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AIR EMISSION PERMIT NO. 03700043-005 Total Facility Oper. Permit - Reissuance

IS ISSUED TO

Metropolitan Council

Metropolitan Council Environmental Services (MCES)

MCES - SENECA WASTEWATER TREATMENT PLANT 3750 Plant Road

Eagan, Dakota County, MN 55122 The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 03700043-005 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220, and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70/Major for NSR;

Operating Permit Issue Date: April 13, 2010

Expiration Date: April 13, 2015 – All Title I Conditions do not expire. * The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received on 04/27/2007) Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit Reissuance 04/27/2007 005

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices

Appendix A: Insignificant Activities Required to be Listed Appendix B: Equation to Determine Mercury Emissions

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: The MCES-Seneca Wastewater Treatment Plant (WWTP) is an advanced secondary waste water treatment facility located at Minnesota River mile 6.5 in Eagan, Dakota County, Minnesota; the plant serves approximately 300,000 people in the communities of Eagan, Bloomington, Burnsville, Lakeville, Apple Valley, Savage and parts of Inver Grove Heights. The facility has a permitted average wet weather design flow of 38 million gallons per day; discharge of treated waste water to the Minnesota River is authorized by NPDES/SDS permit number MN0030007. Primary and secondary sludges from the waste water treatment process are dewatered prior to incineration on-site. The primary source of emissions at this facility is the incineration of sewage sludge, along with small amounts of spent activated carbon, scum and granulated nonhazardous sorbent materials generated on-site in two multiple hearth incinerators. Each incinerator has seven hearths which normally fire 1.2 to 1.6 tons of dry sludge per hour. Pollution control is facilitated by an after burner, venturi scrubber and aftercooler. Emissions from the incinerators are vented to a common exhaust stack. Auxiliary burners, located on hearths 3, 5, and 6, are used for startup and to maintain sludge combustion and incinerator temperatures. The auxiliary burners are fueled with natural gas. Emissions also result from aeration of the waste water during the treatment process, operation of emergency generators, ash and materials handling, fuel storage activities, and routine maintenance activities.

TABLE A: LIMITS AND OTHER REQUIREMENTS 04/13/10

Seneca Wastewater Treatment Plant

03700043 - 005

Facility Name:

Permit Number:

A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itA. SOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

Minn. R. 7007.0800, subp. 2

B. DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEWSOURCE REVIEW (NSR)

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These requirements apply if a reasonable possibility (RP) as defined in 40 CFRSection 52.21(r)(6)(vi) exists that a proposed project, analyzed using theactual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test atSection 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, mayresult in a significant emissions increase (SEI). If the ATPA test is not used for theproject, or if there is no RP that the proposed project could result in a SEI, theserequirements do not apply to that project. The Permittee is only subject to thePreconstruction Documentation requirement for a project where a RP occurs onlywithin the meaning of Section 52.2(r)(6)(vi)(a).

Even though a particular modification is not subject to New Source Review (NSR),or where there isn't a RP that a proposed project could result in a SEI, a permitamendment, recordkeeping, or notification may still be required by Minn. R.7007.1150 - 7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following:

1. Project description;2. Identification of any emission unit (EU) whose emissions of an NSR pollutantcould be affected;3. Pre-change potential emissions of any affected existing EU, and the projectedpost-change potential emissions of any affected existing or new EU;4. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excluded dueto increases not associated with the modification and that the EU could haveaccommodated during the baseline period, an explanation of why the amountswere excluded, and any creditable contemporaneous increases and decreases thatwere considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R.7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potential emissionsin the hybrid test. The Permittee shall calculate and maintain a record of the sum ofthe actual and potential (if the hybrid test was used in the analysis) emissions of theregulated pollutant, in tons per year on a calendar year basis, for a period of 5years following resumption of regular operations after the change, or for a period of10 years following resumption of regular operations after the change if the projectincreases the design capacity of or potential to emit of any unit associated with theproject.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subps. 4 & 5



03700043 - 005

Facility Name:

Permit Number:

A-2

The Permittee must submit a report to the Agency if the annual summed (actual,plus potential if used in hybrid test) emissions differ from the preconstructionprojection and exceed the baseline actual emissions by a significant amount aslisted at 40 CFR Section 52.21(b)(23). Such report shall be submitted to theAgency within 60 days after the end of the year in which the exceedances occur.The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subps. 4 & 5

C. OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated unlessotherwise noted in Table A of this permit.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Episode Emission Reduction Plan: Submit to the commissioner an episodeemission reduction plan to be implemented at the facility or stationary source in theevent of a declaration by the commissioner of an air pollution episode. The planshall be submitted to the commissioner within 90 days of the designation of thearea as having exceeded the alert levels in Minn. R. 7009.1060, Table 1, followingall requirements found in Minn. R. 7009.1000 to 7009.1110.

Minn. R. 7009.1000 through7009.1110

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

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

Minn. R. 7007.0800, subp. 16

Episode Emission Reduction Plan: The Permittee shall submit to the Commissioneran episode emission reduction plan to be implemented at the facility or stationarysource in the event of a declaration by the Commissioner of an air pollutionepisode. The plan shall be submitted to the Commissioner within 90 days of thedesignation of the area as having exceeded the alert levels in Minn. R. 7009.1060,Table 1, following all requirements found in Minn. R. 7009.1000 to 7009.1110.

Minn. R. 7009.1000 through7009.1110

D. PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A or B.

Minn. R. ch. 7017



03700043 - 005

Facility Name:

Permit Number:

A-3

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit.See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance Test unless analternate schedule is given in the applicable compliance document. The owner oroperator of the emission facility may request in the test plan that the submittaldeadline be extended by up to 15 days if the complexity of the test schedule or thelaboratory analysis is such that submittal within 45 days is impractical.Performance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4,Minn. R. 7017.2035, subps. 1-2

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

Minn. R. 7017.2025, subp. 3

E. MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit) if the emissionunit being monitored is operated at any time during the calendar year.

