function
properly with a 3"wcp/8"wcv valve. [10 CSR 10-5.220(3XC)1.C.(III)]
Repordn
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.O.
Box 176, Jefferson City, MO 65102, no later than ten (10) days after any exceedance of any of the terms
imposed by this regulation. Any deviations from this permit condition shall also be reported in the semi-annual
monitoring report and annual compliance certification, as required by Section V of this permit.
Permit Condition (EP10) - 002
10 CSR 10-6.075 Maximum Achievable Control Technology Regulations
40 CFR Part 63, Subpart CCCCCC National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities
Emission Limitation:
40 CFR §63.11116 Requirements for facilities with monthly throughput of less than 10,000 gallons of
gasoline.
1) The permittee must not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following:
[40 CFR §63.11116(a)]
a) Minimize gasoline spills; [40 CFR §63.11116(a)(1)]
b) Clean up spills as expeditiously as practicable; [40 CFR §63.11116(a)(2)]
c) Cover all open gasoline containers and all gasoline storage tank fill -pipes with a gasketed seal when not
in use; [40 CFR §63.11116(a)(3)]
MSD -Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 33
Project No. 2007-06-088
installation ID: 510-0053
d) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators. [40 CFR §63.11116(a)(4)]
2) The permittee is not required to submit notifications or reports as specified in 40 CFR §63.11125,
§63.11126, or Subpart A of 40 CFR Part 63, but the permittee roust have records available within 24 hours
of a request by the Administrator to document the permittee's gasoline throughput. [40 CFR §63.11116(b)]
3) Portable gasoline containers that meet the requirements of 40 CFR Part 59, Subpart F, Control of
Evaporative Emissions From New and In -Use Portable Fuel Containers, are considered acceptable for
compliance with 40 CFR §63.11116(a)(3). [40 CFR §63.11116(d)1
EP14 through EP16 - Sludge Building Boilers
Emission
Unit
EP14
EP15
EP16
Description
Manufaebirer•I
Model- #
Sludge Building Boiler #1 —
(instal.led — 1990)
Sludge Building Boiler #2 —
(installed — 1990)
Sludge Building Boiler #3
(installed — 1990)
14.65 MMBtu/hr natural gas -fired boiler.
14.65 MMBtu/hr natural gas -fired boiler.
—14.65 MMBtu/hr natural gas -fired boiler.
Cleaver Brooks, CB-350
Permit Condition (EP14 through EP16) - 001
10 CSR 10-6.060 Construction Permits Required
;Construction Permit No. 95-05-029A, Issued November 4, 1997
Emission Limitation:
1) The permittee must limit the natural gas usage in these boilers (EP14, EP15 and EP16) to less than or equal
to 33 million cubic feet in any consecutive 12-month period.
2) The permittee shall operate and maintain all equipment according to the manufacturer's instruction.
3) Personnel shall be qualified to operate and maintain these equipment.
Monitorinj/Record keepinv:
The permittee shall maintain an accurate record of the natural gas usage in the boilers. The permittee shall
record monthly and running 12-month totals of natural gas usage. The permittee shall also keep records of
equipment maintenance.
Reporting:
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.O.
Box 176, Jefferson City, MO 65102 or AirComplianceReporting@dnr.mo.gov, no later than ten (10) days after
any exceedance of any of the terms imposed by this regulation. Any deviations from this permit condition shall
also be reported in the semi-annual monitoring report and annual compliance certification, as required by
Section Y of this permit.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit
34
Project No. 2007-06-088
Permit Condition (EP14 through EP16) - 002
10 CSR 10-6.070 New Source Performance Regulations
40 CFR Part 60 Subpart De
Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units
Emission Limitation:
Not applicable
Monitorin, Record keepin2/Reuortinp:
The permittee shall record and maintain records of the amounts of fuel combusted during each calendar month.
[40 CFR §60.48c(g)(2)]
•
n Unit
EP 18
EP 19
EP20
EP18 — Pump Station Boilers
EP19 — Primary Control Building Boiler
EP20 — Administrative Building Boilers
EP22 — Trickling Filter Pump Station Boilers
Pump Station Boilers (2) — 7.32 MMBtu/hr (each) natural gas -fired
boilers.
Primary Control Building Boiler — 0.15 MMBtu/hr natural gas -fired
boiler.
Administration Building Boilers (2) —1.35 MMBtu/hr (each) natural
gas -fired boilers.
I au r[
Model #
Cleaver Brooks
EP22
Trickling Filter Pump Station Boiler — 1.3 MMBtu/hr natural gas -fired
boiler.
Hydrothenn/
AM 150
Weil McLain/
BG 688WF
Burnham/
4F W-127-40-G-6P
Permit Condition (EP18 through EP20) - 001 and
Permit Condition (EP22) - 001
10 CSR 10-6.060 Construction Permits Required
Construction Permit No. 95-05-029A, Issued November 4, 1997
Emission Limitation:
1) Natural gas usage in these boilers (EP18, EP19, EP20 and EP22) shall not exceed 60 million cubic feet in
any consecutive 12-month period.
2) The permittee shall operate and maintain all equipment according to the manufacturer's instruction.
3) Personnel shall be qualified to operate and maintain the equipment.
Monitoring/Record keeping:
The permittee shall maintain an accurate record of the natural gas usage in the boilers. The permittee shall
record monthly and running 12-month totals of natural gas usage. The permittee shall also keep records of
equipment maintenance.
Reporting:
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.O.
Box 176, Jefferson City, MO 65102 or AirComplianceReporting@a dnr.mo.gov, no later than ten (10) days after
any exceedance of any of the terms imposed by this regulation. Any deviations from this permit condition shall
also be reported in the semi-annual monitoring report and annual compliance certification, as required by
Section V of this permit,
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 35
Installation ID: 510-0053 Project No. 2007-06-088
EP23 — Biofilter
Emission
Unit.
EP23
Description
Biofilter to control hydrogen sulfide (H2S) emissions from the wastewater treatment plant. Installed: 1996
Permit Condition (EP23) 0 1
10 CSR 10-6.060 Construction Permits Required
Construction Permit No. 95-05-069, Issued March 1, 1996
Emission Limitation:
1) The permittee must limit hydrogen sulfide (H2S) emissions from the biofilter system to less than or ten (10)
tons in any 12-month period.
2) The permittee shall operate and maintain all equipment according to the manufacturer's instructions,
Monitoring:
The permittee shall measure the concentration of hydrogen sulfide on a monthly basis to characterize the
efficiency of the biofilter system and the amount of the H2S emitted in to the ambient air. The concentration of
H2S shall be determined using a Hydrogen Sulfide Analyzing instrument calibrated using National Institute of
Standards and Technology (MIST) traceable H2S gas.
Recordkeeping:
The permittee shall keep accurate, easily understood, up to date records of H2S concentrations; and biofilter
loading rate to determine:
1) The quantity of H2S gas released into the ambient air.
2) The efficiency of the biofilter system in removing H2S from the clarifiers. These records shall be kept as
month to month moving average indicating hydrogen sulfide emissions during the previous 12 months.
Reporting:
The permittee shall report to the Air Pollution Control Program, Compliance and Enforcement Section, P.C.
Box 176, Jefferson City, MO 65102 or AirComplianceReporting@dnr.mo.gov, no later than ten (10) days after
any exceedance of any of the terms imposed by this regulation. Any deviations from this permit condition shall
also be reported in the semi-annual monitoring report and annual compliance certification, as required by
Section V of this permit.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 36
Project No. 2007-06-088
IV. Core Permit Requirements
The installation shall comply with each of the following regulations or codes. Consult the appropriate sections
in the Code of Federal Regulations (CFR), the Code of State Regulations (CSR), and local ordinances for the
full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as
of the date that this permit is issued. The following are only excerpts from the regulation or code, and are
provided for summary purposes only.
City of St. Louis Ordinance 68657, §16 Open Burning Restrictions
1) No person shall cause, suffer, allow or permit the open burning of refuse.
2) No person shall conduct, cause or permit the conduct of a salvage operation by open burning.
3) No person shall conduct, cause or permit the disposal of trade waste by open burning.
4) No person shall cause or permit the open burning of leaves, trees or the byproducts therefrom, grass, or
other vegetation.
5) It shall be prima -facie evidence that the person who owns or controls property on which open burning
occurs, has caused or permitted said open burning.
10 CSR 10-6.050 Start-up, Shutdown and Malfunction Conditions
1) In the event of a malfunction, which results in excess emissions that exceed one hour, the permittee shall
submit to the director within two business days, in writing, the following information:
[10 CSR 10-6.050(3)(A)]
a) Name and location of installation;
b) Name and telephone number of person responsible for the installation;
c) Name of the person who first discovered the malfunction and precise time and date that the malfunction
was discovered.
d) identity of the equipment causing the excess emissions;
e) Time and duration of the period of excess emissions;
f) Cause of the excess emissions;
g) Air pollutants involved;
h) Estimate of the magnitude of the excess emissions expressed in the units of the applicable requirement
and the operating data and calculations used in estimating the magnitude;
i) Measures taken to mitigate the extent and duration of the excess emissions; and
j) Measures taken to remedy the situation that caused the excess emissions and the measures taken or
planned to prevent the recurrence of these situations.
2) The permittee shall submit the paragraph 1 information to the director in writing at least ten days prior to
any maintenance, start-up or shutdown activity which is expected to cause an excessive release of emissions
that exceed one hour. if notice of the event cannot be given ten days prior to the planned occurrence, notice
shall be given as soon as practicable prior to the activity.
[10 CSR 10-6.050(3XB)]
3) Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under
section 643.140, RSMo, the permittee may provide information showing that the excess emissions were the
consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the
paragraph 1 list and shall be submitted not later than 15 days after receipt of the notice of excess emissions.
Based upon information submitted by the permittee or any other pertinent information available, the director
or the commission shall make a determination whether the excess emissions constitute a malfunction, start-
up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement
action under section 643.080 or 643.151, RSMo. [l0 CSR I0-6.050(3)(C)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 37
Project No. 2007-06-088
4) Nothing in this rule shall be construed to limit the authority of the director or commission to take
appropriate action, under sections 643.080, 643.090 and 643.151, RSMo to enforce the provisions of the Air
Conservation Law and the corresponding rule. [10 CSR 10-6.050(3)(D)]
5) Compliance with this rule does not automatically absolve the permittee of liability for the excess emissions
reported. [10 CSR 10-6.050(3)(E)]
10 CSR 10-6.060 Construction Permits Required
The permittee shall not commence construction, modification, or major modification of any installation subject
to this rule, begin operation after that construction, modification, or major modification, or begin operation of
any installation which has been shut down longer than five years without first obtaining a permit from the
permitting authority. [10 CSR 10-6.060(1)(C)]
10 CSR 10-6.065 Operating Permits
The permittee shall file a complete application for renewal of this operating permit at least six months before
the date of permit expiration. In no event shall this time be greater than eighteen months. The permittee shall
retain the most current operating permit issued to this installation on -site. The permittee shall immediately snake
such permit available to any Missouri Department of Natural Resources personnel upon request. [10 CSR 10-
6.065(6)(C)3.B]
10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants and 40 CFR Part 61 Subpart M
National Emission Standard for Asbestos
The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for any activities
occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart M, National
Emission Standard for Asbestos.
