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Home My Public Portal AboutExhibit MSD 84L7 - Federal Clean Air Act Emissions - Bissell Point PlantN{'_ Coy(f u: L~ DEC 3 0 2002 ·-: ... : -" - Bob Holden, Governor • Stephen i\-L Mahfood, Direcwr WW"W.dnr.state.mo.us DEC 2 6 2002 Mr. Jeffrey L. Theerman Assistant Director of Waste Water Metropolitan St. Louis Sewer District 1900 Sulphur Avenue St. Louis, MO 63110 Re: MSD -Bissell Point Plant St. Louis, MO 63147, City of St. Louis Permit Number: OP 2 0 0 2. -0 77 Dear Mr. Theerman: Enclosed with this letter is your 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. If you have any questions or need additional information regarding this permit, please contact Berhanu Getahun of the Air Pollution Control Program at (573) 751-4817, or you may write to the Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102. Sincerely, POLLUr;r;;;:::::_ Pamela S. Muren, P.E. Operating Permits Unit Chief PSM: bgd Enclosures c: Harriett Jones, EPA Region VII City of St. Louis, Air Pollution Control Program PAMS File: 1997-05-008 Integrity and excellence in all we do c. llECVCU:D P.o.PER ~---------------~~ -------- Exhibit MSD 84L7 STATE OF ,.MISSciURJ Bob Holden. Governor • Stephen M. Mahfood, Director DEPARTMENT OF NATURAL RESOURCES ,;-"~;~t3:;~~~h . www.dnr.state.mo.us ' . ' PERMIT TO OPERATE Under the authority ofRSMo 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 here in. Operating Permit Number: Expiration Date: Installation ID Project Number: Installation Name and Address MSD -Bissell Point Plant I 0 East Grand A venue StLouis, MO 63147 City of St Louis OP 2 0 0 2-0 7 7 DEC 2 3 'lfiJ! 510-0053 1997-05-008 Parent Company's Name and Address Metropolitan St Louis Sewer District 1900 Sulphur Avenue St. Louis, MO 63110 Installation Description: The Bissell Point Plant treats wastewater and sewage from the St. Louis area. The plant incinerates the sludge produced during the treatment process. The installation is located in an ozone non-attainment area and is a major source for nitrogen oxides and carbon monoxide. EffectiTeDate 1 DireCtor nes;gi;e Department ofNatural Resources Integrity and excellence in all we do 0 REcYClED PAPfR MSD -Bissell Point Plant Installation ID: 510-0053 Table of Contents 2 Project No. 1997-05-008 I. INSTALLATION DESCRIPTION AND EQillPMENT LISTING •••••••••••••••••••••••••••••••••••••••••••••••••••••• 4 INSTALLATION DESCRIPTION ................................................................................................. 4 EMISSION UNITS WITH LIMITATIONS ...................................................................................... 4 EMISSION UNITS WITHOUT LIMITATIONS ................................................................................ 5 DOCUMENTS INCORPORATED BY REFERENCE ......................................................................... 5 II. PLAN"T WIDE EMISSION LIMITATIONS •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••6 Permit Condition PWOO 1 ..................................................................................................................................... 6 10 CSR 10-6.170 ..................................................................................................................................... 6 Permit Condition PW002 ..................................................................................................................................... 7 10 CSR 10-6.220 ..................................................................................................................................... 7 St. Louis City Ordinance 64749, §16 ........................................................................................................ 7 Permit Condition PW003 ..................................................................................................................................... 8 10 CSR 10-5.443 ..................................................................................................................................... 8 III. El\1ISSION UNIT SPECIFIC EMISSION Lll\1ITATIONS ••.•••••••••...••••••..•.•••••.••••••.••••••••.•••••••••••••• 9 EUOO 10 through EU0060 ............................................................................................................. 9 Permit Condition EUOO 10-001 through EU0060-00 1 ......................................................................................... 9 10 CSR 10-6.060 ..................................................................................................................................... 9 Permit #95-05-068 ................................................................................................................................... 9 Permit Condition EUOO 10-002 through EU0060-002 ....................................................................................... 1 0 10 CSR 10-6.080 ................................................................................................................................... 10 40 CFR Part 61 Subpart C ..................................................................................................................... 10 10 CSR 1 0-6.060; Permit #95-05-068 .................................................................................................... 10 Permit Condition EU0010-003 through EU0060-003 ....................................................................................... 11 10 CSR 10-6.080 ................................................................................................................................... 11 40 CFR Part 61 Subpart E ..................................................................................................................... 11 10 CSR 10-6.060; Permit #95-05-068 .................................................................................................... 11 Permit Condition EUOO 10-004 through EU0060-004 ....................................................................................... 12 10 CSR 10-6.060; Permit #95-05-068 .................................................................................................... 12 Permit Condition EUOO 10-005 through EU0060-005 ....................................................................................... 13 10 CSR 10-6.260 ................................................................................................................................... 13 Permit Condition EU0060-006 .......................................................................................................................... 14 10 CSR 10-6.070 ................................................................................................................................... 14 40 CFR Part 60 Subpart 0 ..................................................................................................................... 14 Permit Condition EUOO 10-007 through EU0060-007 ....................................................................................... 16 10 CSR 10-5.510 ................................................................................................................................... 16 EU0070 ................................................................................................................................. 17 Permit Condition EU0070-001 ................. , ........................................................................................................ 17 10 CSR 10-6.400 ............................... : ................................................................................................... 17 EU0080 ................................................................................................................................. 18 Permit Condition EU0080-001 .......................................................................................................................... 18 10 CSR 10-6.400 ................................................................................................................................... 18 EU0090 ................................................................................................................................. 19 Permit Condition EU0090-00 1 .......................................................................................................................... 19 10 CSR 10-6.260 ................................................................................................................................... 19 EU00100 through EU0120 ......................................................................................................... 20 Permit Condition EU0100-001 through EU0120-001 ...................................................................................... .20 10 CSR 10-6.060; Permit #94-05-029A .................................................................................................. 20 Permit Condition EU0100-002 through EU0120-002 ....................................................................................... 20 10 CSR 10-6.070 ................................................................................................................................... 20 40 CFR Part 60 Subpart De ................................................................................................................... 20 EU00130 ............................................................................................................................... 21 Permit Condition EU0130-001 .......................................................................................................................... 21 -~--------~· -·~--~-----·-------------------·-------· , ___ , ___ ,_ ----------------· MSD -Bissell Point Plant Installation ID: 510-0053 3 Project No. 1997-05-008 10 CSR 10-6.060; Pennit #95-05-69 ...............................•................................................•..................... 21 EU00140 ............................................................................................................................... 22 Permit Condition EUO 140-001 .......................................................................................................................... 22 10 CSR 10-5.300 ............................................•................................••.................................................... 22 EU00150 through EUO 180 ......................................................................................................... 24 Permit ConditionEU0150-001 throughEU0!80 .............................................................................................. .24 10 CSR 10-6.060: Pennit #94-05-029A ...................................................•.............................................• 24 EUOOI90 ............................................................................................................................... 25 Permit Condition EU0!90-001 .......................................................................................................................... 25 10 CSR 10-5.220 ······································································'···························································· 25 IV. CORE PERI\11T REQUIREMENTS ••••••...•••••••••..•••••.••••••••••••••••••••••••••••.••••••••.••••••••••••••••• 26 v. GENERAL PE~T REQUIREJ.\IENTS .•.•.•...•.•.•.•••.•..•..•..•..•.•••...•.•.••••......•.•••..••.•..•••.•...•.. 31 PERMIT DURATION .••••.•••.•.•.•••••.•••••.••.•••••.••.•.••...•••..•••.....•••.•••.•••...••.•••.••.•••..••••.••.•••••.•••••..••.•••. 31 GENERAL RECORD KEEPING AND REPORTING REQUIREMENTS .•.••••••.••••.•••••••.•••.•..•.•••••••.•.••••••••••.••.••.•• 31 RISK MANAGEMENT PLANS UNDER SECTION 1!2(R) .•.••.•.•.•••..••..•••••..••••••.•••••.•.•..•.••••.••...••.•••.•.•••..••• 32 SEVERABILITY CLAUSE ....••••••.•.••..•.•.••••.•••..••......•.••..•••.•.•••.••.•..••••...••...••••..•.•.••••....••••••.•..•...••••. 32 GENERAL REQUIREMENTS ..•..•••••••..•••••.•••..•••.••••.•.•••.•.....•.•.•..•....•.••••••..••••.•••....••.••.•••••.•••...•••••... 32 INCENTIVE PROGRAMS NOT REQUIRING PERMIT REVISIONS •••.••••..••.••.•••••..••••••.•••.••..••••••..•••••.•...•.•..... 32 REASONABLY ANTICIPATED OPERATING SCENARIOS •.••••.•.••..••..•...•..••••..••.••••••.•.••••••.••••••••••.•••••••••••.. 32 TITLE IV ALLOWANCES ....••.•••••..•.••.•.......•••.•••....•••.•....•.•.....••.••..•••••••.•.••.•.•......•••••....•••••...•.••.... 32 EMISSIONS TRADING ..•..•••..•.•..••••.•....••..••••.•....••.•.•..•••..••....••..•.•••.•..•.•..••.•..•••..••.•••••••••..••••••..•..• 33 COMPLIANCE REQUIREMEms •••.•..••••••..•••.•••.•••...••••.••..•..•..•••.•.•..••••••.••••••.•.•..•••.••••......•••....•......• 33 PERMIT SHIELD .•..•••.••....••.••.....•..•••.••...••••..•......•..••...•••...•..•••...•.••••••...•••........•.•.••.•..••.•.....••••... 33 EMERGENCY PROVISIONS •..•.....••..••.•.....•••.••...•••.••••.....•..•..•••.•...•.•••..•.•••••.•.•..••..•••••.•..•.•••..•••.•.... 34 OPERATIONAL FLEXIBILITY .•......••••.•.•••..••••.•....••.•...•..••.•.•..•••.•.•.•••••••.•.••••.•.•.•.••.•••.••••.•••••.•.•••••.. 34 OFF-PERMIT CHANGES ...•.••.••.•....••.•..•..•.•.••..••...•••••.••....•...••.•.•.•••••••••.••••••.••.••••••••.••••..•••....•••.... 34 RESPONSIBLE OFFICIAL ..••••••...••••.•••.•••...•••.••..••..•.•.•....••••....•.•.••••.••••••...••.•.•...••.••••••.•••.••••..••••... 35 REOPENING PERMIT FOR CAUSE •.•..•••..•..•...•••.