HomeMy Public PortalAboutExhibit MSD 84L8 - Federal Clean Air Act Emissions - Lemay Wastewater Treatment PlantSTATE OF ,\!ISSOlJHI
DEPARTMENT OF NATURAL RESOURCES
---[)JVISIO~ Ul' ENVIRONME:\'L\L l~UAI.IT\ ------
PO. Box 176 JcHI:rsonCiry. ),10 (J)!02-Ul~(J
PERMIT TO OPERATE
Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to
operate the air contaminant source(s) described below, in accordance with the laws, rules, and
conditions set forth here in.
Operating Permit Number: OP2000100
Expiration Date: Novenber 1, 2005
Project Number: 1998-07-071
Installation Name and Address
Lemay Wastewater Treatment Plant
201 Hoffmeister Avenue
St. Louis, MO 63125-1607
St. Louis County
Parent Company's Name and Address
Metropolitan St. Louis Sewer District
201 Hoffmeister Avenue
St. Louis, MO 63125-1607
Installation Description:
The installation is a 167 mgd wastewater treatment plant with four (4) sludge
multiple hearth incinerators with afterburners and scrubbers. Dry ash from
the incinerators is conveyed to storage, while wet ash is conveyed to basins.
Other emission units at this facility include pipeline natural gas fueled
boilers, an emergency generator, water heaters, a parts washer, fuel storage
tanks, paint spray booths and a sand blaster. The installation emits major
levels of carbon monoxide (CO) and has the Potential to Emit (PTE) major
amounts of nitrogen dioxide (NOx).
NOV 01 2000 & iJ,lft:.v~,....--
Effective Date
Department of Natural Resources
Exhibit MSD 84L8
STATF OF ~IISSOl'Rl
DEPARTMENT OF NATURAL RESOURCES
---DI\'ISION OF I 'NIRON,\IE'\'1~\L <~U.\LITY -----
I~O. Box 17() jdfc'f.~Oll City. \10 ()')]02-0!-(J
Novanber 1, 2000
Metropolitan St. Louis Sewer District
20 I Hoffmeister A venue
St. Louis, MO 63 I 25-I 607
Re: Lemay Wastewater Treatment Plant
St. Louis, MO 63125-1607, St. Louis County
Permit Number: OP2000108
Dear Sir/Madam:
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.
If you have any questions or need additional information regarding this permit, please
contact the Air Pollution Control Program (APCP) at (573) 75 I -4817, or you may write
to the Department of Natural Resources, Air Pollution Control Program, P .0. Box 176,
Jefferson City, MO 65102.
Sincerely,
~"<N' CONTROL PROGRAM
r
RER:jhc
Enclosures
c: US EPA Region VII
St. Louis Regional Office
PATs File: 1998-07-071
0 It,., ... ,.,., ..•• ~ .•
---------------
Lemay Wastewater Tn .. ment Plant
Project No. 1998-07-071
Table of Contents
2
I. INSTALLATION DESCRIPTION AND EQUIPMENT LISTING ...................••.•.....•.•................... .4
INSTALLATION DESCRIPTION ............................................................................................... 4
EMISSION UNITS WI1H LIMITATIONS ................................................................................... 4
EMISSION UNITS WITHOUT LIMITATIONS ............................................................................ 4
DOCUMENTS INCORPORATED BY REFERENCE .................................................................. 4
II. PLANT WIDE EMISSION LIMITATIONS ..••...•••.••..•..•....•...••...•..........•..• , ••..•..•..••.•...••...... 5
Permit Condition PWOO 1 ....................................................................................................... 5
• 10 CSR 10-6.080 ...................................................................................................................................... 5
• 40 CFR Part 61 Subpart M ....................................................................................................................... 5
Permit Condition PW002 ....................................................................................................... 5
• 10 CSR 10-6.250 ...................................................................................................................................... 5
Permit Condition PW003 ....................................................................................................... 6
• 10 CSR 10-5.090 and 10 CSR 1 0-6.220 .................................................................................................... 6
Permit Condition PW004 ....................................................................................................... 7
• IOCSRI0-5.290 ...................................................................................................................................... 7
Permit Condition PW005 ....................................................................................................... 8
• 10 CSR 10-5.250 ...................................................................................................................................... 8
Permit Condition PW006 ....................................................................................................... 8
• 10 CSR 10-5.443 ...................................................................................................................................... 8
Permit Condition PW007 ....................................................................................................... 8
• 10 CSR 10-5.040 ...................................................................................................................................... 8
Permit Condition PW008 ....................................................................................................... 9
• 10 CSR 10-6.260[4) .................................................................................................................................. 9
III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ........................ , .............................. 1 0
EUOOIO .............................................................................................................................................................. 10
Permit Condition EU0010-001 ............................................................................................. 10
• 10 CSR 10-5.050 and 10 CSR 10-6.400 .................................................................................................. 10
Permit Condition EU0010-002 ............................................................................................. 11
Permit Condition EU0010-003 ............................................................................................. 11
• 10 CSR 10-6.080 .................................................................................................................................... II
• 40 CFR Part 61 Subpart C ...................................................................................................................... II
Permit Condition EU0010-004 ............................................................................................. 12
• I 0 CSR I 0-6.260[3) ................................................................................................................................ 12
Permit Condition EU0010-005 ............................................................................................. 12
• 10 CSR I0-6.080 .................................................................................................................................... 12
• 40 CFR Part 61 Subpart E ........... .-......................................................................................................... 12
EU0020 .............................................................................................................................................................. 13
Permit Condition EUOOZ0-001 ............................................................................................. 13
• 10 CSR 10-6.070 .................................................................................................................................... 13
• 40 CFR Part 60 Subpart 0 ...................................................................................................................... 13
Permit Condition EU0020-002 ............................................................................................. 14
Permit Condition EUOOZ0-003 ............................................................................................. 15
• I 0 CSR I 0-6.260(3) ................................................................................................................................ 15
Permit Condition EU0020-004 ............................................................................................. 15
• 10 CSR I0-6.080 .................................................................................................................................... 15
• 40 CFR Part 61 Subpart E ...................................................................................................................... l5
Permit Condition EU0020-005 ............................................................................................. 16
• 10 CSR I0-6.080 .................................................................................................................................... 16
• 40 CFR Part 61 Subpart C ...................................................................................................................... 16
EU0030 .............................................................................................................................................. ~ ............... 16
Permit Condition EU0030-00 1 ............................................................................................. 16
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
3
• 10 CSR 10·5.050 and I 0 CSR 10-6.400 .................................................................................................. I6
EU0040 .............................................................................................................................................................. I7
Permit Condition EU0040-00 1 ..........•...................................••.........•••.......••........••...•.........• 17
• 10 CSR I 0-5.050 and I OCSR 10-6.400 ................................................................................................... 17
EU0050 .............................................................................................................................................................. I7
Permit Condition EU0050-00 1 ...............................................•............................................. 17
• I 0 CSR I 0-5.220 ...................................................... , .............................................................................. I 7
EU0060 .............................................................................................................................................................. 18
Permit Condition EUOOG0-001 ......•................••........................................................•••......... 18
• IO CSR I0-5.180 .................................................................................................................................... I8
EU0070 .............................................................................................................................................................. 19
Permit Condition EU0070-00 1 .......•.•............•.•...•..............•...........•...........•.........•............... 19
• 10 CSR 10-5.050 and I 0 CSR 10-6.400 .................................................................................................. 19
EU0080 .............................................................................................................................................................. 19
Permit Condition EUOOS0-001 ...••...••••......•....•.•...••......•........•...........•........•••........•....•..•...... 19
• 10 CSR 10-5.050 and 10 CSR 10-6.400 .................................................................................................. I9
EU0090 .............................................................................................................................................................. 20
Permit Condition EU0090-00 1 ...••.....•.••.....•....•••....•••....•..•.•.......•.........•.•.......•.......••....•.•...•. 20
• 10 CSR 10-5.300 .................................................................................................................................... 20
EUOI00 .............................................................................................................................................................. 21
Permit Condition EU0100-001 .........•.......•.....••....•.......••......•.......•.........••.......••.....••••...••..... 21
• 10 CSR 10-5.050 a.Ild IOCSR 10-6.400 ................................................................................................... 21
IV. CoRE PERMIT REQUIREMENTS ..••••.••.••••..•••••••••.•••••.•••••••.•.••..•••••••••••••••••••••••••••.••••. 23
v. GENERAL PERMIT REQUIREMENTS .••.•••.....•...••.••••.••.•••..•.••......•..•.•••••.•.•.••••••••••••••••• 29
PERMIT DURATION ...........••.....•.....••....•.......•....•.••.••••....•.............••••.......••.......••..•..•••.....••...•••. 29
GENERAL REcoRD KEEPING AND REPORTING REQUIREMENTS ..•...•...........•.............•••....•••.•...•••••. 29
RISK MANAGEMENT PLANS UNDER SECTION 112(R) ..................•.................•.......••.......•.•.....•....•. 30
SEVERABILI1Y ClAUSE ..... ···•··· ............................••.....•.....••......•........... ······••·.···•·••····· .••.....••••. 30
GENERAL REQUIREMENTS ..•..•••....•.....•......••.....•....•.•..•••.....•.•..•.••.................•.......•••.....•....•••••• 30
INCENTIVE PROGRAMS NOT REQUIRING PERMIT REVISIONS ..•••..•...••.......•.......•••.....•••.•..•.••....••••.. 31
REASONABLY ANTICIPATED OPERATING SCENARIOS ....••.•............•.....••..•........••.....•••....••......•...•.. 31
Tl1LE IV ALLOWANCES ......•••....•.....•....•.............•....••.....•.......••....••..........•......••......••.......•....•.• 31
EMISSIONS TRADING .....•..•...••••...••...••....•............••...•.••......••...•.................•.•....••....••.•.....•••..•.. 31
COMPLIANCE REQUIREMENTS ...•.••...•....•......•.....••••.•••...•••....••....•.•.......•.•••....•......•••....•.....•••.... 31
PERMIT SHIELD ...•.........•......•.•.........•.....•..........•.•.....•.....•.....••......•.......•••.....•......•....•..••....•••. 32
EMERGENCY PROVISIONS ........•.......................•.......••........•..................••.....•.•....••.....•••........... 33
OPERATIONAL F'LEXIBILI1Y ..........••...•.....•...........•....•......••....••.....••...••..••............•....••......••...••.• 33
OFF-PERMIT CHANGES ..•.••.....•.........•.....•......•.....••...•.•...•••....•.....••.....•.•......•..•..........••....•...•.. 34
RESPONSIBLE OFFICIAL .•.....•......•...•....•......•.....••...•.....•••....•.•....•......•.......•.......•...••.•....•....••.... 34
STATEMENT OF BASIS ....•••...••...••..•••...•.....••••....••..•••....•......••....•....•........................................ 35
• Attachment A ......................................................................................................................................... 36
• Attachment B ......................................................................................................................................... 37
Lemay Wastewater Tn __ cment Plant
Project No. 1998-07-071
I. Installation Description and Equipment Listing
INSTALLATION DESCRIPTION
4
The installation is a 167 mgd wastewater treatment plant With four (4) sludge multiple
hearth incinerators With afterbumer and scrubbers. Dry ash from the incinerator is
conveyed to storage, while wet ash is conveyed to basins. Other emission units at this
facility include pipeline natural gas fueled boilers, an emergency generator, water heaters, a
parts washer, fuel storage tanks. paint spray booths and a sand blaster. The installation
emits major levels of carbon monoxide (CO) and has the Potential to Emit (PTE) major
amounts of nitrogen dioxide (NOx).
