HomeMy Public PortalAboutExhibit MSD 89C- Lemay Air PermitExhibit MSD 89C
MISSOURI
DEPARTMENT Or
NATURAL RESOURCES
Air Pollution Control Progfasn
PART 70
PERMIT TO OPERATE
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. OP2018-007
Expiration Date: JAN 2 9 2023
Installation ID: 189-0217
Project Number: 2005-06-025
Installation Name and Address
MSD - Lemay Wastewater Treatment Plant
201 Hoffmeister Avenue
St. Louis, MO 63125
St. Louis County
Parent Company's Na2tre and Address
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis MO, 63103
Installation Description:
The Metropolitan Saint Louis Sewer District (MSD), Lemay Plant is a 340 MOD wastewater
treatment plant with three sludge multiple hearth incinerators (11 hearths each). Each
Incinerator has its own heat recovery boiler and Venturi/Impingement Tray scrubber. The
exhaust from each incinerator and set of scrubbers is then directed to one exhaust stack.
Additional equipment on site includes two natural gas emergency generators, one parts washer,
sand blaster, and fuel storage tanks. Along with the heat recovery boilers, there are two
natural gas auxiliary boilers.
MSD-Lemay Plant is located in St. Louis County, a nonattainment area for the 8-hourozone
standard and the-PM25 standard and an attainment area for all other criteria pollutants. MSD-
Lemay Plant emits major levels of carbon monoxide (CO) and has the Potential to Emit (PTE)
major amounts of nitrogen dioxide (NOx).
t&1-11
repared by
Berhanu A. Getahun
Operating Permit Unit
Cx.
Director or signee
DiNfirtrrithratural_Resources..
Effective Date
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 2
Installation ID: 189-0217 Project No. 2005-06-025
Table of Contents
I. INSTALLATION EQUIPMENT LISTING 4
EMISSION UNITS WITH LIMMITATIONS 4
EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS 4
IL PLANT WIdr`M. EMISSION LIMITATIONS 5
M. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS 6
EP1 - THREE (3) MULTIPLE HEARTH INCINERATORS 6
Permit Condition EPI - 001 6
10 CSR 10-6.060 Construction Permits Required 6
Construction Permit Amendment to St. Louis County APCP Permit No. 5768, Issued August 31, 20176
Permit Condition EP 1 - 002 8
10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutant 8
40 CFR Part 61 Subpart C National Emission Standard for Beryllium 8
Permit Condition EP1 - 003 8
10 CSR 10-6.191 Sewage Sludge Incinerators 8
10 CSR 10-6.191(3)(b) Operator Training and Qualifications — 40 CFR §§60.5130 through 60.5160 8
Permit Condition EP1 - 004 10
10 CSR 10-6.191 Sewage Sludge Incinerators 10
10 CSR 10-6.191(3)(C) Emission Limits, Emission Standards, Operating Limits and Requirements -- 40
CFR §§60.5165 through 60.5181 10
Permit Condition EP1 - 005 14
10 CSR 10-6.191 Sewage Sludge Incinerators 14
10 CSR 10-6.191(3)(D) Initial Compliance Requirements -- 40 CFR §§60.5185 through 60.5200 14
10 CSR 10-6.191(3)(D) Continuous Compliance Requirements — 40 CFR §§60.5205 through 60.5215 14
Permit Condition EP1 - 006 17
10 CSR 10-6.191 Sewage Sludge Incinerators 17
10 CSR 10-6.191(3)(G) Performance Testing, Monitoring, and Calibration Requirements — 40 CFR
§§60.5220 through 60.5225 17
Permit Condition EP1 - 007 20
10 CSR 10-6.191 Sewage Sludge Incinerators 20
10 CSR 10-6.191(4) Reporting and Record Keeping — 40 CFR §§60.5230 through 60.5235 20
EP4 — INCINERATOR ASH CONVEYING AND STORAGE 28
Permit Condition EP4 - 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 EP4 - 002 29
10 CSR 10-6.400 Restriction of Emission of Particulate Matter from Industrial Processes 29
EP5 — EMERGENCY GENERATOR 29
Permit Condition EP5-001 29
10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 29
40 CFR Part 63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines 29
EP7—UNDERGROUND GASOLINE STORAGE TANK 34
Permit Condition EP7 - 001 34
10 CSR 10-5.220 Control of Petroleum Liquid Storage, Loading and Transfer 34
Permit Condition EP7 - 002 35
10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 35
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 3
Installation ID: 189-0217 Project No. 2005-06-025
40 CFR Part 63, Subpart CCCCCC National Emission Standards for Hazardous Air Pollutants for Source
Category: Gasoline Dispensing Facilities 35
EP11 — PARTS WASHER 35
Permit Condition EP11 - 001 35
10 CSR 10-5.300 Control of Emissions from Solvent Metal Cleaning 35
IV. CORE PERMIT REQUIREMENTS 38
V. GENERAL PERMIT REQUIREMENTS 45
VI. ATTACHMENTS 50
Attachment A - Representative Operating Conditions Metrics 51
Attachment B - Fugitive Emission Observations 52
Attachment C - Opacity Emission Observations 53
Attachment D- Method 9 Opacity Emissions Observations 54
Attachment E - Solvent Containing Waste Transfer Log 55
Attachment F - Inspection/Maintenance/Repair/Malfunction Log 56
Attachment G - Purchase Records for Cold Cleaning Solvent 57
Attachment H - Employee Solvent Metal Cleaning Training Log 58
Attachment I Inspection/Maintenance/Repair/Malfunction Log 59
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 4
Installation ID: 189-0217 Project No. 2005-06-025
I. Installation Equipment Listing
EMISSION 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
EP1 Three (3) Multiple Hearth Incinerators
EP4 Wet Ash Conveying
EP5 340 HP Emergency Generator, Pipeline Natural Gas -fired
EP7 3 Underground Gasoline Storage Tanks, 550 gallons capacity each
EP11 Parts Washer (25 gallon capacity), 1,000 gallons/year usage
EMISSION UNITS WITHOUT SPi :CTFIC 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 # Description of Emission Unit
EP2 Wastewater Treatment:
Wastewater treatment consists of grit removal, primary settling tanks, aeration
tanks, final clarifier tanks and disinfection.
EP6 Two (2) Pipeline Natural Gas -fired Auxiliary Boilers, 12.6 MMBtulhr each, 1980
EP8 550-Gallon Underground Diesel Fuel Oil Storage Tank.
EP 10 Two (2) Paint Spray Booths
EP12 Sand Blaster
EP14 Two (2) Pipeline Natural Gas -fired Primary Sludge Pump Station Heaters, 0.03
MMBtufhr each
EP15 Two (2) Pipeline Natural Gas -fired Makeup air Dandling Units, 0.777 MMBtuihr total
EP16 Pipeline Natural Gas -fired 895 KW (1,200 HP) Emergency Generator
Engine Manufacture Date: October 21, 2008
Construction Commencement Date: June 23, 2008
MSD - Lenny Wastewater Treatment Plant Part 70 Operating Permit 5
Installation ID: 189-0217 Project No. 2005-06-025
H. 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 I under Emission Units with Limitations and
Emission Units without Limitations.
None
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217 Project No. 2005-06-025
6
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.
EPI - Three (3) Multiple Hearth Incinerators
Emission
Unit
Description
Manufacturer/
Model #
EP1
Incinerator #1 — Multiple Hearth Sewage Sludge Incinerator (SSI) (constructed
1968)
Air Pollution Control — Impingement Tray and Venturi Scrubbers (CD-1)
Incinerator #2 — Multiple Hearth Sewage Sludge Incinerator (SSI) (constructed
1968)
Air Pollution Control — Impingement Tray and Venturi Scrubbers (CD-2)
Incinerator #3 — Multiple Hearth Sewage Sludge Incinerator (SSI)
(constructed 1968)
Air Pollution Control — Impingement Tray and Venturi Scrubbers (CD-3)
Nichols
Model 22'3"
(11 hearths)
Permit Condition EPI 001.
10 CSR 10-6.060 Construction Permits Required
Construction Permit Amendment to St. Louis County APCP Permit No. 5768, Issued August 31, 2017
New Source Review Permit Amendment - Project No. AP2017-09-008, Issued October 3, 2017
Qercationaal Requirement:
1) MSD Lemay Wastewater Treatment Plant (WWTP) total plant -wide daily average feed rate of dry
sludge for all hours of operation during each 24-hour period shall not exceed 7.41 tons per hour.
2) Monitoring, recordkeeping, and calculation of daily average sludge feed rate and daily average
moisture content for each incinerator shall be performed according to 40 CFR Part 60, Subpart
MMMM, §60.5170(f).
3) Daily average moisture content along with daily average feed rate for each incinerator shall be used
to calculate a total plant -wide daily average feed rate of dry sludge for all hours of operation during
each 24-hour period.
4) The daily average feed rate limitation on dry sludge in Operational Requirement 1) shall not have the
same meaning as the maximum permitted capacity discussed in 40 CFR Part 60, Subpart MMIMM,
§60.5220.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 7
Installation ID: 189-0217
Project No. 2005-06-025
Control Device Requirement — Scrubbers:
1) The permittee shall control emissions from the equipment listed in Table 1 below using venturi
scrubbers and impingement tray scrubbers (CD-1 through CD-3) as specified in the permit
application.
Table 1: MSD Lemay WWTP Sewage Sludge Incinerator Scrubber Systems
Emission
Unit
Emission Unit Description
Control Device
EP1
Sewage Sludge Incinerator #1
Impingement Tray / Venturi Scrubber (CD1)
Sewage Sludge Incinerator #2
Impingement Tray / Venturi Scrubber (CD2)
Sewage Sludge Incinerator #3
,
Impingement Tray / Venturi Scrubber (CD3)
2) The permittee shall establish operating limits for minimum pressure drop across wet scrubber,
minimum scrubber liquid flow rate (measured at the inlet to each wet scrubber), minimum scrubber
liquid pH, and minimum afterburner temperature, according to 40 CFR Part 60, Subpart MMMM,
§60.5190.
3) Continuous compliance will be demonstrated if the operating parameters are maintained above the
operating parameter limits. Operating parameter limits and compliance with the operating parameter
limits shall be established according to 40 CFR Part 60, Subpart MMMM, §60.5210.
4) Each scrubber system and any related instrumentation or equipment shall be operated and
maintained in accordance with the manufacturer's specifications, which shall be kept on site.
5) The permittee shall maintain records and perform applicable reporting of control device
malfunctions, control device inspections, control device repairs, and continuous parameter
monitoring system malfunctions according to 40 CFR Part 60, Subpart Mtv1MM for each individual
scrubber system described in Table 1.
Recordkeening:
The permittee shall maintain all records required by this permit condition for not less than five years and
shall make them available immediately to any St. Louis County Department of Health (SLCDH) or
Missouri Department of Natural Resources' Personnel upon request.
Reportine:
The permittee shall report to the St. Louis County Department of Health (SLCDH) Air Pollution Control
Program (or designated agency), 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri
Department of Natural Resources Air Pollution Control Program, Compliance and Enforcement Section,
P.O. Box 176, Jefferson City, Missouri 65102, no later than fifteen days after any exceedance of any of
the terms imposed by this permit condition. 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 - Lemay Wastewater Treatment Plant Part 70 Operating Permit 8
Installation ID: 189-0217 Project No. 2005-06-025
Permit Condition EP1 - 002
10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutant
L40 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 the installation that 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 (0.022 pound (lb)) of beryllium over a 24-hour period.