••••....•••••..••.•.••...•.••.••••••••••....•...••..•••.••......•..••....•..•. 35 STATEMENT OF BASIS .•.•••••.•.•.•••••••.•.•••..••••.•..••••...•...••..•....•••••..••.•••••..•••••...•..•••......••••...•.••.•...... 35 Attachment A. ...............•............................•......••..........•.........................................................•.............. 36 Attachment B ..............................................•.•.........•..............................•.........................•.................... 37 Attachment C ...........................................................................................•.........•.................................. 38 Attachment D .......................................................................................•..................................•............. 39 Attachment E .................................•.............••.................•......................•..........•........•..•....................... 40 Attachment F •..........................•.........................................................••..................................•............... 41 Attachment G ........................................................................................................................................ 42 Attachment H ....................................................•...................................•.....................•......................... 43 Attachment!. .......................................................................................•.................................•.... ; .......... 44 MSD -Bissell Point Plant Installation ID: 510-0053 I. Installation Description and Equipment Listing INSTALLATION DESCRIPTION 4 Project No. 1997-05-008 The Bissell Point Plant treats wastewater and sewage from the St. Louis area. They incinerate the sludge which is produced during the treatment process. The installation is located in an ozone non-attainment area and is a major source for nitrogen oxides and carbon monoxide. The actual emissions for the past five (5) years for the installation are listed below: Reported Air Pollutant Emissions, tons per year Particulate Matter Nitrogen Volatile Organic Carbon Hazardous · ::; Ten Microns Sulfur Oxides Oxides Compounds Monoxide Lead Air Pollutants Year (PMw) (SOx) (N0x) (VOC) (CO) (Pb) (HAPsl_ 1996 30.04 4.50 105.22 49.99 541.81 0.20 10.73 1997 24.96 3.75 87.!3 44.68 555.05 0.!8 9.48 1998 32.66 4.65 109.02 54.38 757.21 0.27 8.60 1999 26.16 4.08 98.11 53.00 567.80 0.19 1.18 2000 31.43 92.78 104.16 70.72 442.70 0.21 3.26 EMISSION UNITS WITH LIMITATIONS The following list provides a description of the equipment at this installation which emit air pollutants and which are identified as having unit-specific emission limitations. Emission Unit# EUOOlO EU0020 EU0030 EU0040 EUOOSO EU0060 EU0070 EU0080 EU0090 EUOlOO EUOllO EU0120 EU0130 EU0140 EU0150 EU0160 EU0170 EU0180 EU0190 Description of Emission Unit Incinerator # 1 Incinerator #2 Incinerator #3 Incinerator #4 Incinerator #5 Incinerator #6 Dry Incinerator Ash Storage Wet Ash Conveying Diesel Emergency Generator Sludge Building Boiler #1 Sludge Building Boiler #2 Sludge Building Boiler #3 Biofilter Parts Washer Pump Station Boilers (2) Primary Control Building Boiler Two Administration Building Boilers (2) Trickling Filter Pump Station Boiler 1000 Gallon Underground Gasoline Storage Tank MSD -Bissell Point Plant Installation ID: 510-0053 EMISSION UNITS WITHOUT LIMITATIONS 5 Project No. 1997-05-008 The following list provides a description of the equipment that does not have unit specific limitations at the time of permit issuance. Description of Emission Source Six (6) Grit Removal Tanks-Primary Treatment Seven (7) Grinders -Primary Treatment Eight (8) Primary Settling Tanks Two (2) Sludge Holding Tanks Two (2) Ash Settling Basins One (I) Trickling Pump Station Influent Pump Station Effluent Pump Station Six ( 6) Trickling Filters Six (6) Aeration Tanks Twelve (12) Final Clarifiers Sand Blaster Small Parts Spray Booth Natural Gas Fired Sludge Building Boiler 4, 0.65 MMBtu/hr Four (4) Natural Gas Fired Water Heaters, 0.75 MMBtu!hr (total) Four (4) Natural Gas Direct Fired Heaters, 0.85 MMBtu/hr (each) DOCUMENTS INCORPORATED BY REFERENCE These documents have been incorporated by reference into this permit. I) St. Louis City Construction Permit #94-05-029A 2) St. Louis City Construction Permit #95-05-068 3) St. Louis City Construction Permit #95-05-069 ~--.--- MSD -Bissell Point Plant Installation ID: 510-0053 II. Plant Wide Emission Limitations 6 Project No. 1997-05-008 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. Permit Condition PWOOl 10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin Emission Limitation: 1) The pennittee 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 or 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. 2) The pennittee 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. 3) Should it be determined that noncompliance has occurred, the director may require reasonable control measures as may be necessary. Monitoring: 1) The permittee shall conduct inspections of its facilities sufficient to determine compliance with this regulation. If a violation of this regulation is discovered, the source shall undertake corrective action to eliminate the violation. The following monitoring schedule must be maintained: a) Weekly observations shall be conducted for a minimum of eight (8) consecutive weeks after penni! issuance. Should no violation of this regulation be observed during this period then- b) Observations must be made once every two (2) weeks for a period of eight (8) weeks. If a violation is noted, monitoring reverts to weekly. Should no violation of this regulation be observed during this period then- c) Observations must be made once per month. If a violation is noted, monitoring reverts to weekly. 2) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an identical manner to the initial monitoring frequency. Record Keeping: I) A log must be maintained noting the following: a) Whether air emissions (except water vapor) remain visible in the ambient air beyond the property line of origin. b) Whether the visible emissions were normal for the installation. c) Equipment malfunctions that could cause an exceedance of 10 CSR 10-6.170. d) Any violations of 10 CSR 10-6.170 and any cbrrective actions undertaken to correct the violation. 2) Attachment A contains a log including these record keeping requirements. This log, or an equivalent created by the permittee, must be used to certify compliance with this requirement. Reporting: . The pennittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to Air Pollution Control Program (APCP), 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. MSD -Bissell Point Plant Installation ID: 510-0053 10 CSR 10-6.220 St. Louis City Ordinance 64749, §16 Permit Condition PW002 Restriction of Emission of Visible Air Contaminants Emission Limitation: 7 Project No. 1997-05-008 No person shall discharge into the atmosphere from any source of emission any air contaminant greater than 20% visible opacity for a period in excess of six (6) minutes in any consecutive sixty (60) minute period. Any emissions in excess of 40% opacity, regardless of time, are considered excessive emissions. Monitoring: 1) The permittee shall conduct opacity readings on the emission units using the procedures contained in USEPA Test Method 22. Readings are only required when the emission unit(s) is operating and when the weather conditions allow. lf no visible or other significant emissions are observed using these procedures, then no further observations would be required. For emission units with visible emissions perceived or believed to exceed the applicable opacity standard, the source representative would then conduct a Method 9 observation. 2) The following monitoring schedule must be maintained: a) Weeldy observations shall be conducted for a minimum of eight (8) consecutive weeks after permit issuance. Should no violation of this regulation be observed during this period then- b) Observations must be made once every two (2) weeks for a period of eight (8) weeks. If a violation is noted, monitoring reverts to weekly. Should no violation of this regulation be observed during this period then- c) Observations must be made once per month. lf a violation is noted, monitoring reverts to weekly. 3) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an identical manner from the initial monitoring frequency. Record Keeping: 1) The permittee shall maintain records of all observation results (see Attachment B & C), 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, and c) Whether the visible emissions were normal for the process. 2) The permittee shall maintain records of any equipment malfunctions. 3) The permittee shall maintain records of any Method 9 test performed in accordance with this permit condition (see Attachment D). Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and the APCP, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than ten (10) days after any exceedance of the opacity limit established by this regulation, or any malfunction which causes an opacity exceedance. MSD-Bissell Point Plant Installation ID: 510-0053 10 CSR 10-5.443 Permit Condition PW003 Control of Gasoline Reid Vapor Pressure Emission Limitation 8 Project No. 1997-05-008 The Reid Vapor Pressure (RVP) of gasoline used during the period of June 1 to September 15 shall be limited to seven pound per square inch (7.0 psi) or less. Gasoline blends having at least nine percent (9%) but not more than ten percent (10%) ethyl alcohol by volume of the blended mixture shall have an RVP limit of one pound per square inch (1.0 psi) higher. Monitoring/Record Keeping I) Each bill oflading. invoice, lading ticket, delivery ticket, and other document which accompanies a shipment of gasoline shall contain a legible and conspicuous statement that the RVP of the gasoline does not exceed the above mentioned limits or is reformulated gasoline as specified in 10 CSR 10-5.443(8)(E). 2) Each bill oflading, invoice, lading ticket, delivery ticket, and other document which accompanies a shipment of gasoline containing ethyl alcohol shall contain a legible and conspicuous statement that the gasoline being shipped contains ethyl alcohol and the percentage concentration of ethyl alcohol is between nine percent to ten percent (9% to 10%). 3) All persons subject to this rule must retain all record of the bill of lading, invoice, loading ticket, delivery ticket, and other documents accompanying a shipment of gasoline during the compliance period for a period of at least two (2) years from the date of delivery. 4) These records shall be made available immediately for inspection to the Department of Natural Resources' personnel upon request. 5) All records shall be maintained for a period of five (5) years. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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. MSD -Bissell Point Plant Installation ID: 510-0053 III. Emission Unit Specific Emission Limitations 9 Project No. 1997-05-008 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. EUOOlO through EU0060 Incinerators # 1-#6 General Description: Incinerators #1-#6 with venturi and impingement trav scrubbers Manufacturer/Model #: Nichols Hershoff, 22' 3" II Hearths EIQ Reference # (Year): EP#2, 3, 4, 5, 6, & 7 (2000) Permit Condition EUOOI0-001 through EU0060-001 10 CSR 10-6.060 Construction Permits Required Permit #95-05-068. Emission Limitation: !) No more than an average of 68.88 tons per day of dry solid sludge shall be charged to these incinerators. However, no more than an average, on an annual basis of203.75 tons per day of combined dry sewage sludge into the six (6) incinerators at the Bissell Point Waste Water Treatment Plant. Therefore, the amount of combined sewage sludge that may be burned at this installation shall not be more than 74,369 tons per year. 2) The particulate emission rate shall not exceed 1.3 pounds per ton of dry sludge input. 3) No incinerator shall be charged at a rate greater than the sludge rate as determined by the performance test. 4) The system shall be operated in such a manner that the emission from any stack will not exceed twenty percent (20%) opacity for a period in excess of six (6) minutes in any consecutive sixty (60) minute period. 5) The sewage Sludge Incinerators must be operated within the combustion temperature range of the performance test which demonstrated compliance for the incinerator design for each of the regulated pollutants, the determination of the maximum temperature limit shall be on the same basis as the maximum temperature requirement of 40 CFR 503.45. 6) The incinerators shall be operated in accordance with the plans and specifications as submitted and with the manufacturers operating manual and guidance. Monitoring: 1) An initial performance test according to applicable parts of Section V of the construction permit was required and performed. 2) The incinerator must be retested at least every six (6) years to meet the most stringent performance requirements in effect at the time of retesting. Pretest forms stating !~sting methods and dates shall be completed and approved prior to testing. 