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
EU0050
EU0060
EU0070
EU0080
EU0090
EU0100
Description of Emission Unit
3 Multiple Hearth Incinerators, Under construction on 3/24/67;
Multiple Hearth Incinerator, 1983;
Dry Incinerator Ash Conveying & Storage, 1968;
Wet Ash Conveying, 1983;
3 Underground Gasoline Storage Tanks, 550 gallons capacity each;
340 hp Emergency Generator, Pipeline Natural Gas fired
Paint Spray Booth, 14.4 gallons/hr. water curtain type. 1978
Paint Spray Booth, 0. 75 gallon/hr. filter type. 1978
Parts Washer (25 gallon capacity). 1,000 gallons/year usage.
Sand Blaster
EMISSION UNITS WITHOUT LIMITATIONS
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
Wastewater Treatment System, 160 mgd
1\vo (2) Pipeline Natural Gas fired Boilers, 12.5 MMBtu/hr each, 1980
Four (4) Pipeline Natural Gas Fired Water Heaters, 1.76 MMBtu/hr total--exempt.
550-gallon underground diesel fuel oil storage tank
DOCUMENTS INCORPORATED BY REFERENCE
These documents have been incorporated by reference into this permit.
1) St. Louis County Department of Health Operating Permit #5768.
2) St. Louis County Department of Health Operating Permit #5365.
3) Letter from Mr. Donald Toensing, Chief, Air Permitting & Compliance Branch, EPA
Region VII, Dated February 7, 2000, granting the waiver of emission testing for CFR Part
61, Subpart C, National Emission Standard for Beryllium for Incinerators #1 and #3.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
II. Plant Wide Emission Limitations
5
The installation shall comply with each of the following emission limitations. Consult the
appropliate sections in the Code of Federal Regulations (CFR) and Code of State
Regulations (CSR) for the full text of the applicable requirements.
Permit Condition PWOO I
• lO CSR 10-6.080
Emission Standards for Hazardous Air Pollutants
• 40 CFR Part 61 Subpart M
National Emission Standard for Asbestos
Emission Limitation:
The pennittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for
any actiVities occuning at this installation which would be subject to proVisions for 40 CFR
Part 61, Subpart M. National Emission Standard for Asbestos.
Monitoring:
Any appropriate monitming to demonstrate compliance With registration, certification,
notification, and Abatement Procedures and Practices standards as specified in 40 CFR Part
61, Sub~art M.
Record keeping:
Any appropriate record keepin~ as specified in 40 CFR Part 61, Subpart M.
Reporting:
Any appropriate reportin~ as SIJ_ecified in 40 CFR Part 61. Subpart M.
Permit Condition PW002
• 10 CSR 10-6.250
Asbestos Abatement Projects -Certification, Accreditation, and Business Exemption
Requirements
Emission Limitation:
The permittee shall conduct all asbestos abatement projects within the procedures
established for certification and accreditation by 10 CSR 10-6.250.
• An indiVidual must receive certification from the department before that IndiVidual
participates in an asbestos abatement project operating in Missouri according to Section (3).
This certification is annually renewable. Certification as an AHERA inspector, AHERA
management planner and AHERA project designer apply to AHERA-related projects.
• To be a training proVider for the purpose of this rule a school shall apply for accreditation to
the department and comply with the United States Environmental Protection Agency AHERA
Model Accreditation plan 40 CFR part 763 Appendix C, subpart E. Details of the
requirements for accreditation are found in Section (4).
Monitoring:
Any appropriate monitoring to demonstrate compliance With Certification and Accreditation
standards.
Record keeping:
Any appropriate record keeping to demonstrate compliance With Certification and
Accreditation standards.
Reporiing:
Any appropriate reporting to demonstrate compliance With Certification and Accreditation
standards.
Lemay Wastewater TrL-cment Plant
Project No. 1998-07-071
6
Permit Condition PW003
• 10 CSR 10-5.090 and 10 CSR 10-6.220
Restriction of Emission of Visible Air Contaminants
Emission Limitation:
No person may discharge into the ambient air from any single new source of emission whatsoever,
any air contaminant:
• Of a shade or density equal to or darker than that designated as No. 1 on the Ringlemann
chart or 20% opacity.
• Exception: A person may discharge into the atmosphere from any single source of emissions
for a period(s) aggregating not more than six (6) minutes in any sixty (60) minutes air
contaminants of a shade or density not darker than No. 2 on the Ringlemann Chart or 40%
opacity.
This rule applies to emissions from Stack No. I only when Incinerator No. 4 is not online.
Monitoring:
• The permittee shall conduct opacity measurements on this emission unit using the procedures
contained in USEPA Test Method 22. Readings are only required when the emission unit is
operating and when the weather conditions allow. If no Visible or other significant emissions
were observed, then no further observations would be required at that reading. 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.
• The following monitoring schedule must be maintained:
1. Weekly 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-
2. Observations must be made once evecy two 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-
3. Observations must be made once per month. If a Violation is noted, monitoring reverts to
weekly.
• If the source reverts to weekly monitoring at any time, monitoring frequency will progress in
an identical manner from the initial monitoring frequency.
• The ~rmittee shall conduct an annual opacity measurement on the emission unit by USEPA
Test ethod 9 with a certtfied Method 9 observer.
Record keeping:
• The permittee shall maintain records of all observation using Attachment A or another form
proViding equivalent information noting:
l. Whether any air emissions (except for water vapor) were Visible from the emission units,
2. All emission units from which Visible emissions occurred, and
3. Whether the Visible emissions were normal for the process.
• The permittee shall maintain records of any equipment malfunctions that cause a Violation of
this permit condition.
• The permittee shall maintain records of the annual USEPA Method 9 opacity test and any
other Method 9 test performed in accordance with this permit condition.
• All records will be retained for a minimum of 60 consecutive months .
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the Air Pollution Control Enforcement Section, P.O. Box
176, Jefferson City, MO 65102, no later than 15 days after any exceedance of the opacity limit
established by 10 CSR 10-5.090 or 10 CSR 10-6.220, based upon any USEPA Method 9 Visual
Observations or any malfunction that causes an opacity exceedance.
10 CSR 10-6.220 is a State-only rule. 10 CSR 10-5.090 expires and 10-6.220 becomes federally
enforceable when 10-6.220 is ap-proved for the State Implementation Plan
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
Permit Condition PW004
• lO CSR 10-5.290
7
More Restrictive Emission Limitations for Particulate Matter in the South St. Louis Area
Emission Limitation:
• No person may cause or permit the handling, transporting, or storage of any material in a
manner which allows particulate matter to become airborne in quantities and concentrations
that-!) it remains visible in the ambient air beyond the premises where it originates or 2) its
presence may be found beyond the premises where it oliginates and it is larger than forty (40)
microns in size. The size of the particulate matter shall be determined by microscopy or any
other technique proven to be equally accurate.
• No person may cause or permit a building or its appurtenances, a road, a driveway, a parking
lot. or an open area to be constructed, used, repaired, or demolished without applying all
reasonable measures as may be required to prevent particulate matter from becoming
airborne. The director may require a person owning, operating, or otherwise in control of the
building, appurtenance. road, driveway, parking lot, or open area to take reasonable
measures as may be necessary to prevent particulate matter from becoming airborne
including, but not limited to. paving or frequent cleaning of roads. driveways, and parking
Jots. application of dust-free surfaces, application of water. and the planting and maintenance
of vegetative ground cover or buffer zones.
• No person may emit into the ambient air from any air contaminant source fugitive emissions
greater than that which would be emitted after application of all reasonably available control
technologies and all reasonable maintenance of plant and equipment.
Monitoring:
The permittee shall conduct inspections of its installation 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:
Weekly 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-
• Observations must be made once every two weeks for a period of eight (8) weeks. If a
violation is noted, monitoling reverts to weekly. Should no violation of this regulation be
observed during this peliod, then-
• Observations need be done no more often than once per month. If a violation is noted.
monitonng reverts to weekly.
If the source reverts to weekly monitoring at any time. monitoring frequency will progress in
an identical manner to the initial monitoring freguency.
Record keeping:
A Jog must be maintained noting the following:
• Whether air emissions ( except water vapor) remain visible in the ambient air beyond the
property line of oligin.
• Whether the visible emissions were normal for the installation.
• Equipment malfunctions that could cause an exceedance of 10 CSR 10-5.290.
• Any violation of 10 CSR 10-5.290 and any corrective actions taken to correct the violation
Attachment B 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.
All records must be maintained for a minimum of 60 consecutive months.
Lemay Wastewater Tre~-ment Plant
Project No. 1998-07-071
8
Reporting:
0
The pennittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the Air Pollution Control Enforcement Section, P.O. Box
l 76. Jefferson City, MO 65 I 02, no later than 15 days after any exceedance of any of the
terms imposed by this regulation, or any malfunction that causes an exceedance of this
regulation.