10 CSR 10-6.110 Reporting of Emission Data, Emission Fees and Process Information
1) 1) The permittee shall submit a Full Emissions Report either electronically via MoE1S, which requires
Form 1.0 signed by an authorized company representative, or on Emission Inventory Questionnaire (E1Q)
paper forms on the frequency specified in Table 4 of 10 CSR 10-6.100 and in accordance with the
requirements of 10 CSR 10-6.110. Alternate methods of reporting the emissions, such as spreadsheet file,
can be submitted for approval by the director.
[10 CSR 10-6.110(4)(B) and (C)]
2) Public Availability of Emission Data and Process Information. Any information obtained pursuant to the
rule(s) of the Missouri Air Conservation Commission that would not be entitled to confidential treatment
under 10 CSR 10-6.210 shall be made available to any member of the public upon request.
[10 CSR 10-6.110(3)(D)]
3) The permittee shall pay an annual emission fee per ton of applicable pollutant emissions identified in Table
2 of 10 CSR 10-6.110. [10 CSR 10-6.110(3)(A)]
10 CSR 10-6.130 Controlling Emissions During Episodes of High Air Pollution Poten ii .i
This rule specifies the conditions that establish an air pollution alert (yellow/orange/red/purple), or emergency
(maroon) and the associated procedures and emission reduction objectives for dealing with each. The permittee
shall submit an appropriate emergency plan if required by the Director.
[10 CSR 10-6.130(4)]
MSD - BisseIl Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 38
Project No. 2007-06-088
10 CSR 10-6.150 Circumvention
The permittee shall not cause or permit the installation or use of any device or any other means which, without
resulting in reduction in the total amount of air contaminant emitted, conceals or dilutes an emission or air
contaminant which violates a rule of the Missouri Air Conservation Commission,
10 CSR 10-6.165 Restriction of Emission of Odors
This requirement is a State Only permit requirement.
No person may cause, permit or allow the emission of odorous matter in concentrations and frequencies or for
durations that odor can be perceived when one volume of odorous air is diluted with seven volumes of odor -free
air for two separate trials not less than 15 minutes apart within the period of one hour. This odor evaluation
shall be taken at a location outside of the installation's property boundary.
10 CSR 10-6.170
Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin
I) The permittee shall not cause or allow to occur any handling, transporting or storing of any material;
construction, repair, cleaning or demolition of a building or its appurtenances; construction or use of a road,
driveway or open area; or operation of a commercial or industrial installation without applying reasonable
measures as may be required to prevent, or in a manner which allows or may allow, fugitive particulate
matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found
on surfaces beyond the property line of origin. The nature or origin of the particulate matter shall be
determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the
director. [10 CSR 10-6.170(1)(A)]
2) The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remain visible
in the ambient air beyond the property line of origin. [10 CSR 10-6.170(1)(B)]
3) Should it be determined that noncompliance has occurred, the director may require reasonable control
measures as may be necessary. These measures may include, but are not limited to, the following: [10 CSR
10-6.170(2)]
a) Revision of procedures involving construction, repair, cleaning and demolition of buildings and their
appurtenances that produce particulate matter emissions; [10 CSR 10-6.170(2)(A)]
b) Paving or frequent cleaning of roads, driveways and parking Iots; [10 CSR 10-6.170(2)(B)]
c) Application of dust -free surfaces; [10 CSR 10-6.170(2)(C)]
d) Application of water; and [10 CSR 10-6.170(2)(D)]
e) Planting and maintenance of vegetative ground cover. [10 CSR 10-6.170(2)(E)]
10 CSR 10-6.180 Measurement of Emissions of Air Contaminants
I) The director may require any person responsible for the source of emission of air contaminants to make or
have made tests to determine the quantity or nature, or both, of emission of air contaminants from the
source. The director may specify testing methods to be used in accordance with good professional practice.
The director may observe the testing. All tests shall be performed by qualified personnel. [10 CSR 10-
6.180(1)]
2) The director may conduct tests of emissions of air contaminants from any source. Upon request of the
director, the person responsible for the source to be tested shall provide necessary ports in stacks or ducts
and other safe and proper sampling and testing facilities, exclusive of instruments and sensing devices as
may be necessary for proper determination of the emission of air contaminants. [10 CSR 10-6.180(2)]
3) The director shall be given a copy of the test results in writing and signed by the person responsible for the
tests. [l0 CSR 10-6.180(1)]
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 39
Installation ID: 510-0053 Project No. 2007-06-088
10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants
E issio29ILipr+riagatIon:
1) The permittee shall not cause or permit to be discharged into the atmosphere from any source, not exempted
under 10 CSR 10-6.220, any visible emissions with an opacity greater than 20%,
[10 CSR 10-6.220(3)(A)]
2) Exception: The permittee may discharge into the atmosphere visible emissions of up to 40% for a period
not aggregating more than one (1) six (6) minutes period in any 60 minutes.
[10 CSR 10-6.220(3)(B)]
Monitor/NE,
1) The permittee shall conduct opacity readings on each emission unit using the procedures contained in
USEPA Test Method 22 (unless another method or procedure is specified in this permit). The permittee is
only required to take readings when the emission unit is operating and when the weather conditions allow.
if the permittee observes no visible or other significant emissions using these procedures, then no further
observations are required. For emission units with visible emissions perceived or believed to exceed the
applicable opacity standard, a source representative would then conduct a Method 9 observation.
2) The permittee must maintain the thllowing monitoring schedule:
a) Observations must be made once per month. If a violation is noted, then
b) Weekly observations shall be conducted for a minimum of eight (8) consecutive weeks. Should rio
violation of this regulation be observed during this period then monitoring reverts to monthly
monitoring.
RecordkeepinR:
1) The permittee shall maintain records of ali observation results using Attachment B (or its equivalent),
noting:
a) Whether any air emissions (except for water vapor) were visible from the emission units;
b) All emission units from which visible emissions occurred;
c) Whether the visible emissions were normal for the process;
d) The permittee shall maintain records of any equipment malfunctions, which may contribute to visible
emissions; and,
2) The permittee shall maintain records of any Method 9 test performed in accordance with this permit
condition. (See Attachment C).
10 CSR 10-6.250 Asbestos Abatement Projects — Certification, Accreditation, and Business Exemption
Requirements
This requirememt is a State Only permit requirement.
The permittee shall conduct all asbestos abatement projects within the procedures established for certification
and accreditation by 10 CSR 10-6.250.
1) This rule requires individuals who work in asbestos abatement projects to be certified by the Missouri
Department of Natural Resources Air Pollution Control Program. [10 CSR 10-6.250(3)(A)].
2) This rule requires training providers who offer training for asbestos abatement occupations to be accredited
by the Missouri Department of Natural Resources Air Pollution Control Program.
[10 CSR 10-6.250(3)(D)]
3) This rule requires persons who hold exemption status from certain requirements of this rule to allow the
department to monitor training provided to employees. [10 CSR 10-6.250(3)(E)]
10 CSR 10-6.280 Compliance Monitoring Usage
1) The permittee is not prohibited from using the following in addition to any specified compliance methods
for the purpose of submission of compliance certificates: [10 CSR 10-6.280(3)(A)]
a) Monitoring methods outlined in 40 CFR Part 64; [10 CSR 10-6.280(3)(A)1.]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 40
Project No. 2007-06-088
b) Monitoring method(s) approved for the permittee pursuant to 10 CSR 10-6.065, "Operating Permits",
and incorporated into an operating permit; and [10 CSR 10-6.280(3)(A)2.]
c) Any other monitoring methods approved by the director. [10 CSR 10-6.280(3)(A)3.]
2) Any credible evidence may be used for the purpose of establishing whether a permittee has violated or is in
violation of any such plan or other applicable requirement. Information from the use of the following
methods is presumptively credible evidence of whether a violation has occurred at an installation: [10 CSR
10-6.280(3)(B)]
a) Monitoring methods outlined in 40 CFR Part 64; [10 CSR 10-6.280(3)(B)1.]
b) A monitoring method approved for the permittee pursuant to 10 CSR 10-6.065, "Operating Permits",
and incorporated into an operating permit; and [10 CSR 10-6.280(3)(B)21
c) Compliance test methods specified in the rule cited as the authority for the emission Iimitations.
[10 CSR 10-6.280(3)(B)3j
3) The following testing, monitoring or information gathering methods are presumptively credible testing,
monitoring, or information gathering methods: [10 CSR 10-6.280(5)]
a) Applicable monitoring or testing methods, cited in: [10 CSR 10-6.280(5)(A)]
i) 10 CSR 10-6.030, "Sampling Methods for Air Pollution Sources";
ii) 10 CSR 10-6.040, "Reference Methods";
iii) 10 CSR 10-6;070, "New Source Performance Standards";
iv) 10 CSR 10-6.080, "Emission Standards for Hazardous Air Pollutants"; or
b) Other testing, monitoring, or information gathering methods, if approved by the director, that produce
information comparable to that produced by any method listed above.
[10 CSR 10-6.280(5)(B)]
10 CSR 10-5.040 Use of Fuel in Hand -Fired Equipment Prohibited
(Rescinded on September 30, 2018, Contained in State Implementation Plan)
No owner or operator shall operate applicable hand -fired, fuel -burning equipment unless the owner or operator
meets the conditions set forth in 10 CSR 10-5.040(3). This regulation shall apply to all hand -fired fuel -burning
equipment at commercial facilities including, but not limited to, furnaces, heating and cooking stoves and hot
water furnaces. It shall not apply to wood-buming fireplaces and wood -burning stoves in dwellings, nor to fires
used for recreational purpose, nor to fires used solely for the preparation of food by barbecuing or to other
equipment exempted under 10 CSR 10-5.104(1). Hand -fired fuel -burning equipment is any stove, furnace, or
other fuel -burning device in which fuel is manually introduced directly into the combustion chamber.
[I0 CSR 10-5.040(2)(B) and 10 CSR 10-6.020(2)(H)(3)]
10 CSR 10-5.060 Refuse Not to be Burned in Fuel Burning Installations
(Rescinded on February 11,1979, Contained in St .' to Implementation Plan)
No person shall burn or cause or permit the burning of refuse in any installation which is designed for the
primary purpose of burning fuel.
40 CFR Part 82 Protection of Stratospheric Ozone (Title VI)
The permittee shall comply with the standards for labeling of products using ozone -depleting substances
pursuant to 40 CFR Part 82, Subpart E:
a) All containers in which a class I or class II substance is stored or transported, all products containing a
class I substance, and all products directly manufactured with a class I substance must bear the required
warning statement if it is being introduced into interstate commerce pursuant to 40 CFR §82.106. [40
CFR §82.106(a) and 40 CFR §82.102].
b) The placement of the required warning statement must comply with the requirements of 40 CFR
§82.108.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 41
installation ID: 510-0053 Project No. 2007-06-088
c) The form of the label bearing the required warning statement must comply with the requirements of 40
CFR §82.110.
d) No person may modify, remove, or interfere with the required warning statement except as described in
40 CFR §82.112.
2) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR
Part 82, Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B of 40 CFR
Part 82:
a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required
practices described in 40 CFR §82.156.
b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the
standards for recycling and recovery equipment described in 40 CFR §82.158.
c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an
approved technician certification program pursuant to 40 CFR §82.161.
d) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with the
record keeping requirements of 40 CFR §82.166. ("MVAC-like" appliance as defined at 40 CFR
§82.152).
e) Persons owning commercial or industrial process refrigeration equipment must comply with the leak
repair requirements pursuant of 40 CFR §82.156.
f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records
of refrigerant purchased and added to such appliances pursuant to 40 CFR §82.166.