[40 CFR §61.32(a)]
Monitoring:
MSD shall perform stack sampling and testing as specified in 40 CFR §61.33.
Recordkeeping:
Copies of emission test results shall be retained. Any other data needed to determine total emissions
shall be retained as specified in §61.33(e) for a minimum of 2 years.
Reporting:
MSD shall report to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley,
Missouri 63134 and the Missouri Department of Natural Resources Air Pollution Control Program;
Compliance and Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102, no later than
fifteen 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 EP1 - 003
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
Operator Training and Qualification Requirements: [40 CFR §60.5130]
1) The permittee shall not operate the SST 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)1
ii) Basic combustion principles, including products of combustion.
[40 CFR §60.5130(c)(1)(ii)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 9
Installation ID: 189-0217 Project No. 2005-06-025
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)(1)(ix)]
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 Course: [40 CFR §60.5135]
The Permittee shall complete the operator training course as required by §60.5135.
Operator 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)]
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. [§60.5145(b)]
c) Inspection and maintenance. [§60.5145(c)]
d) Prevention of malfunctions or conditions that may lead to malfunction. [§60.5145(d)]
e) Discussion of operating problems encountered by attendees. [§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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 10
Installation ID: 189-0217 Project No. 2005-06-025
not accessible and include this deviation in the annual report as specified under 40 CFR
§60.5235(d). [40 CFR §60.5155(a)]
b) When a qualified operator is not accessible for 2 weeks or more, the permittee must take the two
actions 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)]
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(l,)(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)J
(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 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)J
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 EP1- 004
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 permittee must meet the emission limits and standards specified in Table 3 to Subpart MNLMM
of 40 CFR Part 60 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 unit(s) is operating
and during periods of malfunction. The emission limits and standards apply to emissions from a
bypass stack or vent while sewage sludge is in the combustion chamber (i.e., until the sewage sludge
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 11
Installation ID: 189-0217 Project No. 2005-06-025
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
The permittee must meet
this emission limit°
Using these averaging methods and
minimum sampling volumes or
durations
And determining
compliance using this
method
Particulate matter
80 milligrams per dry
standard cubic meter
3-run average (collect a minimum
volume of 0.75 dry standard cubic
meters per run)
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
1.2 parts per million by
dry volume
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)
Performance test (Method 26
or 26A at 40 CFR Part 60,
Appendix A-8).
Carbon monoxide
3,800 parts per million by
dry volume
3-run average (collect sample for a
minimum duration of one hour per run)
Performance test (Method
10, 10A, or 10B at 40 CFR
Part 60, Appendix A-4).
Dioxins/furans
(total mass basis)
5.0 nanograms per dry
standard cubic meter; or
3-run average (collect a minimum
volume of 1 dry standard cubic meters
per run)
Performance test (Method 23
at 40 CFR Part 60, Appendix
A-7).
Dioxins/furans
(toxic equivalency
basis)"
0,32 nanograms per dry
standard cubic meter
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 1 dry
standard cubic meters per run. For
Method 30B, collect a minimum
sample as specified in Method 30B at
40 CFR part 60, appendix A 8)
Performance test (Method 29
at 40 CFR part 60, appendix
A-8; Method 30B at 40 CFR
Part 60, Appendix A-8; or
ASTM D6784-02
(Reapproved 2008)).°
Oxides of nitrogen
220 parts per million by
dry volume
3-run average (Collect sample for a
minimum duration of one hour per run)
Performance test (Method 7
or 7E at 40 CFR Part 60,
Appendix A-4).
Sulfur dioxide
26 parts per million by dry
volume
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)
Performance test (Method 6
or 6C at 40 CFR part 40,
Appendix A4; or
ANSI/ASME PTC 19.10-
1981).c
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
12
Project No. 2005-06-025
For the air
pollutant
The permittee must meet
this emission limit`
Using these averaging methods and
minimum sampling volumes or
durations
And determining
compliance using this
method
Cadmium
0.095 milligrams per dry
standard cubic meter
3-run average (collect a minimum
volume of I dry standard cubic meters
per run)
Performance test (Method 29
at 40 CFR part 60, Appendix
A-8).
Lead
0.30 milligrams per dry
standard cubic meter
3-run average (collect a minimum
volume of 1 dry standard cubic meters
per run)
Performance test (Method 29
at 40 CFR Part 60, Appendix
A-8).
a All emission limits are measured at 7 percent oxygen, dry basis at standard conditions.
b The permittee has the option to comply with either the dioxin/furan emission limit on a total mass basis or
the 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 §60.5180]
Opersathag Liffsitsa rr Rer�a�arecaw'it
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 §G0.5170 (f) and the requirements in 40 CFR §60.5170 (g) for meeting any new operating
limits, re-established in §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]
Table 4 to Subpart MMMM of 40 CFR Part 60—Operating Parameters for Existing Sewage Sludge
ncineration Units'
For these operating parameters
The permittee must
establish these operating
limits
And monitor using these minimum frequencies
Data
measurement
Data
a
recording
Data averaging
period for
compliance
Combustion chamber operating
temperature (not required if
afterburner temperature is monitored)
Minimum combustion
chamber or afterburner
operating temperature
Continuous
Every 15
minutes
12-hour block.
Pressure drop across each wet
scrubber
Minimum pressure drop
Continuous
Every 15
minutes
12-hour block.
Scrubber liquid flow rate
Minimum flow rate
Continuous
Every 15
minutes
12-hour block.
Scrubber liquid pH
Minimum pH
Continuous
Every 15
minutes
3-hour block.
a A er.nrrfirrt in SMf1 S 14f1 the nermit may nCP a continuous emissions monitor= system or continuous
automated sampling system in lieu of establishing certain operating limits.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 13
Installation ID: 189-0217 Project No, 2005-06-025
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 must use hourly averages to calculate the 12-hour or 3-hour block
average specified in this table for demonstrating compliance. The permittee must maintain records of 1-hour
averages.
1) The permittee must meet the site -specific minimum combustion chamber operating temperature
established in40 CFR §60.5190. The minimum combustion chamber operating temperature shall be
equal to the lowest 4-hour average combustion chamber 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 §60.5170(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 MIMIvIIM 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 meet the operating limits specified in 40 CFR §60.5170(a) and (b) by the final
compliance date. [40 CFR §60.5170(e)]
4) 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)]
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 the daily average
feed rate, as specified in 40 CFR §60.5230(f)(3)(ii). [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. Tf 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 §60.51700)(2)]
5) 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)]
i
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 14
Installation ID: 189-0217 Project No. 2005-06-025
Permo CiMel 110PP EP i 005
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
Initial Compliance Requirements:
1) To demonstrate initial compliance with the emission limits and standards in Table 3 to Subpart
MMMM of 40 CFR Part 60 (Permit Condition EP1-004, the permittee shall use the procedures
specified in §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 SST 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, dioxinsifurans (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 Subpart MMMM of 40 CFR Part 60 (Permit Condition EP1-004 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 Subpart MMMM of 40 CFR Part 60 (Permit
Condition EP1-004), 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 4C CFR Part 60 (Permit
Condition EP1-004). The performance test must have used the test methods specified in
Table 3 to Subpart MMMM of 40 CFR Part 60. [§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 §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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 15
Installation ID: 189-0217 Project No. 2005-06-025
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 shall 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]
Continuous 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 EP1-004), the permittee must use the
procedures specified in §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 MMM 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)(1)]
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 permittee can conduct performance tests Iess 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 Condition EP1-004), 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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit i6
Installation ID: 189-0217 Project No. 2005-06-025
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)]
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 permitter must notify the Director in writing as specified in
§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 performance 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)]
2) Continuous compliance with operating limits:
The permittee must continuously monitor the operating parameters as specified in §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. [§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 permittee did not meet one of the permittee's operating
limits established under this subpart. [40 CFR §60.5210(b)]
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 §60.5210(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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 17
Installation ID: 189-0217 Project No. 2005-06-025
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 EP1 - 006
10 CSR 10-6.191 Sewage Sludge Incinerators
10 CSR 10-6.191(3)(G) Performance Testing, Monitoring, and Calibration Requirements — 40 CFR
§§60.5220 through 60.5225
Performance Testing 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 bumed 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 log 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) All 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)]
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(a)(4)]
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)]
6) All pollutant concentrations must be adjusted to 7 percent oxygen using the following equation
(Equation 1 of 40 CFR §60.5220): [§60.5220(a)(6)]
MSD - Lernay Wastewater Treatment Plant Part 7u Operating Permit 18
Installation ID: 189-0217 Project No. 2005-06-025
(20.97)
Cad
�meas (Equation 1)
[(2;)]
Where:
Cadj = Pollutant concentration adjusted to 7 percent oxygen.
Cmeas = 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)1
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 alternative 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 permittee 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 clays 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)(B)]
b) Safe sampling platform(s). [40 CFR §60.5220(a)(9)(ii)]
c) Safe access to sampling platform(s). [§60.5220(a)(9)(iii)]
d) Utilities for sampling and testing equipment. [40 CFR §60.5220(a)(9)(iv)]
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,
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 19
Installation ID: 189-0217
Project No. 2005-06-025
failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances, beyond the permittee's control, compliance may, upon the Director's approval, be
determined using the arithmetic mean of the results of the two other runs. [§60.5220(a)(10)]
11) During each test run specified in 40 CFR §60.5220 (a)(1), the permittee must operate the permittee's
sewage sludge incinerator at a minimum of 85 percent of the permittee's maximum permitted
capacity. [40 CFR §60.5220(a)(11)]
12) As an alternative to §60.5220(a)(11) and upon approval by the Director, 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 §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,
13) 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)]
Monitoring and Calibration Requirements 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.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 20
Installation ID: 189-0217 Project No. 2005-06-025
Any such periods must be reported in the permittee's annual deviation report.
[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)]
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) The permittee must 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 SSI 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 EPl 0 007
l0 CSR 10-6.191 Sewage Sludge Incinerators
10 CSR 10-6.191(4) Reporting and Record Keeping ---- 40 CFR §§60.5230 through 60.5235
Recordkeepinw.
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 SSI unit operators the following documentation specified in 40 CFR
§60.5230(c)(1). [40 CFR §60.5230(c)1
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.
[§60.5230(c)(l)(iii)]
iv) Procedures for maintaining proper combustion air supply levels.
[40 CFR §60.5230(c)(1)(iv)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 21
Installation ID: 189-0217 Project No. 2005-06-025
v) Procedures for operating the incinerator and associated air pollution control systems within
the standards established under this subpart. [40 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 in addition to sewage sludge.
[40 CFR §60.5230(c)(1)(ix)]
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 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 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)(2)]
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)(3)]
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
tirneframe 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). [§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)]
MSD - Lemay Wastewater Treatment Plant Part 7u Operating Permit 22
Installation ID: 189-0217 Project No. 2005-06-025
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 MMIVIM 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 §60.5235(e) and (f):
[40 CFR §60.5230(h)]
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 §60.5230(j)]
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 Nvith 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(1)]
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:
The permittee must submit the reports specified in 40 CFR §60.5235 (a) through (i). See Table 6 to
Subpart MMMM of 40 CFR Part 60 for a summary of these reports.