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A and B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

F. RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

Minn. R. 7007.1200, subp. 4

G. REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3



03700043 - 005

Facility Name:

Permit Number:

A-4

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 - 7007.1500

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

Minn. R. 7007.1400, subp. 1(H)

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095



03700043 - 005

Facility Name:

Permit Number:

A-5

Subject Item: GP 001 Multiple Hearth Sludge Incinerators

Associated Items: CE 001 Direct Flame Afterburner 1

CE 002 Venturi Scrubber 1

CE 003 Direct Flame Afterburner 2

CE 004 Venturi Scrubber 2

EU 001 Multiple Hearth Sludge Incinerator 1


SV 001 Common Incinerator Stack

SV 002 Relief Stack 1

SV 003 Relief Stack 2

What to do Why to do itA. EMISSION LIMITS hdr

At the time of permit issuance the Stack Vents (SV) and Control Equipment (CE)listed above are associated with each Emission Unit (EU) as shown in the followingtable:

Emission Unit Stack Vents Control EquipmentEU001 Incinerator #1 SV001 & 002 CE 001 & 002EU002 Incinerator #2 SV001 & 003 CE 003 & 004

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Total Particulate Matter: less than or equal to 1.30 lbs/ton dry sludge input forEU001 measured at SV001 according to the DETERMINATION OF LIMITS foundbelow:

Minn. R. 7007.0800, subp. 2; (most stringent, meetslimits set by Minn. R. 7011.1305)

Total Particulate Matter: less than or equal to 1.30 lbs/ton dry sludge input forEU002 measured at SV001 according to the DETERMINATION OF LIMITS foundbelow:

Minn. R. 7007.0800, Subp. 2; (most stringent, meetslimits set by Minn. R. 7011.1305)

Total Particulate Matter: less than or equal to 7.31 lbs/ton using 24-hour BlockAverage dry sludge input for EU002 which includes emissions from SV001 plusemissions from SV003 to account for periods of relief stack opening. Emissionsshall be calculated according to the procedures found under DETERMINATION OFLIMITS as found below.

Minn. R. 7011.1305 C

Total Particulate Matter: less than or equal to 7.31 lbs/ton using 24-hour BlockAverage dry sludge input for EU001 which includes emissions from SV001 plusemissions from SV002 to account for periods of relief stack opening. Emissionsshall be calculated according to the procedures found under DETERMINATION OFLIMITS as found below.

Minn. R. 7011.1305 C

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 33 percent opacity. An exceedance of this opacitystandard occurs whenever any one-hour period contains two or more six-minuteperiods during which the average opacity exceeds 20 percent or whenever anyone-hour period contains one or more six-minute periods during which the averageopacity exceeds 33 percent.

Minn. R. 7011.1305 C

Mercury: less than or equal to 3200 grams per 24-hour period for all incinerationunits combined

40 CFR section 61.52; 40 CFR section 61.54; Minn. R.7011.9950

B. DETERMINATION OF LIMITS hdr

Total Particulate Matter emissions in lbs/ton dry sludge input from the controlledstack shall be determined by a front half Method 5 measurement at the controlledstack, SV001.

Total Particulate Matter emissions in lbs/ton dry sludge input from the controlledstack plus emissions from the relief stacks due to relief stack openings, expressedas a daily average, shall be determined as the sum of the following two quantities:

1. The contribution from the controlled stack, which is assumed to be equal to theemission factor in lbs/ton dry sludge input determined during the most recent stacktest.

(continued)

Minn. R. 7007.0800, subp. 2



03700043 - 005

Facility Name:

Permit Number:

A-6

2. The contribution from the relief stack is determined as follows:a. At the moment that the relief stack opens and the feed to the incinerator isstopped (t =0), the emission rate from the relief stack (ERrelief stack) in lbs PM persecond shall be calculated from the AP-42 uncontrolled emission factor for multiplehearth sewage sludge incinerators and the actual average feed rate for thecalendar day. The emission rate at time t =0 shall be calculated as follows:

ERrelief stack0 = [AP-42 uncontrolled emission factor (lb/Dt) * daily average feedrate (Dt/hr)]/3600

ERrelief stack0 (lb PM/sec) = [ 100 lb/Dt * daily average feed rate (Dt/hr)]/3600

(continued)

Minn. R. 7007.0800, subp. 2

b. The emission rate from the relief stack shall be assumed to decrease at a linearrate from the starting emission rate at the time that the relief stack opens asdetermined by paragraph (a) above to a value of zero 30 minutes (1800 seconds)after the relief stack opens. The emission rate at time t = n seconds after the reliefstack opens (ERrelief stack(n) ) shall be calculated as follows: ERrelief stack(n) (lbPM/sec) = [ ERrelief stack 0 (lb PM/sec) * (1800-n/1800) ]

(continued)

Minn. R. 7007.0800, subp. 2

c. The total PM emissions from the relief stack during an opening of duration t = nseconds shall be calculated as follows:PM(n) (lbs PM) = [ERrelief stack0 * n * (3600-n/3600)]

d. The total PM emissions from the relief stack for each opening during thecalendar day shall be summed. The total relief stack emissions shall then bedivided by the total dry tons of sludge processed by the incinerator during that dayto determine the average daily relief stack emission factor.

3. During periods of relief stack opening the daily average emissions from theincineration system are determined by summing the emissions using the controlledand relief stack emission factors in Step 2.

Minn. R. 7007.0800, subp. 2

REPORTING: The Excess Emissions/Downtime Report, which is to be submittedquarterly, shall indicate the daily particulate mass emission rate for each day onwhich the cumulative emissions from SV001 and SV002, or from SV001 andSV003, exceed 7.31 lbs/ton dry sludge input.

Minn. R. 7007.0800, subp. 2

C. MERCURY TRIGGER LEVEL hdr

Mercury: less than or equal to 1.5 ppm average dry centrifuge sludge concentrationusing a 12 month rolling average. This is a state-only requirement and is notenforceable by the EPA Administrator, nor subject to the citizen suit provisions ofsection 304 of the Clean Air Act, 42 U.S.C. section 7604.

Minn. R. 7007.0800, subp. 2

If the mercury trigger level is exceeded the permittee shall submit and beginimplementing a mercury reduction plan within 60 days of the exceedance. Theplan shall include the reasons for increased mercury loading (sewer cleaning orconstruction activities, changes in in-plant activities) and the pollution preventionand other relevant mercury reduction activities to minimize the effects of the above.This is a state-only requirement and is not enforceable by the EPA Administrator,nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42U.S.C. section 7604.