Permit Condition PW005
10 CSR 10-5.250
Time Schedule for Compliance
Emission Limitation:
Except as otherwise specified, all new installations shall comply with regulations as of going
into operation.
Monitoring:
NONE
Record keeping:
NONE
Reporting:
NONE
Permit Condition PW006
0 10 CSR 10-5.443
Control of Gasoline Reid Vapor Pressure
Emission Limitation:
No person shall sell, dispense, supply, offer for sale, offer for supply, transport, or exchange
in trade for use gasoline intended for final use in the applicable areas that exceeds the Reid
Vapor Pressure (RVP) limit as follows: 7.0 psi or less from June 1 through September 15.
Gasoline blends having at least nine percent (9%) but not more than ten percent (10%) ethyl
alcohol by volume of the blended mtxture shall have an RVP limit of one pound per square
inch {psi) higher than the above limit.
Monitoring:
NONE
Record keeping:
The pennittee shall maintain records of each bill of lading, invoice, loading ticket. delivery
ticket, and other documents accompanying a shipment of gasoline during the period from
June l through September 15 for at least 60 months after the date of delivery. These records
shall be made available immediately for inspection to St. Louis County Department of Health
personnel upon request. The director may require additional recordkeeping on a case-by-
case basis.
Reporting:
NONE
Permit Condition PW007
• 10 CSR 10-5.040
Use of Hand-fired Equipment Prohibited
Emission Limitation:
The p_ennittee shall not operate any_ hand-fired fuel burning equipment.
Monitoring:
None.
Record keepinq:
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
None. ReoamnG:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, lll South
9
Meramec, Clayton, MO 63105 and to the Air Pollution Control Enforcement Section, P.O. Box
l 76, Jefferson City, MO 65102. no later than 15 days after a violation of any of the terms
imposed by this regulation.
Permit Condition PW008
• 10 CSR 10-6.260(4)
Restriction of Emission of Sulfur ComDounds
Emission Limitation:
No person shall cause or permit the emission of sulfur compounds from any source which
causes or contJibutes to concentrations exceeding those specified in 10 CSR 10-6.010 Ambient
Air Qualitv Standards.
Monitoring:
Compliance shall be determined by source testing as specified 10 CSR 10-6.040 for measuring
ambient sulfur compound concentrations. (Ambient air modeling submitted with permit
application shows compliance for the entire facility with National Ambient Air Quality
Standards for both hvdrogen sulfide and sulfur dioxide.)
Record keeping:
The permittee shall retain the results of the Ambient Air Modeling showing compliance with
this regulation.
Reporting:
None.
10 CSR 10-6.260(4) is a state-only requirement
Lemay Wastewater Trt..ment Plant
Project No. 1998-07-071
10
III. Emission Unit Specific Emission Limitations
The installation shall comply with each of the folloWing emission limitations. Consult the
appropriate sections in the Code of Federal Regulations (CFR) and Code of State
Regulations (CSR) for the full text of the applicable requirements.
EUOOIO
3 Multiple Hearth Incinerators
General Description: Multiple Hearth Incinerator #1: tested at 2.45 tons/hour dry sludge,
Multiple Hearih Incinerator #2; tested at 2. 74 tons/hour dry sludge
Multiple Hearih Incinerator #3; tested at 2.17 tons/hour dry sludge
Each, with an afterburner and venturi and impingement scrubbers.
Manufacturer /Model #: Nichols Model 22'3" [11 hearths). 1968
EIQ Reference# (1998): EPL
Permit Condition EUOOI0-001
• 10 CSR 10-5.050 and 10 CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
The permittee shall not emit pariiculate matter in excess of 7.47 lbs/hr from Incinerator# 1
The permittee shall not emit pariiculate matter in excess of 8.06 lbs/hr from Incinerator #2
The permittee shall not emit pariiculate matter in excess of 6.89 lbs/hr from Incinerator #3
Whenever the incinerators are online the permittee shall not operate Incinerator # 1 or #3 at
less than 28 inches W.C. total pressure drop across the scrubbers averaged over 15 minutes
or Incinerator #2 at less than 27.3 inches W.C. total pressure drop averaged over 15 minutes.
Monitoring:
• The permittee shall continuously monitor the combined pressure drop across the scrubbers to
ensure that total pressure drop across the scrubbers, averaged for 15-minutes. never falls
more than 30% below the average pressure drop of inches W.C., recorded during the
performance test. The device to monitor the pressure drop shall be accurate within [:!: 1 inch
water guage) and callbrated annually in accordance With the manufacturer's instructions.
• The permittee shall monitor the scrubber flow rates of online incinerators to determine proper
nozzle functioning.
• The permittee shall inspect the venturi and impingement scrubber systems on at least a
quarterly basis for proper condition [nozzles, sheet metal, etc).
Record keeping:
• The permittee shall maintain records of the following:
1. The combined pressure drop across each scrubber set and scrubber flow rates.
2. Scrubber inspections, results and any maintenance performed.
3. These records shall be made available immediately to St. Louis Department of Health
personnel for inspection upon request. and shall be retained for 60 consecutive months.
• The ~rmittee shall retain copies of the stack tests showing compliance with 10 CSR 10-5.050 .
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and to the Air Pollution Control Enforcement Section, P.O. Box
176, Jefferson City, MO 65102, no later than 15 days after any malfunction that causes an
exceedance of 10 CSR 10-5.050. or after any event in which the recorded total pressure drop
across the scrubbers, averaged for 15-minutes, falls below that listed in Emission
Limitation.[30% below the average pressure drop recorded durin!! the performance test).
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federally enforceable and 10 CSR 10-5.050 will cease to au-olv.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
11
Permit Condition EUOOI0-002
St. Louis County Department of Health Chapter 612.110-Permit #5763 '1
Construction Permits Reauired '.....-
Emission Limitation:
One of the three (3) incinerators must be offline, whenever Incinerator #4 is online.
The throughput of dry sludge is not to exceed that level achieved during a successful
performance test for each incinerator.
Monitoring:
The oermittee shalllo!!: the ooeratin!!: times of each incinerator and the hourly throuahout.
Record keeping:
The permittee shall maintain an accurate record of when each incinerator is online and the
hourly throughput into each incinerator. These records shall be made available immediately
for inspection to St. Louis County Department of Health personnel upon request and shall be
retained for 60 consecutive months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102. no later than 15 days after any violation of the terms established by St. Louis
Countv Permit #5763.
Permit Condition EUOOI0-003
• 10 CSR 10-6.080
Emission Standards for Hazardous Air Pollutants
• 40 CFR Part 61 Subpart C
National Emission Standard for BeiTllium
Emission Limitation:
The permittee shall not emit to the atmosphere more than 10 grams of beryllium over a 24-
hour period. The burning of beryllium and/or beryllium-containing waste, except propellants.
is orohibited exceot in incinerators, emissions from which must comply With the standard.
Monitoring:
The permittee shall perform testing as specified in 40 CFR Part 61, § 61.33. (Incinerator #2
has already been tested and test results indicate compliance. Based on Incinerators #1 & #3
being identical in design to Incinerator #2, and burning the same sludge, the permittee has
received a waiver of the testing requirement from the EPA for # 1 and #3 Incinerators.)
The pressure drop monitoring required for permit condition EU0010-001 will suffice for this
oennit condition.
Record keeping:
Copies of emission test results shall be retained. Any other data needed to determine total
emissions shall be retained as specified in§ 61.33(e) for 60 consecutive months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and the APC Enforcement section, P.O. Box 176 Jefferson City,
MO 65102, no later than 15 days after any malfunction that causes an exceedance of the
emission limit established bv 40 CFR Part 61. § 61.32.
Lemay WastewaterTrt--cment Plant
Project No. 1998-07-071
12
Permit Condition EUOOI0-004
• l 0 CSR 10-6.260(3)
Restriction of Emission of Sulfur CompoWlds
Emission Limitation:
• Emissions from any existing source operation shall not contain more than two thousand parts
per million by volume (2000 ppmv) of sulfur dioxide.
• Emissions from any existing source operation shall not contain more than seventy milligrams
(70 mg) per cubic meter of sulfulic acid or sulfur tlioxide or any combination of those gases
averaged on any consecutive three hour time peliod.
• The emission units shall be limited to burning dry_ sludge or pipeline natural_g_as .
Monitoring:
Compliance shall be determined by source testing as specified in lO CSR 10-6.030(6) for
elllissions. [Stack testing results (for Incinerator #2) and emission calculations (for Incinerator
# l & Incinerator #3) using an AP-42 emission factor show compliance with the sulfur dioxide
elllission limit, with the maximum sulfur dioxide concentration being less than 50 ppmv for
each incinerator.)
Record keeping:
Stack test results and calculations showing compliance with 10 CSR 10-6.260(3) shall be retained.
These records shall be immediatelv available to SLCDOH personnel for inspection upon request.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction that causes an exceedance of the
emission limit established bv I 0 CSR l 0-6.260(3) or any violation of fuel limitations.
Permit Condition EUOOI0-005
• lO CSR 10-6.080
Emission Standards for Hazardous Air Pollutants
• 40 CFR Part 61 Subpart E
National Emission Standard for Mercury
Emisswn Limitation:
• Emissions to the atmosphere from sludge incineration plants. sludge drying plants, or a
combination of these that process wastewater treatment plant sludge. shall not exceed 3200
grams of mercury over a 24-hour peliod.
• No changes in the operation of this facility shall be made which would potentially increase
emissions above the level determined by the most recent sludge test until the new emission
level has been estimated by calculation and the results reported to the SLCDOH.
Monitoring:
• The permittee shall either perform testing as specified in 40 CFR Part 61, § 6l.53(d) or
demonstrate compliance using the methods and procedures specified in 40 CFR Part 61, §
61.54 (Sludge Sampling).
If emission level calculations or sludge tests (as noted above) show that mercury emissions
exceed 1,600 grams per 24-hour peliod, monitoling shall be performed at intervals of at least
once per year as specified in 40 CFR Part 61, § 6l.55(a). Note: Sludge testing is done on a
monthly basis at this installation.