3) If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the permittee is
subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption
Controls.
4) If the permittee performs a service on motor (fleet) vehicles when this service involves ozone -depleting
substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the
permittee is subject to all the applicable requirements contained in 40 CFR part 82, Subpart B, Servicing of
Motor Vehicle Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle
in which final assembly of the vehicle has not been completed. The term "MVAC" as used in Subpart B
does not include the air -tight sealed refrigeration system used as refrigerated cargo, or system used on
passenger buses using HCFC-22 refrigerant.
5) The permittee shall be allowed to switch from any ozone -depleting substance to any alternative that is listed
in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G,
Significant New Alternatives Policy Program. Federal Only - 40 CFR part 82
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 42
Project No. 2007-06-088
V. General Permit Requirements
The installation shall comply with each of the following requirements. Consult the appropriate sections in the
Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable
requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit
is issued,
10 CSR 10-6.065(6)(C)1.B Permit Duration
10 CSR 10-6.065(6)(E)3.0 Extension of Expired Permits
This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at
the end of this period unless renewed. If a timely and complete application for a permit renewal is submitted,
but the Air Pollution Control Program fails to take final action to issue or deny the renewal permit before the
end of the term of this permit, this permit shall not expire until the renewal permit is issued or denied.
10 CSR 10-6.065(6)(C)LC General Record Keeping and Reporting Requirements
1) Record Keeping
a) All required monitoring data and support information shall be retained for a period of at least five years
from the date of the monitoring sample, measurement, report or application.
[10 CSR 10-6.065(6)(C)(1)(C)(JI)(b)]
b) Copies of all current operating and construction permits issued to this installation shall be kept on -site
for as long as the permits are in effect. Copies of these permits shall be made immediately available to
any Missouri Department of Natural Resources' personnel upon request.
2) Reporting
a) All reports shall be submitted to the Air Pollution Control Program, Compliance and Enforcement
Section, P. O. Box 176, Jefferson City, MO 65102 or AirComplianceReporting@dnr.mo.gov.
b) The permittee shall submit a report of all required monitoring by:
[10 CSR 10-6.065(6)(C)(1)(C)(I11)]
i) October 1st for monitoring which covers the January through June time period, and
ii) April 1st for monitoring which covers the July through December time period.
c) Each report shall identify any deviations from emission limitations, monitoring, record keeping,
reporting, or any other requirements of the permit, this includes deviations or Part 64 exceedances. [10
CSR 10-6.065(6)(C)(1)(C)(III)(b)]
d) Submit supplemental reports as required or as needed. All reports of deviations shall identify the cause
or probable cause of the deviations and any corrective actions or preventative measures taken. [10 CSR
10-6.065(6)(C)(1)(C)(III)(c)]
i) Notice of any deviation resulting from an emergency (or upset) condition as defined in paragraph
(6)(C)7.A of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to the permitting
authority either verbally or in writing within two working days after the date on which the emission
limitation is exceeded due to the emergency, if the permittee wishes to assert an affirmative defense.
The affirmative defense of emergency shall be demonstrated through properly signed,
contemporaneous operating logs, or other relevant evidence that indicate an emergency occurred and
the permittee can identify the cause(s) of the emergency. The permitted installation must show that it
was operated properly at the time and that during the period of the emergency the permittee took all
reasonable steps to minimize levels of emissions that exceeded the emission standards or
requirements in the permit. The notice must contain a description of the emergency, the steps taken
to mitigate emissions, and the corrective actions taken. [10 CSR 10-6.065(6)(C)(1)(C)(III)(c)(I)]
ii) Any deviation that poses an imminent and substantial danger to public health, safety or the
environment shall be reported as soon as practicable. [10 CSR 10-6.065(6)(C)(1)(C)(III)(c)(II)]
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 43
Project No. 2007-06-088
iii) Any other deviations identified in the permit as requiring more frequent reporting than the
permittee's semiannual report shall be reported on the schedule specified in this permit.
[10 CSR 10-6.065(6)(C)(l)(C)(Ii1)(c)(I11)]
e) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation
must be submitted within ten days after the deviation, the report may be submitted without a
certification if the report is resubmitted with an appropriate certification within ten days after that,
together with any corrected or supplemental information required concerning the deviation. [10 CSR 10-
6.065 (6)(C)(1)(C)(111)(d)]
f) The permittee may request confidential treatment of information submitted in any report of deviation.
[10 CSR 10-6.065(6)(C)(1)(C)(III)(e)]
10 CSR 1G-6.065(6)(C)Il.D Risk Management Plan Under Section 112(r)
If the installation is required to develop and register a risk management plan pursuant to Section 112(R) of the
Act, the permittee will verify that it has complied with the requirement to register the plan.
10 CSR 10-6.065(6)(C)12 Sevewa �'a y Clause
In the event of a successful challenge to any part of this permit, all uncontested permit conditions shall continue
to be in force. All terms and conditions of this permit remain in effect pending any administrative or judicial
challenge to any portion of the permit. If any provision of this permit is invalidated, the permittee shall comply
with all other provisions of the permit.
10 CSR iiO-6.065(6)(C)I.G General Requirements
1) The permittee must comply with all of the terms and conditions of this permit. Any noncompliance with a
permit condition constitutes a violation and is grounds for enforcement action, permit termination, permit
revocation and re -issuance, permit modification or denial of a permit renewal application. [10 CSR 10-
6.065(6)(C)(1)(G)(I)1
2) The permittee may not use as a defense in an enforcement action that it would have been necessary for the
permittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the
permit. [10 CSR 10-6.065(6)(C)(1)(G)(II)1
3) The permit may be modified, revoked, reopened, reissued or terminated for cause. Except as provided for
minor permit modifications, the filing of an application or request for a permit modification, revocation and
reissuance, or termination, or the filing of a notification of planned changes or anticipated noncompliance,
does not stay any permit condition.
[10 CSR 10-6.065(6)(C)(1)(G)(III)]
4) This permit does not convey any property rights of any sort, nor grant any exclusive privilege.
[10 CSR 10-6.065(6)(C)(1)(G)(IV)]
5) The permittee shall furnish to the Air Pollution Control Program, upon receipt of a written request and
within a reasonable time, any information that the Air Pollution Control Program reasonably may require to
determine whether cause exists for modifying, reopening, reissuing or revoking the permit or to determine
compliance with the permit. Upon request, the permittee also shall furnish to the Air Pollution Control
Program copies of records required to be kept by the permittee. The permittee may make a claim of
confidentiality for any information or records submitted pursuant to 10 CSR 10-6.065(6)(C)1. [10 CSR 10-
6.065(6)(C)(1)(G)(V)]
10 CSR 10-6.065(6)(C)1.H Incentive Programs Not Requiring Permit Revisions
No permit revision will be required for any installation changes made under any approved economic incentive,
marketable permit, emissions trading, or other similar programs or processes provided for in this permit.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 44
Project No. 2007-06-088
10 CSR 10-6.065(6)(C)1.I Reasonably Anticipated Operating Scenarios
None.
10 CSR 10-6.065(6)(C)3 Compliance Requirements
1) Any document (including reports) required to be submitted under this permit shall contain a certification
signed by the responsible official. [10 CSR 10-6.065(6)(C)(3XA)]
2) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow
authorized officials of the Missouri Department of Natural Resources, or their authorized agents, to perform
the following (subject to the installation's right to seek confidential treatment of information submitted to,
or obtained by, the Air Pollution Control Program):
[10 CSR 10-6.065(6)(C)(3)(B)]
a) Enter upon the premises where a permitted installation is located or an emissions -related activity is
conducted, or where records must be kept under the conditions of this permit;
b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c) Inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including
monitoring and air pollution control equipment), practices, or operations regulated or required under this
permit; and
d) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample or
monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the
terms of this permit, and all applicable requirements as outlined in this permit.
3) All progress reports required under an applicable schedule of compliance shall be submitted semiannually (or
more frequently if specified in the applicable requirement). These progress reports shall contain the
following: [10 CSR 10-6.065(6)(C)(3)(D)]
a) Dates for achieving the activities, milestones or compliance required in the schedule of compliance, and
dates when these activities, milestones or compliance were achieved, and
b) An explanation of why any dates in the schedule of compliance were not or will not be met, and any
preventative or corrective measures adopted.
4) The permittee shall submit an annual certification that it is in compliance with all of the federally
enforceable terms and conditions contained in this permit, including emissions limitations, standards, or
work practices. These certifications shall be submitted annually by April 1st, unless the applicable
requirement specifies more frequent submission. These certifications shall be submitted to EPA Region VII,
11201 Renner Blvd., Lenexa, KS 66219, as well as the Air Pollution Control Program, Compliance and
Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64 exceedances and
excursions must be included in the compliance certifications. The compliance certification shall include the
following: [10 CSR 10-6.065(6)(C)(3)(E)]
a) The identification of each term or condition of the permit that is the basis of the certification;
b) The current compliance status, as shown by monitoring data and other information reasonably available
to the installation;
c) Whether compliance was continuous or intermittent;
d) The method(s) used for determining the compliance status of the installation, both currently and over the
reporting period; and
e) Such other facts as the Air Pollution Control Program will require in order to determine the compliance
status of this installation.
10 CSR 10-6.065(6)(C)6 Permit Shield
1) Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements
as of the date that this permit is issued, provided that: [10 CSR 10-6.065(6)(C)(6)(A)]
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 45
Installation ID: 510-0053 Project No. 2007-06-088
a) The applicable requirements are included and specifically identified in this permit, or
b) The permitting authority, in acting on the permit revision or permit application, determines in writing
that other requirements, as specifically identified in the permit, are not applicable to the installation, and
this permit expressly includes that determination or a concise summary of it.
2) Be aware that there are exceptions to this permit protection. The permit shield does not affect the following:
[10 CSR 10-6.065(6)(C)(6)(B)]
a) The provisions of section 303 of the Act or section 643.090, RSMc concerning emergency orders,
b) Liability for any violation of an applicable requirement which occurred prior to, or was existing at, the
time of permit issuance,
c) The applicable requirements of the acid rain program,
d) The authority of the Environmental Protection Agency and the Air Pollution Control Program of the
Missouri Department of Natural Resources to obtain information, or
e) Any other permit or extra -permit provisions, terms or conditions expressly excluded from the permit
shield provisions.