Minn. R. 7007.0800, Subp. 2

D. OPERATIONAL LIMITS hdr

Materials Incinerated: only sewage sludge, spent activated carbon, scum, andgranulated nonhazardous sorbent materials generated on-site may be fed to theincinerators

Minn. R. 7007.0800, subp. 2

Process Throughput: less than or equal to 27,156 tons/year using 12-month RollingSum of sewage sludge, spent activated carbon, scum, and granulatednonhazardous sorbent materials generated on-site in Incinerators 1 and 2, (EU001and EU002) combined.

Minn. R. 7007.0800, subp. 2

Process Throughput: less than or equal to 1.44 tons/hour using 24-hour BlockAverage is the average sludge feed rate limit in dry tons per hour for Incinerator 1(EU001) as demonstrated during the most recent MPCA-approved performancetest demonstrating compliance.

Minn. R. 7007.0800, subp. 4; Minn. R. 7017.2025,subps. 2.B, 3.C and 3a.(B)

Process Throughput: less than or equal to 1.46 tons/hour using 24-hour BlockAverage is the average sludge feed rate limit in dry tons per hour for Incinerator 2(EU002) as demonstrated during the most recent MPCA-approved performancetest demonstrating compliance.

Minn. R. 7007.0800, subp. 4; Minn. R. 7017.2025,subps. 2.B, 3.C and 3a.(B)

Temperature: greater than or equal to 1200 degrees F using 1-Hour Block Averagemeasured in the hottest hearth.

Minn. R. 7011.1305.C



03700043 - 005

Facility Name:

Permit Number:

A-7

Fuel Usage: only natural gas or propane may be used as a fuel in the incineratorauxiliary burners.

Minn. R. 7007.0800, subp. 2

E. OPERATIONAL REQUIREMENTS TO MINIMIZE EMISSIONS FROM RELIEFSTACKS

Good operating practices include, but are not limited to, the following operatingrequirements.

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Induced (ID) Fan Alarms: The Permittee shall maintain the procedure for:

(1) maintaining alarms in the Seneca WWTP multiple hearth incinerator controlroom so that the incinerator operator is alerted when the revolutions per minute(RPM) for the ID Fans reaches 1950 RPM; and

(2) immediately taking appropriate corrective action in order to attempt to preventan emergency damper opening when ID Fan speed reaches 1950 RPM.

(3) maintain a record of each occurence of the speed of the ID fans reaching 1950RPM, the corrective measures taken in response to the alarm and the results of theaction.

Minn R. 7007.0800, subp. 2

Operator Training: The permittee shall maintain a training schedule to providetraining to Seneca Waste Water Treatment Plant (WWTP) multiple hearthincinerator operators. Such training shall be designed to train operators inassessing and responding to conditions that may lead to an emergency damperopening.

Minn. R. 7007.0800, subp. 2

Emergency Damper Openings: For each emergency damper opening duringoperation of the multiple hearth incinerators at the Seneca WWTP, the permitteeshall notify MPCA in writing by the end of the following calendar quarter as part ofthe excess emissions report (EER). This notification shall describe the incident andindicate the reason for the emergency damper opening and shall also describecorrective measures taken by the permittee to prevent future occurrences.Notwithstanding the preceding sentences of this paragraph, the permittee shall notbe prohibited from activating the emergency dampers during a situation of imminentor actual significant threat to the safety of on-site personnel.

Minn. R. 7007.0800, subp. 2

F. NESHAP MERCURY TESTING REQUIREMENTS hdr

Sludge Sampling: Sludge cake shall be sampled, handled, prepared and analyzedfor mercury content on a monthly basis in accordance with the proceduresdescribed in 40 CFR 61.54(c)(1), Method 105 in appendix B - Determination ofMercury in Wastewater Treatment Plant Sewage Sludges.

40 CFR Section 61.54(c)(3); Minn. R. 7007.0800,subp. 4

The maximum 24-hour period sludge incineration rate shall be determined by useof a flow rate measurement device that can measure the mass rate of sludgecharged to the incinerators with an accuracy of plus or minus 5 percent over itsoperating range.

40 CFR Section 61.54(c)(2); Minn. R. 7007.0800,subp. 4

Mercury emissions shall be determined by using the equation in 40 CFR 61.54(d)(see Appendix)

40 CFR 61.54(d)

Report: due 30 days after end of each calendar half-year following Permit Issuance.(The report shall contain the monthly mercury sample analysis of the mixed sludgecharged to the incinerators)

Minn. R. 7007.0800, subp. 4

G. STATE STATUTE MERCURY TESTING REQUIREMENTS hdr

This permit provides approval of a method other than stack testing for determiningmercury in air emissions. Monthly sludge sampling and analysis will be used todetermine mercury emissions as an alternative to quarterly stack testing. This is astate-only requirement and is not enforceable by the EPA Administrator, nor subjectto the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section7604.

Minn. Stat. 116.85, paragragh (b), alternative samplingmethod

The permittee shall sample, handle, prepare and analyze the sludge cake formercury content once per month in accordance with the procedures described in 40CFR 61.54(c)(1), Method 105 in appendix B - Determination of Mercury inWastewater Treatment Plant Sewage Sludges. This is a state-only requirementand is not enforceable by the EPA Administrator, nor subject to the citizen suitprovisions of section 304 of the Clean Air Act, 42 U.S.C. section 7604.


Report: due 30 days after end of each calendar half-year following Permit Issuance(The report shall contain the monthly mercury sample analysis of the mixed sludgecharged to the incinerators). This is a state-only requirement and is notenforceable by the EPA Administrator, nor subject to the citizen suit provisions ofsection 304 of the Clean Air Act, 42 U.S.C. section 7604.


G. MONITORING REQUIREMENTS hdr



03700043 - 005

Facility Name:

Permit Number:

A-8

Calibrate, maintain and operate temperature measuring devices at every hearth oneach incinerator. The permittee shall operate a minimum of one thermocouple ineach hearth in the cooling and drying zones, and a minimum of two thermocouplesin each hearth in the combustion zone. Each temperature measuring device shallbe certified by the manufacturer to have an accuracy of +/- 5% over its operatingrange. The temperature monitoring devices shall be operated continuously anddata recorded during all periods of operation of the incinerators.