1) Increments of progress report. If the permittee plans to achieve compliance more than 1 year
following the effective date of state plan approval, the permittee must submit the following reports,
as applicable: [40 CFR §60.5235(a)]
a) A final control plan as specified in §§60.5085(a) and 60.5110. [40 CFR §60.5235(a)(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
§§60.5095 and 60.5100. [§60.5235(a)(2)]
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 §60.5105. [§60.5235(a)(3)]
d) If the permittee's plan to close the permittee's SSI unit rather than comply with the state plan, the
permittee must submit a closure notification as specified in 40 CFR §60.5125. [§60.5235(a)(4)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 23
Installation ID: 189-0217
Project No. 2005-06-025
2) Initial compliance report. The permittee must submit the following information no later than 60 days
following the initial performance test. [40 CFR §60.5235(b)]
a) Company name, physical address, and mailing address. [§60.5235(b)(1)]
b) Statement by a responsible official, with that official's name, title, and signature, certifying the
accuracy of the content of the report. [§60.5235(b)(2)]
c) Date of report. [§60.5235(b)(3)]
d) The complete test report for the initial performance test results obtained by using the test
methods specified in Table 3 to Subpart NIlVIMM of 40 CFR Part 60. [40 CFR §60.5235(b)(4)]
e) If an initial performance evaluation of a continuous monitoring system was conducted, the
results of that initial performance evaluation. [40 CFR §60.5235(b)(5)]
f) The values for the site -specific operating limits established pursuant to 40 CFR §§60.5170 and
60.5175 and the calculations and methods, as applicable, used to establish each operating limit.
[40 CFR §60.5235(b)(6)]
g) The results of the initial air pollution control device inspection required in §60.5195, including a
description of repairs. [40 CFR §60.5235(b)(8)]
h) The site -specific monitoring plan required under §60.5200, at least 60 days before the
permittee's initial performance evaluation of the continuous monitoring system. [§60.5235(b)(9)]
i) The site -specific monitoring plan for the ash handling system required under §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)]
3) 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. [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)]
(2) For scrubber liquid pH, the highest and lowest 3-hour average values. [40 CFR
§60.5235(c)(5)(ii)(B)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 24
Installation ID: 189-0217 Project No. 2005-06-025
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 §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)]
I) 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)1
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
§60.11(d), including actions taken to correct a malfunction. [40 CFR §60.5235(c)(16)]
4) Deviation reports. [40 CFR §60.5235(d)]
a) The permittee must submit a deviation report if: [§60.5235(d)(1)]
i) Any recorded operating parameter level, based on the averaging time specified in Table 4 to
Subpart MIVIMM 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 this
subpart. [40 CFR §60.5235(d)(1)(v)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 25
Installation ID: 189-0217 Project No. 2005-06-025
iv) The permittee had a malfunction that caused or may have caused any applicable emission
limit to be exceeded. [§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).
[§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).
[40 CFR §60.5235(d)(3)]
i) Company name, physical address, and mailing address. [40 CFR §60.5235(d)(3)(i)]
ii) Statement by a responsible official, with that off cial'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)]
(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. [§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)]
(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 § 60.523 5(d)(3)(viii)(G)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 26
Installation ID: 189-0217 Project No. 2005-06-025
(8) An identification of each parameter and pollutant that was monitored at the SSI unit.
[§60.5235(d)(3)(viii)(H)]
(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)1
(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: [§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)1
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 §60.5235(d)(1)(vii), including a
description of actions taken during the malfunction to minimize emissions in accordance
with §60.11(d) and to correct the malfunction. [40 CFR §60.5235(d)(4)(viii)]
5) 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)(1)(i) and (e)(1)(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)(1)(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)]
(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)(ii)(A) through (e)(1)(ii)(C) (listed below). [40 CFR §60.5235(e)(1)(ii)]
(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(e)(1)(ii)(C)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 27
Installation ID: 189-0217 Project No. 2005-06-025
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)]
6) Notification 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)]
a) The permittee 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(fl(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 performance 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(f)(2)]
7) 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)]
8) 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 MM MM 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/ertlert_tool.htmll) 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. [§60.5235(h)(2)]
9) 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 - Lemay Wastewater "treatment Plant Fart 70 Operating Permit
Installation ID: 189-0217
28
Project No. 2005-06-025
EP4 — Incinerator Ash Conveying and Storage
Emission
Unit
Description
Manufacturer/
Model #
EP4
Wet Ash Conveying, (constructed 1983)
Air Pollution Control — Venturi/Impingement Scrubber (CD4)
CEA designed,
Zimpro Inc. fabricated
Permit Condition EP4 - 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 Linsitation 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 IVMMM 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 wet ash conveying system is operating and during periods of malfunction.
Table 3 to Subpart MMMM of 40 CFR Part 60 —Emission Limits and Standards
For the air
The permittee must
Using these averaging methods and
And determining
pollutant
meet this emission
limit
minimum sampling volumes or durations
compliance using this
method
Visible emissions of
combustion ash from
an ash conveying
Fugitive
system (including
Visible emission test
emissions from
conveyor transfer
Three 1-hour observation periods
(Method 22 of Appendix A -
ash handling
points) for no more
than 5 percent of the
hourly observation
period
7 of 40 CFR Part 60).
Oyer�atin Lirsaits and Regaa retnents:
The permittee must meet the operating limits and requirements specified in 40 CFR §60.5170 (d),
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] The permittee must also 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)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
29
Project No. 2005-06-025
Permit Condition EP4 - 002
10 CSR 10-6.400 Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
1) The permittee shall not emit particulate matter in excess of 9.71 lbs/hr from EP04.
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.
Monitorinff/Recordkeeping/ReportinR:
This emission unit uses the same stack as the incinerators. The continuous parametric monitoring and
testing requirements of the incinerators as required in Permit Condition EP1-006, suffices for this Permit
Condition. Calculations in the Statement of Basis show the emission limit would not be exceeded.
EP5 — Emergency Generator
Emission
Unit
Description
Manufacturer/
Model #
EP5
340 HP Emergency Generator, pipeline natural gas fired,
(constructed 1966)
Climax Engine Mfg. Co.,
Model #V-80
Permit Condition EP5-001
10 CSR 10-6.075 Maximum Achievable Control Technology Regulations
40 CFR Part 63, Subpart 7.777 National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Emission Limitation:
The permittee must comply with the requirements in Table 2d to Subpart ZZZZ of 40 CFR Part 63
which apply to the facility (listed below). [40 CFR §63.6603(a)]
For each
The permittee must meet the
following requirement, except
during periods of startup
During periods of startup you must
a. Change oil and filter every 500
hours of operation or annually,
Minimize the engine's time spent at
idle and minimize the engine's
whichever comes first;
b. Inspect air cleaner every 1,000
hours of operation or annually,
startup time at startup to a period
Emergency SI 2
whichever comes first, and
needed for appropriate and safe
replace as necessary; and
loading of the engine, not to exceed
30 minutes, after which time the
c. Inspect all hoses and belts every
500 hours of operation or
non -startup emission limitations
annually, whichever comes
first, and replace as necessary
apply.
' Thepermittee has the option to utilize an oil analysisprogram as described in 40 CFR 63.6625 i in
P � Y � § (�}
order to extend the specified oil change requirement in Table 2d of Subpart 77.77
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30
2 If the emergency engine is operating during an emergency and it is not possible to shut down the engine
in order to perform the management practice requirements on the schedule required in Table 2d of
Subpart ZZZZ, or if performing the management practice on the required schedule would otherwise pose
an unacceptable risk under Federal, State, or local law, the management practice can be delayed until the
emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management
practice should be performed as soon as practicable after the emergency has ended or the unacceptable
risk under Federal, State, or local law has abated. The permittee must report any failure to perform the
management practice on the schedule required and the Federal, State or local law under which the risk
was deemed unacceptable.
Mongioriaaz, Operation and Maintenance Requirements:
1) The permittee must operate and maintain the stationary RICE and after -treatment control device (if
any) according to the manufacturer's emission -related written instructions or develop the permittee's
maintenance plan which must provide to the extent practicable for the maintenance and operation of
the engine in a manner consistent with good air pollution control practice for minimizing emissions.
[40 CFR §63.6625(e)]
2) The permittee must install a non-resettable hour meter if one is not already installed.
[40 CFR §63.6625(f)]
3) The permittee must minimize the engine's time spent at idle during startup and minimize the engine's
startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the emission standards applicable to all times other than startup in Table
2d to Subpart ZZZZ of Part 63 apply. [40 CFR §63.6625(h)]
4) The permittee has the option of utilizing an oil analysis program in order to extend the specified oil
change requirement in Tables 2d to Subpart ZZZZ of 40CFR Part 63. The oil analysis must be
performed at the same frequency specified for changing the oil in Table 2d to Subpart ZZZZ of 40
CFR Part 63. The analysis program must at a minimum analyze the following three parameters:
Total Base Number, viscosity, and percent water content. The condemning limits for these
parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of
the oil when new; viscosity of the oil has changed by rnore than 20 percent from the viscosity of the
oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning
limits are not exceeded, the permittee is not required to change the oil within 2 business days of
receiving the results of the analysis; if the engine is not in operation when the results of the analysis
are received, the engine owner or operator must change the oil within 2 business days or before
commencing operation, whichever is later. If any of the limits are exceeded, the permittee must
change the oil before continuing to use the engine. The permittee must keep records of the
parameters that are analyzed as part of the program, the results of the analysis, and the oil changes
for the engine. The analysis program must be part of the maintenance plan for the engine.
[40 CFR §63.6625(i)]
Compliance Requirements:
1) The permittee must be in compliance with the emission limitations and operating limitations in
Subpart ZZZZ of 40 CFR Part 63 that apply to the permittee at all times. [40 CFR §63.6605(a)]
2) The permittee must monitor and collect data according to §63.6635.
a) Except for monitor malfunctions, associated repairs, required performance evaluations, and
required quality assurance or control activities, the permittee must monitor continuously at all
times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent,
not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures
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Project No. 2005-06-025
Installation ID: 189-0217
that are caused in part by poor maintenance or careless operation are not malfunctions.
[40 CFR §63.6635(b)]
b) The permittee may not use data recorded during monitoring malfunctions, associated repairs, and
required quality assurance or control activities in data averages and calculations used to report
emission or operating levels. The permittee must, however, use all the valid data collected during
all other periods. [§63.6635(c)]
3) The permittee must demonstrate continuous compliance with each emission limitation and operating
limitation in Tables 2d to Subpart ZZZZ of 40 CFR Part 63 that apply to the permittee according to
methods specified below (from Table 6 to Subpart ZZZZ of 40 CFR Part 63). [40 CFR §63.6640(a)]
For Each...
Complying with the requirements
to ...
The permittee must demonstrate continuous
compliance by ...
i Operating and maintaining the stationary
RICE according to the manufacturer's
emission -related operation and maintenance
Existing stationary instructions; or
RICE not subject to Work or Management practices i Develop and follow your own maintenance
any numerical plan which must provide to the extent
emission limitations practicable for the maintenance and
operation of the engine in a manner
consistent with good air pollution control
practice for minimizing emissions.
4) The permittee must operate the emergency stationary RICE according to the requirements in
paragraphs (t)(1), (f)(1)(i), (f)(2), (f)(2)(i) and(f)(4)(ii) of 40 CFR §63.6640. In order for the engine
to be considered an emergency stationary RICE under this subpart, any operation other than
emergency operation, maintenance and testing, emergency demand response, and operation in non -
emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (4) of 40 CFR
§63.6640, is prohibited. If you do not operate the engine according to the requirements in
paragraphs (f)(1) through (4) of §63.6640, the engine will not be considered an emergency engine
under this subpart and must meet all•requirements for non -emergency engines.