10 CSR 10-6.065(6)(C)7 Emergency Provisions
1) Art emergency or upset as defined in 10 CSR 10-6.065(6)(C)7.A shall constitute an affirmative defense to
an enforcement action brought for noncompliance with technology -based emissions limitations. To establish
an emergency- or upset -based defense, the permittee must demonstrate, through properly signed,
contemporaneous operating logs or other relevant evidence, the following:
a) That an emergency or upset occurred and that the permittee can identify the source of the emergency or
upset,
b) That the installation was being operated properly,
c) That the permittee took all reasonable steps to minimize emissions that exceeded technology -based
emissions limitations or requirements in this permit, and
d) That the permittee submitted notice of the emergency to the Air Pollution Control Program within two
working days of the time when emission limitations were exceeded due to the emergency. This notice
must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective
actions taken.
2) Be aware that an emergency or upset shall not include noncompliance caused by improperly designed
equipment, lack of preventative maintenance, careless or improper operation, or operator error.
10 CSR 10-6.065(6)(C)8 Operational Flexibility
An installation that has been issued a Part 70 operating permit is not required to apply for or obtain a permit
revision in order to make any of the changes to the permitted installation described below (and in subparagraph
(6)(C)(8)(A) of 10 CSR 10-6.065) if the changes are not Title 1 modifications, the changes do not cause
emissions to exceed emissions allowable under the permit, and the changes do not result in the emission of any
air contaminant not previously emitted. The permittee shall notify the Air Pollution Control Program,
Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VIl,
11201 Renner Blvd., Lenexa, KS 66219, at least seven days in advance of these changes, except as allowed for
emergency or upset conditions. Emissions allowable under the permit means a federally enforceable permit
term or condition determined at issuance to be required by an applicable requirement that establishes an
emissions limit (including a work practice standard) or a federally enforceable emissions cap that the source has
assumed to avoid an applicable requirement to which the source would otherwise be subject.
1) Section 502(b)(10) changes. Changes that, under section 502(b)(10) of the Act, contravene an express
permit term may be made without a permit revision, except for changes that would violate applicable
requirements of the Act or contravene federally enforceable monitoring (including test methods), record
keeping, reporting or compliance requirements of the permit.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit 46
Project No. 2007-06-088
a) Before making a change under this provision, The permittee shall provide advance written notice to the
Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City,
MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 662I9, describing the
changes to be made, the date on which the change will occur, and any changes in emission and any
permit teens and conditions that are affected_ The permittee shall maintain a copy of the notice with the
permit, and the APCP shall place a copy with the permit in the public file. Written notice shall be
provided to the EPA and the APCP as above at least seven days before the change is to be made. If less
than seven days notice is provided because of a need to respond more quickly to these unanticipated
conditions, the permittee shall provide notice to the EPA and the APCP as soon as possible after
learning of the need to make the change.
b) The permit shield shall not apply to these changes.
10 CSR 10-6.065(6)(C)9 Off -Permit Changes
1) Except as noted below, the permittee may make any change in its permitted operations, activities or
emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit
revision. Insignificant activities listed in the permit, but not otherwise addressed in or prohibited by this
permit, shall not be considered to be constrained by this permit for purposes of the off -permit provisions of
this section. Off -permit changes shall be subject to the following requirements and restrictions:
a) The change must meet all applicable requirements of the Act and may not violate any existing permit
term or condition; the permittee may not change a permitted installation without a permit revision if this
change is subject to any requirements under Title IV of the Act or is a Title I modification;
b) The permittee must provide contemporaneous written notice of the change to the Air Pollution Control
Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as
EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219. This notice shall not be required for changes
that are insignificant activities under 10 CSR 10-6.065(6)(B)3. This written notice shall describe each
change, including the date, any change in emissions, pollutants emitted and any applicable requirement
that would apply as a result of the change.
c) The permittee shall keep a record describing all changes made at the installation that result in emissions
of a regulated air pollutant subject to an applicable requirement and the emissions resulting from these
changes; and
d) The permit shield shall not apply to these changes.
10 CSR 10-6.065(6)(E)6 Reopening -Permit for Cause
This permit shall be reopened for cause if:
I) The Missouri Department of Natural Resources (MoDNR) receives notice from the Environmental
Protection Agency (EPA) that a petition for disapproval of a permit pursuant to 40 CFR § 70.8(d) has been
granted, provided that the reopening may be stayed pending judicial review of that determination,
2) MoDNR or EPA determines that the permit contains a material mistake or that inaccurate statements were
made which resulted in establishing the emissions limitation standards or other terms of the permit,
3) Additional applicable requirements under the Act become applicable to the installation; however, reopening
on this ground is not required if—:
a) The permit has a remaining term of less than three years;
b) The effective date of the requirement is later than the date on which the permit is due to expire; or
c) The additional applicable requirements are implemented in a general permit that is applicable to the
installation and the installation receives authorization for coverage under that general permit,
4) The installation is an affected source under the acid rain program and additional requirements (including
excess emissions requirements), become applicable to that source, provided that, upon approval by EPA,
excess emissions offset plans shall be deemed to be incorporated into the permit; or
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 47
Installation ID: 510-0053 Project No. 2007-06-088
5) MoDNR or EPA determines that the permit must be reopened and revised to assure compliance with
applicable requirements.
10 CSR 10-6.065(6)(E)1.0 Statement of Basis
This permit is accompanied by a statement setting forth the legal and factual basis for the permit conditions
(including references to applicable statutory or regulatory provisions). This Statement of Basis, while
referenced by the permit, is not an actual part of the permit.
10 CSR 10-6.020(2)(R)34 Responsible Official
The application utilized in the preparation of this permit was signed by Ed Cope, Operations Division Manager.
On May 14, 2015, the Air Pollution Control Program was informed that Rebecca Coyle, Operations Division
Manager is now the responsible official. If this person terminates employment, or is reassigned different duties
such that a different person becomes the responsible person to represent and bind the installation in
environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Director
of the Air Pollution Control Program of the change. Said notification shall be in writing and shall be submitted
within 30 days of the change. The notification shall include the mine and title of the new person assigned by
the source owner or operator to represent and bind the installation in environmental permitting affairs. All
representations, agreement to terms and conditions and covenants made by the former responsible person that
were used in the establishment of limiting permit conditions on this permit will continue to be binding on the
installation until such time that a revision to this permit is obtained that would change said representations,
agreements and covenants.
VI. Attachments
Attachments follow.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 48
Installation ID: 510-0053 Project No. 2007-06-088
Attachment A - Representative Operating Conditions Metrics
Since the 40 CFR Part 60, Subpart MMMM 85% maximum permitted capacity requirement does not define metrics relevant to the
Installation's unique operating conditions, the Program and Installation concur that the criteria in the Table below should be used to
evaluate compliance with 40 CFR Part 60, Subpart A. The Program requests the Installation document the metrics in a table and
compare it to historical reduction data and operating parameters documented during all prior performance tests for incinerators 2
through 5, but not earlier than those tests conducted after the combination impingement tray scrubbers and venturi scrubbers were
installed The table should be submitted with the performance test report for each performance test completed.
meter
::$iPSoiids ;Feed :t ate"-
BiosOlids.ealieSglids
N9lair4'ri @I£01,04 Fg .:..
Maxltinurn' Blosoltdsd.t
>Avera$e.siQSalld,��ed;
lit its
wet tons/flour, for'each,test run
11Prai:nt; i o, ,e-lib est.run
dr :.i..nOgyr. rmn1murn.;of. all test runs
• 'drytohs/hbur, maxxmirr of all test funs
ryorisi
our. of all test runs
•
5-Year 8iosoiids.feed Mate
30-day Biosolids: feed Rate
Monthly Blosolidsfeed Rate
._
uarteriy Biosatids Feed
leverage iosolyds.Feed (late,port ltuIe.
lssIs's1pp) River :5tage #
ississilppi River Stage. et St.
verage t ally:Flow Into plant,an Tsst.Qa
Volatile Solids
'average dry tens/hour-,
f: 5 years of operation, beginning 3/16/16t
0)*AgedailV dry tuns/hour
(tor. the previous 30 days prior to test event)
average dry tons/hour:
(for days incinerator li in operation over previous 12 rnon to test event)
#1rghe.t ua a,y/qrter average, dry.tons/hour
L = Dec -Feb, Mar May - Jun -Aug, Q4 = Sep -Nov for same Q tested)
Pel Gentile
:I rmrned from dally.fged rate data for last 5 years 9.f.911-F1VOP, beginning
:•3/16/16) . .
•
feet ,
•(mean on test day rrogi streamgau.)
f et
Irangefrnm highest to lowest for previous 12 months prior to test event)
millions gallons per day
percent,.for each test: run
Filterabie Particulate Matter -.
Isig/dscm;:average..of 3 runs
:Sulfur. Dioxide
ppmvd;average.of3 runs
:oxides. pf.IVitrogen
eibein Monoxide
ppmvd, average of 3 runs
•`ppmvd, average of.3 runs
:HydrOch'Ior1c,. ►cl
pprnvd, average of 3 runs
G,edrr}iunns
Iead
<:rrig/dscm, average of 3 runs
/dscm, average of 3 runs
ercury:
dscm, average of 3 runs
er iurn:`
hlorinated Diberizo-pdioxins/Poiyr.Jilorinate
°Dibenzofurans.
'-e.r/24-hr, period, average of 3 runs
dscm TEF, average of 3.runs
Fugitive.Emission = -
percent•
i4fterburrier:Exlt Ternp. ' . f .
degrees Fahrenheit, for each test run -
°Total ,Scrubber Hater flow :,
;Total SrIiobor Pre';:siirerQR' ::.: ...
eallen/n.1inute, for.each test run
• :14ties fH.c..'for.each test run
sater:outlet dH for each. run
1. Fugitive emissions from the ash handling area shall be determined in accordance with EPA Method 22, and includes observing the
process area(s) during normal operations for a 60 minute observation period.
MSD - Bissell Point Wastewater Treatment Plant fart 70 Operating Permit 49
Installation ID: 510-0053 Project No. 2007-06-088
Attachment B - Fugitive Emission Observations
Date
Time
Visible
Emissions
Beyond
Boundary
Abnormal Emissions
No 3 Yes
Cause
Corrective
Action
Initial
1
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 50
Installation ID: 510-0053 Project No. 2007-06-088
Attachment C - Method 22 Visible Emissions Observations
Installation Name
Location
Sky Conditions
Precipitation
Time
°ert� •
stiii7.Y�•tc'r
Observer Name
Date
Wind Direction
Wind Speed
Emission unit
Sketch emission unit: indicate observer position relative to emission unit; indicate potential emission points and/or
actual emission points.
2
installation shall note when the visible emissions were observed and shall conduct a Method 9 opacity observation..
r
,
iij
`II'�+.'+"•z ..',p �'� '.-�
s,e -fig a 'i' _ . , +
e R •31: _`iK V+1'4 �F
# •�
•
,, I. -.ems' .r1"
.�,i` .ws
+ t� f : t ,' � • -
,
..f a. t
t ��.�, i
0
1
2
3
4
—
5
6
MSD - Bissell Point Wastewater Treatment Plant
installation ID: 510-0053
Part 70 Operating Permit
Attachment D - Method 9 Opacity Emissions Observations
Company
Location
Date
Time
51
Project No. 2007-06-088
Observer Certification Date
Emission Unit
Control Device
Readings ranged from to % opacity.