Minn. R. 7007.0800, subp, 4

Calibrate, maintain and operate a monitoring device on each incinerator thatcontinuously measures and records the oxygen content of the incinerator exhaustgas. The oxygen monitor shall be located upstream of any rabble shaft cooling airinlet into the incinerator exhaust gas stream, fan, ambient air recirculation damper,or any other source of dilution air. The oxygen monitoring device shall be certifiedby the manufacturer to have a relative accuracy of +/-5% over its operating rangeand shall be calibrated according to method(s) prescribed by the manufacturer atleast once each 24-hour operating period.

Minn. R. 7007.0800, subp. 4

Sludge Feedrate Monitoring: Calibrate, maintain and operate a flow measuringdevice for recording & determining the mass or volume of sludge charged to eachincinerator. The weighing device shall be certified by the manufacturer to have anaccuracy of +/- 5 % over its operating range. Sludge flow to each incinerator shallbe measured continuously and data recorded during all periods of operation of theincinerators.

40 CFR 61.54(c)(2)

Monitor: The Permittee shall calibrate, maintain and operate a device for measuringthe fuel flow to each incinerator. The flow measuring device shall be certified bythe manufacturer to have an accuracy of +/- 5% over its operating range. The fuelflow measuring device shall be operated continuously and data recorded during allperiods of operation of each incinerator.

Minn. R. 7007.0800, subp, 4

Calibrate, operate, and maintain a Continuous Opacity Monitoring System (COMS)to measure opacity from the common stack.

Minn. R. 7017.1006

Continuous Operation: COMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit startup,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A COMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Minn. R. 7017.1090, subp. 1

H. RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, electronicdata and copies of all reports required by the permit. Records must conform to therequirements listed in Minn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Emergency Relief Stack Use: the permittee shall record in the operating log all timeperiods of use of the emergency relief stack when sludge is being combusted. Thisincludes the burnout period after charging has stopped and sludge is being burnedout of the unit.

Minn. R. 7008.0800, subp. 4(B) and 5(C)

Recordkeeping: Maintain records of the measured temperature for each hearth ineach incinerator

Minn. R. 7007.0800, subp. 5

Recordkeeping: Maintain records of the fuel use for each incinerator. Minn. R. 7007.0800, subp. 5

Recordkeeping: Maintain records of materials charged to each incinerator includingthe mass or volume of sludge and other materials charged to each incinerator andthe total solids and volatile solids content of sludge and other materials charged tothe incinerators.

Minn. R. 7007.0800, subp. 5

Recordkeeping: by the 30th day of each month calculate and record the tons ofmaterials charged to the incinerators for the previous month, and the previous12-month period (by summing monthly material tonnage data for the previous 12months).

Minn. R. 7007.0800, subp. 5

Recordkeeping: The owner or operator must retain records of all COMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

Minn. R. 7017.1130

I. REPORTING hdr

QA Plan Required: Maintain a written quality assurance plan which covers eachCOMS. The plan shall be on site and available for inspection within 30 days aftermonitor certification. The plan shall contain the written procedures listed in Minn. R.7017.1210, subp. 1.

Minn. R. 7017.1210



03700043 - 005

Facility Name:

Permit Number:

A-9

MPCA reserves the right to reopen the permit as permitted by the reference ruleprovision to amend the temperature requirements to address odor concerns. This isa state-only requirement and is not enforceable by the EPA Administrator, norsubject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C.section 7604.

Minn. R. 7007.1600, subp. 2. C.



03700043 - 005

Facility Name:

Permit Number:

A-10

Subject Item: GP 002 COMS

Associated Items: MR 001 SV 001 Opactiy Monitor

What to do Why to do itCOMS REQUIREMENTS hdr

All COMS shall complete a minimum of one cycle of sampling and analyzing foreach successive 10-second period and one cycle of data for each successive6-minute period.

Minn. R. 7017.1200, subp. 1, 2 & 3; 40 CFR Section60.13(e)(1); 40 CFR Section 60.13(h)

Continuous Operation: COMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A COMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B,C and D of Minn. R. 7017.1090, subp. 2.

Minn. R. 7017.1090, subp. 1; 40 CFR Section 60.13(e)

QA Plan Required: Develop and implement a written quality assurance plan whichcovers each COMS. The plan shall be on site and available for inspection within30 days after monitor certification. The plan shall contain the written procedureslisted in Minn. R. 7017.1210, subp. 1.

Minn. R. 7017.1210, subp. 1

COMS QA/QC: The owner or operator of an affected facility is subject to theperformance specifications listed in 40 CFR pt. 60, Appendix B and shall operate,calibrate, and maintain each COMS according to the QA/QC procedures in Minn.R. 7017.1210.

40 CFR Section 60.13(a); Minn. R. 7017.1210

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic tothe opacity monitor, check the zero and upscale (span) calibration drifts at leastonce daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1.The zero and upscale calibration levels must be determined using the span valuespecified in the applicable requirement. If the applicable requirement does notspecify a span value, a span value of 60, 70, or 80 percent opacity must be usedunless an alternative span value is approved by the commissioner. 40 CFR pt. 60,Appendix F, shall be used to determine out-of-control periods for COMS.

Minn. R. 7017.1210, subp. 2; 40 CFR Section60.13(d)(l) regarding COMS and 60.13(d)(2)

COMS Calibration Error Audit: due before end of each calendar half-year followingCOMS Certification Test or Permit Issuance. Conduct three point calibration erroraudits at least 3 months apart but no greater than 8 months apart. Conduct auditsin accordance with Minn. R. 7017.1210, subp. 3.

Minn. R. 7017.1210, subp. 3

COMS Attenuator Calibration: The Permittee shall semiannually have anindependent testing company conduct calibrations of each of the neutral densityfilters used in the calibration error audit according to the procedure in 40 CFR pt.60, Appendix B.