3) A continuous operation of the following monitors shall be required and monitoring data shall be recorded during operation of the incinerators. The monitoring systems shall be maintained, calibrated and certified within an accuracy of(±) five percent (5%) over its operating range. a) Sewage sludge flow monitors and weighing scales; b) Pressure drop of the gas flow through the scrubber; c) Fuel flow monitoring device; and d) Combustion temperature monitoring device for incinerators as required by 40 CFR 503.45(d). 4) A daily grab sample of the sludge fed to the incinerators shall be collected and analyzed for dry sludge content and volatile solids content. 5) The permittee shall conduct opacity measurements and keep records on the emission units as described in the Monitoring and Record Keeping section of PW002 Record Keeping: Accurate records shall be maintained for these incinerators upon the premises. These records include: MSD -Bissell Point Plant Installation ID: 510-0053 I) The mass of total solids fed to the incinerators; 2) The monitored moisture content of stack exit gas; 3) Copies of the most recent stack tests; 10 Project No. 1997-05-008 4) The measured pressure drop of the gas flow through the wet scrubbers in the incinerators; 5) The temperature profile of the incinerators; 6) The fuel flow to the incinerators; and 7) The total solids and volatile solids content of the sludge fed to the incinerators. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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 permit condition. Permit Condition EUOOl0-002 through EU0060-002 I 0 CSR I 0-6.080 Emission Standards for Hazardous Air Pollutants 40 CFR Part 61 Subpart C National Emission Standard for Beryllium 10 CSR 10-6.060 Construction Permits Required Permit #95-05-068 Emission Limitation: The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart C for any activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart C, National Emission Standard for Beryllium. Emissions to the atmosphere from stationary sources shall not exceed 10 grams of beryllium over a 24-hour period. [40 CFR 61.32(a)] Monitoring: All incinerators must be retested at least every six ( 6) years to meet the most stringent performance requirements of any Federal, State, or Local regulation in effect at the time of retesting. Record Keeping: Record of emission test results and/or other data needed to determine total emissions shall be retained at the source and shall be made available for inspection for a minimum of six ( 6) years. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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, or any malfunction which could possibly cause an exceedance of this regulation. MSD -Bissell Point Plant Installation ID: 510-0053 11 Project No. 1997-05-008 Permit Condition EUOOl0-003 through EU0060-003 10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants 40 CFR Part 61 Subpart E National Emission Standard for Mercury 10 CSR 10-6.060 Construction Permits Required Permit #95-05-068 Emission Limitation: The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart E for any activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart E, National Emission Standard for Mercury. The combined mercury (Hg) emissions from all incinerators shall not exceed 3200 grams over a 24-hour period. [Permit #95-05-068, Section II G.] Monitoring: All incinerators must be retested at least every six (6) years to meet the most stringent performance requirements of any Federal, State, or Local regulation in effect at the time of retesting. [Permit #95-05-068, Section III G.] Record Keeping: Record of emission test results and/or other data needed to determine total emissions shall be retained at the source and shall be made available for inspection for a minimum of six ( 6) years. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP 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, or any malfunction which could possibly cause an exceedance of this regulation. MSD -Bissell Point Plant Installation ID: 510-0053 12 Project No. 1997-05-008 Permit Condition EUOOl0-004 through EU0060-004 10 CSR 10-6.060 Construction Permits Required Permit #95-05-068 Emission Limitation: The total hydrocarbon (THC) emission rate shall not exceed one hundred parts per million by volume (100 ppmv) based on a monthly average and corrected for zero percent (0%) moisture and seven percent (7%) oxygen when using the instrument required by 40 CFR Part 503.45. [Permit #95-05-068, Section II F.] Monitoring: I) An instrument that measures and records the total hydrocarbons concentration in the sewage sludge incinerator stack exit gas continuously shall be installed, calibrated, operated, and maintained for each sewage sludge incinerator, as specified by the permitting authority. [40 CFR 503.45(a)(1)] 2) The THC instrument shall employ a flame ionization detector; shall have a heated sampling line maintained at a temperature of 150 degrees Celsius or higher at all times; and shall be calibrated at least once every 24-hour operating period using propane. [40 CFR 503.45(a)(2)] 3) An instrument that measures and records the oxygen concentration in the sewage sludge incinerator stack exit gas continuously shall be installed, calibrated, operated, and maintained for each sewage sludge incinerator. [40 CFR 503.45(b)] 4) An instrument that measures and records information used to determine the moisture content in the sewage sludge incinerator stack exit gas continuously shall be installed, calibrated, operated, and maintained for each sewage sludge incinerator. [40 CFR 503.45(c)] Record Keeping: 1) The measured THC for stack exist gases. [Permit #95-05-068, Section VI A.9.] 2) The measured oxygen content of the exhaust gases from the incinerators. [Permit #95-05-068, Section VI A.2.] Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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 permit condition, or any malfunction which could possibly cause an exceedance of this permit condition. MSD -Bissell Point Plant Installation ID: 510-0053 13 Project No. 1997-05-008 Permit Condition EUOOI0-005 through EU0060-005 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds 1 Emission Limitation: 1) Emissions from the operation of incinerator #1 through #5 (EUOOIO-EU0050 shall not contain more than two thousand parts per million by volume (2000 ppmv) of sulfur dioxide or more than seventy milligrams (70 mg) per cubic meter of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three (3) hour time period. 2) Emissions from the operation of incinerator #6 shall not contain more than five hundred parts per million by volume (500 ppmv) of sulfur dioxide or more than thirty-five milligrams (35 mg) per cubic meter of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three (3) hour time period. 3) No person shall cause or permit the emission of sulfur compounds from any source which causes or contributes to concentrations exceeding those specified in 10 CSR 10-6.0 I 0 Ambient Air Quality Standards. [10 CSR 10-6.260(4) &10 CSR 10-6.010 Ambient Air Quality Standards] PoUutant a) Sulfur Dioxide (SO,) b) Hydrogen Sulfide (H2S) c) Sulfuric Acid (H,so.) Monitoring Concentration by Volume 0.03 parts per miUion (ppm) 0.14 ppm (365 micrograms per cubic meter (f!g/m3)) 0.5 ppm (1300 f1g/m 3) 0.05 ppm (70 f1g/m 3) 0.03 ppm ( 42 f1g/m 3) 30 f1g/m 3 Remarks Annual arithmetic meao 24-hour average not to be exceeded more thao once per year 3-hour average not to be exceeded more thao once per year Y,-hour average not to be exceeded over 2 times per year Y,-hour average not to be exceeded over 2 times in aoy 5 consecutive days 24-hour average not to be exceeded more thao once in aoy 90 consecutive days !-hour average not to be exceeded more thao once in aoy 2 consecutive days Emission calculations using an AP-42 emission factor show compliance with the sulfur dioxide emission limit, with the sulfur dioxide concentration being less than 2.2 ppmv for each incinerator. Therefore no monitoring is required. (see statement of basis) Record Keeping:· Calculations showing compliance with 10 CSR 10-6.260 (4) shall be retained. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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 permit condition, or any malfunction which could possibly cause an exceedance of this permit condition. 1 10 CSR 10-6.260(4) is a state-only requirement MSD -Bissell Point Plant Installation ID: 510-0053 14 Project No. 1997-05-008 Permit Condition EU0060-006 10 CSR 10-6.070 New Source Performance Regulations 40 CFR Part 60 Subpart 0 Standards of Performance for Sewage Treatment Plants Emission Limitation: On and after the date on which the performance test required to be conducted by 40 CFR 60.8 is completed, the permittee shall not discharge or cause the discharge into the atmosphere: I) Particulate matter at a rate in excess of 0.65 grams per kilogram dry sludge input (1.30 lb/ton dry sludge input). [40 CFR 60.152(a)(l)] 2) Any gases which exhibit twenty percent (20%) opacity or greater for a period in excess of six (6) minutes in any consecutive sixty (60) minute period during periods other than startup, shutdown, and malfunction. [40 CFR 60.152(a)(2) & 40 CFR 60.1l(c)] Monitoring: 1) The permittee shall install, calibrate, maintain, and operate a flow measuring device which can be used to determine either the mass or volume of sludge charged to the incinerator. The flow measuring device shall be certified by the manufacturer to have an accuracy of±five percent (5%) over its operating range. Except as provided in 40 CFR 60.153(d), the flow measuring device shall be operated continuously and data recorded during all periods of operation of the incinerator. [40 CFR 60.153(a)(l)] 2) The permittee shall provide access to the sludge charged so that a well-mixed representative grab sample of the sludge can be obtained. [ 40 CFR 60.153(a)(2)] 3) The permittee shall calibrate, maintain and operate a monitoring device that continuously measures and records the pressure drop of the gas flow through the wet scrubbing device. Where a combination of wet scrubbers is used in series, the pressure drop of the gas flow through the combined system shall be continuously monitored. The device used to monitor scrubber pressure drop shall be certified by the manufacturer to be accurate within ±250 pascals (±I inch water gauge) and shall be calibrated on an annual basis in accordance with the manufacturer's instructions. [40 CFR 60.153(b)(l)] 4) The permittee shall install, calibrate, maintain and operate a monitoring device that continuously measures and records the oxygen content of the incinerator exhaust gas. The oxygen monitor shall be located upstream of any rabble shaft cooling air inlet into the incinerator exhaust gas stream, fan, ambient air recirculation damper, or any other source of dilution air. The oxygen monitoring device shall be certified by the manufacturer to have a relative accuracy of ±five percent (5%) over its operating range and shall be calibrated according to method(s) prescribed by the manufacturer at least once each 24-hour operating period. [40 CFR 60.153(b)(2)] 5) The permittee shall install, calibrate, maintain and,operate temperature measuring devices at every hearth. A minimum of one thermocouple shall be installed in each hearth in the cooling and drying zones, and a minimum of two (2) thermocouples shall be installed in each hearth in the combustion zone. Each temperature measuring device shall be certified by the manufacturer to have an accuracy of±five percent (5%) over its operating range. Except as provided in 40 CFR 60.153(d), the temperature monitoring devices shall be operated continuously and data recorded during all periods of operation of the incinerator. [40 CFR60.153(b)(3)]. 6) The permittee shall install, calibrate, maintain and operate a device for measuring the fuel flow to the incinerator. The flow measuring device shall be certified by the manufacturer to have an accuracy of ±five percent (5%) over its operating range. Except as provided in 40 CFR 60.153(d), the fuel flow measuring device shall be operated continuously and data recorded during all periods of operation of the incinerator. [40 CFR 60.153(b)(4)] 7) The permittee shall collect and analyze a grab sample of the sludge fed to the incinerator once per day. The dry sludge content and the volatile solids content of the sample shall be determined in accordance with the method specified under 40 CFR 60.154(b )( 5), except that the determination of volatile solids, step (3)(b) of the method, may -------·----·-----·-------------------------- MSD -Bissell Point Plant Installation ID: 510-0053 not be deleted. [40 CFR 60.!53(b)(5)] 15 Project No. 1997-05-008 8) The pennittee shall conduct opacity measurements and keep records on the emission units as described in the Monitoring and Record Keeping section of PW002 Record Keeoing: The pennittee shall retain the following information and make it available for inspection: I) A record of the measured pressure drop of the gas flow through the wet scrubbing device, as required by 40 CFR 60.153(b)(l). . [40 CFR 60.153(c)(l)] 2) A record of the measured oxygen content of the incinerator exhaust gas, as required by 40 CFR 60.153(b )(2). [40 CFR 60.153(c)(2)] 3) A record of the rate of sludge charged to the incinerator, the measured temperatures of the incinerator, the fuel flow to the incinerator, and the total solids and volatile solids content of the sludge charged to the incinerator, as required by 40 CFR 60.153(a)(l), 40 CFR 60.153(b)(3), 40 CFR 60.153(b)(4), and 40 CFR 60.153(b)(5). [40 CFR 60.153(c)(3)] 4) A record of the performance test, as required by 40 CFR 60.154(d)(l). Reporting: The pennittee shall submit to the Administrator semi-annually a report in writing which contains the following: [40 CFR 60.155 (a) & (b)] I) A record of average scrubber pressure drop measurements for each period of fifteen (15) minutes duration or more during which the pressure drop of the scrubber was less than, by a percentage specified below, the average scrubber pressure drop measured during the most recent performance test. The percent reduction in scrubber pressure drop for which a report is required shall be determined as follows: [40 CFR 60.155 (a)( I) & (a)(l)(ii)] a) A percent reduction in pressure drop greater than that calculated according to the following equation shall be rep_orted: P= IIIE+72.15 where: P = Percent reduction in pressure drop, and E =Average particulate matter emissions (kglmegagram) 2) A record of average oxygen content in the incinerator exhaust gas for each period of !