Record keeping:
• Records of calculations, sludge sampling, charging rate determination and other data needed
to determine the mercury content of sludge at this facility shall be retained as specified in 40
CFRPart 61, § 6l.54(g) for 60 consecutive months. These records shall be made immediately
available to SLCDOH personnel for inspection upon request.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of the
emission limit established by_ 40 CFR Part 61. !:i 61.52(b).
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
EU0020
Multiple Hearth Incinerator
I3
General Description: Incinerator #4, tested at MHDR 2.36 tons/hour dried sludge. with an
afterburner and venturi and imome:ement scrubbers. I983.
Manufacturer/Model#: CEA Model 22' 3" (II hearths)
EIQ Reference# (1998): EPI.
Permit Condition EU0020-00 1
o 10 CSR 10-6.070
New Source Performance Regulations
o 40 CFR Part 60 Subpart 0
Standards of Performance for Sewlll!:e Treatment Plants
Emission Limitation:
The pennittee shall not emit particulate matter in excess of 1.30 lbs/dcy ton sludge input.
The pennittee may not discharge into the ambient air from this emission unit any gases:
of a shade or density equal to or darker than 20% opacity. This rule applies to emissions from
Stack I, whenever Incinerator No. 4 is operating.
The oennittee shall oerform testine: as soecified in 40 CFR Part 60, !'! 60.154.
Monitoring:
o The pennittee 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 ±5% over its
operating range. §60.153(a)( I)
o The pennittee shall provide access to the sludge charged so that a well-mixed representative
grab sample of the sludge can be obtained. §60.I53(a)(2).
o The pennittee shall install, calibrate, maintain, and operate a monitoring device that
continuously measures and records the pressure drop of the gas flow through the combined
system of wet scrubbers. The device 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 annually in accordance With the manufacturer's instructions. §60.I53(b)(I).
o The pennittee 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 monitor shall be certified by the manufacturer to have a relative
accuracy of ±5% over its operating range and shall be calibrated according to methods
prescribed by the manufacturer at least once each 24-hour operating period. §60.153(b)(2).
o The permittee shall install, calibrate, maintain, and operate temperature measuring devices at
evecy hearth in multiple hearth furnaces. A minimum of one thermocouple shall be installed
in each hearth in the cooling and dcylng zones and a minimum of two thermocouples shall be
installed in each hearth in the combustion zone. Each measuring device shall be certified by
the manufacturer to have an accuracy of ±5% over its operating range. §60.I53(b)(3).
o 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 ±5% over its operating range. §60.153(b)(4).
0 The permittee shall conduct opacity measurements and keep records on this emission unit as
described in the Monttorina and Record keeoina sections of Pennit Condition PW003 ..
Record keeping
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
14
• The following records shall be maintained as the particulate matter emission rate during the
performance test required under §60.154(d) was less than or equal to 0.75lb/ton dry sludge:
(l) The permittee shall maintain continuous accurate records of the measured combined
pressure drop of the flow through the wet scrubbing devices and a record of the annual
calibration of the pressure drop monitonng device. §60.153(c)(l).
(2) The permittee shall maintain continuous accurate records of the measured oxygen content
on a wet basis of the incinerator exhaust gas and a record of the daily calibration of the
oxygen monitoling device. §60.153(c)(2).
• The permittee shall maintain records of any equipment malfunctions.
• The permittee shall maintain records of the opacity observations.
• These records shall be made available immediately for inspection to St. Louis County
Department of Health personnel upon request and shall be kept for at least 5 years.
• Record keeping_ of opacity observations shall be as noted in Permit Condition PW003.
Reporting:
• A semi-annual compliance monitoling report which contains the following:
( 1) A record of the average scrubber pressure drop measurements for each peliod of 15
minutes duration or more during which the pressure drop reduction of the scrubber was
more than 30% from the average pressure drop recorded duling the most recent
performance test. [Based on the performance test conducted October 11, 1989, this
corresponds to an average scrubber pressure drop of Jess than 28.9 in. W.C.)
(1) A record of average oxygen content in the incinerator exhaust gas for each period of 1-hour
duration or more that the oxygen content of the incinerator exhaust gas exceeds the
average oxygen content measured duling the most recent performance test by more than
3%. [Based on the performance test conducted October 11. 1989. this corresponds to an
average oxygen content on a wet basis of more than 9.15%.)
• The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction that causes an exceedance of the
limits in 40 CFR 60. 152, or any violation of the terms of this regulation.
Pennit Condition EU0020-002
St. Louis County Department of Health Chapter 612.110 -Permit #5365
Construction Permits Reg_uired
Emission. Limitation:
• Throughput of dry sludge is not to exceed 6,400 Jbs/hour.
• One of the other three [3) incinerators [# 1, #2, or #3) must be offline. whenever this incinerator
is in operation.
Monitoring:
The permittee shall monitor the hourly throughput of dry sludge for the incinerator, as
required in Permit Condition EU0020-00 I , and the times of operating the incinerator online.
Record keeping:
The permittee shall maintain an accurate record of when each incinerator is online and the
hourly throughput into this incinerator. These records shall be made available immediately
for inspection to St. Louis County Department of Health personnel upon request, and shall be
retained for 60 consecutive months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of the rule
limit.
-----------
Lemay Wastewater 'Ireatment Plant
Project No. 1998-07-071
Permit Condition EU0020-003
• 10 CSR 10-6.260(3)
Restriction of Emission of Sulfur Compounds
Emission Limitation:
15
• Emissions from any new source operation shall not contain more than five hundred parts per
million by volume (500 ppmv) of sulfur dioxide.
• Emissions from any new source operation shall not contain 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 hour time period.
• The emission unit shall be limited to burnin~ drv sludge or pipeline natural gas .
Monitoring:
None.
Record keeping:
The permittee shall retain the calculations showing compliance with 10 CSR 10-6.260.
Reporiing:
The permittee shall report to the Air Pollution Control Section of the SLCDOH. Ill South
Meramec. Clayton, MO 63105, and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of the
redulation.
10 CSR 10-6.260 is a state-onlv reauirement
Permit Condition EU0020-004
• 10 CSR 10-6.080
Emission Standards for Hazardous Air Pollutants
• 40 CFR Part 61 Subpart E
National Emission Standard for Mercurv
Emission Limitation:
• Emissions to the atmosphere from sludge incineration plants, sludge drying plants, or a
combination of these that process wastewater treatment plant sludges, shall not exceed 3200
grams of mercury over a 24-hour period.
• No changes In the operation of this facility shall be made which would potentially increase
emissions above the level determined by the most recent sludge test until the new emission
level has been estimated bv calculation and the results reported to the SLCDOH.
Monitoring:
• The permittee shall either perform testing as specified in §61.53(d), or shall demonstrate
compliance using the methods and procedures specified in§61.54 (Sludge Sampling).
• If emission level calculations or monthly sludge tests (as noted above) show that mercury
emissions exceed 1,600 grams per 24-hour period. monitoring shall be performed at intervals
of at least once per year as specified in §61.55(a). Note. Sludge testing is done on a monthly
basis at this installation.
Record keeping:
Records of calculations, sludge sampling charging rate determination and other data needed to
determine the mercury content of sludge at this facility shall be retained as specified in
§61.54(g) for 60 consecutive months. These records shall be made immediately available to
SLCDOH nersonnel for inspection uoon reouest.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105, and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102. no later than 15 days after any malfunction causes an exceedance of the
emission limit established bv 40 CFR Part 61. a 61.52(b). · ·
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
Permit Condition EU0020-005
• 10 CSR 10-6.080
Emission Standards for Hazardous Air Pollutants
• 40 CFR Part 61 Subpart C
National Emission Standard for Beryllium
Emission Limitation:
16
The permittee shall not emit to the atmosphere more than 1 0 grams of beryllium over a 24-
hour period. The burning of beryllium and/or beryllium-containing waste, except propellants.
is prohibited except tn inctnerators, emissions from which must comply With the standard.
Monitoring:
The permittee shall perform testing as specified tn §61.33. (Incinerator #4 has been tested and
test results indicate compliance With the rule.
The total pressure drop monitoring required for pennit condition EU0020-00 I Will suffice for
this permit condition.
Record keeping:
Copies of emission test results shall be retained. Any other data needed to determine total
emissions shall be retained as specified in 40 CFR Part 61, § 61.33(e) for 60 consecutive
months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction that causes an exceedance of the
emission limit established bv 40 CFR Part 61. § 61.32.
EU0030
Drv Incinerator Ash Conveying & Storage
General Description: Dry Incinerator Ash Conveytng & Storage, w/Baghouse, 2.08
tons/hour, 1968
Manufacturer /Model #: Fuller Co.
EIQ Reference# (1998): EP3.
Permit Condition EU0030-00 1
• 10 CSR 10-5.050 and 10 CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
The permittee shall not emit particulate matter in excess of 6. 70 lbs/hr from this emission
unit.
Monitoring:
None. Calculations indicate the emission unit would always be expected to be in compliance
with 10 CSR 10-5.050.
Record keeping:
The permittee shall retain the stack test results shoWing compliance With this regulation.
These records shall be made available immediately for inspection to St. Louis County
Department of Health personnel upon request.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of 10 CSR
10-5.050.
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federally enforceable and 10 CSR 10-5.050 will cease to ap1Jlv.
-------------------~-------
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
17
EU0040
Wet Ash ConveYing
General Desclintion: Wet Ash Convevim!. 4.16 tons/hour. manufactured in 1983.
Manufacturer/Model#: CEA designed. Zimpro Inc. fablicated
EIQ Reference# (1998): EP4.
Permit Condition EU0040-00 1
• 10 CSR 10-5.050 and 10CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
The permittee shall not emit particulate matter in excess of 10.7lb/hr from this emission
unit.
Monitoring:
The continuous monitortng of the total pressure drop across the scrubbers of Incinerator #4,
as reouired in Permit Condition EU0020-001, suffices for this Permit Condition
Record keeping:
The permittee shall retain the calculations showing compliance with lO CSR 10-5.050.