Minn. R. 7017.1210, subp. 4

Recordkeeping: The owner or operator must retain records of all COMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

Minn. R. 7017.1130



hdr



03700043 - 005

Facility Name:

Permit Number:

A-11

Subject Item: GP 003 Ash Processing

Associated Items: EU 003 CFS-1060 Ash Receiver for Incinerators 1& 2

EU 004 CFS-1061 Ash Receiver for Incinerators 1& 2

EU 005 T-1060 Ash storage silo for incin. 1& 2

EU 006 T-1061 Ash storage silo for incin. 1& 2

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent of either Minn. R. 7011.0730 or Minn. R. 7011.0735

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)



03700043 - 005

Facility Name:

Permit Number:

A-12

Subject Item: SV 001 Common Incinerator Stack

Associated Items: EU 001 Multiple Hearth Sludge Incinerator 1


GP 001 Multiple Hearth Sludge Incinerators

MR 001 SV 001 Opactiy Monitor

What to do Why to do itPERFORMANCE TESTING(see CE and GP requirements for additional information)

hdr



hdr

Testing for EU 001 hdr

Performance Test: due before end of each 24 months following Performance Testto measure particulate matter emissions for EU001. 24 months after PerformanceTest is defined as 24 months after the completion of the previous peformance test.

For additional applicable performance test requirements, see 'PerformanceTesting" in Table A, Subject Item "Total Facility".

Minn. R. 7017.2020, subp. 1

Testing for EU 002 hdr

Performance Test: due before end of each 24 months following Performance Testto measure particulate matter emissions for EU002. 24 months after PerformanceTest is defined as 24 months after the completion of the previous peformance test.

For additional applicable performance test requirements, see 'PerformanceTesting" in Table A, Subject Item "Total Facility".

Minn. R 7017.2020, subp. 1



03700043 - 005

Facility Name:

Permit Number:

A-13

Subject Item: EU 003 CFS-1060 Ash Receiver for Incinerators 1& 2

Associated Items: CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

GP 003 Ash Processing

SV 004 Ash Receivers Stack


Minn. R. 7011.0715, subp. 1(A)




03700043 - 005

Facility Name:

Permit Number:

A-14

Subject Item: EU 004 CFS-1061 Ash Receiver for Incinerators 1& 2



SV 004 Ash Receivers Stack


Minn. R. 7011.0715, subp. 1(A)




03700043 - 005

Facility Name:

Permit Number:

A-15

Subject Item: EU 005 T-1060 Ash storage silo for incin. 1& 2



SV 005 Ash Silo Stack


Minn. R. 7011.0715, subp. 1(A)




03700043 - 005

Facility Name:

Permit Number:

A-16

Subject Item: CE 001 Direct Flame Afterburner 1



What to do Why to do itTemperature: greater than or equal to 1050 degrees F using 1-Hour Block Averagewith a 0.3 second retention in the afterburner combustion zone. The Commissionerhas approved the alternate temperature of 1050 degrees F.

Minn. R. 7011.1305, C; Minn. R. 7007.0800, subp. 2

Maintain and operate a temperature measuring device(s) on the afterburner. Thepermittee shall operate a minimum of one thermocouple in the combustion zone ofthe afterburner. Each temperature measuring device shall be certified by themanufacturer to have an accuracy of +/-5% over its operating range. Thetemperature monitoring device shall be operated continuously and data recordedduring all periods of operation of the incinerator. ("Continuously" is defined asdetermining at least one data point in each 15-minute time interval.)

Minn. R. 7007.0800, subp. 4

Fuel Usage: only natural gas or propane may be used as a fuel in the incineratorafterburner.

Minn. R. 7007.0800, subp. 2

Corrective Actions: If the temperature is below the minimum specified by this permitor if the thermal oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the temperature to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the thermal oxidizer. The Permittee shall keep a record of the type anddate of any corrective action taken.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the thermal oxidizer in accordance withthe Operation and Maintenance (O & M) Plan. The Permittee shall keep copies ofthe O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Recordkeeping: Maintain permanent records for a period of five years of theoperating temperature as measured in the afterburner. ("Permanent records"means records that are in a form that is retrievable and readable such as a hardcopy or a computer disk.)

Minn. R. 7007.0800, subp. 4



03700043 - 005

Facility Name:

Permit Number:

A-17

Subject Item: CE 002 Venturi Scrubber 1



What to do Why to do itHydrochloric acid: greater than or equal to 80 percent control efficiency Minn. R. 7007.0800 subp. 16J

Total Particulate Matter: greater than or equal to 90 percent control efficiency Minn. R. 7007.0800 subp. 16J

Particulate Matter < 10 micron: greater than or equal to 90 percent controlefficiency

Minn. R. 7007.0800 subp. 16J

Pressure Drop: greater than or equal to 15 inches of water column using a15-minute block average as measured during the most recent MPCA-approvedperformance test. Pressure Drop shall be greater than or equal to 30 percentbelow the average scrubber pressure drop measured during the most recentperformance test showing compliance for each venturi scrubber with a minimumpressure drop not less than 15 inches of water column.

Minn. R. 7007.0800, subp. 2

Water flow rate: greater than or equal to 576 gallons/minute using 1-Hour Averageas measured during the most recent MPCA-approved performance test. Waterflow rate shall be greater than or equal to 10 percent below the average water flowrate measured during the most recent performance test showing compliance foreach wet scrubber system (venturi flow plus the subcooler flow) but not less than aminimum water flow rate of 380 gallons per minute using a 1-hour block average

Minn. R. 7007.0800, subp. 2

Calibrate, maintain and operate a monitoring device on each wet scrubber thatcontinuously measures and records the pressure drop of the gas flow through thewet scrubbing device. The device used to monitor scrubber pressure drop shall becertified by the manufacturer to be accurate within +/- 250 pascals (+/- 1 inch watergauge) and, if the unit is to be operated at any time during the calendar year, itshall be calibrated prior to operation and on an annual basis in accordance with themanufacturer's instructions.

Minn. R. 7007.0800, subp, 4

Calibrate, maintain and operate a monitoring device on each wet scrubber thatcontinuously measures and records the water flow rate of the water flow throughthe wet scrubbing device. The device used to monitor scrubber water flow rateshall be certified by the manufacturer to be accurate within +/- 5% and, if the unit isto be operated at any time during the calendar year, it shall be calibrated prior tooperation and on an annual basis in accordance with the manufacturer'sinstructions.