Was the emission unit in compliance at the time of evaluation?
YES NO Signature of Observer
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit 52
Installation ID: 510-0053 Project. No. 2007-06-088
Attachment E: Compliance Assurance Monitoring Plan (CAM)
Visible emissions from Venturi
Scrubber/Mist Eliminator exhaust
• shall be monitored using EPA
' . " Reference Method 22 procedures.
• The indicator range is defined as no
visible emissions. An excursion is
defined as the presence of visible
emissions.
Indicator #2
Pressure Drop
Pressure drop across Venturi Scrubber/Mist
Eliminator shall be continuously monitored using a
Supervisory Control and Data Acquisition (SCADA)
system.
The indicator range is defined as a pressure drop
between 1 and 10 inches of water column (in H20).
An excursion is defined as a pressure drop that is
less than 1 in H2O and/or greater than 10 inches
H20.
An excursion of either indicator constitutes an excursion. If visible emissions are present
. when the pressure drop is within its specified indicator range, the pressure drop indicator
range shall be re-evaluated by the permittee, Excursions trigger an inspection, corrective
action, and need to be reported in the next Semiannual Monitoring Report. Excursions shall
be corrected i nrnediately upon detection; if an excursion results in excess emissions
exceeding 1 hour, the permittee may elect to file a startup, shutdown, and malfunction
assertion under 10 CSR 10-6.050 if appropriate to the situation.
The QIP threshold for any individual emission unit is 9 excursions in a 6-month reporting
period. Han emission unit reaches the QIP threshold, the permittee shall submit a QIP for that
- unit along with the Semiannual Monitoring Report for that reporting period.
1
a`.:..
•
Measurements shall be made at the
emission point (i.e., Venturi
Scrubber/Mist Eliminator exhaust).
Pressure drop taps are located at the inlet and outlet
of Venturi Scrubber/Mist Eliminator. The
differential pressure gauges have a minimum
accuracy of 0.25 in H2O.
NA
Pressure drop taps are checked for plugging
quarterly or upon reasonable suspicion of gauge
malfunction
:<•
>
1,
4
t :The
l�r e.
. . - :; •
;�:_ r :. ,
visible emissions observer shall
be familiar with EPA Reference
Method 22 and follow Method 22
procedures.
The differential pressure gauges shall be calibrated
no less frequently than semiannually in accordance
with the manufacturer's specifications.
^
z �—
�
�.,:.
A 6-minute Method 22 observation
shall be performed daily.
Continuously.
.x
, ,
11 .:•
• ''
The VE observation is manually
recorded (i.e., documented) daily by
the observer.
An instantaneous measurement shall be manually
recorded daily.
A,
ru, ,`
NA
None
e' r
1: -- _
<... .• ,•'
Summary information on the number, duration, and cause for any excursions and differential
pressure gauge downtime shall be reported semiannually as part of MSD's Part 70 Semiannual
Monitoring Report.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit
Installation 1D: 510-0053
Attachment F - Inspection/MaintenancefRePair/Malfiuiction Log
Emission Unit #
53
Project No. 2007-06-088
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit SB - 1
Installation ID: 5I0-0053 Project No. 2007-06-088
STATEMENT OF BASIS
INSTALLATION DESCRIPTION
The Metropolitan St. Louis Sewer District (MSD) - Bissell Point Plant is one of the largest wastewater
treatment facilities in Missouri. The Bissell Point Watershed consists of an 81.4 square mile area served
by 1,300 miles of combined and separate sanitary sewers, The system serves the St. Louis downtown
business district, the northern industrial area, and the residential areas in the northern part of the city and
county, and it discharges into the Mississippi River.
Six (6) multiple hearth incinerators, namely Incinerator Nos. 1 through 6, are present at the facility.
Incinerator #1 and Incinerator #6 will be taken out of service on or before the compliance date of 40
CFR Part 60 Subpart MMMM, Emission Guidelines and Compliance Times for Existing Sewage Sludge
Incineration Units. MSD currently operates the remaining four (4) incinerators.
The incinerators are equipped with multiple hearths. Sludge is dewatered with belt filter presses and
conveyed to the multiple hearth furnaces with belt conveyors. The sludge conveyors are equipped with
weigh scales for continuous monitoring of the amount of sludge being incinerated. The dewatered
sludge is introduced at hearth 2 and rabbled down through successive hearths in a spiral path. The
moisture in the sludge is evaporated in the upper hearths as hot combustion gases traveling counter
concurrently from the middle hearths where combustion takes place. The furnace is equipped with
auxiliary natural gas burners at seven (7) of the eleven (11) hearths. The firing rate of the burners is
modulated by a central control system to sustain the desired hearth temperatures.
The air pollution control system of the incinerators is comprised of quench section, Venturi -Pak (venturi
throat sections and mist eliminator) and impingement tray scrubber system. Exhaust gases pass through
this system via induced draft fan then to the atmosphere.
The Bissell Point Plant is located in an ozone non -attainment area and is a major source for nitrogen
oxides and carbon monoxide.
Updated Potential to Emit (PTE) for the Installation and
Reported Air Pollutant Emissions, tons aer year
P �c �1( x
Y
. r
� y
ti. trll twos
Particulate Matter
Ten Microns (PM10)
10.60
22.30
29.81
23.65
20.98
22.81
Particulate Metier
< 2.5 Microns (PM2.5)
9.15
15.10
19.03
15.54
12.80
2.77
Sulfur Oxides
(SOx)
7.40
6.29
10.27
5.81
12.54
37.85
Nitrogen Oxides
(NOx)
181.46
74.92
59.47
45.93
57.82
69.24
Volatile Organic
Compounds (VOC)
39.31
26.37
33.44
24.96
33.17
36.07
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit SB - 2
Project No. 2007-06-088
Pollutants
Potential
to Ernie
Carbon Monoxide
(CO)
981.68
Lead (Pb)
0.24
Hazardous AirPollutants17.53
(- HAP's)
Ammonia (NH3)
520.19
Hydrogen Sulfide (H2S)
<10
Reported Actual Emissions
2016
2015
, 2014 I
.20 13. _
2012
482.03
674.97
600.21 I
485.40
517.04
0.01
0.22
0.18
0.15
0.15
1.19
1.40
1.24
1.07
0.86
407.89
453.66
414.19
415.96
369.00
Note:'Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted.
• Potential emissions of the four incinerators were based on the federally enforceable limitations found
in the issued construction permit No. 95-05-068A.
• Potential emissions of the sludge building boilers were based on the federally enforceable limitations
found in the issued construction permit No. 95-05-029A.
o Potential emissions of the pump station boilers, primary control building boiler, administrative
building boilers and trickling filter pump station boilers were based on the federally enforceable
limitations found in the issued construction permit No. 95-05-029A.
• PM10, PM2.5 and SOx PTE are less than the reported emissions due to:
(a) Shut down of two (2) incinerators (Incinerator #1 and #6) and
(b) Scrubber upgrades —MSD replaced impingement tray scrubbers and single venturi scrubbers for
incinerators #2 through #5 (EP-3 through EP-6) with combination of impingement tray scrubbers
and multiple fixed venturi scrubbers in order to comply with 40 CFR Part 60 Subpart MMMM,
Emission Guidelines and Compliance Times for Existing Sewage Sludge Incineration Units. the
new scrubbers improved control efficiency.
Permit Reference Documents
These documents were relied upon in the preparation of the operating permit. Because they are not
incorporated by reference, they are not an official part of the operating permit.
1) Part 70 Operating Permit Application, received June 25, 2007; revised November 2, 2009;
2) P70 Operating Permit Administrative Amendment, Project #2010-01-063, received December 2,
2010;
3) P70 Operating Permit Administrative Amendment, Project #2012-01-036, received January 12,
2012;
4) Modified Renewal Application, received May 14, 2015;
5) 2016 Emissions Inventory Questionnaire, received April 27, 2017 ;
6) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume 1, Stationary
Point and Area Sources, Fifth Edition;
7) St. Louis City Construction Permit #94-05-029A;
8) St. Louis City Construction Permit #95-05-068;
9) St. Louis City Construction Permit 495-05-069; and
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit SB - 3
Project No. 2007-06-088
10) New Source Review Permit Amendment - Permit Number: 95-05-068A, Project Number: 2014-08-
028
Applicable Requirements Included in the Operating Permit but Not in the Application or Previous
Operating Permits
In the operating permit application, the installation indicated they were not subject to the following
regulation(s). However, in the review of the application, the agency has determined that the installation
is subject to the following regulation(s) for the reasons stated.
None
Other Mr Regulations Determined Not to Apply to the Operating Permit
The Air Pollution Control Program (APCP) has determined the following requirements do not apply to
this installation at this time for the reasons stated.
1) St. Louis City Ordinances Nos. 64749, 65108, 65488, 65442 and 65645
These ordinances were reviewed and considered at the time the application for this permit was
submitted. Since that time, these ordinances have been repealed and replaced with St. Louis City
Ordinance No. 68657. The only section of Ordinance 65645 that corresponds to a rescinded
ordinance included in the State SIP and therefore federally enforceable is Section 16 - Open Burning
Restrictions. This section of the new ordinance is the only section included in the operating permit
at this time.
2) 10 CSR 10-5.450, Control of VOC Emissions from Traffic Coatings
This regulation was determined to not apply to this plant since the plant controls the ingress and
egress of traffic at the plant, thus the plant is not public property.
3) 10 CSR 10-6.261, Control of Sulfur Dioxide Emissions
This rule does not apply to the installation because the combustion equipment at this installation is
fueled exclusively with natural gas and according to paragraph (I)(A) of this rule, combustion
equipment that uses exclusively pipeline grade natural gas as defined by American Society for
Testing and Materials (ASTM) is exempt.
4) 10 CSR 10-6.405, Restriction of Particulate Matter Emissions From Fuel Burning Equipment Used
for Indirect Heating.
This regulation does not apply to the boilers because they bum only natural gas and are exempt
according to 10 CSR 10-6.405(1)(C).
Construction Permit History
The following revisions were made to construction permits for this installation:
1) St. Louis City Construction Permit #95-05-068
Section V of construction permit #95-05-068 deals with the initial performance test requirements for
41 through 45 incinerators. Since the installation has already completed the performance testing
requirements for construction permit number #95-05-068, the conditions are not included in the
operating permit.
Section VII construction permit 495-05-068 deals with inspections and the authority to inspect.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit SB - 4
Installation ID: 510-0053 Project No. 2007-06-088
Since inspection and the authority to inspect are requirements of the P70 permit and included in the
general requirements section of this permit, the provisions of Section Vll of construction permit 1495-
05-068 are not included in the operating permit.
New SVuE rce Perfoncmnannse Sneed;:rds (NOS) Apipbleability
10 CSR 10-6.070, New Source Performance Regulations
1) 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial -Commercial -
Institutional Steam Generating Units
This rule is applicable to Sludge Building Boilers #1 - #3 (EP14 — EF16) due to the installation date
and the size of the boiler. However, since this facility only uses natural gas and propane for fuel,
there are no specific limitations for sulfur dioxide and particulate matter from this rule except the
record keeping requirement of 40 CFR §60.48c.