The permittee's record keeping of the scrubber total drop in Permit Condition EU0020-00 1
suffices for this Permit Condition. The records shall be retained for 60 consecutive months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any exceedance of 10 CSR 10-5.050, or after any
event in which the recorded total pressure drop across the scrubbers falls below 28.91 in.
w.c.
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federally enforceable and 10 CSR 10-5.050 will cease to apply.
EU0050
3 Undentround Gasoline Storage Tanks
General Desclintion: 3 Underl!round Gasoline Storal(e Tanks, 550 l(allons capacity each.
Manufacturer/Model#: None.
EIQ Reference# (1998): EP7.
Permit Condition EU0050-001
• 10 CSR 10-5.220
Control of Petroleum Liquid Stora.l!e, Loadine:, and Transfer
Emission Limitation:
No owner or operator of a gasoline storage tank shall cause or permit the transfer of gasoline
from a delivery vessel into a gasoline storage tank with a capacity greater than 500 gallons
unless-
The storage tank is equipped with a submerged fill pipe extending unrestricted to within 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;
All storage tank caps and fittings are vapor-tight when gasoline transfer is not taking place;
each storage tank is vented via a conduit that is at least 2" inside diameter, is at least 12' in
height above grade, and is equipped with a pressure/vacuum valve that is California Air
Resources Board (CARB) certified at three inches 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.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
18
Monitoring:
None
Record keeping:
The permittee shall maintain records documenting the vessel owners and number of delivery
vessels unloaded by each owner for at least five [5) years after the date of delivery. These
records shall be made available immediately for inspection to St. Louis County Department
of Health personnel within five days of a request.
The permittee shall keep on-site copies of the loading ticket, manifest. or delivery receipt for
each grade of product received, subject to examination by SLCDH personnel 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 most recent records
for each grade of product.
Reporting:
None
EU0060
Emergency Generator
General Descri_]J_tion: 340 h]J Emergency Generator. pipeline natural _gas fired, 1966
Manufacturer/Model#: Climax Engine Mfg Co., Model #V-80
EIQ Reference# (1998): EP5.
Permit Condition EU0060-001
• 10 CSR 10-5.180
Emission of Visible Air Contaminants from Internal Combustion Engine
Emission Limitation:
• No person shall cause or permit the emission of Visible air contaminants from any internal
combustion engine for more than 10 consecutive seconds at any one time.
• Where the presence of uncombined water is the only reason for failure of an emission to meet
the requirements of this regulation, the provisions of this regulation shall not ap_IJ]y.
Monitoring:
• The permittee shall conduct opacity measurements on this emission unit using the procedures
contained in USEPA Test Method 22. Readings are only required when the emission unit is
operating and when the weather conditions allow. If no Visible emissions are observed, then no
further observations would be required. If Visible emissions are observed, the length of time
the emissions are visible shall be noted and recorded.
• Observations shall be conducted each dav that this unit is started .
Record keeping:
• The permittee shall maintain records of all observations using Attachment B or another form
proViding equivalent information noting:
1. Whether any air emissions [except for water vapor) were Visible from the emission unit, and
2. The length of time that the emissions were Visible.
• The permittee shall maintain records of any equipment malfunctions .
• These records shall be retained for 60 consecutive months and shall be made available
immediately to St. Louis County Department of Health ]Jersonnel upon request.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APCP Enforcement Section, P.O. Box 176 Jefferson
City, MO 65102, no later than 15 days after any malfunction that causes an exceedance of
the opacity limits of this regulation.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
EU0070
General Desclintion: Paint Spray Booth #1, 14.4 gallons/hour.
Manufacturer/Model#: DeVilbiss Companv. Dvnaclean water curtain tvPe. 1978.
EIQ Reference# (1998): EPlO.
Permit Condition EU0070-001
• lO CSR 10-5.050 and 10 CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
19
The pennittee shall not emit particulate matter in excess of 0.67lbs/hr from Paint Booth #l.
The oaint booth shall not be ooerated without the fan and water curtain operating properly.
Monitoring:
The pennittee shall operate and maintain the paint booth and the emission control devices
accordin!! to the manufacturer's instructions.
Record keeping:
A record shall be maintained of the maintenance performed on the spray booth and control
system. These records and the Mateiial Safety Data Sheets for all spray paints used shall be
retained for 60 consecutive months. The manufacturer's operating instructions for the booth
and the calculations showing compliance with 10 CSR 10-5.050 shall be retained. All of the
above records shall be made available immediately for inspection to St. Louis County
Deoartment of Health personnel uoon reauest.
Reporting:
The pennittee shall report to the Air Pollution Control Section of the SLCDOH. 111 South
Meramec, Clayton. MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of 10 CSR
10-5.050.
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federaiJv enforceable and 10 CSR 10-5.050 will cease to apply.
EUOOSO
General Descliption: Paint Sorav Booth #2, 0.75fallons/hour.
Manufacturer /Model #: DeVilbiss Company ,Paint Arrester filter type, 1978.
E.f.O Reference # (1998): EP10.
Pertnit Condition EUOOS0-00 1
• 10 CSR 10-5.050 and lO CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission Limitation:
The pennittee shall not emit particulate matter in excess of 0.09 lbs/hr from Paint Booth #2.
The Daint booth shall not be operated without a filter in place.
Monitoring:
The pennittee shall operate and maintain the paint booth and filter according to the
manufacturer's instructions and reolace the filter as necessarv.
Record keeping:
A record shall be maintained of any maintenance performed on the spray booth and control
system. These records and the Matelial Safety Data Sheets for all spray paints shall be
retained for 60 consecutive months. The manufacturer's operating Instructions for the booth
and the calculations showing compliance with 10 CSR 10-5.050 shall be retained. All of the
above records shall be made available immediately for inspection to St. Louis County
Department of Health personnel upon request. · ·
Lemay Wastewater TreaLment Plant
Project No. 1998-07-071
Reporting:
20
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after any malfunction causes an exceedance of 10 CSR
10-5.050.
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federallv enforceable and 10 CSR 10-5.050 will cease to a~ply.
EU0090
Parts Washer
General Descrtption: 25 gallon capacity
Manufacturer/Model#: Cold Cleaner
EIQ Reference# (1998): EPII.
Permit Condition EU0090-00 1
• 10 CSR 10-5.300
Control of Emissions From Solvent Metal Cleanine:
Emission Limitation:
• No owner or operator shall allow the operation of any cold cleaner using a cold cleaning
solvent with a vapor pressure greater than 2.0 millimeters of Mercucy (mmHg) [0.038 pounds
per square inch (psi)] at twenty degrees Celsius (20°C) [sixty-eight degrees Fahrenheit (68°F)]
unless the cold cleaner is used for carburetor cleaning. After Aprtl I. 200 1, no owner or
operator shall allow the operation of any cold cleaner using a cold cleaning solvent with a
vapor pressure greater than 1.0 mmHg (0.019 psi) at 20°C (68°F) unless the cold cleaner is
used for carburetor cleaning. (Note: The MSDS for solvent used in this emission unit lists the
vapor pressure as 0.391 mmHg at 68°F and 2.0 mmHg at l00°F.)
• Each cold cleaner shall have a cover which will prevent the escape of solvent vapors from the
solvent bath while in the closed position or an enclosed reservoir which will limit the escape of
solvent vapors from the solvent bath whenever parts are not being processed in the cleaner.
• Each cold cleaner shall have a drainage facility, which will be internal, so that parts are
enclosed under the cover while draining. If an internal drainage facility cannot fit into the
cleaning system and the solvent volatility is less than 0.6 psi measured at I00°F, then the cold
cleaner shall have an external drainage facility which provides for the solvent to drain back
into the solvent bath.
• Solvent sprays, if used, shall be a solid fluid stream (not a fine. atomized, or shower-type
spray) and at a pressure which does not cause splashing above or beyond the freeboard.
(Note: While a spray is not currently used at this facility, this paragraph would apply if such a
spray were used in the future.)
• A permanent conspicuous label summarizing the operating procedures shall be affiXed to the
equipment.
• Cold cleaner covers shall be closed whenever parts are not being handled in the cleaners or
the solvent must drain into an enclosed reservoir.
• Cleaned parts shall be drained in the freeboard area for at least fifteen seconds or until
dripping ceases, whichever is longer.
• Whenever a cold cleaner fails to perform within the operating parameters established for it by
this rule, the unit shall be shut down immediately and secured. It shall remain shut down
until trained service personnel are able to restore operation within the established parameters.
Solvent leaks shall be repaired immediately or the degreaser will be shut down and the leaks
secured until they can be more permanently repaired.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
21
Any waste matertal removed from a cold cleaner shall be disposed of by one of the following
methods or equivalent (after Director approval) and tn accordance with 10 CSR 25, as applicable.
Either reduction of the waste material to Jess than twen1y percent VOC solvent by distillation and
disposal of the still bottom waste: or storage tn closed contatners for transfer to a contract
reclamation service or a disposal facility approved by ihe Director.
Waste solvent shall be stored in closed contatners only.
• Only persons tratned tn at least the operational and equipment requirements specified tn this
rule for their particular solvent metal cleaning process shall be permitted to operate the
equipment.
• The supervisor of any person who operates a solvent metal cleaning process shall receive equal
or greater operational tratning than ihe operator.
• Refresher tratning shall be given to all solvent metal cleaning equipment operators at least
once every twelve months.
Monitoring:
None.
Record keeping:
• The permittee shall matntatn monthly tnventory records of solvent tnventory 1ypes and
amounts purchased and solvent consumption. These records shall tnclude all1ypes and
amounts of solvent contatning waste material transferred to either a contract reclamation
service or to a disposal facility and all amounts distilled on the premises. The records also
shall tnclude matntenance and repair logs for both ihe degreaser and any associated control
equipment.
• The permittee shall matntatn records which include for each purchase of cold cleaning solvent
the name and address of the solvent supplier, the date of purchase, the 1ype of solvent, and
the vapor pressure of the solvent tn mmHg at 20°C (68°F).
• The permittee shall keep a record of solvent metal cleaning training for each employee .
• The Director may require further recordkeeping if necessary to adequately demonstrate
compliance with this rule. All records shall be made available to the Director upon his/her
request. All of the above records shall be retatned for 60 consecutive months.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, 111 South
Meramec, Clayton, MO 63105 and to the APC Enforcement Section, P.O. Box 176, Jefferson
City, MO 65102, no later than 15 days after anv Violation of the terms of this ree:ulation.