-hour duration or more that the oxygen content of the incinerator exhaust gas exceeds the average oxygen content measured during the most recent performance test by more than three percent (3%). [40 CFR 60.155 (a)(2)] 3) The pennittee shall include in the report for each calendar day that a decrease in scrubber pressure drop or increase in oxygen content of exhaust gas is reported a record of the following: [40 CFR 60.155 (b)(!), (2), (3), (4), (5) & (6)] a) Scrubber pressure drop averaged over each !-hour incinerator operating period. b) Oxygen content in the incinerator exhaust averaged over each !-hour incinerator operating period. c) Temperatures of every hearth in multiple hearth incinerators; of the bed and outlet of fluidized bed incinerators; and of the drying, combustion, and cooling zones of electric incinerators averaged over each !-hour incinerator operating period. d) Rate of sludge charged to the incinerator averaged over each !-hour incinerator operating period. e) Incinerator fuel use averaged over each 8-hour incinerator operating period. f) Moisture and volatile solids content of the daily grab sample of sludge charged to the incinerator. MSD -Bissell Point Plant Installation ID: 510-0053 16 Project No. 1997-05-008 Permit Condition EUOOl0-007 through EU0060-007 10 CSR 10-5.510 Control of Emissions of Nitrogen Oxides Emission Limitation: I) The permittee shall complete an annual adjustment or tune up on the combustion process. This adjusttnent or tune up shall include at a minimum the following items: a) Inspection, adjustment, cleaning or replacement of fuel burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer; b) Inspection of the flame pattern or characteristics and adjustments necessary to minhnize total emissions of nitrogen oxides (NOJ and, to the extent practicable, minhnize emissions of carbon monoxide; and c) Inspection of the air to fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer. 2) The permittee shall be in compliance with this rule no later than May 1, 2002. Monitorimz!Record Keeping: The permittee shall maintain records of the annual adjustment or tune up including all inspections and any action resulting from the inspection. Reporting: The permittee shall report to the City of St. Louis Division of Air Pollution Control, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 no later than ten (10) days after any deviation from any of the terms imposed by this regulation .. MSD -Bissell Point Plant Installation ID: 510-0053 General Description: Manufacturer/Model #: EIO Reference # (Year): I 0 CSR 10-6.400 EU0070 Dry Incinerator Ash Stora_ge Dry Incinerator Ash Storage With baghouse and scrubbers United Conveyor EP#8 (2000) Permit Condition EU0070-001 Restriction of Emission of Particulate Matter from Industrial Processes Emission Limitation: 17 Project No. 1997-05-008 I) The pennittee shall not emit particulate matter in excess of25.2lbslhr from this emission unit. 2) No person shall 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. Monitoring: 1) The pennittee shall monitor, maintain and operate the scrubber in accordance with the water flow rate of thirty-five (35) gallons per minute. · 2) The pennittee shall calibrate, maintain and operate the instrumentation and scrubber according to the manufacturer's specifications and recommendations. Record Keeping: 1) The pennittee shall document all operational readings of the scrubber. 2) All inspections, corrective actions, and instrument calibration shall be recorded. 3) Records may be kept in either written or electronic form. Reporting: The pennittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 no later than ten (1 0) days after any exceedance of any of the terms imposed by this regulation. MSD -Bissell Point Plant Installation ID: 510-0053 19 Project No. 1997-05-008 EU0090 Emergency Diesel Generator General Description: 580 Horsepower (HP) Emergency Diesel Generator (1.48 MMBtu/hr) Manufacturer/Model #: Onan, 350DFU-4XR8/6495B EIQ Reference# (Year): EP# 13 (2000) Permit Condition EU0090-001 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds 1 Emission Limitation: 1) Emissions from this source operation shall not contain more than five hundred parts per million by volume (500 ppmv) of sulfur dioxide or more than thirty-five milligrams (35 mg) per cubic meter of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three (3) hour time period. 2) No person shall cause or permit the emission of sulfur compounds from any source which causes or contributes to concentrations exceeding those specified in 10 CSR 10-6.010 Ambient Air Quality Standards. [10 CSR 10-6.260(4) &10 CSR 10-6.010 Ambient Air Quality Standards] Pollutant a) Sulfur Dioxide (SO,) b) Hydrogen Sulfide (H2S) c) Sulfuric Acid (H2S04) Concentration by Volume 0.03 parts per million (ppm) 0.14 ppm (365 micrograms per cubic meter (J.Ig/m3)) 0.5 ppm (1300 J.lg/m3) 0.05 ppm (70 J.lg/m 3 ) 0.03 ppm (42 J.ig/m3 ) 10 J.lg/m3 Remarks Annual arithmetic mean 24-hour average not to be exceeded more than once per year 3-hour average not to be exceeded more than once per year Yz-hour average not to be exceeded over 2 times per year Y,-hour average not to be exceeded over 2 times in any 5 consecutive days 24-hour average not to be exceeded more than once in any 90 consecutive days !-hour average not to be exceeded more than once in any 2 consecutive days 3) The emission units shall be limited to burning fuel oil with a sulfur content of no more than 0.5% by weight sulfur. Monitoring: The permittee shall monitor the percent of sulfur in the diesel fuel as delivered to accurately track the SO, emissions. The sulfur content can be vendor supplied or facility generated. Record Keeping: The permittee shall maintain records on the premises of the fuel suppliers analysis of diesel fuel oil fired in the engines which shows weight percentage of sulfur in the fuel. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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. MSD -Bissell Point Plant Installation ID: 510-0053 General Description: Manufacturer/Model #: EIQ Reference# (Year): 10 CSR 10-6.400 EU0080 Wet Ash Conveying Wet Ash Conveying With wet venturi scrubber and mist eliminator United Conveyor EP#9 (2000) Permit Condition EUOOS0-001 Restriction of Emission of Particulate Matter from Industrial Processes Emission Limitation: 18 Project No. 1997-05-008 1) The pennittee shall not emit particulate matter in excess of 25.2 1bslhr from this emission unit. 2) No person shall cause, allow or penni! the emission of particulate matter from any source in a concentration in excess of 0.30 grain per standard cubic foot of exhaust gases. Monitoring: 1) Monitor and maintain a normal operating pressure drop range of one to eight inches (1" to 8") of water across the Venturi scrubber. 2) The pennittee shall calibrate, maintain and operate the instrumentation and the venturi scrubber according to the manufacturer's specifications and recommendations. Record Keeping: 1) The pennittee shall document all operational readings of the venturi scrubber. 2) All inspections, corrective actions, and instrument calibration shall be recorded. Records may be kept in either written or electronic form. Reporting: The pennittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to APCP, 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. MSD -Bissell Point Plant Installation ID: 510-0053 EUOOlOO through EU0120 Sludge Building Boilers #1, #2 & #3 20 Project No. 1997-05-008 General Description: Sludge Building Boilers #1-#3 (14.65 MMBtu!hr each, Natural Gas) Installed: 1990 Manufacturer/Model #: Cleaver Brooks, CB-350 EIQ Reference# (Year): EP#14, 15, & 16 (2000) Permit Condition EUOl00-001 through EU0120-001 10 CSR 10-6.060 Construction Permits Required Permit #94-05-029A Emission Limitation: I) Natural gas usage in these boilers (EUOlOO, EUOilO and EU0120) shall not exceed 33 million cubic feet in any consecutive twelve (12) month period. 2) All equipment shall be operated and maintained according to the manufacturer's instruction. 3) Personnel shall be qualified to operate and maintain this equipment. Monitoring/Record Keeping: The permittee shall maintain an accurate record of the natural gas usage in the boilers. The permittee shall record monthly and running twelve (12) month totals of natural gas usage. The permittee shall also keep records of equipment maintenance. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to Air Pollution Control Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 no later than ten (I 0) days after any exceedance of any of the terms imposed by this permit condition. Permit Condition EUOl00-002 through EU0120-002 10 CSR 10-6.070 New Source Performance Regulations 40 CFR Part 60 Subpart De Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Emission Limitation: Not applicable Monitoring/Record Keeping/Reporting: The owner or operator of each affected facility shall record and maintain records of the amounts of each fuel combusted during each day. [§60.48c(g)] MSD -Bissell Point Plant Installation ID: 510-0053 General Description: Manufacturer/Model #: EIQ Reference# (Year): I 0 CSR I 0-6.060 Construction Permits Required Permit #95-05-69 Emission Limitation: EU00130 Biofilter 21 Project No. 1997-05-008 Biofilter to control hydrogen sulfide (H2S) emissions from the wastewater treatment olant. Installed: 1996 EP#23 (2000) Permit Condition EU0130-001 I) Hydrogen sulfide (H2 S)emissions from the biofilter system shall not equal or exceed ten (10) tons in any twelve (12) month period. 2) All equipment shall be operated and maintained according to the manufacturer's instructions. Monitoring: I) The concentration of hydrogen sulfide shall be measured daily using H2S detector tube and averaged on a monthly basis to characterize the efficiency of the biofilter system and the amount of the H2S emitted in tons. 2) The Division shall be allowed to conduct any inspections, tests and observations deemed necessary when the installation is in operation. Record Keeping: Accurate, easily understood, up to date records shall be kept of H2S concentrations and any other parameters necessary to determine: 1) The quantity ofH2S gas released into the ambient air. 2) The efficiency of the biofilter system in removing H2S from the clarifiers. These records shall be kept as a month to month moving average indicating hydrogen sulfide emissions during the previous 12 months. MSD -Bissell Point Plant Installation ID: 510-0053 General Description: Manufacturer/Model #: EIQ Reference# (Year): 10 CSR 10-5.300 EU00140 Parts Washer Parts Washer Safety Kleen EP#26 (2000) Permit Condition EU0140-001 Control of Emissions from Solvent Metal Cleaning Emission Limitation: 22 Project No. 1997~05-008 1) After September 30, 1998, no owner or operator shall operate a cold cleaner using a solvent with a vapor pressure greater than 2.0 millimeters of Mercury (mmHg) (0.038 psi) at twenty degrees Celsius (20°C)(sixty-eight degrees Fahrenheit (68"F)). Exception: This limitation shall not apply when using an aqueous solvent. 2) After April 1, 2001, no owner or operator shall operate a cold cleaner using a solvent with a vapor pressure greater than 1.0 mmHg at 20°C (68°F). Exception: a) The permittee may use an alternative method for reducing cold cleaning emissions if the level of emission control is equivalent to or greater than the requirements listed above. The director must approve the alternative method. b) This limitation shall not apply when using an aqueous solvent. 