Minn. R. 7007.0800, subp, 4

Recordkeeping: Maintain records of the measured pressure drop of the gas flowthrough each wet scrubbing system

Minn. R. 7007.0800, subp. 4

Recordkeeping: Maintain records of the measured water flow rate through each wetscrubbing system.

Minn. R. 7007.0800, subp. 4

Submittal: due 30 days after end of each calendar half-year the Permittee shallsubmit a Semiannual Deviations Report to the MPCA containing a record of theaverage scrubber pressure drop measurements of each period of 15 minuteduration or more during which the pressure drop of the scrubber was less than avalue that is 30% below the average scrubber pressure drop measured during themost recent performance test.

Minn. R. 7007.0800, subp. 6

Corrective Actions: If the pressure is below the minimum specified by this permit orif the venturi scrubber or any of its components are found during the inspections toneed repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the pressure to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the venturi scrubber. The Permittee shall keep a record of the typeand date of any corrective action taken.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the control device in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



03700043 - 005

Facility Name:

Permit Number:

A-18

Subject Item: CE 003 Direct Flame Afterburner 2



What to do Why to do itTemperature: greater than or equal to 1050 degrees F using 1-Hour Block Averagewith a 0.3 second retention in the afterburner combustion zone. The Commissionerhas approved the alternate temperature of 1050 degrees F.

Minn. R. 7011.1305 C.; Minn. R. 7007.0800, subp. 2

Maintain and operate a temperature measuring device(s) on the afterburner. ThePermittee shall operate a minimum of one thermocouple in the combustion zone ofthe afterburner. Each temperature measuring device shall be certified by themanufacturer to have an accuracy of +/-5% over its operating range. Thetemperature monitoring device shall be operated continuously and data recordedduring all periods of operation of the incinerator. ("Continuously" is defined asdetermining at least one data point in each 15-minute time interval)

Minn. R. 7007.0800, subp. 4

Fuel Usage: only natural gas or propane may be used as a fuel in the incineratorafterburner

Minn. R. 7007.0800, subp. 2

Corrective Actions: If the temperature is below the minimum specified by this permitor if the thermal oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the temperature to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the thermal oxidizer. The Permittee shall keep a record of the type anddate of any corrective action taken.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the thermal oxidizer in accordance withthe Operation and Maintenance (O & M) Plan. The Permittee shall keep copies ofthe O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Recordkeeping: Maintain permanent records for a period of five years of theoperating temperature as measured in the afterburner. ("Permanent records"means records that are in a form that is retrievable and readable such as a hardcopy or a computer disk)

Minn. R. 7007.0800, subp. 4



03700043 - 005

Facility Name:

Permit Number:

A-19

Subject Item: CE 004 Venturi Scrubber 2



What to do Why to do itHydrochloric acid: greater than or equal to 80 percent control efficiency Minn. R. 7007.0800 subp. 16J

Total Particulate Matter: greater than or equal to 90 percent control efficiency Minn. R. 7007.0800 subp. 16J

Particulate Matter < 10 micron: greater than or equal to 90 percent controlefficiency

Minn. R. 7007.0800 subp. 16J

Pressure Drop: greater than or equal to 15 inches of water column using a15-minute block average as measured during the most recent MPCA-approvedperformance test. Pressure Drop shall be greater than or equal to 30 percentbelow the average scrubber pressure drop measured during the most recentperformance test showing compliance for each venturi scrubber with a minimumpressure drop not less than 15 inches of water column.

Minn. R. 7007.0800, subp. 2

Water flow rate: greater than or equal to 590 gallons/minute using 1-Hour Averageas measured during the most recent MPCA-approved performance test.

Minn. R. 7007.0800, subp. 2

Calibrate, maintain and operate a monitoring device on each wet scrubber thatcontinuously measures and records the pressure drop of the gas flow through thewet scrubbing device. The device used to monitor scrubber pressure drop shall becertified by the manufacturer to be accurate within +/- 250 pascals (+/- 1 inch watergauge) and, if the unit is to be operated at any time during the calendar year, itshall be calibrated prior to operation and on an annual basis in accordance with themanufacturer's instructions.

Minn. R. 7007.0800, subp, 4

Calibrate, maintain and operate a monitoring device on each wet scrubber thatcontinuously measures and records the water flow rate of the water flow throughthe wet scrubbing device. The device used to monitor scrubber water flow rateshall be certified by the manufacturer to be accurate within +/- 5% and, if the unit isto be operated at any time during the calendar year, it shall be calibrated prior tooperation and on an annual basis in accordance with the manufacturer'sinstructions.

Minn. R. 7007.0800, subp, 4

Recordkeeping: Maintain records of the measured pressure drop of the gas flowthrough each wet scrubbing system

Minn. R. 7007.0800, subp. 4

Recordkeeping: Maintain records of the measured water flow rate through each wetscrubbing system.

Minn. R. 7007.0800, subp. 4

Submittal: due 30 days after end of each calendar half-year the Permittee shallsubmit a Semiannual Deviations Report to the MPCA containing a record of theaverage scrubber pressure drop measurements of each period of 15 minuteduration or more during which the pressure drop of the scrubber was less than avalue that is 30% below the average scrubber pressure drop measured during themost recent performance test.

Minn. R. 7007.0800, subp. 6

Corrective Actions: If the pressure is below the minimum specified by this permit orif the venturi scrubber or any of its components are found during the inspections toneed repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the pressure to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the venturi scrubber. The Permittee shall keep a record of the typeand date of any corrective action taken.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the control device in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

TABLE B: SUBMITTALSFacility Name: Seneca Wastewater Treatment Plant

Permit Number: 03700043 - 005

04/13/10B-1

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Seneca Wastewater Treatment Plant


04/13/10B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

TABLE B: RECURRENT SUBMITTALSFacility Name: Seneca Wastewater Treatment Plant


04/13/10B-3

What to send When to send Portion of Facility AffectedCOMS Calibration Error Audit ResultsSummary

due 30 days after end of each calendarquarter following Permit Issuance

MR001

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter following Permit Issuance. SubmitDeviations Reporting Form DRF-1 asamended. The EER shall indicate all periodsof monitor bypass and all periods ofexceedances of the limit includingexceedances allowed by an applicablestandard, i.e. during startup, shutdown, andmalfunctions. The EER must be submittedeven if there were no excess emissions,downtime or bypasses during the quarter.