EUOIOO
Sand Blaster
General Descrtp_tion: Sand Blaster with Dust Collector
Manufacturer/Model#: Trinco Master Model 48 Cabinet: Trinco Model BP-2 Dust Collector
EIQ Reference # (2000): EP12.
Permit Condition EUOI00-001
• 10 CSR 10-5.050 and 10CSR 10-6.400
Restriction of Emission of Particulate Matter from Industrial Processes
Emission limitation:
The permittee shall not emit particulate matter tn excess of 0.49 lbs/hr from this emission
unit.
Monitoring:
The permittee shall operate and matntatn the sand blaster and dust collector accordtng to the
manufacturer's tnstructions and replace the filter as necessary. . .
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Lemay Wastewater TreaLment Plant
Project No. 1998-07-071
Record keeping:
None.
Reporting:
The permittee shall report to the Air Pollution Control Section of the SLCDOH, Ill South
22
Meramec. Clayton, MO 63105 and to the APC Enforcement Section. P.O. Box I 76, Jefferson
City, MO 65102. no later than 15 days after any malfunction that causes an exceedance of this
rej;(u!ation.
10 CSR 10-6.400 is a State-only rule until promulgated in the Federal Register. At that time 10
CSR 10-6.400 will be federally enforceable and 10 CSR 10-5.050 will cease to apply.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
IV. Core Permit Requirements
23
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
The permittee shall submit the following information to the director not later
than fifteen (15) days after receipt of the notice of excess emissions excess
emissions.
(a.) Name and location of installation;
(b.) Name and telephone number of person responsible for the installation;
(c.) The identity of the equipment causing the excess emissions;
(d.) The time and duration of the period of excess emissions;
(e.) The cause of the excess emissions;
(f.) The type of air contaminant involved;
(g.) A best estimate of the magnitude of the excess emissions expressed in
the units of the applicable emission control regulation and the operating
data and calculations used in estimating the magnitude;
(h.) The measures taken to mitigate the extent and duration of the excess
emissions; and
(i.) The measures taken to remedy the situation which caused the excess
emissions and the measures taken or planned to prevent the recurrence
of these situations.
10 CSR 10-6.060, Construction Permits Required
The permittee shall not commence construction, modification, or major
modification of any installation subject to this rule, begin operation after that
construction, modification, or major modification, or begin operation of any
installation which has been shut down longer than five (5) years without first
obtaining a permit from the permitting authority.
10 CSR 10-6.065, Operating Permits
The permittee shall ille for renewal of this operating permit no sooner than
eighteen months, nor later than six months, prior to 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 St. Louis County Department of Health personnel
upon request.
10 CSR 10-6.110, Submission of Emission Data, Emission Fees and Process
Information
The permittee shall complete and submit an Emission Inventory
Questionnaire (EIQ) in accordance with the requirements outlined in this
rule.
Lemay Wastewater Trea.cment Plant
Project No. 1998-07-071
10 CSR 10-6.130, Controlling Emissions During Episodes o(High Air
Pollution Potential
24
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 pennit 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 10-5.070, Open Burning Restrictions
(a.) The permittee shall not conduct, cause, permit or allow a salvage
operation, the disposal of trade wastes or burning of refuse by open
buming.
(b.) Exception-Open burning of vegetation may be permitted only when it
can be shown that open burning is the only feasible method of disposal
or an emergency exists that requires open burning.
(c.) Any person intending to engage in open burning shall file a request to do
so with the director. The request shall include the following:
(1.) The name, address and telephone number of the person submitting
the application; The type of business or activity involved; A
description of the proposed open burning operations, including the
type, quantity and composition of vegetation to be bumed;
(2.) The schedule ofbuming operations;
(3.) The exact location where open burning will be used to dispose of the
vegetation;
(4.) Reasons why no method other than open burning is feasible; and
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
25
(5.) Evidence that the proposed open buming has been approved by the
fire control authority which has jurisdiction.
(d.) Upon approval of the open burning permit application by the director,
the person may proceed with the operation under the terms of the open
buming permit. Be aware that such approval shall not exempt Lemay
Treatment Plant from the provisions of any other law, ordinance or
regulation.
(e.) The permittee shall maintain flies with letters from the director approving
the open burning operation and previous SLCDOH inspection reports.
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.
(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 (1)A.l. and (2) of the rule when
air containing odorous matter is diluted with four (4] or more volumes of
odor-free air.
The previously mentioned requirement shall apply only too 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 10-6.100, Alternate Emission Limits
Proposals for altemate emission limitations shall be submitted on Altemate
Emission Limits Permit forms provided by the department. An installation
owner or operator must obtain an Alternate Emission Limits Permit in
accordance with 10 CSR 10-6.100 before altemate emission limits may
become effective.
ST. LOUIS COUNTY AIR POLLUTION CONTROL CODE REQUIREMENTS
The following requirements are non-Federally enforceable and are only enforced by the St.
Louis County Air Pollution Control Program.
The St. Louis County Air Pollution Control Code. Section 612.040, Air
Quality Standards and Air Pollution Control Regulations
(1] Emission Standards: Saint Louis County Air Pollution Control may enforce
Missouri Code of State Regulations as adopted and promulgate by the Air
Conservation Commission of the State of Missouri consisting of Title 10,
Division 10, Chapter 5 and 6.
(2) Record Keeping Requirements: None
(3] Monitoring Requirements: None.
(4) Reporting Requirements: None.
·----------
Lemay Wastewater TreaLment Plant
Project No. 1998-07-071
The St. Louis County Air Pollution Control Code, Section 612.100,
Emergency Abatement of Violation
26
( 1) Emission Standards: By Wiitten approval of the County Executive, any
facility indirectly or directly discharging any air contaminant in violation of
The St. Louis County Air Pollution Control Code where it is the opinion of
the Director that the discharge creates an emergency which requires
immediate action to protect the public health, shall order the person in
writing to discontinue immediately.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.110, Permits
Required
(I) Emission Standards: The Permittee shall obtain St. Louis County
Department of Health (DOH) operating permits for its installation. The
Permittee shall not commence consiruction, modification. or major
modification of any installation subject to this rule without obtaining a
permit from St. Louis County DOH.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.120, Permits
to be Visibly Affixed or Placed
(l) Emission Standards: The Permittee shall Visibly affix St. Louis County
DOH Permit on or near permitted equipment.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: Visuallnspection performed during periodic St.
Louis County inspections.
(4) Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.200, Testing
Prior to Granting of Operating Permit
( l) Emission Stnndards: Before an authority to construct or permit to operate
is granted, the Director may require the applicant to conduct tests to
determine the kind or amount of the air contaminant emitted from the
equipment. Such tests shall be conducted, reviewed and certified by a
licensed engineer. The permittee shall notifY the County of the time and
place of testing for the purpose of witnessing the test.
(2) Record Keeping Requirements: Records shall be kept during testing as
approved in a test protocol submitted to the County prior to testing.
(3) Monitoring Requirements: Monitoring during testing shall be as approved in
a test protocol submitted to the County prior to testing.
(4) Reporting Requirements: The permittee shall report to the Air Pollution
Control Section of the SLCDOH, Ill South Meramec, Clayton, MO 63105.
no later than ten ( l 0) days after any exceedance of any of the terms
imposed by this regulation. or any condition which could possibly cause
an exceedance of this regulation.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
The St. Louis County Air Pollution Control Code, Section 612.220,
Suspension or Revocation of Permits
27
(1) Emission Standards: The Director may suspend or revoke a permit to
operate or authortty to construct for willful or continued violation of The
St. Louis County Air Pollution Control Code
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.260, Schedules
(1) Emission Standards: The Permittee shall pay St. Louis County DOH
Construction Permit fees when applicable and annual Operating Permit
fees in accordance with the rule.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.280, Testing
by Order of the Board
(1) Emission Standards: If any article, machine, equipment or other
contrtvance is in violation of The St. Louis County Air Pollution Control
Code, the Director may file with the Board for its approval an order
directing the permittee of such equipment to conduct such tests as are
necessary in the opinion of the Director and approved by the Board to
determine whether the equipment is in violation of this Code.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: The entire test results shall be reviewed and
certified by an engineer licensed under Chapter 327, R.S.Mo 1959. The
engineer shall be selected by the permittee and approved by the Board.
(4) Reporting Requirements: The permittee shall give at least seven (7) days
notice prtor to the commencement of the test. The permittee shall report to
the Air Pollution Control Section of the SLCDOH, 111 South Meramec,
Clayton, MO 63105.
The St. Louis County Air Pollution Control Code, Section 612.290. Right of
Entry; Inspections; Samples
(1) Emission Standards: The Permittee shall allow the Director or His agent to
enter at all times with reasonable notice. inspect any equipment, control
apparatus, fuel. matter or things which affect or may affect the emission of
air contaminants. inspect any records relating to the use of any equipment
or control apparatus which affect or may affect the emission of air
contaminants, and sample any equipment, control apparatus. fuel, matter
or things which affect or may affect the emission of air contaminants.
(2) Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
Lemay Wastewater Trehcment Plant
Project No. 1998-07-071
28
The St. Louis County Air Pollution Control Code, Section 612.310, Upset
Conditions, Breakdown or Scheduled Maintenance
(l) Emission Standards: None.
(2) Record Keeping Requirements: None.
(3} Monitoring Requirements: None.
(4} Reporting Requirements: The permittee shall report to the Air Pollution
Control Section of the SLCDOH, Ill South Meramec, Clayton, MO 63105
within 24 hours of occurrence of any unavoidable upset in or breakdown
of equipment and in case of shutdown for necessary scheduled
maintenance, the intent to be shutdown shall be reported to Air Pollution
Control Section 24 hours prior to shutdown.
The St. Louis County Air Pollution Control Code, Section 612.340, Air
Pollution Nuisances Prohibited
(I} Emission Standards: It is unlawful for the Permittee to cause of such
quantities of soot, cinders, noxious acids, fumes and gases or other
particulate matter from whatever source in such place or matter as to be
detrimental to any person or the public or to endanger the health, comfort
and safety of any person or the public, injury or damage to property or
business.