[40 CFR §63.6640(f)]
a) There is no time limit on the use of emergency stationary RICE in emergency situations.
[40 CFR §63.6640(f)(1)]
b) The permittee may operate the emergency stationary RICE for any combination of the purposes
specified in paragraphs (f)(2)(i) of §40 CFR 63.6640 for a maximum of 100 hours per calendar
year. Any operation for non -emergency situations as allowed by paragraph (f)(4) of 40 CFR
§63.6640 counts as part of the 100 hours per calendar year allowed by this paragraph 0)(2).
[§63.6640(f)(2)]
i) The emergency stationary RICE may be operated for maintenance checks and readiness
testing, provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine.
The owner or operator may petition the Administrator for approval of additional hours to be
used for maintenance checks and readiness testing, but a petition is not required if the owner
or operator maintains records indicating that federal, state, or local standards require
maintenance and testing of emergency RICE beyond 100 hours per calendar year.
[40 CFR §63.6640(f)(2)(i)]
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Project No. 2005-06-025
Installation ID: 189-0217
c) The emergency stationary RICE may be operated for up to 50 hours per calendar year in non -
emergency situations. The 50 hours of operation in non -emergency situations are counted as part
of the 100 hours per calendar year for maintenance and testing and emergency demand response
provided in paragraph (f)(2) of 40 CFR §63.6640. Except as provided in paragraph (f)(4)(ii) of
40 CFR §63.6640, the 50 hours per year for non -emergency situations cannot be used for peak
shaving or non -emergency demand response, or to generate income for a facility to an electric
grid or otherwise supply power as part of a financial arrangement with another entity.
i) The 50 hours per year for non -emergency situations can be used to supply power as part of a
financial arrangement with another entity if all of the following conditions are met:
[40 CFR §63.6640(f)(4)(ii)]
(A) The engine is dispatched by the local balancing authority or local transmission and
distribution system operator. [40 CFR §63.6640(f)(4)(ii)(A)]
(B) The dispatch is intended to mitigate local transmission and/or distribution limitations so
as to avert potential voltage collapse or line overloads that could lead to the interruption
of power supply in a local area or region. [40 CFR §63.6640(f)(4)(ii)(B)]
(C) The dispatch follows reliability, emergency operation or similar protocols that follow
specific NERC, regional, state, public utility commission or local standards or guidelines.
[40 CFR §63.6640(f)(4)(ii)(C)]
(D) The power is provided only to the facility itself or to support the local transmission and
distribution system. [40 CFR §63.6640(f)(4)(ii)(D)]
(E) The owner or operator identifies and records the entity that dispatches the engine and the
specific NERC, regional, state, public utility commission or local standards or guidelines
that are being followed for dispatching the engine. The local balancing authority or local
transmission and distribution system operator may keep these records on behalf of the
engine owner or operator. [40 CFR §63.6640(f)(4)(ii)(E)1
Rccordkeepira
1) The permittee must keep the records described in paragraphs (a)(1) through (a)(5), (b)(1) through
(b)(3) and (c) of §63.6655. [40 CFR §63.6655(a)]
a) A copy of each notification and report that the permittee submitted to comply with Subpart
ZZZZ of 40 CFR Part 63, including all documentation supporting any Initial Notification or
Notification of Compliance Status that you submitted, according to the requirement in 40 CFR
§63.10(b)(2)(xiv). [40 CFR §63.6655(a)(1)]
b) Records of the occurrence and duration of each malfunction of operation (i.e., process
equipment) or the air pollution control and monitoring equipment. [40 CFR §63.6655(a)(2)]
c) Records of actions taken during periods of malfunction to minimize emissions in accordance
with 40 CFR §63.6605(b). [40 CFR §63.6655(a)(5)]
2) The permittee must keep the records required in Table 6 of Subpart ZZZZ of 40 CFR Part 63 to
show continuous compliance with each emission or operating limitation that applies to the permittee.
[40 CFR §63.6655(d)]
3) The permittee's records must be in a form suitable and readily available for expeditious review
according to 40 CFR §63.10(b)(1). [40 CFR §63.6660(a)]
4) As specified in 40 CFR §63.10(b)(1), the permittee must keep each record for 5 years following the
date of each occurrence, measurement, maintenance, corrective action, report, or record.
[40 CFR §63.6660(b)]
5) The permittee must keep each record readily accessible in hard copy or electronic form for at least 5
years after the date of each occurrence, measurement, maintenance, corrective action, report, or
record, according to 40 CFR §63.10(b)(1). [40 CFR §63.6660(c)]
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Installation ID: 189-0217 Project No. 2005-06-025
ReDortira ;
1) The permittee must report each instance in which the permittee did not meet each emission
limitation or operating limitation in Table 2d to Subpart ZZZZ of 40 CFR Part 63 that applies.
These instances are deviations from the emission and operating limitations in Subpart ZZZZ of 40
CFR Part 63. These deviations must be reported according to the requirements in 40 CFR §63.6650.
[40 CFR §63.6640(b)]
2) The permittee must also report each instance in which the permittee did not meet the applicable
requirements in Table 8 to Subpart 7ZZZ of 40 CFR Part 63 -- Applicability of General Provisions
to Subpart Z7.7Z. [40 CFR §63.6640(e)]
3) Reporting requirements [40 CFR §63.6650]
a) The permittee must submit each report in Table 7 of Subpart ZZZZ of 40 CFR Part 63 that
applies. [40 CFR §63.6650(a)]
b) Unless the Administrator has approved a different schedule for submission of reports under
§63.10(a), the pennittee must submit each report by the date in Table 7 of Subpart ZZZZ of 40
CFR Part 63 and according to the requirements in paragraphs (b)(5), (b)(8) and (b)(9) of
§63.6650. [40 CFR §63.6650(b)]
i) The permittee shall submit compliance reports according to the dates specified in 10 CSR 10-
6.065(6)(C)1.C, General Record Keeping and Reporting Requirements and 10 CSR 10-
6.065(6)(C)3, Compliance Requirements, of Section V of this permit instead of according to
the dates specified in in paragraphs (b)(1) through (b)(4) of 40 CFR §63.6650.
[40 CFR §63.6650(b)(5)]
ii) For annual Compliance reports, each subsequent Compliance report must cover the annual
reporting period from January 1 through December 31. [40 CFR §63.6650(b)(8)]
iii) For annual Compliance reports, each subsequent Compliance report must be postmarked or
delivered no later than January 31. [40 CFR §63.6650(b)(9)]
c) The Compliance report must contain the information in paragraphs (c)(1) through (6) of 40 CFR
§63.6650. [40 CFR §63.6650(c)]
i) Company name and address. [40 CFR §63.6650(c)(1)]
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 §63.6650(c)(2)]
iii) Date of report and beginning and ending dates of the reporting period.
[40 CFR §63.6650(c)(3)]
iv) 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 which
occurred during the reporting period and which caused or may have caused any applicable
emission limitation to be exceeded. The report must also include a description of actions
taken by the permittee during a malfunction of an affected source to minimize emissions in
accordance with 40 CFR §63.6605(b), including actions taken to correct a malfunction.
[40 CFR §63.6650(c)(4)]
v) If there are no deviations from any emission or operating limitations that apply, a statement
that there were no deviations from the emission or operating limitations during the reporting
period. [§63.6650(c)(5)]
d) For each deviation from an emission or operating limitation that occurs for the stationary RICE
where the permitter is not using a CMS to comply with the emission or operating limitations in
Subpart ZZZZ of 40 CFR Part 63, the Compliance report must contain the information in
paragraphs (c)(1) through (4) of 40 CFR §63.6650 and the information in paragraphs (d)(1) and
(2) of 40 CFR §63.6650. [40 CFR §63.6650(d)]
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Installation ID: 189-0217 Project No. 2005-06-025
i) The total operating time of the stationary RICE at which the deviation occurred during the
reporting period. [40 CFR §63.6650(d)(1)]
ii) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable), as applicable, and the corrective action taken. [40 CFR §63.6650(c)(2)]
e) The permittee must report all deviations as defined in Subpart ZZZZ of 40 CFR Part 63 in the
semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR
71.6(a)(3)(iii)(A). If the permittee submits a Compliance report pursuant to Table 7 of Subpart
ZZZZ of 40 CFR Part 63 along with, or as part of, the semiannual monitoring report required by
40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the Compliance report includes all
required information concerning deviations from any emission or operating limitation in Subpart
ZZZZ of 40 CFR Part 63, submission of the Compliance report shall be deemed to satisfy any
obligation to report the same deviations in the semiannual monitoring report. However,
submission of a Compliance report shall not otherwise affect any obligation the permittee may
have to report deviations from permit requirements to the permit authority.
[40 CFR §63.6650(f)]
EP7 — Underground Gasoline Storage Tank
Emission
Unit
Description
EP7 Three (3) Underground Gasoline Storage Tanks, 550 gallon capacity each
Permit Condition EP7 6 001
10 CSR 10-5.220 Control of Petroleum Liquid Storage, Loading and Transfer.
Operational Limitation/Eq&ipme,t S,iecb7catioras:
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.]