2) 40 CFR Part 60 Subpart 0, Standards of Performance for Sewage Treatment Plants
The provisions of this subpart apply to incinerators that combust wastes containing more than 10
percent sewage sludge (dry basis) produced by municipal sewage treatment plants, or each
incinerator that charges more than 1000 kg (2205 lb) per day municipal sewage sludge (dry basis)
and that commences construction or modification after June 11, 1973. Since incinerators #2 through
#5 (EPO3 EP06) were constructed in 1967, and incinerator #1 (EP02) and #6 (EP07) have been
decommissioned or out of service, the requirements of this subpart would not apply.
3) 40 CFR Part 60 Subpart MMMM, Emission Guidelines and Compliance Times for Existing Sewage
Sludge Incineration Units.
This subpart applies to incinerators #2 through #5 (EPO3 — EP06) and the ash handling system
(EP09). Incinerator #1 (EP02) and #6 (EP07) are not in operation.
Maxi train AcihlevEble Control Technology (MAC L'') Appileabitity
10 CSR 10-6.075, Maximum Achievable Control Technology Regulations
1) 40 CFR Part 63 Subpart VVV, National Emission Standards for Hazardous Air Pollutants: Publicly
Owned Treatment Works
The plant is considered an existing non -industrial source under this rule. As an existing non-
industrial source, the plant does not have additional control requirements and is not required to
submit a notification of compliance status under this subpart.
2) 40 CFR Part 63, Subpart T, National Emission Standards for Halogenated Solvent Cleaning
The provisions of this subpart apply to each individual batch vapor, in -line vapor, in -line cold, and
batch cold solvent cleaning machine that uses any solvent containing methylene chloride,
perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or
any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent
by weight, as a cleaning and/or drying agent. Wipe cleaning activities, such as using a rag
containing halogenated solvent are not covered under the provisions of this subpart.
The permittee has a Parts Washer (EP26) which does not use halogenated solvents as defined in 40
CFR 63.460, therefore the unit is not subject to the MACT standards for halogenated solvent
cleaning.
MSD - Bissell Point Wastewater Treatment Plant
Part 70 Operating Permit SB - 5
Installation ID: 510-0053 Project No, 2007-06-088
1) 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers and Process Heaters
This Subpart applies to a facility that owns or operates a industrial boilers, institutional boilers,
commercial boilers, and process heaters that is a major source, or is located at a major source, or is
part of a major source of HAP emissions. A process heater is defined as a unit in which the
combustion gases do not directly come into contact with process material or gases in the combustion
chamber (e.g., indirect fired). A boiler is defined as an enclosed device using controlled flame
combustion and having the primary purpose of recovering thermal energy in the form of steam or hot
water.
This regulation does not apply the boilers and heaters at this facility because the installation is an
area source of hazardous air pollutants (HAPS).
3) 40 CFR Part 63 Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources
This regulation does not apply the boilers and process heaters at this facility because they are gas -
fired.
National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability
10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants
1) 40 CFR Part 61, Subpart C, National Emission Standard for Beryllium
The provisions of this subpart apply to extraction plants, ceramic plants, foundries, incinerators, and
propellant plants which process beryllium ore, beryllium, beryllium oxide, beryllium alloys, or
beryllium -containing waste; and machine shops which process beryllium, beryllium oxides, or any
alloy when such alloy contains more than 5 percent beryllium by weight. The permittee has six
incinerators which burn beryllium containing sewage sludge, therefore the incinerators are subject to
the NESHAP standard for beryllium.
2) 40 CFR Part 61, Subpart E, National Emission Standard for Mercury
The provisions of this subpart are applicable to those stationary sources which process mercury ore
to recover mercury, use mercury chlor-alkali cells to produce chlorine gas and alkali metal
hydroxide, and incinerate or dry wastewater treatment plant sludge. The permittee operates four
incinerators which burn dry wastewater treatment plant sludge, therefore the incinerators are subject
to the NESHAP standard for mercury.
While this Subpart is applicable to the facility, because the requirements of 40 CFR Part 60, Subpart
MMMM contain a more stringent limit for mercury, the limitations imposed by Subpart MMMM are
the operative limits. Therefore, the requirements of 40 CFR Part 61, Subpart E are not included in
this permit.
1) 40 CFR Part 61 Subpart M — National Emission Standard for Asbestos
40 CFR Part 61 Subpart M — National Emission Standard for Asbestos.
The installation is not subject to any NESHAP standard with the exception of Subpart M - National
Emission Standard for Asbestos. The installation is potentially subject to Subpart M. If the
installation conducts any demolition or renovation projects to a building(s) containing asbestos, they
must determine applicability with the following NESHAP regulations:
• Demolition and Renovation - 40 CFR 61.145
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit SB - 6
Installation ;D: 510-0053 Project No. 2007-06-088
• Waste Disposal for Manufacturing, Fabricating, Demolition, Renovation, and Spraying - 40 CFR
61.150
Compliance Assurance Monitoring (CAM) Applicability
40 CFR Part 64, Compliance Assurance Monitoring (CAM)
The CAM rule applies to each pollutant specific emission unit that:
Is subject to an emission limitation or standard, and
e Uses a control device to achieve compliance, and
c Has pre -control emissions that exceed or are equivalent to the major source threshold.
The Wet Ash Conveying System (Unit ID EP09) is potentially subject to CAM. The Wet Ash
Conveying System is equipped with venturi scrubber/mist eliminator and has the potential to emit
prior to control of greater than 100 tons per year of particulate matter (PM). PM is regulated under
10 CSR 10-6.400.
The Wet Ash Conveying System utilizes a control device to limit PM emissions from the process
and has a potential to emit 2,102 tons of PM pre -control, which exceeds the major source threshold
(applicability criteria #3). The Wet Ash Conveying System has a process weight limit of 25.16
pounds of PM per hour and uses venturi scrubber/mist eliminator to achieve this limit. Since the
Wet Ash Conveying System triggers all three CAM criteria, MSD has submitted CAM Plan as
required by the CAM rule. The CAM plan is incorporated into this permit.
Greenhouse Gas Emissions
Potential emissions of greenhouse gases (CO2e) for this installation are calculated to be 7,314.07 tons,
classifying the installation as a minor source of GHGs. There are :no currently issued GHG regulations
applicable to this installation. Missouri regulations do not require the installation to report CO2c
emissions in their Missouri Emissions inventory Questionnaire; therefore, the installation's CO2e
emissions were not included within this permit.
Other Regulatory Determinations
1) 10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes
a) The following are calculations of particulate emissions from EPOS and EPO9 that show that the
units do not exceed the emission limits for particulate matter:
EPO9 — Wet Ash Convevingw/venturi scrubber and mist eliminator
Process Weight rate (P) = 15 ton/hr
Exhaust Stack Temperature (T) = 90°F
Exhaust Flow Rate = 15,000 ACFM
ACFM x 528° R
SCFM ==14,400 SCFM
T0F+460°R
Emission Limit (lb/hr) = 4.1 PO 67 = 4.1 x 150 67 = 25.16 lb PM/hr
Emission Factor (uncontrolled) = 32 lb PM/ton (Fire - SCC 30500717)
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit SB - 7
Installation ID: 510-0053 Project No. 2007-06-088
PM Emission Uncontrolled(lb/hr)= 32 tan x 15 hr = 480lb
PM Emission Controlled (lb/hr) = 32 lbx 15 ton x (1— 0.99) x (1— 0.75) =1.21b
ton lir hr
At maximum design rate, the uncontrolled potential PM emission rates in lbs/hr for EPOS
exceeds the 10 CSR 10-6.400 limit. However, the hourly controlled emission rate is far below
the regulatory limit. Since the pre -control PM emissions rate in tons per year is above the major
source threshold of 100 tons per year and the particulate emissions control is required to comply
with the 10 CSR 10-6.400 limit, the unit is subject to CAM. CAM plan for this unit is
incorporated in the operating permit.
b) Sand Blaster and Paint Spray Booth
The particulate matter potential emissions from the operation of the sand blaster and small parts
spray paint operation are 0.001 lb/hr and 0.084 lb/hr, respectively. Since these units potentially
emit less than one-half (0.5) pounds of particulate matter per hour they are exempt from the
requirements of this rule. [10 CSR 10-6.400(1)(B)12.].
2) 10 CSR 10-5.330, Control ofEmissions from Industrial Surface Coating Operations.
MSD does operate a small parts spray booth, but for this rule to apply, the installation's actual
emissions of VOCs from surface coating operations covered under this rule must be greater than
three (3) tons per twelve (12)-month rolling period, before the consideration of controls.
Annual paint usage = 40 gallons at 8.3 lbs of VOC per gallon of paint,
VOC Emission = (40 gal x 8.3 Ibs/gal) x 0.0005 ton/lb = 0.166 ton/year
MSD's actual emissions are much lower than the applicability threshold of 3 tons per year, therefore
this rule does not apply to small parts spray booth.
3) 10 CSR 10-5.080, Incinerators
This regulation was rescinded on December 9, 1991 but it remains in the State Implementation Plan.
Though the installation is subject to the requirements of this rule, the requirements of 10 CSR 10-
5.080 are not included in the operating permit because the particulate matter standard of 10 CSR 10-
5.080 is less stringent than the installation's construction permit (Permit No. 95-05-068A) and the
NSPS Subpart MMMM standards. Compliance with the construction permit and NSPS Subpart
MMMM will ensure compliance with this rule.
4) St. Louis City Ordinance 68657 §17, Incinerators
Though the installation is subject to the requirements of this rule, the requirements of St. Louis City
Ordinance 68657 § 17 are not included in the operating permit because the standards for
incinerators in this ordinance are less stringent than the installation's construction permit (Permit No.
95-05-068A) and the NSPS Subpart MMMM standards. Compliance with the construction permit
and the NSPS Subpart MMMM will ensure compliance with this ordinance.
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit SB - 8
Project No. 2007-06-088
5) 10 CSR 10-6.065(1)(B)(15), Operating Permits
The installation has reported combustion units of varying size listed in the table below as
insignificant emission units. All of these combustion units emit only combustion products; produce
less than one hundred fifty (150) pounds per day of any air contaminant and have a maximum rated
capacity of less than ten (10) million British thermal units (BTUs) per hour heat input by using
exclusively natural gas and/or propane. The APCP has determined that units such as these are not
necessary to include in the operating permit.
EP 4 Description
21 Four Direct Fired Heaters
Fuel Type*
Natural Gas
24 Four (4) Water Heaters Natural Gas
* Propane will be used for emergency back-up fuel.
6) The following is the list of storage tanks which are identified as insignificant activities at the time of
permit issuance. None of the storage tanks at this installation are large enough for 40 CFR 60
Subparts K, Ka and Kb regulations to apply.