3) Each cold cleaner shall have the following: a) A cover which will prevent the escape of solvent vapors from the solvent bath while in the closed position, or b) An enclosed reservoir which limits the escape of solvent vapors from the solvent bath whenever parts are not being processed in the cleaner. Cold cleaner covers shall be closed whenever parts are not being handled in the cleaners or the solvent must drain into the enclosed reservoir. c) When one (1) or more of the following conditions exist, the design of the cover shall be such that it can be easily operated with one (1) hand and without disturbing the solvent vapors in the tank. For covers larger than ten (10) square feet, this shall be accomplished by either mechanical assistance such as spring loading or counter weighing or by power systems: i) The solvent volatility is greater than 0.3 pounds per square inch (psi) measured at one hundred degrees Fahrenheit (1 OO"F) such as in mineral sprits; ii) The solvent is agitated; or iii) The solvent is heated. d) Drainage facility which will be internal so that the parts are enclosed under the cover while draining. e) If the internal drainage facility cannot fit into the cleaning system and the solvent volatility is less than 0.6 psi measured at one hundred degrees Fahrenheit (1 OO"F), then the cold cleaner shall have an external drainage facility which provides for the solvent to drain back into the solvent bath. f) Solvent sprays, if used, shall be a solid fluid stteam (not fine, atomized, of shower type spray) and at a pressure which does not cause splashing above or beyond the freeboard. g) A permanent conspicuous label summarizing the operating procedures shall be affixed to the equipment. h) If the solvent volatility is greater than 0.6 psi measured at one hundred degrees Fahrenheit (100"F) or is heated above one hundred twenty degrees Fahrenheit (120"F), then one of the following control devices must be used: i) Freeboard ratio of at least .75 ii) Water cover over solvent iii) Demonstrate an overall VOC emission reduction efficiency greater than or equal to sixty-five percent (65%) through a control system approved by the director. 4) Each cold cleaner shall be operated as follows: a) Cold cleaner covers shall be closed whenever parts are not being handled in the cleaners or the solvent must drain into an enclosed reservoir. b) Clean parts shall be drained in the freeboard area for at least fifteen (15) seconds or until dripping ceases, whichever is longer. MSD -Bissell Point Plant Installation ID: 510-0053 23 Project No. 1997-05-008 c) Whenever a cold cleaner fails to perform within the operating parameters established for it by this regulation, the unit shall be shut down immediately and shall remain shut down until trained service personnel are able to restore operation within the established operating procedures. d) Solvent leaks shall be repaired immediately or the cleaner shall be shut down and leaks secured until the leaks are repaired. e) Any waste material removed from a cold cleaner shall be disposed of by one (I) of the following methods in accordance with the Missouri Hazardous Waste Management Commission Rules codified as 10 CSR 25, as applicable: i) Reduction of the waste material to less than twenty percent (20%) VOC solvent by distillation and proper disposal of the still bottom waste, or ii) Stored in a closed containers for transfer to a contract reclamation service or disposal facility approved by the director. f) Waste solvent shall be stored in covered containers only. 5) Operators must be trained as follows: a) Only persons trained in at least the operation and equipment requirements specified in this rule for their particular solvent metal cleaning process to operate this equipment; b) The supervisor of any person who operates a solvent metal cleaning process shall receive equivalent or greater operational training than the operators; and c) Refresher training shall be given to all solvent metal cleaning equipment operators at least once every twelve (12) month period. Monitoring: The permittee shall monitor the throughputs of the solvents monthly and maintain material safety data sheets of the cleanup solvents used at the installation. Record Keeeing: I) The permittee shall maintain the following records for each purchase of cold cleaner solvent (Attachment E): a) Name and address of the solvent supplier. b) Date of purchase. c) Type of solvent purchased. d) Vapor pressure of solvent in rnm Hg at 20°C or 68"f. 2) The permittee shall keep monthly inventory records of solvent types and amounts purchased and solvent consumed. The records shall included all types and amounts of solvent containing waste material transferred to either a contract reclamation service or to a disposal installation and all amounts distilled on the premises. The record also shall include maintenance and repair logs that occurred on the cold cleaner (Attachments F, G & H). 3) The permittee shall keep training records of solvent metal cleaning for each employee on an annual basis (Attachment I). Reporting: The pennittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63!06 and to APCP, 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. MSD -Bissell Point Plant Installation ID: 510-0053 24 Project No. 1997-05-008 EU00150 through EU0180 Six Natural Gas Fired Boilers Heat Input Manufacture/ EUID General Description (Million Btulhr) Model# EU0!50 Pump Station #I Boilers (2) 7.32 (each) Cleaver Brooks EU0160 Primarv Control Building Boiler 0.15 Hydrotherm/ AMI 50 EU0170 Administration Building Boilers (2) 1.35 (each) Wei! McLain/BG 688WF EU0!80 Trickling Filter Pump Station Boiler 1.3 Bumham/4FW-127-40-G- 6P Permit Condition EUOlS0-001 through EU0180 10 CSR 10-6.060; Construction Permits Required Permit #94-05-029A Emission Limitation: EIQ Reference # (Year) EP18 (2000 EPI9 (2000 EP20_(2000 EP22 (2000) Natural gas usage in these boilers shall not exceed 60 million cubic feet in any consecutive twelve (12) month period. Monitoring/Record Keeping: The permittee shall maintain an accurate record of the natural gas usage in the boilers. The permittee shall record monthly and running twelve (12) month totals of natural gas usage. Reporting: The permittee shall report to the City of St. Louis Air Pollution Control Division, 1415 North Thirteenth Street, St. Louis, MO 63106 and to Air Pollution Control Program, 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 permit condition. MSD -Bissell Point Plant Installation ID: 510-0053 General Description: Manufacturer/Model #: EIQ Reference# (Year): 10 CSR 10-5.220 EU00190 Underground Gasoline Storage Tank 1000 Gallon Underground Gasoline Storage Tank EP#lO (2000) Permit Condition EU0190-001 Control of Petroleum Liquid Storage,_ Loading and Transfer Emission Limitation: 25 Project No. 1997-05-008 No owner or operator of a gasoline storage tank or delivery vessel shall 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 unless- !) The 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; 2) All storage tank caps and fittings are vapor-tight when gasoline transfer is not taking place; and 3) Each storage tank is vented via a conduit that is- a) At least two inches (2") inside diameter; b) At least twelve feet (12') in height above grade; and c) Equipped with a pressure/vacuum valve that is CARB certified at three inches (3") water column pressure/eight inches water column vacuum (3"wcp/8"wcv) except when the owner or operator provides documentation that the system is CARB certified for a different valve and will not function properly with a 3"wcp/8"wcv valve. Monitoring/Record Keeping The permittee shall keep records documenting the vessel owners and number of delivery vessels unloaded by each owner. Records shall be kept for two (2) years and shall be made available to the staff director within five (5) days of a request. The owner or operator shall retain on-site copies of the loading ticket, manifest or delivery receipt for each grade of product received, subject to examination by the staff director upon request. If a delivery receipt is retained rather than a manifest or loading ticket, the delivery ticket shall bear the following information: vendor name, date of delivery, quantity of each grade, point of origin, and the manifest or loading ticket number. The required retention on-site of the loading ticket, manifest or delivery receipt shall be limited to the four ( 4) most recent records for each grade of product. Reporting: The permittee shall report to the APCP, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 and to the City of St. Louis Air Pollution Control Division, 1415 N. 13th Street, St. Louis, MO 63106, no later than ten (10) days after any exceedance of any of the terms imposed by this regulation. MSD -Bissell Point Plant Installation ID: 510-0053 IV. Core Permit Requirements 26 Project No. 1997-05-008 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. 10 CSR 10-6.050, Start-up. Shutdown and Malfunction Conditions (a) In the event of a malfunction, which results in excess emissions that exceed one (1) hour, the permittee shall submit to the director within two (2) business days in writing the following information: (1) Name and location of installation; (2) Name and telephone number of person responsible for the installation; (3) Name of the person who first discovered the malfunction and precise time and date that the malfunction was discovered; ( 4) Identity of the equipment causing the excess emissions; (5) Time and duration of the period of excess emissions; ( 6) Cause of the excess emissions; (7) Air pollutants involved; (8) Best 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; (9) Measures taken to mitigate the extent and duration of the excess emissions; and (! 0) Measures taken to remedy the situation that caused the excess emissions and the measures taken or planned to prevent the recurrence of these situations. (b) The permittee shall submit the paragraph (a) information list to the director in writing at least ten (10) days prior to any maintenance, start-up or shutdown, which is expected to cause an excessive release of emissions that exceed one (1) hour. If notice of the event cannot be given ten (10) days prior to the planned occurrence, it shall be given as soon as practicable prior to the release. lf an unplanned excess release of emissions exceeding one (1) hour occurs during maintenance, start-up or shutdown, the director shall be notified verbally as soon as practical during normal working hours and no later than the close of business of the following working day. A written notice shall follow within ten ( 1 0) working days. (c) 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 (a) list and shall be submitted not later than fifteen ( 15) days after receipt of the notice of excess emissions. Based upon information submitted by the permittee or any other pertinent information available, the director or the commission shall make a determination whether the excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement action under section 643.080 or 643.151, RSMo. (d) 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. : (e) Compliance with this rule does not automatically absolve the permittee of liability for the excess emissions reported. MSD -Bissell Point Plant ·Installation ID: 510-0053 10 CSR 10-6.060. Construction Permits Required 27 Project No. 1997-05-008 The pennittee 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 (5) years without frrst obtaining a permit from the permitting authority. 10 CSR 10-6.065. Operating Permits The permittee shall flle for renewal of this operating permit no sooner than eighteen (18) months, nor later than six (6) months, priorto the expiration date of this operating permit. The permittee shall retain the most current operating permit issued to this installation on-site and shall immediately make such permit available to any Missouri Department ofNatural Resources' personnel upon request. 10 CSR 10-6.110. Submission o(Emission Data. Emission Fees and Process Information (a) The permittee shall complete and submit an Emission Inventory Questionnaire (EIQ) in accordance with the requirements outlined in this rule. (b) The permittee shall pay an annual emission fee per ton of regulated air pollutant emitted according to the schedule in the rule. This fee is an emission fee assessed under authority ofRSMo. 643.079 to satisfy the requirements of the Federal Clean Air Act, Title V. (c) The fees shall be due April! each year for emissions produced during the previous calendar year. The fees shall be payable to the Department ofNatural Resources and shall be accompanied by the Emissions Inventory Questionnaire (EIQ) form or equivalent approved by the director. 10 CSR 10-6.130. Controlling Emissions During Episodes of High Air Pollution Potentia[ This rule specifies the conditions that establish an air pollution alert (yellow/red), watch or emergency and the associated procedures and emissions reduction objectives for dealing with each. The permittee shall submit an appropriate emergency plan if required by the Director. 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 10-6.180. Measurement o(Emissions o(Air Contaminants (a) 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. (b) 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.' (c) The director shall be given a copy of the test results in writing and signed by the person responsible for the tests. 10 CSR 10-6.100. Alternate Emission Limits Proposals for alternate emission limitations shall be submitted on Alternate Emission Limits Permit forms provided by the department. An installation owner or operator must obtain an Alternate Emission Limits Permit in accordance with I 0 CSR 10-6.100 before alternate emission limits may become effective. 