1) 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 gasoline 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) Each gasoline 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"wcp18"wcv) except when the permittee provides
documentation that the system is CARB certified for a different valve and will not function
properly with a 3"wcpl8"wcv valve. [10 CSR 10-5.220(3)(C)l.C(III)]
Resorting:
The permittee shall report to the SLCDH Air Pollution Control Program, 6121 North Hanley Road,
Berkeley, Missouri 63134 and the Missouri Department of Natural Resources 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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
35
Project No. 2005-06-025
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 EP7 - 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:
§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: [§63.11116(a)]
a) Minimize gasoline spills; [§63.11116(a)(1)]
b) Clean up spills as expeditiously as practicable; [§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; [§63.11116(a)(3)]
d) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators. [§63.11116(a)(4)]
2) The permittee is not required to submit notifications or reports as specified in §63.11125, §63.11126,
or Subpart A of 40 CFR Part 63, but the permittee must have records available within 24 hours of a
request by the Administrator to document the permittee's gasoline throughput. [§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 §63.11116(a)(3). [§63.11116(d)]
EP11 — Parts Washer
Emission
Unit
Description
EP11
Parts Washer — 25 gallon capacity, 1,000 gallons per year usage
Permit Condition EP11 - 001
10 CSR 10-5.300 Control of Emissions from Solvent Metal Cleaning_
Emission Limitation:
1) The permittee shall not use cold cleaning solvent with a vapor pressure greater than 1.0 millimeters
of Mercury (mmHg) (0.019 psi) at 20 degrees Celsius (20°C) (68 degrees Fahrenheit (68°F)). [10
CSR 10-5.300(3)(A)1.A]
2) Exception: The permittee may use an altemative method for reducing cold cleaning emissions if the
level of emission control is equivalent to or greater than the requirements of subparagraph (3)(A)1.A
and (3)(A)1.B of 10 CSR 10-5.300. The director and the U.S Environmental Protection Agency
(EPA) must approve the alternative method. [10 CSR 10-5.300(3)(A)1.D]
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Installation ID: 189-0217 Project No. 2005-06-025
Operational Limitation/Equipment Specification:
The permittee shall comply with the following operational limitations and equipment specifications
unless an exemption under 10 CSR 10-5.300(1)(D) applies:
1) Equipment specifications:
a) Each cold cleaner will have a cover, which will prevent the escape of solvent vapors from the
solvent bath while in the closed position or an enclosed reservoir, which will limit the escape of
solvent vapors from the solvent bath whenever parts are not being processed in the cleaner. [10
CSR 10-5.300(3)(A)1.C]
b) Alternate methods for reducing cold cleaning emissions may be used if the permittee shows the
emission control is at least equivalent to the control in (a) above and is approved by the Director
and the EPA. [10 CSR 10-5.300(3)(A)1.D]
c) When one (1) or more of the following conditions exist, the cover shall be designed to operate
easily such that minimal disturbing of the solvent vapors in the tank occurs. (For covers larger
than ten (10) square feet, this shall be accomplished by either mechanical assistance or by a
power system). [10 CSR 10-5.300(3)(A)1.E]
i) The solvent vapor pressure is greater than 0.3 psi measured at one hundred degrees
Fahrenheit (100°F) [10 CSR 10-5.300(3)(A)1.E(I)]
ii) The solvent is agitated. [10 CSR 10-5.300(3)(A)1.E(II)]
iii) The solvent is heated. [10 CSR 10-5.300(3)(A)1.E(I11)]
d) Each cold cleaner shall have an internal drainage facility so that parts are enclosed under the
cover while draining. [10 CSR 10-5.300(3)(A)l.F]
e) If an internal drainage facility as in 10 CSR 10-5.300(3)(A)1.F cannot fit into the cleaning
system and the solvent vapor pressure is less than 0.6 psi measured at one hundred degrees
Fahrenheit (100°F), then the cold cleaner shall have an external drainage facility which provides
for the solvent to drain back into the solvent bath. [10 CSR 10-5.300(3)(A)1.G]
f) Solvent sprays shall be a solid fluid stream (not a fine, atomized or shower type spray) and at a
pressure which does not cause splashing above or beyond the freeboard. [10 CSR 10-
5.300(3)(A)1.H]
g) A permanent conspicuous label summarizing the operating procedures shall be affixed to the
equipment or in a location readily visible during operation of the equipment. [10 CSR 10-
5.300(3)(A)1.1]
h) Any cold cleaner which uses a solvent that has a solvent vapor pressure greater than 0.6 psi
measured at one hundred degrees Fahrenheit (100°F) or heated above one hundred twenty
degrees Fahrenheit (120°F) must use one (1) of the following control devices: [10 CSR 10-
5.300(3)(A)1.J]
i) A freeboard ratio of at least 0.75 [10 CSR 10-5.300(3)(A)1.J(1)]
i) Water cover (solvent must be insoluble in and heavier than water) [10 CSR 10-
5.300(3)(A)1.J(II)]
ii) Other control system that has a mass balance demonstrated overall VOC emission reduction
efficiency of at least sixty-five percent (65%) and is approved by the Director and EPA prior
to use. [10 CSR 10-5.300(3)(A)1.J(III)]
2) Operating procedures:
a) Cold cleaner covers shall be closed whenever parts are not being handled in the cleaners, or
solvent must drain into an enclosed reservoir except when performing maintenance or collecting
solvent samples. [10 CSR 10-5.300(3)(B)1.A]
b) Cleaned parts shall be drained in the free board area for at least fifteen (15) seconds, or until
dripping stops, whichever is longer. [10 CSR 10-5.300(3)(B)1.B]
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Installation ID: 189-0217 Project No. 2005-06-025
c) Whenever a cold cleaner fails to perform within the operating parameters established by 10 CSR
10-5.300, the unit shall be shut down and shall remain shut down until operation is restarted to
meet 10 CSR 10-5.300's operating requirements. [10 CSR 10-5.300(3)(B)1.C]
d) Solvent leaks shall be repaired immediately, or the cold cleaner shall be shut down until the
leaks are repaired. [10 CSR 10-5.300(3)(B)1.D]
e) Waste material removed from a cold cleaner shall be disposed of by one of the methods listed in
the 10 CSR 10-5.300 or an equivalent method approved by the director and EPA. [10 CSR 10-
5.300(3)(B)1.E]
f) Waste solvent shall be stored in closed containers only. [10 CSR 10-5.300(3)(B)1.F]
3) Operator and Supervisor Training:
a) Persons who operate a cold cleaner shall be trained in the operational and equipment
requirements specified in 10 CSR 10-5.300 for the permittee's particular solvent metal cleaning
process. [10 CSR 10-5.300(3)(C)1]
b) The supervisor of any person who operates a cold cleaner shall receive equal or greater
operational training than the operator. [10 CSR 10-5.300(3)(C)2]
c) Persons who operate a cold cleaner shall receive a procedural review at least once each twelve
(12) months. [10 CSR 10-5.300(3)(C)3]
MonitorineRecordkeeping:
1) .The permittee shall maintain the following records for each purchase of cold cleaner solvent
(Attachment G): [10 CSR 10-5.300(4)(B)]
a) Name and address of the solvent supplier. [10 CSR 10-5.300(4)(B)1]
b) Date of purchase. [10 CSR 10-5.300(4)(B)2]
c) Type of solvent purchased. [10 CSR 10-5.300(4)(B)3]
d) Vapor pressure of solvent in mm Hg at 20°C or 68°F. [10 CSR 10-5.300(4)(B)4]
2) The permittee shall keep records of all types and amounts of solvents containing waste material from
cleaning or degreasing operations transferred either to a contract reclamation service or to a disposal
facility and all amounts distilled on the premises. (see Attachment E). The record also shall include
maintenance and repair logs that occurred on the degreaser and any associated control equipment
(Attachment F). These records shall be kept current and made available for review on a monthly
basis. The director may require additional recordkeeping if necessary to adequately demonstrate
compliance with this rule. [10 CSR 10-5.300(4)(A]
3) The permittee shall keep records of solvent metal cleaning training as required by 10 CSR 10-
5.300(3)(C) (Attachment H).
4) MI records shall be retained for five years and be available to the director upon request. [10 CSR 10-
5.300(4)(E)]
/jwortin
The permittee shall report any deviations/exceedances of this permit condition using the semi-annual
monitoring report and annual compliance certification to the to the SLCDH Air Pollution Control
Program, 6121 North Hanley Road, Berkeley, Missouri 63134, and the Missouri Department of Natural
Resources Air Pollution Control Program, Compliances and Enforcement Section, P.O. Box 176,
Jefferson City, MO 65102, as required by Section V of this permit.
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Installation ID: 189-0217 Project No. 2005-06-025
IVo 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.
10 CSR 10-6.045 Open Burning Requirements
1) General provisions. The open burning of tires, petroleum -based products, asbestos containing
materials, and trade waste is prohibited, except as allowed below. Nothing in this rule may be
construed as to allow open burning which causes or constitutes a public health hazard, nuisance, a
hazard to vehicular or air traffic, nor which violates any other rule or statute. [10 CSR 10-6.045(3)]
2) Certain types of materials may be open burned provided an open burning permit is obtained from the
director. The permit will specify the conditions and provisions of all open burning. The permit may
be revoked if the owner or operator fails to comply with the conditions or any provisions of the
permit. [10 CSR 10-6.045(3)(B)]
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(3)(B)]
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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 39
Installation ID: 189-0217 Project No. 2005-06-025
and duration of the excess emissions warrant enforcement action under section 643.080 or 643.151,
RSMo. [10 CSR 10-6.050(3)(C)]
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 make 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 10-6.100 Alternate Emission Limits
Proposals for alternate emission limitations shall be submitted on Alternate Emission Limits Permit
forms provided by the department. [10 CSR 10-6.100(3)(A)1]. An installation owner or operator must
obtain an Alternate Emission Limits Permit in accordance with 10 CSR 10-6.100 before alternate
emission limits may become effective. [10 CSR 10-6.100(3)(A)2]
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 MoEIS, which
requires Form 1.0 signed by an authorized company representative, or on Emission Inventory
Questionnaire (EIQ) 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)(13) 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)]
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Installation ID: 189-0217 Project No. 2005-06-025
10 CSR 10-6.130 Controlling Emissions During Episodes of High Air Pollution Potential
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)]
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 10-6.155 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
1) 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 lots; [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
1) 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)]
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Installation ID: 189-0217 Project No, 2005-06-025
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. [10 CSR 10-6.180(1)]
10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants
Emission Limitation:
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)]
Monitoring:
1) The permittee shall conduct opacity readings on each emission unit using the procedures contained
in USEPA Test Method 22. 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 following 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
no violation of this regulation be observed during this period then monitoring reverts to monthly
monitoring.
Recordkeeping:
1) The permittee shall maintain records of all 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 requirement 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.
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Project No. 2005-06-025
Installation ID: 189-0217
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)l.]
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)l.]
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)2.1
c) Compliance test methods specified in the rule cited as the authority for the emission limitations.
[10 CSR 10-6.280(3)(B)3.]
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
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 -burning 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.
[10 CSR 10-5.040(2)(B) and 10 CSR 10-6.020(2)(H)(3)]
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 43
Installation ID: 189-0217 Project No. 2005-06-025
10 CSR 10-5.060 Refuse Not to be Burned in Fuel Burning Installations
(Rescinded on February 11,1979, Contained in State 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)
1) 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.
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.
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Installation ID: 189-0217 Project No. 2005-06-025
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 - Lemay Wastewater Treatment Plant Part 70 Operating Permit 45
Installation ID: 189-0217 Project No. 2005-06-025
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)1.0 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)(!n(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.
b) The permittee shall submit a report of all required monitoring by:
[10 CSR 10-6.065(6)(C)(1)(C)(III)]
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)(110(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
MSD - Lemay Wastewater '1'reat/nent _Plant Part 70 Operating Permit 46
Project No. 2005-06-025
Installation ID: 189-0217
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)(1)]
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)]
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)(1)(C)(III)(c)(III)]
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)(III)(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 10-6.065(6)(C)1.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)1.F Severability 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 10-6.065(6)(C)1.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)]
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)]
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)(II1)]
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
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 47
Installation ID: 189-0217 Project No. 2005-06-025
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.
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)(3)(A)]
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 lst, unless the applicable
requirement specifies more frequent submission. These certifications shall be submitted to EPA
Region WI, 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;
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Installation ID: 189-0217 Project No. 2005-06-025
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)]
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, RSMo 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) An 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)0 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 I modifications, the changes
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 49
Installation ID: 189-0217 Project No. 2005-06-025
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 VII, 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.
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 66219,
describing the changes to be made, the date on which the change will occur, and any changes in
emission and any permit terms 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.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit sa
Project No. 2005-a6-050
Installation ID: 189-0217
10 CSR 10-6.065(6)(E)6 Reopening -Permit for Cause
This permit shall be reopened for cause if:
1) 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
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)LC 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 Neil F. Frankenberg, Operations
Division Manager. 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 name 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 - Lemay Wastewater Treatment Plant Part /o Operating Permit 51
Project No. 2005-06-025
Installation ID: 189-0217
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 1
through 3, 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.