(2} Record Keeping Requirements: None.
(3} Monitoring Requirements: None.
(4} Reporting Requirements: None.
The St. Louis County Air Pollution Control Code, Section 612.380,
Interfering with or Obstructing Division Personnel
(1) Emission Standards: No Person shall hinder, resist, interfere with or
obstruct the Director or any Division employee in carrying out any duty for
the Director or the Board.
(2} Record Keeping Requirements: None.
(3) Monitoring Requirements: None.
(4) Reporting Requirements: None.
The above requirements are non-Federally enforceable and are only enforced by
the St. Louis County Air Pollution Control Program.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
V. General Permit Requirements
Permit Duration
10 CSR l0-6.065(6)[C) LB.
29
This pennit 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 pennits issued to this installation
shall be kept on-site for as long as the pennits are in effect. Copies of these pennits
shall be made immediately available to any St. Louis County Department of Health
personnel upon request.
II) Reporting
A) The pennittee shall submit a report of all required monitoring by:
I) October lst for monitoring which covers the January through June time period,
and
2) April lst 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 30 days after the end of the calendar
quarter in which the measurements were taken.
B) Each report must identifY any deviations from emission limitations, monitoring,
record keeping, reporting, or any other requirements of the pennit.
C) All reports shall be submitted to the Air Pollution Control Section of the SLCDOH,
Ill South Meramec, Clayton, MO 63105 and to the APCP 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 fifteen (15) 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 measeres
taken.
1) Notice of any deviation resulting from an emergency (or upset) condition as
defined in paragraph (6J(C)7 of 10 CSR 10-6.065 (Emergency Provisions) shall be
submitted to the pennitting 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 affmnative 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 pennittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards or ·
Lemay WastewaterTreuLIIlent Plant
Project No. 1998-07-071
requirements in the pennit. The notice must contain a description of the
emergency, the steps taken to mitigate emissions, and the corrective actions
taken.
30
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 pennittee'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 fifteen (15) 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 pennittee may request confidential treatment of information submitted in any
report of deviation.
G) These supplemental reports shall be submitted to the Air Pollution Control Section of
the SLCDOH, 111 South Meramec, Clayton, MO 63105 and the APCP Enforcement
Section, P.O. Box 176, Jefferson City, MO 65102, no later than fifteen (15) days after
any exceedance of any applicable rule, regulation, or other restriction.
Risk Management Plans Under Section 112(r)
10 CSR 10-6.065(6)(C) l.D.
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:
1) 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.
In the event of a successful challenge to any part of this permit, all uncontested permit
conditions shall continue to be in force.
General Requirements
10 CSR 10-6.065(6J(C) l.G
1) The pennittee must comply with all of the terms and conditions of this pennit. Any
noncompliance with a permit condition constitutes a violation and is grounds for
enforcement action, permit termination, permit revocation andre-issuance, permit
modification or denial of a permit renewal application.
Lemay Wastewater Trearment Plant
Project No. 1998-07-071
31
2) The permittee may not use as a defense in an enforcement action that it would have
been necessary for the permittee to halt or reduce the permitted activity in order to
maintain compliance with the conditions of the permit.
3) The permit may be modified. revoked, reopened, reissued or terminated for cause.
Except as provided for minor permit modifications, the filing of an application or request
for a permit modification. revocation andre-issuance, or termination, or the filing of a
notification of planned changes or anticipated noncompliance, will not stay any permit
condition.
4) Tills permit does not convey any property rights of any sort, nor grant any exclusive
privilege.
5) The permittee shall furnish to the St. Louis County Department of Health, upon receipt
of a written request and within a reasonable time, any information that the St. Louis
County Department of Health reasonably may require to determine whether cause exists
for modifying, reopening, reissuing or revoking the permit or to determine compliance
with the permit. Upon request, the permittee also shall furnish to the St. Louis County
Department of Health 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 l0-6.065(6)(C)l.
Incentive Programs Not Requiring Permit Revisions
10 CSR 10-6.065(6)(C)l.H.
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
lO CSR 10-6.065(6)(C)l.I.
None.
Title IV Allowances
Not applicable.
Emissions Trading
10 CSR 10-6.065(6)(C) l.J.
Not applicable.
Compliance Requirements
10 CSR l0-6.065(6)(C)3.
I) Any document (including reports) required to be submitted under this permit shall
contain a certification signed by the responsible official.
II) Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow authorized officials of the St. Louis County Department of Health,
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 St. Louis
County Department of Health):
Lemay Wastewater Trt~-ment Plant
Project No. 1998-07-071
32
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 ConseiVation Law, Chapter 643, RSMo or the Act,
sample or monitor, at reasonable times, substances or parameters for the purpose of
assuring compliance with the terms of this permit, and all applicable requirements as
outlined in this permit.
III) 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. 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 St. Louis County Department of Health 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 all
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 summcuy of it.
II) Be aware that there are exceptions to this permit protection. The permit shield does not
affect the following:
Lemay Wastewater Treaunent Plant
Project No. 1998-07-071
A) The provisions of section 303 of the Act or section 643.090. RSMo concerning
emergency orders,
33
B) Liability for any violation of an applicable requirement which occurred prior to, or
was existing at, the time of permit issuance,
C) The applicable requirements of the acid rain program,
D) The administrator's authority to obtain information, or
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 10 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 St. Louis County Department of
Health 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 a1r contaminant not previously emitted. The permittee shall notifY the
St. Louis County Department of Health 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)(l0) changes. Changes that, under section 502(b)(l0) 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
Lemay Wastewater Trea.LIIlent Plant
Project No. 1998-07-071
34
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 St. Louis County Department of Health 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 with 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 l0-6.065(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:
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 l0-6.020(2)(R)l2.
The application utilized in the preparation of this was signed by Neil F. Frankenberg, P.E ..
Assistant Director of Wastewater. 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 St. Louis County Departrnent of
Health Air Pollution Control Section of the change. Said notification shall be in writing and
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
35
shall be submitted within 30 days of the change. The notification shall include the name
and title of the new person assigned by the source owner or operator to represent and bind
the installation in environmental permitting affairs. All representations, agreement to
terms and conditions and covenants made by the former responsible person that were used
in the establishment of limiting permit conditions on this permit will continue to be binding
on the installation until such time that a revision to this permit is obtained that would
change said representations, agreements and covenants.
Statement of Basis
lO 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
Lemay Wastewater Treaunent Plant
Project No. 1998-07-071
• Attachment A
Opacity Emission Observations
Visible Emissions Abnormal Emissions
Date Time Emission Normal Less Greater Cause Corrective Action
Source Than Than
36
Sign-
ature
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
• Attachment B
F uR;itive E mission
Visible Emissions
Beyond Less Greater
Date Time Boundary tban Normal Than
No Yes Normal Normal
37
Ob servations
Abnormal Emissions
Cause Corrective Action !nit-
ial
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
STATEMENT OF BASIS
Permit Reference Documents
SB-l
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.
I) Part 70 Operating Permit Application, received May 12, 1997; revised
July 26, 1999 and September 29, 1999.
2) 1998 Emissions Inventory Questionnaire, received May 25, 1999;
3) U.S. EPA document AP-42, CompUation 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.
Tills rule has been included in the operating permit in order to provide
citing for the allowance of requests for emission data results. On past
forms issued by the Air Pollution Control Program. including the
application for this permit, this regulation 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.
In the permit application and according to APCP records, there was no
indication that any 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· Certiftcation, Accreditation, and
Business Exemption Requirements were applicable to this installation. However,
if they 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. Therefore, the rules were placed in the permit.
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Other Air Regulations Determined Not to Apply to the Operating Permit
The Air Pollution Control Program (APCP) has determined the following
requirements to not be applicable to this installation at this time for the
reasons stated.
10 CSR 10-6.170, Restriction of Particulate Matter to the Ambient Air Beyond the
Premises of Origin
Tills rule has been replaced by the more restrictive, 10 CSR 10-5.290.
The installation has reported the following emission sources as being exempt
emission units per 10 CSR 10-6.065(3)(E)l. ("Combustion equipment that
emits only combustion products, produces less than one hundred fifty pounds
per day of any air contaminant, and with either: 1. A capacity of less than ten
million British thermal units (BTUs) per hour heat input by using exclusively
natural or liquefied petroleum gas, or any combination of these; or 2. A
capacity of less than one million BTUs per hour heat input"):
4 Natural Gas Fired Water Heaters, 1. 76 MMBTU /hr total.
Natural Gas Fired Emergency Generator, 340 hp (2.72 MMBTU/hr). The
visible emissions limitation is still applicable to the engine.
10 CSR 10-6.260. Restriction of Emission of Sulfur Compounds
Section (4), Restriction of Concentration of Sulfur Compounds in the
Ambient Air, is applicable to the two 12.5 MMBtu/hr pipeline natural gas
fired boilers, but they would never be expected to exceed the SOz
emission limits. Therefore, the rule was not listed as specific for the
boilers.
10 CSR 10-5.030, Maxi.mumAUowable Emission of Particulate Matter From Fuel
Burning Equipment Used for Indirect Heating.
The rule is applicable to the two 12.5 MMBtu boilers. However, the
emissions of particulate matter (PM) from firing only pipeline natural gas
would never be expected to exceed the 0.30 lb PM/hr limit. Therefore,
the rule was not applied to the boilers in the permit.
10 CSR 10-5.510, Control of Emissions of Nitrogen Oxides.
Tills rule is applicable to this installation since it is a major source of
Nitrogen oxides. However, since the maximum rated heat input capacity
for each incinerator is less than fifty (50) MMBtu/hr, there are no
applicable requirements. Therefore the rule was not placed in the
permit.
Lemay Wastewater Treatment Plant
Project No. 1998-07-071
10 CSR 10-5.520, Control ofVOC Emissions from Existing Major Sources.
SB-3
Til.is rule is not applicable to this installation, as it is not a major source
ofVOC emissions.
Construction Permit Revisions
The following revisions were made to construction permits for this installation:
1) None.