EP11 Underground Diesel Tank, 550 gallons
Other Regulations Not Cited in the Operating Permit or the Above Statement of Basis
Any regulation which is not specifically listed in either the Operating Permit or in the above Statement
of Basis does not appear, based on this review, to be an applicable requirement for this installation for
one or more of the following reasons:
1. The specific pollutant regulated by that rule is not emitted by the installation;
2. The installation is not in the source category regulated by that rule;
3. The installation is not in the county or specific area that is regulated under the authority of that rule;
4. The installation does not contain the type of emission unit which is regulated by that rule; or
5. The rule is only for administrative purposes.
Should a later determination conclude that the installation is subject to one or more of the regulations
cited in this Statement of Basis or other regulations which were not cited, the installation shall determine
and demonstrate, to the APCP's satisfaction, the installation's compliance with that regulation(s). If the
installation is not in compliance with a regulation which was not previously cited, the installation shall
submit to the APCP a schedule for achieving compliance for that regulation(s).
Maximum Heat Input (MMB T U/hr)
0.85 (each)
0.75 (total)
MSD - Bissell Point Wastewater Treatment Plant
Part 70 Operating Permit RPC - 1
Installation ID: 510-0053 Project No. 2007-06-088
Response to Public Comments
The draft Part 70 Operating Permit for MSD — Bissell Point Wastewater Treatment Plant was placed on
public notice on March 16, 2018 for a 30-day comment period. The public notice was published on the
Department of Natural Resources' Air Pollution Control Program's web page at:
http://dnr.mo.govienviapeplpermit-public-notices.htm. The Air Pollution Control Program received
comments from MSD, EPA Region VII, and Great Rivers Environmental Law Center. The comments
are addressed by who sent them and in order as they were listed in the correspondence and are quoted
verbatim.
The following comments were received on April 9, 2018 from MSD:
Comment #1: Permit Condition (EPO3 through EP06) - 007, Monitoring and Calibration Requirements
for Compliance with Operating Limits, please add the following clarification to the citation reference to
provide consistency throughout the permit (bold italics for clarity only).
(1)(a)(iii) Any data collected during monitoring system malfunctions, repairs associated with monitoring
system malfunctions, or required monitoring system quality assurance or control activities must not be
included in calculations used to report emissions or operating levels. Any such periods must be reported
in the permittee's annual deviation report. [40 CFR §60.5225(a)(1)(iii)]
Response to Comment: The draft permit has been modified as requested
Comment #2: Permit Condition (EPO3 through EP06) - 008, Recordkeeping, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(3)(b) Records showing the names of 551 unit operators and other plant personnel who may operate the
unit according to the provisions of 40-CFR 40 CFR. §60.5155(a), as follows: [40 CFR §60.5230(c)(2)]
Response to Comment: The draft permit has been modified as requested.
Comment #3: Permit Condition (EPO3 through EP06) - 008, Recordkeeping, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(3)( b)(ii) Records showing the names of the 551 operators who have completed the operator training
requirements under 40-CFR 40 CFR §60.5130, met the criteria for qualification under 40 CFR
§60.5140, and maintained or renewed their qualification under 40 CFR §60.5145 or §60.5150. Records
must include documentation of training, including the dates of their initial qualification and all
subsequent renewals of such qualifications. [40 CFR §60.5230(c)(2)(ii)]
Response to Comment: The draft permit has been modified as requested
Comment #4: Permit Condition (EPO3 through EP06) - 008, Recordkeeping, please add the following
correction to the citation reference (bold italics for clarity only).
(3xc) Records showing the periods when no qualified operators were accessible for more than 8 hours,
but less than 2 weeks, as required in 40 CFR §60.5155(a). [40 CFR §60.5230(c)(23)1
Response to Comment: The draft permit has been modified as requested
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit RPC - 2
Installation ID: 510-0053 Project No. 2007-06-088
Comment #5: Permit Condition (EPO3 through EP06) - 008, Recordkeeping, please add the following
correction to the citation reference (bold italics for clarity only).
(3)(d) Records showing the periods when no qualified operators were accessible for 2 weeks or more
along with copies of reports submitted as required in 40 CFR §60.5155(b). [40 CFR §60.5230(c)(44)]
Response to Comment: The draft permit has been modified as requested.
Comment #6: Permit Condition (EPO3 through EP06) - 008, Recordkeeping, please correct the
punctuation error by deleting the colon at the end of the sentence. (bold italics for clarity only).
(7) Deviation Reports. Records of any deviation reports submitted under 40 CFR §60.5235(e) and (f). t
[40 CFR §60.5230(h)]
Response to Comment: The draft permit has been modified as requested.
Comment #7: Permit Condition (EPO3 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(1)(a) A final control plan as specified in 40 CFR §§60.5085(a) and 60.5110. [40 CFR §60.5235(a)(1)]
Response to Comment: The draft permit has been modified as requested
Comment #8: Permit Condition (EPO3 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(1)(b) The permittee must submit the permittee's notification of achievement of increments of progress
no later than 10 business days after the compliance date for the increment as specified in 40 CFR
§§60.5095 and 60.5100. 140 CFR §60.5235(a)(2)]
Response to Comment: The draft permit has been modified as requested.
Comment #9: Permit Condition (EPO3 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(1)(c) If the permittee fails to meet an increment of progress, the permittee must submit a notification to
the Director postmarked within 10 business days after the date for that increment, as specified in 40 CFR
§60.5105. [40 CFR §60.5235(a)(3)]
Response to Comment The draft permit has been modified as requested.
Comment #10: Permit Condition (EPO3 through EP06) - 008, Reporting, please correct the spacing
punctuation error (bold italics for clarity only).
(2)(g) The results of the initial air pollution control device inspection required in 40 CFR §60.5195,
including a description of repairs. [40 CFR §60.5235(b)(8)]
Response to Comment: The draft permit has been modified as requested.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit RPC - 3
Installation ID: 510-0053 Project No. 2007-06-088
Comment #11: Permit Condition (EPO3 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(2)(h) The site -specific monitoring plan required under 40 CFR §60.5200, at least 60 days before the
permittee's initial performance evaluation of the continuous monitoring system. [40 CFR
§60.5235(b)(9)]
Response to Comment: The draft permit has been modified as requested.
Comment #12: Permit Condition (EPO3 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(2Xi) The site -specific monitoring plan for the ash handling system required under 40 CFR §60.5200, at
least 60 days before the initial performance test to demonstrate compliance with the fugitive ash
emission limit. [40 CFR §60.5235(b)(10)]
Response to Comment: The draft permit has been modified as requested
Comment #13: Permit Condition (EP03 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(3)(o) If the permittee had a malfunction during the reporting period, the compliance report must include
the number, duration, and a brief description for each type of malfunction that occurred during the
reporting period and that caused or may have caused any applicable emission limitation to be exceeded.
The report must also include a description of actions taken by the permittee during a malfunction of an
affected source to minimize emissions in accordance with 40 CFR §60.11(d), including actions taken to
correct a malfunction. [40 CFR §60.5235(c)(16)]
Response to Comment: The draft permit has been modWed as requested.
Comment #14: Pennit Condition (EP03 through EP06) - 008, Reporting, please add the following
clarification to the citation reference to provide consistency throughout the permit (bold italics for clarity
only).
(4)(d)(viii) A brief description of any malfunction reported in 40 CFR §60.5235(d)(1)(vii), including a
description of actions taken during the malfunction to minimize emissions in accordance with 40 CFR
§60,11(d) and to correct the malfunction. [40 CFR §60.5235(d)(4)(viii)]
Response to Comment: The draft permit has been modified as requested
Comment #15: Permit Condition (EP09) - 001, Emission Limitation and Standards, please add the
following clarification to the citation reference to provide consistency throughout the permit (bold italics
for clarity only).
Table 3 to Subpart MMMM of 40 CFR Part 60 -Emission Limits and Standards
Response to Comment: The draft permit has been modified as requested.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit RPC - 4
Installation ID: 510-0053 Project No. 2007-06-088
Comment #16: Permit Condition (EP09) - 001, Operating Limits and Requirements, please add the
following clarification to the citation reference to provide consistency throughout the permit (bold italics
for clarity only).
Table 4 to Subpart MMMM of 40 CFR Part 60-Operating Parameters for Existing Sewage Sludge
Incineration Units
Response to Co merral: The draft permit has been modified as requested.
Comment #17: Permit Condition (EP09) - 002, Recordkeeping, please add the following clarification to
the citation reference to provide consistency throughout the permit (bold italics for clarity only).
(1)(a) The permittee shall comply with the recordkeeping requirements specified in 40 CFR
§70.6(a)(3)(ii). The permittee shall maintain records of monitoring data, monitor performance data,
corrective actions taken, any written quality improvement plan required pursuant to 40 CFR §64.8 and
any activities undertaken to implement a quality improvement plan, and other supporting information
required to be maintained under 40 CFR Part 64 (such as data used to document the adequacy of
monitoring, or records of monitoring maintenance or corrective actions). [40 CFR 64.9(b)(1)]
Response to Comment: The draft permit has been modified as requested.
Comment #18: Permit Condition (EP09) - 002, Reporting, please add the following clarification to the
citation reference to provide consistency throughout the permit (bold italics for clarity only).
(1) General Reporting Requirements: The permittee shall submit semi-annual monitoring certified by a
responsible official using the semi-annual monitoring report and annual compliance certification to the
Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City,
MO 65102, as required by 10 CSR 10-6.065(6)(01.C.(III). The report shall include, at a minimum, the
following information, as applicable: [46 CFR §64.9(a)(1) & (2)]
Response to Comment: The draft permit has been modified as requested.
Comment #19: Permit Condition (EP09) - 002, Reporting, please add the following clarification to the
citation reference to provide consistency throughout the permit (bold italics for clarity only).
(1)(c) Summary information on the number, duration and cause (including unknown cause, if applicable)
of excursions or exceedances, as applicable, and the corrective actions taken; H40 CFR §64.9(a)(2)(i)]
Response to Cot cent: The draft permit has been modified as requested.
Comment #20: Permit Condition (EP09) - 002, Reporting, please add the following clarification to the
citation reference to provide consistency throughout the permit (bold italics for clarity only).
(2) Documentation of need for improved monitoring: If the permittee identifies a failure to achieve
compliance with this permit condition for which the approved monitoring did not provide an indication
of an exceedance while providing valid data, or the results of compliance or performance testing
document a need to modify the existing indicator ranges or designated conditions, the permittee shall
promptly notify the Air Pollution Control Program and, if necessary, submit a proposed modification to
the 40 CFR pPart 70 permit to address the necessary monitoring changes. Such a modification may
include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the
MSD - Bissell Point Wastewater Treatment Plant
installation ID: 510-0053
Part 70 Operating Permit RPC - 5
Project No. 2007-06-088
frequency of conducting monitoring and collecting data, or the monitoring of additional parameters. [40
CFR §64.7(e)]
Response to Comment: The draft permit has been modified as requested.
Comment #21: Permit Condition (EP23) - 001, please correct the reference to construction permit No.
95-05.069 (bold italics for clarity only).
10 CSR 10-6.060 Construction Permits Required
Construction Permit No. 95-05-069, Issued March 1, 7 1996
Response to Comment: The draft permit has been modified as requested.