Parameter
Units •
Biosolids Feed Rate
wet tons/hour, for each test run
Biosolids Cake Solids
percent, for each test run
Minimum Biosolids Feed Rate
dry tons/hour, minimum of all test runs
Maximum Biosolids Feed Rate
dry tons/hour, maximum of all test runs
Average Biosolids Feed Rate
dry tons/hour, of all test runs
5-Year Biosolids Feed Rate
average dry tons/hour
(for last 5 years of operation, beginning 3/16/16)
30-day Biosolids Feed Rate
average daily dry tons/hour
(for the previous 30 days prior to test event)
Monthly Biosolids Feed Rate
average dry tons/hour
(for days incinerator is in operation over previous 12 months pnortotest event)
Quarterly Biosolids Feed Rate
highest day/quarter — average dry tons/hour
(Q1= Dec —Feb, Q2 = Mar —May, Q3 =Jun —Aug, Q4 = Se_Nov for same Q tested)
Average Biosolids Feed Rate Percentile
Percentile
(determined from daily feed rate data for last 5 years of operation, beginning
3/16/16)
Mississippi River Stage at St. Louis
feet
(mean on test day, from stream gauge)
Mississippi River Stage at St Louis
feet
(range from highest to Iowest for previous 12 months prior to test event)
Average Daily Flow Into Plant on Test Day
millions gallons per day
Volatile Solids
percent, for each test run
Filterable Particulate Matter
mg/dscm, average of 3 runs
Sulfur Dioxide
ppmvd,average of 3 runs
Oxides of Nitrogen
ppmvd, average of 3 runs
Carbon Monoxide
ppmvd, average of 3 runs
Hydrochloric Acid
ppmvd, average of 3 runs
Cadmium
mg/dscm, average of 3 runs
Lead
mg/dscm, average of 3 runs
Mercury
mg/dscm, average of 3 runs
Beryllium
gr/24-hr period, average of 3 runs
J
Polychlorinated Dibenzo-p-dioxins/Polychlorinated
Dr
ng/dscm TEF, average of 3 runs
Fugitive Emissronl
percent
Afterburner Exit Temp-
degrees Fahrenheit, for each test run
Total Scrubber Water Flow
gallon/minute, for each test run
Total Scrubber Pressure Drop
inches w c., for each test run
Scrubber Water Outlet
pH, for each test 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 - Lemay Wastewater "I reatment rant Part 70 Operating Permit
Installation ID: 189-0217
52
Project No. 2005-06-025
Attachment B - Fugitive Emission Observations
Date
Time
Abnormal Emissions
Cause
Corrective
Action
bide/
Visible
.Emissions
Beyond
Boundary
No Yes
MSD - Lemay Wastewater Treatment Plant Part ?u Operating Permit 53
Installation ID: 189-0217 Project No. 2005-06-025
Attachment C - Opacity Emission Observations
Date
Time
Emission
Source
Visible Emissions
Excess Emissions
No
Yes'
Cause
Correciive Adios
'If there arc visible emissions, the permittee shall complete the excess emissions columns.
1
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
54
Project No. 2005-06-025
Attachment D- Method 9 Opacity Emissions Observations
Method 9 Opacity Emissions Observations
Company
Observer
Location
Observer Certification Date
Date
Emission Unit
Time
Control Device
Hour
Minute
Seconds
Steam Plume (check if applicable)
Comments
0
15
30
45
Attached
Detached
0
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
SUMMARY OF AVERAGE OPACITY
Set Number
Time
Obi
Start
End
Sum
Average
1
Readings ranged from
to % opacity.
Was the emission unit in compliance at the time of evaluation?
YES NO Signature of Observer
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit 55
Installation ID: 189-0217 Project No. 2005-06-025
Attachment E - Solvent Containing Waste Transfer Log
10 CSR 10-5.300 Compliance Demonstration
Date
Amount of Total
Solvent Transferred
(gallons)
Amount of Solvent
Transferred to a
Contract Reclamation
Service (gaffs)
Aunt of Solvent
Transferred to a
Disposal Fly
(gallons)
Amount of
Solvent Distilled
en the Premises
(lam)
MSD - Lernay Wastewater Treatment Plant Part 70 Operating Permit 56
Installation ID: 189-0217 Project No. 2005-06-025
Attachment F - Inspection/MaintenanceiRepair/Malfunction Log
10 CSR 10-5e300 Compliance Demonstration
Date
Equipment/Emission Unit
Activities Performed
MSD - Lemay Wastewater Treatment Plant Part 7U uperatmg Permit 57
Installation ID: 189-0217 Project No. 2005-06-025
Attachment G - Purchase Records for Cold Cleaning Solvent
10 CSR 10-5.300 Compliance Demonstration
Date
Solvent Supplier
Name
Solvent Supplier
Address
Type of Solvent
Solvent Volatility in
nuulig at 20C (6$°F)
MSD - Lemay Wastewater Treatment Plant Part 7U Operating Permit 58
Project No. 2005-06-025
Installation ID: 189-0217
Attachment H - Employee Solvent Metal Cleaning Training Log
10 CSR 10-5.300 Compliance Demonstration
Date
Title of Solvent Metal Cleaning Training Course
Instructor
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
59
Project No. 2005-06-025
Attachment I - Inspection/Maintenance/Repair/Malfunction Log
Emission Unit #
Dateffime
Inspection/
Maintenance
Activities
Malfunction Activities
Malfunction
Impact
Duration
Cause
Action
Initials
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit SB - 1
Installation ID: 189-0217 Project No. 2005-06-025
STATEMENT OF BASIS
INSTALLATION DESCRIPTION
The Metropolitan Saint Louis Sewer District (MSD), Lemay Plant is a sewage treatment installation that
has capacity to treat an average daily flow of 114 million gallons with a peak treatment capacity of 240
million gallons per day (MGD) during high rainfall events. MSD operates three (3) multiple hearth
incinerators, namely Unit Nos. 1 through 3. The three sludge multiple hearth incinerators (11 hearths
each) were installed in 1968. Each Incinerator has its own heat recovery boiler, and combination of
impingement tray scrubber and fixed venturi scrubber. The exhaust from each incinerator and set of
scrubbers is then directed to one exhaust stack.
The sludge that is removed from the wastewater is sent to the sludge well where it is blended with
accumulated solids taken from the grit and primary settling tanks. A polymer is added to the sludge to
help coagulate the solids. The sludge is then sent to six belt presses to the pressroom. The belt presses
are used to remove as much moisture from the sludge as possible prior to incineration.
The ash from the incinerators is made into slurry and sluiced to ash lagoons off -site via two underground
lines. Once the slurry reaches the lagoons, the water is decanted off. Ash is hauled to a landfill
approximately once per year.
Additional equipment on site includes two natural gas emergency generators, sand blaster, and one parts
washer. Along with the heat recovery boilers, there are two natural gas auxiliary boilers that do not have
back-up fuel. Also on site is a 550-gallon diesel underground storage tank (UST) and three 550-gallon
(each) unleaded gasoline USTs.
MSD-Lemay Plant is located in St. Louis County, a nonattainment area for the 8-hour ozone standard
and the PM2.5 standard and an attainment area for all other criteria pollutants. MSD-Lemay Plant emits
major levels of carbon monoxide (CO) and has the Potential to Emit (PTE) major amounts of nitrogen
dioxide (NOx). MSD-Lemay Plant is not on the List of Named Installations found in 10 CSR 10-
6.020(3)(8), Table 2.
Updated Potential to Emit (PTE) for the Installation and
Reported Air Pollutant Emissions, tons per year
PollutantsPo�l
to Emit
Reported Actual Emissions
2016
2015
2014
2013
2012
Particulate Matter
< Ten Microns (PM10)
18.43
3.58
4.31
3.95
3.66
3.47
Particulate Matter
< 2.5 Microns (PM2.5)
13.98
2.63
3.25
2.96
2.76
1.57
Sulfur Oxides
(SOx)
11.39
1.35
1.95
1.87
1.77
1.72
Nitrogen Oxides
(NOx)
146.59
28.77
50.22
48.02
46.32
44.39
Volatile Organic
Compounds (VOC)
57.49
15.68
17.43
16.50
15.91
15.14
MSD - Lemay Wastewater Treatment Plant Part 7U Operating Permit
Installation ID: 189-0217
SB - 2
Project No. 2005-06-025
Pollutants
Potential
to Emit'2016
Reported Actual Emissions
2015
2014
2013
2012
Carbon Monoxide
(CO)
1,171.60
245.98
302.48
289.77
275.00
266.84
Lead (Pb)
0.03
0.00
0.02
0.02
0.02
0.02
Hazardous Air Pollutants
(HAP's)
3.84
0.96
1.23
1.10
1.16
0.99
Ammonia (NH3)
1,179.06
410.31
443.27
377.48
416.87
332.88
Note: 'Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted.
o PTE of the incinerators were based on the federally enforceable limitations found in New Source Permit
Amendment to Permit No. 5768 (Project No. 2017-04-008), Project No. 2017-09-008, Issued October 3, 2017.
• PTE from natural gas -fired generators were evaluated at 500 hours of annual operation.
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 May 26, 2005; revised May 29, 2013;
2) 2014 Emissions Inventory Questionnaire, received April 29, 2015;
3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary
Point and Area Sources, Fifth Edition;
4) New Source Permit Amendment to Permit No. 5768, Project No. 2015-01-042, Issued March 11,
2015 for replacement the existing impingement tray scrubbers and single venturi scrubbers for
incinerators #1 through #3 with combination impingement tray scrubbers and multiple fixed venturi
scrubbers;
5) New Source Permit Amendment to Permit No. 5768, Project No. 2017-04-008, Issued August 21,
2017, for sewage sludge incinerator upgrade project which occurred in 2015-2016; and
6) New Source Review Permit Amendment, Project No. 2017-09-008, Issued October 3, 2017.
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.
40 CFR Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities.
This rule has not been included in the renewal application; however, it has been determined to be
applicable to the installation and, therefore, has been included in this operating permit.
MSD - Lemay Wastewater Treatment Plant Part 7U Operating Permit SB - 3
Installation ID: 189-0217 Project No. 2005-06-025
Other Air Regulations Determined Not to Apply to the Operating Permit
The Air Pollution Control Program (APCP) has determined the following requirements to not be
applicable to this installation at this time for the reasons stated.
1) 10 CSR 10-5.330 Control of Emissions From Industrial Surface Coating Operations.
This rule applies to certain installations from which actual emissions of VOCs from surface coating
operations are greater than 3 tons per twelve (12)-month rolling period. While the maximum
potential VOC emissions from the paint spray booths (EP10) are greater than 3 tons per year, the
actual emissions are a few pounds. Therefore, CSR 10-5.330 is not applicable.
2) 10 CSR 10-5.520 Control of VOC Emissions from Existing Major Sources.
This rule is not applicable to this installation, as it is not a major source of VOC emissions.
3) 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds and
10 CSR 10.6.261 Control of Sulfur Dioxide Emissions.
These rules do not apply to the installation because the combustion equipment at this installation is
fueled exclusively with natural gas and according to 10 CSR 10-6.260(1)(A)2. and 10 CSR
10-6.261(1)(A), 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 burn only natural gas and are exempt
according to 10 CSR 10-6.405(1)(C).
5) 10 CSR 10-5.455 Control of Emission from Solvent Cleanup Operations
This regulation applies to certain solvent cleanup operations at which cleaning solvent VOCs are
emitted at 500 lbs/day or greater. Since the maximum potential VOC emissions from the parts
washer (EP11) is less than 500 lbs/day and cold cleaning is exempted from this rule, 10 CSR 10-
5.455 is not applicable.