NSPS Applicability
NSPS Subpart 0 does not apply to EUOOIO (Incinerators #1, #2, & #3 due to
their being constructed before June 11, 1973. The rule is applicable to
Incinerator #4 that was constructed in 1983,
NSPS Subparts K, Ka, & Kb do not apply to EU0050 due to the gasoline tanks
each having a capacity of less than 40 cubic meters (10,567 gallons).
NSPS Subpart De does not apply to the 2 Natural Gas Fired Boilers due to their
being constructed before June 9, 1989.
MACT Applicability
MACT Subpart T does not apply to the parts washer (EU0070) due to the
solvent not containing any of the halogenated HAP solvents listed in §63.460
(based on the MSDS for the solvent used in EU0070).
NESHAP Applicability
CFR Part 61, Subpart C, National Emission Standardjor Beryllium
CFR Part 61, Subpart E, National Emission Standard for Mercury
CFR Part 61, Subpart M, National Emission Standardjor Asbestos
Other Regulatory Determinations
Due to 10 CSR 10-6.070 (NSPS, Subpart 0) being applicable to EU0020
(Incinerator #4}, 10 CSR 10-5.050 (Restriction of Emission of Particulate Matter
From Industrial Processes) and 10 CSR 10-5.090 and 10-6.220(Restriction of
Emission of Visible Air Contaminants) were not applicable to this emission
unit.
In the permit application, the burning of natural gas in the incinerator
afterburners (EU0010 & EU0020) was presented as an alternate operating
scenario; however, according to the DNR's Operating Permit Application
Instructions, based on the EPA definition of"altemate operating scenarios",
they are only needed if different modes of operation would change the method
of documenting compliance. Since there would be no changes to the method of
demonstrating compliance for these emission units due to the above scenario,
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Project No. 1998-07-071
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it is not listed under Reasonably Anticipated Operating Scenarios. Also. the
installation will not need to notify the St. Louis County Department of Health
(SLCDOH) when the afterburners' fuel is changed to pipeline natural gas.
Since both source testing (for Incinerator #2) and emissions calculations using
AP-42 emission factors (for Incinerators #1, #3, & #4) demonstrate that sulfur
dioxide concentrations due to sludge incineration will be minimal, no
additional monitoring. recordkeeping, or reporting requirements were included
in regard to 10 CSR 10-6.260 (Restriction of Emission of Sulfur Compounds)
for EUOOlO and EU0020.
EUOOlO and EU0020 are exempt from St. Louis County Air Pollution Control
Code Sections 612.410 (Incinerators) through 612.520 (Reduction in Quantity
ofWaste Prtor to Incineration) per 612.410(2)(A). Mr. Charles Wildt of the St.
Louis County Department of Health stated on August 25, 1999, that this
exemption continues to apply even though the original basis for the exemption,
10 CSR 10-6.190 (Sewage Sludge and Industrial Waste Incinerators), has been
voided.
10 CSR 10-5.330 (Control of Emissions From Industrial Surface Coating
Operations) applies to certain installations from which actual emissions of
VOCs from surface coating operations are greater than 2. 5 tons in any calendar
year. While the maximum potential VOC emissions from the paint spray
booths (EU0060 and EU0070) are greater than 2.5 tons per year, the actual
emissions are a few pounds. Therefore, CSR 10-5.330 is not applicable.
10 CSR 10-5.455 (Control of Emission from Solvent Cleanup Operations)
applies to certain solvent cleanup operations at which cleaning solvent VOCs
are emitted at 500 lbs/day or greater. Since the maximum potential VOC
emissions from the parts washer (EU0090) is less than 500 lbs/day and cold
cleaning is exempted from this rule, 10 CSR 10-5.455 is not applicable.
In a conversation with Mr. Charles Wildt of the St. Louis County Department of
Health on June 14, 1999, he stated that they do not require a permit to be
obtained for small emission units such as the conveyors. storage tanks, etc.
Thus, SLCDOH Chapter 612.110 (Permits Required) was not listed as being
applicable to EU0040, EU0050, EU0060, EU0070, EUOOSO, EU0090 and
EUOlOO.
The terms "online" and "operating" refer to the time that sludge is being fed to
an incinerator. "Ofiline" refers to that time when sludge is not being fed to the
incinerators.
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The term "dry sludge" is used in this permit to indicate the dewatered solids
removed from wastewater treatment processes. This term shall include
wastewater sludge, low volatile biosolids (grit), scum and digested sludge from
MSD facilities and other publicly owned treatment works.
Calculations:
10 CSR 10-5.030
Installation heat input. Q = 2 x 12.6 (boilers) + l. 76 (water heaters)
Q = 26.96 MMBTU/hr
E =the maximum allowable particulate emission rate in pounds/MMBTU of heat
input, E = 0.8 x Q·0.3ol, E = 0.8 x 26.96·0.301, E = 0.30 lbs/MMBTU
Emissions= 7.2lb PM/106cfx lQ6cf/1050 MMBtu = 0.0072lb PM/MMBtu
10CSR 10-5.050
EU0010
Incinerator #1, Test MHDR = 2.45 ton dry sludge/hr:
Limit= 4.1 x 2.450.67 = 7.47 lb PM/hr, Stack Test= 0.32 lb PM/ton dcy sludge
Emissions = 2.45 x 0.32 = 0. 78 lb PM/hr
Incinerator #2, Test MHDR = 2.74 ton dcy sludge/hr
Limit= 4.1 x 2.74o.67 = 8.06lb PM/hr: Stack Test= 0.18 lb PM/ton dcy sludge
Emissions= 2. 74 x 0.18 = 0.49 lb PM/hr
Incinerator #3, Test MHDR = 2.17 ton dcy sludge/hr
Limit= 4.1 x 2.110.61 = 6.89 lb PM/hr: Stack Test= 0.26 lb PM/ton dcy sludge
Emissions= 2.17 x 0.26 = 0.56lb PM/hr
EU0030, Dcy Ash Conveyor & Storage w/Baghouse, MHDR = 2.45 ton/hr (ave.)
Limit= 4.1 x 2.450.67 = 7.47lb PM/hr: Emission Factor= 0.008lb PM/ton
Emissions = 2.45 ton/hr x 0.008 lb/ton = 0.02 Ib PM/hr
EU0040, Wet Ash Conveying, MHDR = 4.16 ton/hr
Limit= 4.1 x 4.160.67 = 10.66 lb PM/hr: Emission Factor= 8 lb PM/ton
Control efficiency of the venturi scrubber and impingement scrubber = 94%.
Emissions= 4.16 ton/hr x 8lb PM/ton x (1-0.94) = 2lb PM/hr
EU0070, Paint Spray Booth #1, MHDR = 14.4 gal/hr x 9.3lb/gal = 133.9lb/hr
Limit= 4.1 x (133.9/2000)0.67 = 0.67lb PM/hr
Paint sollds = 45%, transfer efficiency = 25%, control efficiency = 99.2%
Emissions= 133.9 X 0.45 X (1-0.25) X (1-0.992) = 0.36lb PM/hr
EU0080, Paint Spray Booth #2, MHDR = 0. 75 gal/hr x 9.3lb/gal = 6.98lb/hr
Limit= 4.1 x (6.98/2000)0.67 = 0.09 lb PM/hr
Paint sollds = 45%, transfer efficiency = 25% and control efficiency = 99.3%
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Project No. 1998-07-071
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Emissions= 6.98 x 0.45 x (l-0.25) x(1-0.993) = 0.02lb PM/hr.
EUOlOO, Sand Blaster, MHDR = 1.4lb/hr x 60 rnin/hr x 1 ton/2000 lb = 0.042
ton/hr
Limit= 4.1 x 0.0420.67 = 0.49 lb PM/hr
Transfer efficiency = 10 %, Control Efficiency = 99%
Emissions= 1.4 x 60 x 0.1 x 0.01 = 0.084lb/hr
Ambient Air Standards
The installation has demonstrated compliance with 10 CSR 10-6.010, Ambient
Air Quality Standards by conducting modeling using the ISCST2 model for S02,
and the ISCST3 model for H2S. The results are shown in the Tables below:
Le may as ewa er rea men an w t t T t t PI t
Total Concentration S02 Standard
(M/m3 ) (ppm) (ppm)
S02 Cone. 3 hr avg. 3.694 0.0014 0.5
S02 Cone. 24 hr av_g. 1.642 0.0006 0.14
S02 Cone. 1 year avg. 0.328 0.0001 0.03
W tC ors ase Od C or one en tr t• tLe a Ions a may
Receptor Avg. Cone. 30-min avg H2S Standard
(Odor Unitsjm3) (ppm) (ppm)
16 0.008 0.03
The odor units represent a sum of pollutant concentrations including H2S,
carbonyl sulfide, methyl mercaptan, etc. As the sum of the pollutants is less
than the standard, then the H2S concentration is in compliance.
EIQ Emission Points
EP-1 Four Sludge Incinerators with afterburners and venturi and
impingement scrubbers, sludge and pipeline natural gas fired, #1, #2
and #3-1968 (under construction prior to 3/24/67), #4-1983
EP-2 Wastewater Treatment Process, 160 MGD,1968 and 1985
EP-3 Dcy Incinerator Ash Storage, Fuller Co., 1968
EP-4 Wet Ash Conveying, Zimpro Inc., 1983
EP-5 Emergency Power Generator, 340 hp Climax Engine Co., pipeline
natural gas fired, 1966
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Project No. 1998-07-071
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EP-6 1\vo Boilers, Superior Boiler Works, 12.5 MMBtu/hr each, pipeline
natural gas fired. 1980
EP-7
EP-8
EP-9
EP-10
EP-11
EP-12
Three (3) underground Gasoline Storage Tanks, 550 gallons each
Diesel Fuel Storage Tank. 550 gallons
Four (4) Hot Water Heaters. 1. 75 MMBtu/hr total. pipeline natural gas
fired
Paint Booth, DeVilbiss Co., Dynaclean, 14.4 gal/hr. 1978
Paint Booth, DeVilbiss Co., Paint Arrester type, 0. 75 gal/hr. 1978
Parts Cold Cleaner, 25 gallon capacity
Sand Blaster
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 Pennit or
in the above Statement of Basis does not appear, based on this review, to be an
applicable requirement for this installation for one ( l) 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).
James 0. Hill
Environmental Engineer