10 CSR 10-6.080. Emission Standards for Hazardous Air Pollutants 40 CFR Part 61 Subpart M. National Emission Standard for Asbestos (a) 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. (b) The permittee shall conduct monitoring to demonstrate compliance with registration, certification, notification, and Abatement Procedures and Practices standards as specified in 40 CFR Part 61, Subpart M. MSD -Bissell Point Plant Installation ID: 510-0053 28 Project No. 1997-05-008 10 CSR 10-6.250. Asbestos Abatement Projects-Certification. Accreditation. and Business Exemption Requirements The permittee shall conduct all asbestos abatement projects within the procedures established for certification and accreditation by 10 CSR 10-6.250. This rule requires individuals who work in asbestos abatement projects to be certified by the Missouri Department of Natural Resources' Air Pollution Control Program. 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. This rule requires persons who hold exemption status from certain requirements of this rule to allow the department to monitor training provided to employees. Each individual who works in asbestos abatement projects must first obtain certification for the appropriate occupation from the department. Each person who offers training for asbestos abatement occupations must first obtain accreditation from the department. Certain business entities that meet the requirements for state-approved exemption status must allow the department to monitor training classes provided to employees who perform asbestos abatement. 10 CSR 10-6.280, Compliance Monitoring Usage (a.) The permittee is not prohibited from using the following in addition to any specified compliance methods for the purpose of submission of compliance certificates: (1.) Monitoring methods outlined in 40 CFR Part 64; (2.) Monitoring method(s) approved for the permittee pursuant to 10 CSR 10-6.065, "Operating Permits", and incorporated into an operating permit; and (3.) Any other monitoring methods approved by the director. (b.) 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 by a permittee: (1.) Monitoring methods outlined in 40 CFR Part 64; (2.) A monitoring method approved for the permittee pursuant to 10 CSR 10-6.065, "Operating Permits", and incorporated into an operating permit; and (3.) Compliance test methods specified in the rule cited as the authority for the emission limitations. (c.) The following testing, monitoring or information gathering methods are presumptively credible testing, monitoring, or information gathering methods: (1.) Applicable monitoring or testing methods, cited in: • 10 CSR 10-6.030, "Sampling Methods for Air Pollution Sources"; • 10 CSR 10-6.040, "Reference Methods"; • 10 CSR 10-6.070, "New Source Performance Standards"; and • 10 CSR 10-6.080, "Emission Standards for Hazardous Air Pollutants"; or (2.) 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 10-5.040. Use o(Fuel in Hand-Fired Equipment Prohibited It shall be unlawful to operate any hand-fired fuel-burning equipment in the St. Louis, Missouri metropolitan area. This regulation shall apply to all fuel-burning equipment including, but not limited to, furnaces, heating and cooking stoves and hot water furnaces. It shall not apply to wood-burning frreplaces and wood-burning stoves in dwellings, nor to fires used for recreational purpose, nor to frres used solely for the preparation of food by barbecuing. Hand-frred fuel-burning equipment is any stove, furnace or other fuel-burning device in which fuel is manually introduced directly into the combustion chamber. City of St. Louis Ordinance 64749, Sec 17, Open Burning Restrictions (a) No person shall cause, suffer, allow or permit the open burning of refuse. (b) No person shall conduct, cause or permit the conduct of a salvage operation by open burning. (c) No person shall conduct, cause or permit the disposal of trade waste by open burning. (d) No person shall cause or permit the open burning of leaves, trees or the byproducts therefrom, grass, or other vegetation. (e) It shall be prima-facie evidence that the person who owns or controls property on which open burning occurs, has caused or permitted said open burning. MSD -Bissell Point Plant Installation ID: 510-0053 10 CSR 10-5.160. Restriction ofEmission of Odors No person shall emit odorous matter as to cause an objectionable odor on or adjacent to: (a) Residential, recreational, institutional, retail sales, hotel or educational premises. 29 Project No. 1997-05-008 (b) Industrial premises when air containing odorous matter is diluted with twenty (20) or more volumes of odor-free air; or (c) Premises other than those in paragraphs (!)A.!. and (2) of the rule when air containing odorous matter is diluted with four ( 4) or more volumes of odor-free air. (d) The previously mentioned requirement shall apply only to objectionable odors. An odor will be deemed objectionable when thirty percent (30%) or more of a sample of the people exposed to it believe it to be objectionable in usual places of occupancy; the sample size to be at least twenty (20) people or seventy-five percent (75%) of those exposed if fewer than twenty (20) people are exposed. This requirement is not federally enforceable. 10 CSR 10-5.240. Additional Air Quality Control Measures May be Required When Sources Are Clustered in a Small Land Area The Air Conservation Commission may prescribe more restrictive air quality control requirements that are more restrictive and more extensive than provided in regulations of general application for: (a.) Areas in which there are one (I) or more existing sources and/or proposed new sources of particulate matter in any circular area with a diameter of two (2) miles (including sources outside metropolitan area) from which the sum of particulate emissions allowed from theses sources by regulations of general application are or would be greater than two thousand (2000) tons per year or five hundred (500) pounds per hour. (b.) Areas in which there are one (1) or more existing sources and/or proposed new sources of sulfur dioxide in any circular area with a diameter of two (2) miles from which the sum of sulfur dioxide emissions from these sources allowed by regulations of general application are or would be greater than one thousand (1 000) tons for any consecutive three (3) months or one thousand (1000) pounds per hour. Title VI-40 CFR Part 82. Protection of Stratospheric Ozone (a) The permittee shall comply with the standards for labeling of products using ozone-depleting substances pursuant to 40 CFR Part 82, Subpart E: (I) 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 §82.106. (2) The placement of the required warning statement must comply with the requirements pursuant to §82.1 08. (3) The form of the label bearing the required warning statement must comply with the requirements pursuant to §82.110. ( 4) No person may modify, remove, or interfere with the required warning statement except as described in §82.112. (b) 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: (I) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to §82.158. (3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to §82.161. (4) Persons disposing of small appliances, MV ACs, and MVAC-like appliances must comply with record keeping requirements pursuant to §82.166. ("MV AC-like" appliance as defined at §82.152). (5) Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to §82.156. ( 6) 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 §82.166. (c) 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. MSD -Bissell Point Plant Installation ID: 510-0053 30 Project No. 1997-05-008 (d) If the pennittee performs a service on motor (fleet) vehlcles when thls service involves ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MY AC), the permittee is subject to all the applicable requirements as specified 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 "MV AC" 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. (e) The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. Federal Only-40 CFR part 82 MSD -Bissell Point Plant Installation ID: 510-0053 V. General Permit Requirements Permit Duration 10 CSR 10-6.065(6)(C)l.B. 31 Project No. 1997-05-008 This permit is issued for a term of five (5) years, commencing on the date of issuance. This permit will expire at the end of this period unless renewed. General Record Keeping and Reporting Requirements 10 CSR 10-6.065(6)(C)l.C I) Record Keeping A) All required monitoring data and support information shall be retained for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. 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 City of St. Louis Air Pollution Control or Missouri Department of Natural Resources' personnel upon request. m Reporting A) The permittee shall submit a report of all required monitoring by: I) October 1st for monitoring which covers the January through June time period, and 2) April I st for monitoring which covers the July through December time period. 3) Exception: Monitoring requirements which require reporting more frequently than semi annually shall report no later than thirty (30) days after the end of the calendar quarter in which the measurements were taken. B) B) Each report must identify any deviations from emission limitations, monitoring, record keeping, reporting, or any other requirements of the permit, this includes deviations or Part 64 exceedances. C) All reports shall be submitted to the St. Louis City Division of Air Pollution Control, 1415 North 13th Street, St. Louis, MO 63106 and the Air Pollution Control Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. D) Submit supplemental reports as required or as needed. Supplemental reports are required no later than ten (10) days after any exceedance of any applicable rule, regulation or other restriction. All reports of deviations shall identify the cause or probable cause of the deviations and any corrective actions or preventative measures taken. I) Notice of any deviation resulting from an emergency (or upset) condition as defined in paragraph (6)(C)7 of I 0 CSR I 0-6.065 (Emergency Provisions) shall be submitted to the permitting authority either verbally or in writing within two (2) working days after the date on which the emission limitation is exceeded due to the · emergency, if you wish 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 that you 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 m!lst contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken. 2) Any deviation that poses an imminent and substantial danger to public health, safety or the environment shall be reported as soon as practicable. 3) 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 the permit. E) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation must be submitted within ten (10) days after the deviation, the report may be submitted without a certification if the report is resubmitted with an appropriate certification within ten (10) days after that, together with any corrected or supplemental information required concerning the deviation. F) The permittee may request confidential treatment of information submitted in any report of deviation. G) These supplemental reports shall be submitted to the St. Louis City Division of Air Pollution Control, 1415 North 13th Street, St. Louis, MO 63106 and the Air Pollution Control Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 no later than ten (10) days after any exceedance of any applicable rule, regulation, or other restriction. MSD -Bissell Point Plant Installation ID: 510-0053 Risk Management Plans Under Section 112(r) 10 CSR 10-6.065(6)(C)l.D. 32 Project No. 1997-05-008 The pennittee shall comply with the requirements of 40 CFR Part 68, Accidental Release Prevention Requirements. If the permittee has more than a threshold quantity of a regulated substance in process, as determined by 40 CFR Section 68.115, the permittee shall submit a Risk Management Plan in accordance with 40 CFR Part 68 no later than the latest of the following dates: I) June 21, 1999; 2) Three (3) years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. Severability Clause 10 CSR 10-6.065(6)(C)l.F. ln the event of a successful challenge to any part of this permit, all uncontested penni! 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 penni! is invalidated, the permittee shall comply with all other provisions of the permit. General Requirements 10 CSR 10-6.065(6)(C)l.G 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, pennit termination, penni! revocation and re- issuance, penni! modification or denial of a permit renewal application. 2) The pennittee may not use as a defense in an enforcement action that it would have been necessary for the pennittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the penni!. 3) The permit may be modified, revoked, reopened, reissued or terminated for cause. Except as provided for minor permit modifications, the flling of an application or request for a permit modification, revocation and re-issuance, or termination, or the flling of a notification of planned changes or anticipated noncompliance, will not stay any penni! condition. 4) This permit does not convey any property rights of any sort, nor grant any exclusive privilege. 5) The pennittee 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 penni! or to determine compliance with the permit. Upon request, the pennittee also shall furnish to the Air Pollution Control Program copies of records required to be kept by the permittee. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 10 CSR 10-6.065(6)(C)l. Incentive Programs Not Requiring Permit Re¥isions 10 CSR 10·6.065(6)(C)lH 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. Reasonably Anticipated Operating Scenarios 10 CSR 10-6.065(6)(C)l.I. None Title IV Allowances Not applicable --------·------------~ ---- MSD -Bissell Point Plant Installation ID: 510-0053 Emissions Trading 10 CSR 10-6.065(6)(C)l.J. None Compliance Requirements 10 CSR 10-6.065(6)(C)3. 