Construction Permit History
1) New Source Permit Amendment to Permit No. 5768, Project No. 2015-U 1-042, Issued
March 11, 2015: The permit amendment supersedes individual throughput limits of permit 5769,
establishes a plant wide dry sludge throughput limit, and update the control equipment that is
required to control incinerator emissions.
2) New Source Permit Amendment to Permit No. 5768, Project No. 2017-04-008, Issued
August 21, 2017, for sewage sludge incinerator upgrade project which occurred in 2015-2016. This
is an amendment to a previously issued St. Louis County Construction Permit #5768 for sewage
sludge incineration units 1, 2, and 3 at the MSD Lemay WWTP, originally issued in 1969 and
amended August 3, 1990 and March 11, 2015.
This is the second amendment to permit 5768 for incinerators #1, #2, and #3 related to this scrubber
upgrade project. This amendment performs two functions; supersede and re-establish previous plant
wide dry sludge throughput rate limits, and establish incinerator control device requirements which
incorporate and reference the operating parameter limits contained in 40 CFR Part 60 Subpart
MMMM. A plant -wide sludge throughput limitation is re-established to demonstrate that there is no
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit SB - 4
Installation ID: 189-0217 Project No. 2005-06-025
increase in emissions or debottlenecking associated with the 2015-2016 scrubber upgrade project.
The conditions of this permit supersede the following special conditions from previously issued
permits:
• All special conditions found in the previously issued construction permit amendment to #5768
with corresponding Project No. 2015-01-042 issued by the Saint Louis County Department of
Public Health Air Pollution Control Program on March 11, 2015.
• From Construction Permit 5768 amendment issued August 3, 1990, "One of the three (3)
incinerators must be offline whenever incinerator #4 (OP 5365) is in operation."
3) New Source Review Permit Amendment, Project No. 2017-09-008, Issued October 3, 2017:
This is an amendment to permit 5768 (issued August 31, 2017) to correct the language contained in
Special Condition 2.A. by superseding Special Condition 2 and establishing a new condition which
contains a specified time period for the plant -wide dry sludge throughput limit.
New Source Performance Standards (NSPS) Applicability
10 CSR 10-6.070 New Source Performance Regulations
The installation is potentially subject to several NSPS rules. Below is a summary of the potentially
applicable subparts and the facilities applicability and compliance status to those subparts.
1) 40 CFR Part 60, Subpart A - General Provisions.
The installation becomes subject to Subpart A - General Provisions upon becoming subject to an
NSPS standard. If the installation is subject to various NSPS Standards; therefore, they are also
subject to Subpart A.
2) 40 CFR Part 60 Subpart De - Standards of Performance for Small Industrial -Commercial -
Institutional Steam Generating Units
The provisions of this subpart apply to each fossil -fuel -fired steam generating unit of more than 73
megawatts heat input rate (250 million Btu per hour) constructed or modified after August 17, 1971
and not covered under Subpart Da.
None of the boilers are rated at greater than 73 megawatts heat input rate (250 million Btu per hour),
therefore this subpart does not apply to this installation.
3) 40 CFR Part 60, Subpart Da - Standards of Petformance for Electric Utility Steam Generating Units
for Which Construction is commenced After September 18, 1978.
The provisions of this subpart apply to each electric utility fossil -fuel (either alone or in combination
with any other fuel) fired steam generating unit of more than 73 megawatts heat input rate (250
million Btu per hour) constructed or modified after September 18, 1978.
None of the boilers are electric utility steam generating units as defined in this subpart nor are rated
at greater than 73 megawatts heat input rate (250 million Btu per hour), therefore this subpart does
not apply to this installation.
4) 40 CFR Part 60, Subpart Db - Standards of Performance for Industrial -Commercial -Institutional
Steam Generating Units.
The provisions of this subpart apply to each steam generating unit that commences construction,
modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels
MSD - Lenny Wastewater Treatment Plant kart "/u operating Permit SB - 5
Installation ID: 189-0217 Project No. 2005-06-025
combusted in the steam generating unit of greater than 29 MW (100 million Btu per hour).
None of the boilers are rated at greater than 29 megawatts heat input rate (100 million Btu per hour),
therefore this subpart does not apply to this installation.
5) 40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial -Commercial -
Institutional Steam Generating Units.
Subpart Dc applies to each steam generating unit for which construction, modification, or
reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity
of 29 megawatts (MW) (100 million Btu/hr) or less, but greater than or equal to 2.9 MW (10 million
Btu/hr).
The boilers have heat input capacities of less than 100 MMBtu/hr but greater than 10 MMBtulhr and
constructed in 1980 prior to the applicability date of the Subpart Dc, therefore these boilers are not
subject to the provisions of this subpart.
6) 40 CFR Part 60, Subparts K - Standards of Performance for Storage Vessels for Petroleum Liquids
for Which Construction, Reconstruction Or Modification Commenced After June 11, 1973, and
Prior to May 19, 1978.
40 CFR Part 60, Subpart Ka - Standards of Performance for Storage Vessels for Petroleum Liquids
for Which Construction, Reconstruction Or Modification Commenced After May 19, 1978, and Prior
to July 23, 1984
The installation does not have any petroleum storage vessels as defined in these subparts that are
subject to this regulation.
7) 40 CFR Part 60 - Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction Or
Modification Commenced After July 23, 1984.
The diesel fuel storage and gasoline tanks are not large enough for these regulations to apply.
8) 40 CFR 60 Subpart IIII - Standards of Performance for Stationary. Compression Ignition Internal
Combustion Engines.
This subpart is applicable to owners and operators of stationary compression ignition (CI) internal
combustion engines (ICE) and other persons who construct, reconstruct, or modify an engine after
July 11, 2005. A compression ignition is a type of stationary internal combustion engine that is not a
spark ignition engine.
This subpart is not applicable because the stationary internal combustion engines are spark ignition
engines not compression ignition engines.
9) 40 CFR 60 Subpart JJJJ - Standards of Performance for Spark Ignition Internal Combustion
Engines,
This subpart is applicable to owners and operators of stationary spark ignition (SI) internal
combustion engines (ICE) who construct, reconstruct, or modify an engine after July 12, 2006. A
stationary internal combustion engine is any internal combustion engine, except combustion
turbines, that converts heat energy into mechanical work and is not mobile. Stationary ICE include
reciprocating ICE, rotary ICE, and other ICE, except combustion turbines.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit SB - 6
Installation ID: 189-0217 Project No. 2005-06-025
The installation operates a natural gas fired spark ignition 895 KW internal combustion engine
(emergency generator identified as EP16). The emergency generator was manufactured on October
21, 2008 and construction commenced on June 23, 2008.
As stated in 40 CFR §60.4230(a)(4)(iv) of Subpart JJJJ, the provisions of this subpart are applicable
to owners and operators of emergency engines constructed on or after January 1, 2009. Since the
emergency generator was constructed before the applicability date of this subpart, the provisions of
this subpart are not applicable to the installation.
10) 40 CFR Part 60 Subpart O - Standards of Peifonnance for Sewage Treatment Plants
The provisions of this subpart apply to each incinerator that combusts 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 #1 through
#3 were constructed in 1967, the requirements of this subpart would not apply.
11) 40 CFR Part 60 Subpart MMMM - Emission Guidelines and Compliance Times for Existing Sewage
Sludge Incineration Units.
This subpart applies to the existing incinerators (EP1 — Incinerator 1 -3) and the ash handling system
(EP4).
Maximum Achievable Control Technology (MACT) Applicability
10 CSR 10-6.075 - Maximum Achievable Control Technology Regulations.
Section 112 of the Clean Air Act lists 187 hazardous air pollutants to be regulated by source category.
EPA has identified "source categories" that must meet technology requirements to control HAP
emissions and is required to develop standards for all industries that emit one or more of the HAPs in
significant quantities. The standards are based on emissions levels already achieved by best- performing
similar facilities.
Industries subject to MACT standards are classified as either major sources or area sources.
• Major sources are sources that emit 10 tons per year of any of the listed HAPs, or 25 tons per
year of a mixture of HAPs.
• Area sources are sources that emit less than 10 tons per year of a single HAP or less than 25 tons
per year of a combination of HAPs. Area sources must employ Generally Available Control
Technology (GACT) which is based on appropriate practices/ techniques commercially available
and taking into account economic and technical considerations.
MACT standards are applicable to major sources, while GACT standards are applicable to area sources.
The installation has the potential to emit various HAPs. Based upon a comparison of the installation
operations to each area source MACT/GACT Standard, the installation is potentially subject to the
following MACT/GACT standards: (NOTE: This is not an analysis of every MACT/GACT standard, it
is an analysis of the MACT/GACT standards that are potentially applicable to the installation)
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit SB - 7
Installation ID: 189-0217 Project No. 2005-06-025
1) 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 andlor drying agent. Wipe cleaning activities, such as using a rag
containing halogenated solvent are not covered under the provisions of this subpart.
The maintenance cold cleaner unit does not use halogenated solvents as defined in 40 CFR 63.460,
therefore the parts washer is not subject to the MACT standards for halogenated solvent cleaning.
2) 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.
3) 40 CFR Part 63, Subpart MMMM - National Emission Standards for Hazardous Air Pollutants for
Surface Coating of Miscellaneous Metal Parts and Products.
This rule applies to a facility that owns or operates a miscellaneous metal parts and products surface
coating operation that is a major source, or is located at a major source, or is part of a major source
of HAP emissions. An affected source that uses 946 liters (250 gallons) per year, or more, of
coatings that contain hazardous air pollutants (HAP) could be subject to this rule.
The installation is an area source of HAP emissions and therefore is not subject to this subpart
4) 40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines.
The Subpart ZZZZ standards are applicable to Reciprocating Internal Combustion Engines (RICE)
located at both major andlor area sources of hazardous air pollutants (HAPs) and RICE with a site
rating of less than or equal to 500 brake horsepower (bhp). In addition, the standards for existing
non -emergency compression ignition (CI) engines with a site rating of greater than 500 bhp at major
sources and revised provisions related to Startup, Shutdown, and Malfunction (SSM) events for
engines previously regulated under the rule. Finally, emergency RICE with a rating greater than 500
bhp located at a major source are subject to this rule, but with limited requirements.
o The installation operates natural gas -fired 340 HP emergency generator (EP5) whose operations
are limited to emergency situations. The engine was installed prior to June 12, 2006 and
according to §63.6590(a)(1)(iii) of this subpart, stationary RICE located at an area source of
HAP emissions is existing if commenced construction or reconstruction before June 12, 2006.
The engine is subject to the Work Practice Standards, Maintenance Plan, Monitoring, and
Recordkeeping requirements. Therefore, this subpart applies.
o The natural gas fired spark ignition 895 KW internal combustion engine (emergency generator
identified as EP16) manufactured on October 21, 2008 and construction commenced on June 23,
2008does not have any applicable requirement under this subpart.
5) 40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial. and Institutional Boilers and Process Heaters.
MSD - Lemay Wastewater Treatment Plant Part 70 Uperatmg Permit SB - 8
Installation ID: 189-0217 Project No. 2005-06-025
The 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)..
6) 40 CFR Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities.
The purpose of this subpart is to establish national emission limitations and management practices
for hazardous air pollutants (HAP) emitted from the loading of gasoline storage tanks at gasoline
dispensing facilities (GDF). The affected source to which this subpart applies is each GDF that is
located at an area source.