GP001

Report due 30 days after end of each calendarhalf-year starting 10/24/2002 (The report shallcontain the mercury sample analysis of themixed sludge charged to the incinerators).This is a state-only requirement and is notenforceable by the EPA Administrator, norsubject to the citizen suit provisions of section304 of the Clean Air Act, 42 U.S.C. section7604.

GP001

Report due 30 days after end of each calendarhalf-year starting 10/24/2002 (The report shallcontain the monthly mercury sample analysisof the mixed sludge charged to theincinerators)

GP001

Semiannual Deviations Report due 30 days after end of each calendarhalf-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). The Permittee shall submitthis on a form approved by the Commissioner,both to the Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

Emissions Inventory Report due 91 days after end of each calendar yearfollowing Permit Issuance, to be submitted ona form approved by the Commissioner.

Total Facility

APPENDIX MATERIAL Facility Name: Seneca Wastewater Treatment Plant Permit Number: 03700043-004 ----------------------------------------------------------------------------------------------------------

Appendix A: Insignificant Activities Required to be Listed

Space Heaters 7007.1300 , Subpart 3(A)

Hot Water Heater Truck Wash 7007.1300, Subpart 3(B)(2)

Unleaded Gasoline Tanks 7007.1300, Subpart 3(E)(1)

Arc Welding 7007.1300, Subpart 3(H)(3)

Painting for Plant Upkeep 7007.1300, Subpart 3(K)

Bar Screens 7007.1300 , Subpart 4

Grit Tanks 7007.1300 , Subpart 4

Primary Clarifiers 7007.1300 , Subpart 4

Aeration Influent Channel 7007.1300 , Subpart 4

Final Clarifiers 7007.1300 , Subpart 4

Chlorination 7007.1300 , Subpart 4

Cascade Aerator Channel 7007.1300 , Subpart 4

Dechlorination 7007.1300 , Subpart 4

Thickening & Dewatering Centrifuges 7007.1300 , Subpart 4

Sludge Storage Tanks 7007.1300 , Subpart 4

Standby 100 kW Generator 7007.1300 , Subpart 4

Standby 30 kW Generator 7007.1300 , Subpart 4

Parts Washer 7007.1300 , Subpart 4

Degreasing 7007.1300 , Subpart 4

Gasoline Pumps 7007.1300 , Subpart 4

Air Handling 7007.1300 , Subpart 4

Boilers 7007.1300 , Subpart 4

Machine Shop Equipment and ash handling 7008.4100

Insignificant Activities and Applicable Requirements The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements.

Minn. R. 7007.1300,

subpart Rule Description of the Activity

Applicable Requirement

3(A) Fuel use: space heaters fueled by, kerosene, natural gas, or propane.

Minn. R. 7011.0510/0515

3(B) Furnaces, boilers, and incinerators:

2. fuel burning equipment with a capacity less than 500,000 Btu/hour but only if the total combined capacity of all fuel burning equipment at the stationary source with a capacity less than 500,000 Btu per hour is less than or equal to 2,000,000 Btu/hour.

Minn. R. 7011.0510/0515

3(E) Storage tanks:

Minn. R. 7007.1300,



1. gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and

Minn. R. 7011.0710/0715 OR

Minn. R. 7011.1505, subp. 2(B)/1505, subp. 3(B) OR

Minn. R. 7011.0105/0110 (if not associated with industrial process per the IPE definition)

3(H)

Miscellaneous:

3. brazing, soldering or welding equipment; Minn. R. 7011.0510/.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0710/0715

3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

Minn. R. 7011.0710/0715

Insignificant Activities Required to Be Listed for Part 70 sources

Minn. R. 7007.1300,



4 Individual emissions units at a stationary source, each of which has:

A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide;

B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and

C. For hazardous air pollutants, emissions units with:

(1) potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in subp. 5; or

(2) combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart.

Varies for different equipment

Conditionally Insignificant Activities

Rule Description of the Activity


Rule Description of the Activity


Minn. R. 7008.4100

Total VOC Usage at the stationary source less than 200 gallons or 2000 pounds in each calendar year. See Minn. R. 7008.4100 for recordkeeping and calculation requirements for this activity.

Minn. R. 7011.0710/0715

Appendix B: The mercury emissions shall be determined by use of the following equation.

EHg = MQ Fsm(avg)/1000 where: EHg = Mercury emissions, g/day. M = Mercury concentration of sludge on a dry solids basis, μg/g. Q = Sludge changing rate, kg/day. Fsm = Weight fraction of solids in the collected sludge after mixing. 1000 = Conversion factor, kg μg/g2.

Technical Support Document, Permit Action Number: 03700043-005 Page 1 of 14 Date: 5/12/2010

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 03700043-005 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information 1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 4952)

Metropolitan Council 390 Robert St. N. St. Paul, MN 55101

MCES Seneca Wastewater Treatment Plant 3750 Plant Rd Eagan, Dakota County, MN 55122

Contact: Mary Gail Scott Phone: 651-602-1073

1.2 Facility Description

The MCES-Seneca Wastewater Treatment Plant was constructed in 1972 and was designed to treat an annual average wastewater flow of 24 million gallons per day (mgd). The Minnesota Pollution Control Agency (MPCA) issued a National Pollutant Discharge Elimination System (NPDES) permit in 1987 that allowed the expansion and upgrade of the wastewater treatment processes to an annual average flow of 38 mgd. An air emission permit issued in 1991 authorized the modification and rehabilitation of the existing incineration system and associated air pollution control equipment. As a result of the expansion, an agreement to address odor and emission concerns was reached between the city of Eagan and the Metropolitan Council. Two multiple hearth furnaces are used at the plant to incinerate sewage sludge produced at the facility. Seneca may also accept sewage sludge from other wastewater treatment plants for incineration. Each incinerator has seven hearths and a separate afterburner. Feed materials include sewage sludge, spent activated carbon, scum and granulated nonhazardous sorbent materials generated on-site. Auxiliary burners, located on hearths 3, 5, and 6, are used for startup and to maintain sludge combustion and incinerator temperatures. The auxiliary burners are fueled with natural gas or propane. The Seneca Wastewater Treatment Plant also includes an alkaline final stabilization facility which processes sewage sludge to produce a Class B land application product (as defined by Minnesota Rules) through the addition of alkaline admixtures.