33 Project No. 1997-05-008 I) Any document (including reports) required to be submitted under this permit shall contain a certification signed by the responsible official. li) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized officials of the Missouri Department ofNaturai 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): 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 ail applicable requirements as outlined in this permit. Ill) 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: 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. IV) 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 unless the applicable requirement specifies more frequent submission. All deviations and Part 64 exceedances and excursions must be included in the compliance certifications. The compliance certification shall include the following: A) The identification of each term or condition of the permit that is the basis of the certification, B) The current compliance status, as shown by monitoring data and other information reasonably available to the installation, C) Whether compliance was continuous or intermittent, D) The method(s) used for determining the compliance status of the installation, both currently and over the reporting period, and E) Such other facts as the Air Pollution Control Program will require in order to determine the compliance status of this installation. Permit Shield 10 CSR 10-6.065(6)(C)6. I) Compliance with the conditions of this permit shall be deemed compliance with ail applicable requirements as of the date that this permit is issued, provided that: 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. li) Be aware that there are exceptions to this permit protection. The permit shield does not affect the following: 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, MSD -Bissell Point Plant Installation ID: 510-0053 D) The administrator's authority to obtain information, or 34 Project No. 1997-05-008 E) Any other permit or extra-permit provisions, terms or conditions expressly excluded from the permit shield provisions. Emergency Provisions 10 CSR 10-6.065(6)(C)7. I) An emergency or upset as defined in I 0 CSR 10-6.065(6)(C)7. 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, you must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following: A) That an emergency or upset occurred and that you can identify the source of the emergency or upset, B) That the installation was being operated properly, C) That you took all reasonable steps to minimize emissions that exceeded technology-based emissions limitations or requirements in this permit, and D) That you submitted notice of the emergency to the Air Pollution Control Program within two (2) 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. II) 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. Operational Flexibility 10 CSR 10-6.065(6)(C)8. 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 if the changes are not Title I modifications, the changes do not cause emissions to exceed emissions allowable under the permit, and the changes do not result in the emission of any air contaminant not previously emitted. The permittee shall notify the Air Pollution Control Program and the Administrator at least seven (7) 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 established 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. I) Section 502(b)(IO) changes. Changes that, under section 502(b)(IO) 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 and to the Administrator, 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 '.11ith the permit, and this agency shall place a copy with the permit in the public file. Written notice shall be provided to the administrator and this agency at least seven (7) days before the change is to be made. If less than seven (7) days notice is provided because of a need to respond more quickly to these unanticipated conditions, The permittee shall provide notice to the administrator and the permitting authority as soon as possible after learning of the need to make the change. B) The permit shield shall not apply to these changes. Off-Permit Changes 10 CSR 10-6.065(6)(C)9. I) 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 application, 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: MSD -Bissell Point Plant Installation ID: 510-0053 35 Project No. 1997-05-008 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 written notice of the change to the permitting authority and to the administrator no later than the next annual emissions report. This notice shall not be required for changes that are insignificant activities under paragraph (6)(B)3. of this rule. 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. Responsible Official 10 CSR 10-6.020(2)(R)l2. The application utilized in the preparation of this was signed by Jeffrey L. Theerman, Assistant Director ofW astewater. 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 thirty (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. Reopening Permit For Cause I 0 CSR 10-6.065(6)(E)6. In accordance with 10 CSR 10-6.065(6)(E)6.A., this permit may be reopened with cause if: I} The Missouri Department of Natural Resources 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) The Missouri Department of Natural Resources 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 the permit has a remaining term ofless than three (3) years, the effective date of the requirement is later than the date on which the permit is due to expire, or 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) The Missouri Department of Natural Resources or EPA determines that the permit must be reopened and revised to assure compliance with applicable requirements. Statement of Basis 10 CSR I0-6.065(6)(E)l.C. This permit is accompanied by a statement setting forth the legal and factual basis for the draft 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. MSD -Bissell Point Plant Installation ID: 510-0053 Attachment A 36 Project No. 1997-05-008 10 CSR 10-6.170 Compliance Demonstration Fugitive Emission Observations This record keeping sheet or something similar may be used to meet the record keeping requirements for Permit Condition PWOOI ------~·---------~~----- MSD -Bissell Point Plant Installation ID: 510-0053 Attachment B 37 Project No. 1997-05-008 I 0 CSR I 0-6.220 Compliance Demonstration Opacity Emission Observations This record keeping sheet or something similar may be used for the recordkeeping requirements of the opacity limitations within the permit. MSD -Bissell Point Plant Installation ID: 510-0053 Attachment C Responsible Installation Operator: Date: Sky Condition: Precipitation: Wind Direction: Wind Speed: Process Unit: Method 22 (Outdoor) Observation Log 38 Project No. 1997-05-008 Sketch process unit: Indicate the position relative to the source and sun; mark the potential emission points and/or the observing points. Begin Observation End Observation MSD -Bissell Point Plant Installation ID: 510-0053 Attachment D 39 Project No. 1997-05-008 10 CSR 10-6.220 Compliance Demonstration Opacity Emission Observations (Method 9) Company: __________ _ Observer: _____________ _ Location: Observer Certification Date: -----------------------------------------Date: ___________ _ Type Facility: _____________ _ Time: -----------------Point Of Emissions: _____________ _ Control Device: _____________ _ Readings ranged from __ to __ % opacity. The Source was/was not in compliance with __ at the time evaluation was made. (Signature of Observer) MSD -Bissell Point Plant Installation ID: 510-0053 Attachment E Purchase Records for Cold Cleaning Solvent ------------------------- 40 Project No. 1997-05-008 MSD -Bissell Point Plant Installation ID: 510-0053 Attachment F Monthly Inventory Records of Solvents 41 Project No. 1997-05-008 . MSD -Bissell Point Plant Installation ID: 510-0053 Attachment G Solvent Containing Waste Transfer Log 42 Project No. 1997-05-008 ----~---~------------------ MSD -Bissell Point Plant Installation ID: 510-0053 Attachment H Maintenance And Repair Logs 43 Project No. 1997-05-008 MSD -Bissell Point Plant Installation ID: 510-0053 Attachment I 44 Project No. 1997-05-008 Employee Solvent Metal Cleaning Training Log . MSD -Bissell Point Plant Installation ID: 510-0053 SB-1 Project No. 1997-05-008 STATEMENT OF BASIS 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 12, 1997; 2) 2000 Emissions Inventory Questionnaire; and 3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary Point and Area Sources, Fifth Edition. Applicable Requirements Included in the Operating Permit but Not in the Application 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. 10 CSR 10-6.180, Measurement of Emissions of Air Contaminants This rule has been included in the operating permit in order to provide citing for the allowance of requests for emissions data results. On past forms issued by the Air Pollution Control Program, including the application for this permit, it was automatically marked as an administrative rule not required to be listed as an applicable requirement. It is no longer judged to be solely administrative and is, therefore, included in the operating permit. 10 CSR 1 0-6.220, Restriction of Emission of Visible Air Contaminants This rule had not been created at the time of application; however, it has been determined to be applicable to the installation and, therefore, has been included in the operating permit. 10 CSR 10-6.260, Restriction of Emission ofSulfor Compounds This rule had not been created at the time of application; however, it has been determined to be applicable to the installation and, therefore, has been included in the operating permit. 10 CSR 10-6.280, Compliance Monitoring Usage On December 5, 2001, the Air Pollution Control Program received a letter from EPA Region VII stating EPA had determined that the language in the State Implementation Plan regarding credible evidence is an applicable requirement and must be included in:each Title V operating permit. On July 2, 2002, the Air Pollution Control Program responded to EPA Region VII and agreed to include 10 CSR 10-6.280, Compliance Monitoring Usage, in the Core Permit Requirements Section of the Title V operating permit to address the issue. 10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes This rule had not been created at the time of application; however, it has been determined to be applicable to the installation and, therefore, has been included in the operating permit. MSD -Bissell Point Plant Installation ID: 510-0053 SB-2 Project No. 1997-05-008 Missouri Air Conservation Law, Asbestos Abatement, 643.225 through 643.250; 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants, Subpart M, National Standards for Asbestos; and 10 CSR 10-6.250, Asbestos Abatement Projects -Certification, Accreditation. and Business Exemption Requirements The installation is subject to these regulations if they undertake any projects that deal with or involve any asbestos containing materials. In the installation's operating permit application and according to agency records, there was no indication that any projects were underway at the time of this review that deal with or involve asbestos containing material at this installation. If the installation should undertake any construction or demolition projects in the future, which deal with or involve any asbestos containing materials, the installation must follow all of the applicable requirements of the above rules related to that specific project Other Air Regulations Determined Not to Apply to the Operating Permit The APCP has determined the following requirements to not be applicable to this installation at this time for the reasons stated. St. Louis City Ordinances Nos. 50163, 55100, 55923, 58040, 59270, 60023, and 60629 These ordinances were reviewed and considered at the time the application for this permit was submitted. Since that time, these ordinances have been repealed and replaced with St. Louis City Ordinance No. 64749. The only section of Ordinance 64749 that corresponds to a rescinded ordinance included in the State SIP and therefore federally enforceable is Section 17 -Open Burning Restrictions. This section is the only section listed in this Operating Permit. 10 CSR I 0-5.150, Emissions of Certain Sulfur Compounds Restricted This rule has been rescinded. Control of emissions of sulfur dioxide is addressed in 10 CSR 10-6.260. 