The followinE six comments (Comment #22 throuEh #28) were received on April 12, 2018 from
EPA Region 7:
Comment #22: Permit Condition (EPO3 through EP06)-001 incorporates applicable requirements of 40
CFR part 61, Subpart C-National Emission Standard for Beryllium, for Incinerator #2 (EP03);
Incinerator #3 (EP04); Incinerator #4 (EPOS); and Incinerator #5 (EP06). MoDNR has included a
monitoring requirement whereby MSD-Bissell Point shall perform stack sampling and testing as
specified in 40 CFR §61.33. §61.33(a)(1) requires an emission test to be performed by May 28, 2014 in
the case of an existing source or a new source which has an initial startup date preceding February 27,
2014. It appears that EP03, EP04, EPOS, and EPO6 are all existing sources and this stack test was to have
been performed by May 28, 2014. Therefore, EPA believes this requirement may no longer be
applicable to these MSD-Bissell Point emission units. However, EPA would encourage MoDNR
consider using their authority, set forth in 10 CSR 10-6.065(6)(C)1.C, and set requirements for MSD-
Bissell Point to perform stack sampling and testing at least once during the term of this Part 70 operating
permit.
Additionally, Record keeping requirement 1), in Permit Condition (EP03 through EP06)-001, requires
the permittee to retain copies of emission test results and "any other data needed" (emphasis added) to
determine total emissions. The term "any other data needed' (emphasis added), is too vague as to be
enforceable as a practical matter. EPA encourages MoDNR consider specifying the other data to be
retained by MSD-Bissell Point to enhance the practical enforceability of Record keeping requirement 1).
Response to Comment:
• The APCP agrees that the stack testing requirement of 40 CFR Part 61, Subpart C-National
Emission Standard for Beryllium is no longer applicable. This requirement is removed and
the stack testing requirement of Construction Permit No. 95-05-068, Issued August 16, 1995
incorporated into Permit Condition (EPO3 through EP06)-601.
• §61.33(e) of 40 CFR Part 61 states "Records of emission test results and other data needed
to determine total emissions shall be retained at the source and made available_.. ". Since
the term "any other data needed" is from 40 CFR Part 61, Subpart C, no revision to this
permit condition is warranted
Comment #23: Permit Condition (EPO3 through EP06)-002 incorporates applicable conditions from
Permit to Construct 95-05-068, issued August 16, 1995. This permit condition establishes an emission
rate of total hydrocarbons (THC) not to exceed one hundred parts per million by volume (100 ppmv),
based on a monthly average and corrected for zero percent (0%) moisture and seven percent (7 % )
oxygen. This permit condition also requires the permittee to keep records of THC for stack exit gases
and measured oxygen content of the exhaust gases from the incinerator. EPA believes that MoDNR may
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit RPC - 6
installation ID: 510-0053 Project No. 2007-06-088
want the permittee to also keep records of the moisture content of the exhaust gases from the
incinerators.
Response go Comment: The draft permit has been modified as requested.
Comment #24: Monitoring / Record keeping requirement 2), in Permit Condition (EPO3 through EP06)-
003, requires the permittee to monitor and record the liquid flow rate through each scrubber at least once
every 24-hours while the scrubbers are in operation. Liquid flow rate is a parameter that is easily
measured on a continuous basis and EPA suggests MoDNR consider including continuous scrubber
liquid flow rate monitoring to verify MSD-Bissell Point maintains the flow rate within the design
conditions specified by the manufacturer's performance warranty.
Response to Comment: The draft permit has been modified as requested
Comment #25: Permit Condition (EPO3 through EP06)-005 incorporates the applicable Emission
Limits, Emission Standards, Operating Limits and Requirements from 10 CSR 10-6.191 and 40 CFR
part 60, Subpart MMMM. Emission Limitation and Standards requirement 1) says "the permittee must
meet the emission limits and standards specified in Table 3 to Subpart MMMM of 40 CFR part 60 by
the final compliance date under the approved State plan, Federal plan or delegation, as applicable." The
Missouri Air Conservation Commission (MACC) adopted the Missouri 111D/129 State Plan for Sewage
Sludge Incinerators on February 5, 2013. This MACC adopted plan established a "final compliance
date" of March 21, 2016 or three years after the effective date of state approved plan approval,
whichever is earlier. Therefore, it appears that this opening statement in Emission Limitation and
Standard 1) is no longer relevant and MoDNR may wish to remove it. Also, Operating Limits and
Requirements 3) says "the permittee must meet the operating limits specified in 40 CFR §60.5170 (a)
and (b) by the final compliance date." Again the MACC adopted plan established a "final compliance
date" of March 21, 2016 or three years after the effective date of state approved plan approval,
whichever is earlier. Therefore, it appears to EPA that the Operating Limits and Requirements 3), in
Permit Condition (EPO3 through EP06)-005 may have already been met and this Operating Limits and
Requirements 3) may no longer be applicable and therefore is not required to be included in the Part 70
operating permit.
Response to Comment: The draft permit has been modified as follows:
Emission Limitation and Standards requirement 1) is revised as:
"The emission limits and standards specified in Table 3 to Subpart of 40 CFR Part
60 apply to emissions from a bypass stack or vent while sewage sludge is in the combustion
chamber (i. e., until the sewage sludge feed to the combustor has been cut offfor a period of
time not less than the sewage sludge incineration residence time). [40 CFR §60.5165]"
o Operating Limits and Requirements 3) is removed from the draft permit as requested.
Comment #26:Permit Condition (EPO3 through EP06)-005 incorporates the applicable Reporting and
Record keeping requirements from 10 CSR 10-6.191 and 40 CFR part 60, Subpart MMMM, for Sewage
Sludge Incinerators. Reporting requirement 10 says "if the permittee plans to achieve compliance more
than 1 year following the effective date of state plan approval, the permittee must submit the increment
of progress reports, as applicable." As stated in the previous comment, the MACC adopted the State
Plan for Sewage Sludge Incinerators on February 5, 2013. This plan established a "final compliance
date" of March 21, 2016 or three years after effective date of state plan approval, whichever is earlier.
Also, Reporting requirement 2) says "the permittee must submit the initial compliance report no later
than 60 days following the initial performance test." Finally, Reporting requirement 3) says "the
MSD - Bissell Point Wastewater Treatment Plant
Installation ID: 510-0053
Part 70 Operating Permit RPC - 7
Project No. 2007-06-088
permittee must submit the first annual compliance report no later than 12 months following the
submission of the initial compliance report." Based on the dates associated with the Missouri adopted
State Plan, these reports may have already been submitted and these reporting requirements may no
longer be applicable and therefore are not required to be included in the Part 70 operating permit.
Response to Comment: The draft permit has been modified as requested.
Comment #27: Permit Condition (EP09)-002 incorporates requirements from the Compliance
Assurance Monitoring (CAM) plan associated with wet ash conveying emission unit EP09. Monitoring
requirement 2) b) requires the permittee to check and document the Venturi Scrubber/Mist Eliminator
pressure drop daily. However, the CAM plan included as Attachment E, in the draft Part 70 operating
permit, requires pressure drop across the Venturi Scrubber/Mist Eliminator to be continuously
monitored. EPA suggests MoDNR consider including continuous monitoring for the pressure drop in
monitoring requirement 2) b ). Also, monitoring requirement 2) a) requires the permittee to monitor
visible emissions from the scrubber stack exhaust using EPA Reference Method 22-like procedures
(emphasis added), on a daily basis, during operation of the unit. In the introduction to EPA Method 22,
EPA indicates minor changes in the test methods should not necessarily affect the validity of the results
and it is recognized that alternative and equivalent methods exist. §60.8 provides authority for the
Administrator to specify or approve (1) equivalent methods, (2) alternative methods, and (3) minor
changes in the methodology of the test methods. Unless otherwise identified, all such methods and
changes must have prior approval of the Administrator. An owner employing such methods or
deviations from the test methods without obtaining prior approval does so at the risk of subsequent
disapproval and retesting with approved methods. If MoDNR is authorizing the use of a modified Test
Method 22, the modified test method should receive formal review and approval, by the Administrator,
and the approved altemate test method should be attached to the issued operating permit.
Response to Comment: The daft permit has been modified as follows:
o Pressure drop across Venturi Scrubber/Mist Eliminator shall be continuously monitored
using a Supervisory Control and Data Acquisition (SCADA) system.
o Visible emissions from the scrubber stack exhaust shall be monitored using the procedures
contained in US. EPA Test Method 22 on a daily basis to ensure no visible emissions during
the operation of this unit.
Comment #28: The Monitoring requirement, in Permit Condition (EP23)-001, requires the permittee to
measure the concentration of hydrogen sulfide "as frequently as necessary" (emphasis added) to
characterize the efficiency of the biofilter system and the amount of H2S emitted into the ambient air.
The term "as frequently as necessary" (emphasis added) is too vague as to be enforceable from a
practical matter. EPA suggests MoDNR consider using its authority, as provided in 10 CSR 10-
6.065(6)(C) 1. C., and establish a practically enforceable H2S monitoring and record keeping
requirement. Additionally, Record keeping requirement, in Permit Condition (EP23)-001, requires the
permittee to keep accurate, easily understood, up to date records of H2S concentrations and "any other
parameters necessary to determine" (emphasis added): quantity of H2S gas released into the ambient air;
and efficiency of biofilter system in removing H2S from the clarifiers. Again, the term "any other
parameters necessary to determine" (emphasis added) is too vague as to be enforceable from a practical
matter. EPA encourages MoDNR consider specifying the other parameters necessary to determine
quantity of H2S gas released and the efficiency of the biofilter to enhance the practical enforceability of
the Record keeping requirement in Permit Condition (EP23)-001.
Response to Comment: The draft permit has been modified as requested.
MSD - Bissell Point Wastewater Treatment Plant Part 70 Operating Permit RPC - 8
installation ID: 510-0053 Project No. 2007-06-088
Comment #29 and #30 from Mr. Bob Menees with Great Rivers Environmental Law:
Comment #29: On Page 25-27, Permit Condition (EP-03 through EP-06) — 008 requires MSD to submit
a deviation report for a deviation from a standard identified in Section 4) i)-iv). Please state whether any
deviation reports have been submitted by MSD to MDNR under this provision and identify which
standard (i.e. i) — iv)) MSD has deviated.
Response ga Comment, MSD reports these deviations as required; that the events happen due to
unexpected rnalfarnctions, that they happen several times per year and that they are for the most
part bypass damper events. MSD sends emails when the events occur, and then MSD gathers the
emails in the twice -a -year reports.
Comment #30; On Page 38, the draft operating permit sets forth a "state only" condition restricting
odor from the facility pursuant to 10 CSR 10-6.165. This condition sets the standard for what is a
violation of the regulation, and describes where the testing procedure to determine a violation should be
taken, but sets forth no actual monitoring frequency. MSD should be required to conduct monitoring to
demonstrate compliance with this condition at least once per month, if not more frequently.
esponse go Comment: Because the determination of an odor violation is inherently subjective,
even when using a Nasal Ranger or similar instrument or technique, compliance determinations
will continue to be done by inspectors from the regional office in response to odor complaints.