A gasoline dispensing facility (GDF) is any stationary facility which dispenses gasoline into the fuel
tank of a motor vehicle, motor vehicle engine, nonroad vehicle, or nonroad engine, including a
nonroad vehicle or nonroad engine used solely for competition. These facilities include, but are not
Limited to, facilities that dispense gasoline into on- and off -road, street, or highway motor vehicles,
lawn equipment, boats, test engines, landscaping equipment, generators, pumps, and other gasoline -
fueled engines and equipment.
The installation receives gasoline, stores it in a underground storage tank, and dispenses it into motor
vehicles and/ or nonroad engines. Therefore, the installation is subject to this rule.
7) 40 CFR Part 63, Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants:
Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources
This rule applies to any area sources that engage in any of the following:
• Paint stripping operations that use methylene chloride (MeC1)-containing paint stripping
formulations;
• Spray application of coatings to motor vehicles and mobile equipment; and
a Spray application of coatings to a plastic and/or metal substrate where the coatings contain
compounds of chromium (Cr), lead (Ph), manganese (Mn), nickel (Ni), or cadmium (Cd).
The Lemay WWTP does not use methylene chloride (MeC1) for paint stripping. None of the
materials that MSD uses contain the target HAP. MSD painters use brushes, rollers, and non -
refillable aerosol cans (i.e., spray cans) in the booths. MSD does not perform spray applications of
coatings to motor vehicles or mobile equipment at the Lemay WWTP. When spray applications are
performed at the Lemay WWTP, they are for the purpose of facility maintenance. Spray coating
applications defined as facility maintenance in 40 CFR §63.11180 are not subject to this rule. The
materials that MSD uses in these spray applications are epoxies, urethanes, and paint materials that
do not contain the target HAP. Spray applications have not historically been performed in the
booths. Therefore, the installation is not subject to 40 CFR Part 63, Subpart HHHHHH.
MSD - Lemav Wastewater "treatment Plant Part 70 Operating Permit SB - 9
Installation ID: 189-0217 Project No. 2005-06-025
8) 40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers - Area Sources
This regulation applies to boilers at area source facilities that burn coal, oil, biomass, or non -waste
materials. Boilers burning natural gas as defined in this regulation would not be affected by the rule.
This regulation does not apply to the boilers because the boilers are natural gas fired boilers. The
rule exempts natural gas fired boilers with fuel oil as back-up fuel. According to this rule, gas -fired
boiler includes any boiler that burns gaseous fuels not combined with any solid fuels, bums liquid
fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing on liquid
fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any
calendar year.
National Enalss cn Standards for IHiazardous Air Pollutants (NESHAP) Appl$czbillty
National Emission Standards for Hazardous Air Pollutants (NESHAPS) are stationary source standards
for hazardous air pollutants. NESHAPS were originally required by the 1970 Clean Air Act (CAA).
These standards were developed for sources and source categories that were determined to pose adverse
risk to human health by the emission of HAPs. The Part 61 NESHAPs regulate only 7 hazardous air
pollutants - Asbestos, Beryllium, Mercury, Vinyl Chloride, Benzene, Arsenic, Radon/Radionuclides.
Prior to 1990, the Clean Air Act required EPA to set standards for each toxic air pollutant individually,
based on its particular health risks. Thus, NESHAPs are risk based standards that apply to all existing
and new/ modified sources regardless if they are a minor or major HAP Facility. (NOTE: This is not an
analysis of every NESHAP standard; it is an analysis of the NESHAP standard that is potentially
applicable to the installation).
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 three
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 has three
incinerators which burn dry wastewater treatment plant sludge, therefore the incinerators are subject
to the NESHAP standard for mercury.
Permit Condition EP1-004 specifies a more stringent mercury limit of 0.28 mg per dry standard
cubic meter pursuant to NSPS Subpart MMMM (Table 3). Complying with the more stringent
requirement of Permit Condition EP1-004 would also be in compliance with 40 CFR Part 61,
Subpart E, therefore 40 CFR Part 61, Subpart E is not included in this permit.
3) 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
MSD - Lemay Wastewater Treatment Plant Part "7u Operating Permit SB - 10
Installation ID: 189-0217 Project No. 2005-06-025
installation conducts any demolition or renovation projects to a buildings) containing asbestos, they
must determine applicability with the following NESHAP regulations:
• Demolition and Renovation - 40 CFR 61.145
• 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
• Uses a control device to achieve compliance, and
• Has pre -control emissions that exceed or are equivalent to the major source threshold.
The Incinerators are the only emission units that have pre -control PM emissions above the major source
threshold. Since these units are subject to 40 CFR Part 60, Subpart MMMM standards and units that are
subject to 111 or 112 standards promulgated after 11/15/90 are excluded from CAM, therefore the
incinerators are not subject to CAM.
Greenhouse Gas Emissions
Potential emissions of greenhouse gases (CO2e) for this installation are calculated to be 15,604.46 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 CO2e
emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2e
emissions were not included within this permit.
Other Regulatory Determinations
1) Incinerator #4 is taken out of service before the compliance date of 40 CFR Part 60 Subpart
MMMM, Emission Guidelines and Compliance Times for Existing Sewage Sludge Incineration
Units.
2) 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants
This rule applies to all particulate emitting sources listed in the emission units with limitations
except the generators and emission units listed in emission units without limitations, i.e., equipment
that does not have unit specific limitations at the time of permit issuance.
At the time of issuance of this permit, the installation had already completed its weekly and bi-
weekly observations, as required by the initial operating permit OP2000-108 conditions. The
installation is currently conducting monthly observations as required by the previously mentioned
permit condition.
The installation had performed the initial weekly/biweekly observations and has been performing
monthly monitoring; therefore it will be required to continue visible emissions observation on a
monthly basis unless a violation occurs. If a violation occurs, the monitoring frequency will revert
to a weekly schedule. This tiered monitoring frequency of visible/no visible emissions observations
using Method 22 like procedures is considered sufficient.
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit
Installation ID: 189-0217
SB-11
Project No. 2005-06-025
3) 10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes
10 CSR 10-6.400 limits the amount of particulate matter that is allowed from an emission unit, and
is dependent on the process weight rate of the material processed. The emission units to which this
rule applies are listed below. The following calculations provide the allowable particulate emission
rate based on 10 CSR 10-6.400 and the potential (maximum) emission rate including particulate
emission control equipment. Potentials to emit presented below were calculated based on sources
Maximum Design Rate (MDR). If the emissions from these emission units can not violate the limits
of this rule then evidence of this is demonstrated in the following calculations.
One of the following equations from 10 CSR 10-6.400 is used to calculate the PM allowable limit:
E = 4.10P°'67 for process weight rates up to 30 tons (60,000 lbs) per hour, and
E = 55.OP°'11— 40 for process weight rates greater than 30 tons (60,000 lbs) per hour
Where: E = rate of emission in lb/hr; and
P = process weight rate in tons/hr (maximum hourly design rate)
a) EPO4 — Wet Ash Conveying with Venturi/Impingement Scrubber
Process Weight rate (P) = 4.16 ton/hr
Baghouse Efficiency = 94%
Emission Limit (lb/hr) = 4.1 P°.67 = 4.1 x 4.160 = 10.66 lb PM/hr
Emission Factor (controlled) = 4.80E-01 lb.rton (2014 EIQ)(Fire - SCC 30500717)
PM Emission Controlled (lb/hr) = 0.48 lb x 4.16 ton = 2 00 lb
ton hr hr
This emission unit uses the same stack as the incinerators. Since the incinerators' PM emissions
are continuously monitored, no monitoring, record keeping or reporting is required for this
emission unit.
b) EP 12 - Sand Blaster with Dust Collector
Process Weight Rate (P) = 1.4 lb solid/min
[1.4 lb/min x 60 min/hr x l ton/2000 lb] = 0.042 ton/hr
Recycle Efficiency = 90%
Control Efficiency = 99.2%
Emission Limit (lb/hr) = 4.1P0•67 = 4.1 x 0.042'67 0.49 lb PM/hr
PM Emission Controlled (lb.ihr) = 0.042 t x (1— 0.9) x (1— 0.99) = 0.084 lb
hr
The particulate matter potential emissions from the operation of the sand blaster is 0.084 lb/hr.
Since this unit potentially emit less than one-half (0.5) pounds of particulate matter per hour it is
exempt from the requirements of this rule. [10 CSR 10-6.400(1)(B)12.].
c) Because 10 CSR 10-6.070 (ASPS, Subpart MMMM) applies to the incinerators (EP1), 10 CSR
10-6.400 does not apply to the incinerators (EP1).
d) The two paint spray booths (EP10) are equipped with control systems with particulate matter
control efficiencies of 99%. According to 10 CSR 10-6.400(1)(B)14, the provisions of 10 CSR
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Permit SB - 12
Installation ID: 189-0217 Project No. 2005-06-025
10-6.400 shall not apply to coating operations equipped with a control system designed to
control at least ninety-five percent (95%) of the particulate overspray.
4) 10 CSR 10-5.080, Incinerators.
a) 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, it is not included in the
operating permit because the particulate matter standard of this rule, 0.3 grains of particulate
matter per standard cubic feet of exhaust gas is less stringent than the NSPS Subpart MMMM
standards of 80 milligrams of particulate matter per cubic meter (0.03 grains per cubic meter).
Compliance with the construction permit and the NSPS Subpart MMMM will ensure compliance
with this rule.
b) In the permit application, the burning of natural gas in the incinerator afterburners was presented
as an alternate operating scenario; however, according to the DNR's Operating Permit
Application Instructions, based on the EPA definition of "alternate operating scenarios", they are
only needed if different modes of operation would change the method of documenting
compliance. Since there would be no changes in the method of demonstrating compliance for
these emission units due to the above scenario, it is not listed under Reasonably Anticipated
Operating Scenarios. Also, the installation will not need to notify the St. Louis County
Department of Health (SLCDOH) when the afterburners' fuel is changed to pipeline natural gas.
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).
MSD - Lemay Wastewater Treatment Plant Part 70 Operating Perrnit RPC - 1
Installation ID: 189-0217 Project No. 2005-06-025
Response to Public Comments
The draft Part 70 Operating Permit for MSD - Lemay Wastewater Treatment Plant was placed on public
notice as of November 17, 2017 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.tno.gov/env/apcp/permit-public-notices.htm on Friday, November 17, 2017. The Air Pollution
Control Program did not receive any public comments during the 30-day comment period.
_IG-11`Z%%21Missouri Department of
C iC i
44
dnr.mo.gov
NATURAL RESOURCES
Eric R. Greitens, Governor Carol S. Comer, Director
JAN 2 9 Zulu
Mr. Neil F. Frankenberg
MSD - Lemay Wastewater Treatment Plant
201 Hoffineister Avenue
St. Louis, MO 63125
Re: Part 70 Operating Permit
Installation ID: 189-0217, Permit Number: OP2018-007
Dear Mr. Frankenberg:
Enclosed with this letter 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 bow 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 itttp://dnr mo.gov/regions/. The online CAV request can be
found at littpil/dnr.mo.gov/cav/coanpliance.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 621.2503. 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 CODITROICPROCGRAM
Michael J. Stansfield, P.E.
Operating Permit Unit Chief
MJS:bgj
Enclosures
c: PAMS File: 2005-06-025
ta)
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