10 CSR 10-5.450, Control ofVOC Emissions from Traffic Coatings This regulation was determined to not apply to this plant since the plant controls the ingress and egress of traffic at the plant, thus the plant is not public property. I 0 CSR 10-5.050, Restriction of Emission of Particulate Matter From Industrial Processes This rule has been rescinded and been replaced by 10 CSR 10-6.400. Construction Permit Revisions The following revisions were made to construction permits for this installation: 1) St. Louis City Construction Permit #95-05-068 Section V deals with the initial performance test requirements for #1 through #5 incinerators. Since the installation has already completed the performance testing requirements for construction permit number #95-05-068, the conditions are not included in the operating permit. Section VII deals with inspections and the authority to inspect. Since inspection and the authority to inspect are requirements of the P70 permit and included in the general requirements section of this permit, the provisions of Section VII of construction permit #95-05-068 are not included in the operating permit. MSD -Bissell Point Plant Installation ID: 510-0053 NSPS Applicability 10 CSR 10-6.070, New Source Performance Regulations SB-3 Project No. 1997-05-008 40 CFR Part 60 Subpart De, Standards of Peiformance for Small Industrial-Commercial-Institutional Steam Generating Units This rule is applicable to Sludge Building Boilers #1-#3 (EU0100-EU0120)) due to the installation date and the size of the boiler. However, since this facility only uses natural gas and propane for fuel, there are no specific limitations for sulfur dioxide and particulate matter from this rule except the record keeping requirement of 40 CFR 60.48c. 40 CFR Part 60 Subpart 0, Standards of Peiformance for Sewage Treatment Plants The provisions of this subpart apply to each incinerator that combusts wastes containing more than ten percent (I 0%) sewage sludge (dry basis) produced by municipal sewage treatment plants, or each incinerator that charges more than I 000 kg (2205 lb) per day municipal sewage sludge (dry basis) and that commences construction or modification after June 11, 1973. Since incinerators #1-#5 (EU001 O-E0050) were constructed in 1967, the requirements of this subpart would not apply. Whereas incinerator #6 (EU0060) installed/constructed in 1991 is subject to the requirements of this subpart. MACT Applicability 10 CSR 10-6.075, Maximum Achievable Control Technology Regulations 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. 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 five percent (5%) by weight, as a cleaning and/or drying agent. Wipe cleaning activities, such as using a rag containing halogenated solvent are not covered under the provisions of this subpart. The permittee has Safety-Kleen unit which does not use halogenated solvents as defined in 40. CFR 63.460, therefore the unit is not subject to the MACT standards for halogenated solvent cleaning. NESHAP Applicability 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants 40 CFR Part 61, Subpart C, National Emission Standard/or 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 five percent (5%) beryllium by weight. The permittee has six (6) incinerators (EUOO 1 O-EU0060) which bum beryllium containing sewage sludge, therefore the incinerators are subject to the NESHAP standard for beryllium. MSD -Bissell Point Plant Installation ID: 510-0053 SB-4 Project No. 1997-05-008 40 CFR Part 61, Subpart E, National 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 six (6) incinerators (EUOOIO- EU0060) which burn dry wastewater treatment plant sludge, therefore the incinerators are subject to the NESHAP standard for mercury. 40 CFR Part 61, Subpart M: National Emission Standard for Asbestos This regulation applies to the installation because of policy made by the department that this subpart will apply to all Part 70 sources. Other Regulatory Determinations I) 10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes a) The following are calculations of particulate emissions from EU0070 and EU0080 that show that the units do not exceed the emission limits for particulate matter: EU0070-Drv Incinerator Ash Storage wlbaghouse and scrubbers Process Weight rate (P) = 15 tonlhr Exhaust Stack Temperature (T) Exhaust Flow Rate = 100'F = 75,000 ACFM SCFM = ACFM x 5280 R 70,714 SCFM T°F +460° R Emission Limit (lblhr) = 4.1P 0·67 = 4.1 x 15°·67 = 25.16lb PM/hr Emission Factor (controlled)= 0.008lb PM/ton (Fire-SCC 30500617) ( ) lb ton lb PM Emission lb/hr = 0.008-x 15-= 0.12- ton hr hr PM Concentration= [ 0.12:. x 7000 ~~ J + [ 70,714scfrnx 60 :n J = 1.97E-4grl scf EU0080-Wet Ash Conveying w/venturi scrubber and mist eliminator Process Weight rate (P) = 15 tonlhr Exhaust Stack Temperature (T) = 90'F Exhaust Flow Rate = 15,000 ACFM SCFM = ACFM x 5280 R 14,400 SCFM T°F +460° R Emission Limit (1blhr) = 4.1P0·67 = 4.1 x 15°67 = 25.16lb PM/hr Emission Factor (uncontrolled)= 32 1b PM/ton (Fire-SCC 30500717) ( ) lb ton ( ) ( ) lb PM Emission 1b/hr = 32-X 15-X 1-0.99 X 1-0.75 = 1.2- ton hr hr PM Concentration= [1.2::; x 7000 ~~ J + [14,400scfrnx 60 ~ J = 9.72E -3gr/scf --. ·---·····---· MSD -Bissell Point Plant Installation ID: 510-0053 b) Sand Blaster and Paint Spray Booth SB-5 Project No. 1997-05-008 The particulate matter potential emissions from the operation of the sand blaster and small parts spray paint operation are 0.0011bslhr and 0.0841bslhr, respectively. Since these units potentially emit less than one-half (0.5) pounds of particulate matter per hour they are exempt from the requirements of this rule. [10 CSR 10-6.400(1)(B)11.]. 2) 10 CSR 10-5.330, Control of Emissions from Industrial Surface Coating Operations. MSD does operate small parts spray booth, but for this rule to apply, the installation's actual emissions must be greater than two and one-half (2.5) tons in any calendar year after December 1, 1989 ofVOCs from surface coating operations covered under this rule. Annual paint usage= 10 gallons at 8.3 lbs ofVOC per gallon of paint, VOC Emission= (1 0 gal x 8.3 lbs/gal) x 0.0005 ton!lb = 0.04 ton/year MSD's actual emissions are much lower than the applicability threshold of2.5 tons per calendar year, therefore this rule does not apply to the small spray booth. 3) 10 CSR 10-6.260, Restriction of Emission ofSulfor Compounds. Compliance Determination for EU0010 through EU0060 (Sulfur Dioxide Concentration Calculations for Incinerators #1 through #6): 10 CSR 10-6.260 limits the S02 concentration from incinerators 1-5 to 2000 ppmv (existing source- installed in 1967) and for Incinerator #6 to 500 ppmv (new source-installed in 1991). The so2 concentration from incinerators 1-6 would not exceed the 2000 ppmv and 500 ppmv S02 concentrations respectively, under any circumstances, as shown below. The S02 emission factor used-0.2 lbs/ton of dry sludge is from AP-42 (for incinerators 1-5) and incinerator 6 was stack tested for the S02 emission rate and concentration. EUOO 10 -Incinerator # 1 tons c:hy sludge lbs S02 1 year lbs so 2 Emission Rate= 12,868 x 0.2 x = 0.3- year ton c:hy sludge 8736 hrs hr Flow Rat (from stack test report) = 14.200 scfm (ave.) = 852,000 cu-ft/hr 0.3lbs/hr EmissionRate(lbs/cu-ft) = = 3.52E-07 lbs/cu-ft 852,000 cu -ft/hr ( . ) [385.1 x 106 cu-ft/mole l :.S02 concentationinppmv(@ 20°C) = 3.52E -'07lbs/cu-ft X = 2.20 ppmv 64lbs I mole(mol wt) MSD -Bissell Point Plant Installation ID: 510-0053 EU0020 -Incinerator #2 SB-6 Project No. 1997-05-008 tons chy sludge lbs 802 1 year lbs so2 Emission Rate= 2.412 x 0.2 x = 0.06- year tonchys1udge 8736hrs hr Flow Rat (from stack test report)= 11.900 scfm(ave.) = 714.000 cu-ft/hr 0.06lbslhr EmisslonRate(lbslcu-ft) = = 8.40E -08lbslcu-ft 714,000 cu-ft/hr ( ) ( 385.1x106 cu-ftlmole) :.S0 2 concentationlnppmv(@ 20°C) = 8.40E-08lbslcu -ft x = 0.51ppmv 64lbslmole(mol wt) EU0030 -Incinerator #3 tons chy sludge lbs so2 1 year lbs S02 Emission Rate= 8,821 x 0.2----=--x = 0.21- year tonchysludge 8736hrs hr Flow Rat (from stack test report) = 13,100 scfrn (ave.) = 786,000 cu-ft/hr 0.2llbslhr Emission Rate (lbslcu-ft) = = 2.67E-07 lbslcu-ft 786,000 cu-ftlhr ( ) ( 385.1x106 cu-ftlmole) :.802 concentationlnppmv(@ 20°C) = 2.67E-07lbs/cu-ft x = 1.6lppmv 64lbslmole(mol wt) EU0040 -Incinerator #4 tons chy sludge lbs 802 1 year lbs 802 Emission Rate= 2,853 X 0.2----=--X = 0.07- year tonchysludge 8736hrs hr Flow Rat (from stack test report) = 12,100 scfrn (ave.) = 726,000 cu-ft/hr 0.07lbslhr Emission Rate (lbs I cu -ft) = = 9. 64E -08 lbs I cu -ft 726,000 cu-ftlhr ( ' ) (385.1 x 106 cu-ftlmole) :.802 concentationlnppmv(@ 20°C] = 9.64E-08lbs/cu-ft x = 0.06ppmv 64lbslmole(mol wt) ---·-···------------------------------~ .... MSD -Bissell Point Plant Installation ID: 510-0053 SB -7 Project No. 1997-05-008 EU0050 -Incinerator #5 tons dry sludge lbs so2 1 year lbs S02Emlss!onRate=6,773 x0.2 x =0.16- year tondrysludge 8736hrs hr Flow Rat (from stack test report) = 12,400 scfm (ave.)= 744,000 cu-ft/hr 0.16lbs/hr Emlss!onRate(lbs/cu-ft) = = 2.15E-07 lbsjcu-ft 744,000 cu-ft/hr ( ) ( 385.1 x 106 cu-ft/mole) :.so 2 concentatlon!nppmv(@ 20°C) = 2.15E -07lbs/cu-ft x = 1.30 ppmv 64lbs/mole(mol wt) EU0060 -Incinerator #6 tons dry sludge lbs so2 1 year lbs S02 Emission Rate= 7,710 X 0.2 X = 0.18- year ton dry sludge 8736 hrs hr Flow Rat (from stack test report) = 18.400 scfm(ave.) = 1,104.,000 cu-ft/hr 0.18lbs/hr Emission Rate (lbsjcu-ft) = = 1.63E-07 lbs/cu-ft 1.104,000 cu-ft/hr ( ) ( 385.1xl06 cu-ft/mole) :.so 2 concentatlon!nppmv(@20°C) = 1.63E-07lbs/cu-ft x = l.OOppmv 64lbs/mole(mol wt) 4) To satisfy/comply with the requirements of the standards for the use and disposal of sewage sludge, including the NSPS, NESHAP and construction permit conditions the permittee has conducted performance tests on the incinerators. The tests were done at various dates/years. The following is the summery of the test results: Particulate Matter (PM) and Visible Emissions Particulate Matter Visible Emission Allowable Average Allowable Rate Average Test Result Rate Test Result Emission Lb/ton dry Lb/ton dry Unit Test Date Gr/dscf sludg~e Gr/dscf sludge (%) (%) EUOO!O May 18 2000 0.08 1.3 0.019 1.222 20 17.16 EU0020 Mav 16 2000 0.08 IJ 0.023 1.011 20 11.87 EU0030 Nov 14 2000 0.08 1.3 0.013 0.71 20 7.8 EU0040 Nov 15 2000 0.08 1.3 0.016 0.61 20 2.2 EU0050 Nov 16,2000 0.08 1.3 O.DI5 0.78 20 5.1 EU0060 July 2,1997 0.08 1.3 0.019 1.017 20 4.3 Mercury, B~lium and Total Hvdrocarbon {THC) Emissions Mercury (All Incinerators Combined) Beryllium THC Allowable Average Test Allowable Average Test Allowable Average Test Emission Rate* Result Rate Result Rate Result Unit Test Date (gr<~ms/24 hr) ( orams/24 hr) (grams/24 ho) (grams/24 ho) (ppmv**) (ppmv**) EU0010 May 18 2000 11.10 10 NID 100 74.27 EU0020 May 16,2000 NID 10 N/D 100 58.53 EU0030 Nov 14,2000 N/D 10 NID 100 75.40 EU0040 Nov 15 2000 N/D 10 N/D 100 56.68 MSD -Bissell Point Plant Installation ID: 510-0053 Mercury, Beryllium and Total Hydrocarbon (THC) Emissions Mercury SB-8 Project No. 1997-05-008 (All Incinerators Combined) Benllium THC .Allowable Average Test Allowable Average Test Allowable Emission Rate* Result Rate Result Rate Unit Test Date (grams/24 hr) (grams/24 hr) (grams/24 ho) (grams/24 ho) _(ppmv**) EU0050 Nov 16, 2000 NID 10 NID 100 EU0060 July 2, 1997 NID 10 NID 100 • All mcmerator combmed allowable Mercury etrusswn rate-3,200 grams over a 24-hour penod •• THC concentration corrected for 0% moisture and 7% oxygen NID = Non detectable 5) 10 CSR 10-5.080, Incinerators Average Test Result Jppmv**) 55.58 22.40 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 for the particulate matter standard of this rule is less stringent than the construction permit (Permit No. 95- 05-068) and the NSPS Subpart 0 standards. Compliance with the construction permit and the NSPS will ensure compliance with this rule. 6) St. Louis City Ordinance 64749 §18, Incinerators Though the installation is subject to the requirements of this rule, it is not included in the operating permit for the standards for incinerators of this ordinance are less stringent than the construction permit (Permit No. 95-05-068) and the NSPS Subpart 0 standards. Compliance with the construction permit and the NSPS will ensure compliance with this ordinance. 7) 10 CSR 10-6.065(3)(0), Operating Permits The installation has reported combustion units of varying size listed in the table below as insignificant emission units. All of these combustion units emit only combustion products, produce less than one hundred fifty (150) pounds per day of any air contaminant and have a maximum rated capacity of less than ten (1 0) million British thermal units (BTUs) per hour heat input by using exclusively natural gas and/or propane. The APCP has determined that units such as these are not necessary to include in the operating permit. EP# Description Fuel Type* Maximum Heat lnput (MMBTU/hr) 17 Sludge Building Boiler 4 Natural Gas 0.63 21 Four Direct Fired Heaters Natural Gas 0.85 (each) 24 Four (4) Water Heaters Natural Gas 0.75 (total) * Propane w1ll be used for emergency back-up fue\. 8) The following is the list of storage tanks which are identified as insignificant activities at the time of permit issuance. None of the storage tanks at this installation are large enough for 40 CFR 60 Subparts K, Ka and Kb regulations to apply. EPll Underground Diesel Tank, 550 gallons EP12 Back-up Underground Diesel Tank, 1000 gallons 9) EU0150 through EU0180-Six Natural Gas Fired Boilers (each less than 10 MMBtu/hr): 10 CSR I 0-6.260 and 10 CSR 10-5.030 are applicable to the boilers. However, the emissions of particulate matter or sulfur compounds from firing natural gas would never be expected to exceed the requirements of these rules. Therefore, these rules are not listed as specific for these boilers. ----------------- MSD -Bissell Point Plant Installation ID: 510-0053 SB-9 Project No. 1997-05-008 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 (1) 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; 5. The rule is only for administrative purposes. Should a later determination conclude that the installation is subject to one (1) 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). Prepared by: Environmental Engineer