1.3 Description of any Changes Allowed with this Permit Issuance This permit action is for the reissuance of the facility’s Part 70 permit. This reissuance updates facility description data, results from performance testing and represents the facility’s current operating conditions.

1.4 Description of All Amendments Issued Since the Issuance of the Last Total Facility Permit

Permit Number and Issuance Date

Action Authorized

03700043-004 (06/19/2008)

An administrative amendment application was received June 14, 2006 in accordance with Minn. R. 7007.1400, subp. 1(B) that requested a change of address for the company owner of the permitted facility. The company owner of Seneca Wastewater Treatment Plant is the Metropolitan Council and their new address is 390 Robert St. N, St. Paul, MN 55101. The previous address was 230 E. Fifth St., St. Paul, MN 55101. The new recordkeeping requirement per Minn. R. 7007.1200, subp. 4 was added to the permit. Duplications of submittal actions for Application for Permit Reissuance and Semiannual Deviations Report were deleted from the permit.

03700043-003 (12/07/2004)

This permit amendment was an MPCA initiated amendment under Minn. R. 7007.1600, subp. 1(D). It incorporated operating limits for GP001, GP002, CE002 and CE004 imposed on the Facility under the performance testing rules (Minn. R. 7017.2025, subp. 3).

03700043-002 (06/28/2004)

This permit amendment was an MPCA initiated amendment under Minn. R. 7007.1600, subp. 1(D). It incorporated operating limits for GP001 imposed on the Facility under the performance testing rules (Minn. R. 7017.2025, subp. 3). The permit also extended the THC monitoring and reporting requirements for GP001 emission units for an additional year to allow for the installation of new burners on the afterburners to optimize burner efficiencies.

03700043-001 (10/24/2002)

Total Facility Operating Permit


1.5 Facility Emissions:

Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

Pb tpy

VOC tpy

SingleHAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions

33.3 33.3 33.3 588.7 180.8 152.0 1.27 17.9 0.21 2.8

Total Facility Actual Emissions (2007)

5.52 3.91 NA 93.37 24.33 74.7 0.07 0.15 HAPs not reported in emission inventory

Table 3. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD x x Part 70 Permit Program x Part 63 NESHAP x

2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under New Source Review regulations.

Part 70 Permit Program

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

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63 Even so, 40 CFR pt. 61 Subpart E-National Emission Standards for Mercury applies. In addition, the Permittee has stated that no area source NESHAPs apply to the facility.


Compliance Assurance Monitoring (CAM)

Table 4. CAM Summary

Emission Unit

Control CAM Applicability1

Pollutant Monitoring

001 None

(Direct Flame Afterburner for volatile HAPs and Venturi Scrubber for Hydrochloric Acid and PM/PM10)

Large CO (Urestricted potential of 757 TPY; Actual Emissions of 17 TPY) SO2 (Urestricted potential of 294 TPY; Actual Emissions of 2.24 TPY)

Continuous Monitors: Oxygen and Opacity

002 None

(Direct Flame Afterburner for volatile HAPs and Venturi Scrubber for Hydrochloric Acid and PM/PM10)

Large SO2

(Urestricted potential of 294 TPY; Actual Emissions of 1.03 TPY)

Continuous Monitors: Oxygen and Opacity

1 - Since the facility does not have add-on controls, CAM does not apply. See the Attachment to this document for the applicants CAM submittal.

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0150: Control of Fugitive Particulate Matter • Minn. R. 7011.0715: Standards of Performance for Post-1969 Industrial Process Equipment • Minn. R. 7011.1305: Standards of Performance for Existing Sewage Sludge Incinerators • Minn. R. 7011.9950: Emission Standards for Hazardous Air Pollutants (Hg)


Table 5. Regulatory Overview of Facility

Level* Applicable Regulations Comments:

GP001 Minn. R. ch. 7017 and part 7007.0800, subp. 2

Requires operation of Continuous Opacity Monitors and temperature monitors for the incinerators.

40 CFR pt. 61, subp. C Federal National Emission Standards for Hazardous Air Pollutants; establishes a limit on the total amount of mercury to be emitted from the two incinerators. The permittee has also accepted a mercury trigger level in the permit that, if exceeded, will initiate activities to identify the source of the increase and reduction strategies.

Minn. R. 7011.1305, A, B and C

Minnesota Rules establishing Standards of Performance for Existing Sewage Sludge Incinerators constructed before 1973; establishes limits for particulate matter and opacity. The Metropolitan Council has accepted a more stringent particulate matter limit in the permit.

GP003 Minn. R. 7011.0700 through 7011.0735

Standards of Performance for Industrial Process Equipment; establishes limits on emission of particulate matter and opacity Periodic Monitoring: The particulate limit is a generous general requirement that applies to all industrial process equipment. These units do not generate particulate matter in any appreciable amounts and therefore periodic monitoring is not required.

CE 001 and

CE 003

Minn. R. 7011.1305, C; Minn. R. 7007.0800, subp. 2

Minimum Incinerator Combustion Temperature, to insure complete combustion of sludge.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.). The language 'This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law. State law requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

3. Technical Information Mercury Since sewage sludge incineration is a known source of mercury emissions to the atmosphere, it is appropriate that the permit should address mercury emissions. There is a current standard for emission of mercury to the atmosphere from sewage sludge incineration (a federal regulation established in 1973). The permittee is in compliance with that standard. The facility has a mercury-monitoring requirement for the treated water under the NPDES permit program. The mercury concentration of the treated wastewater has been consistently nondetectable by the conventional analytical methods. This limitations in the water discharges and air emissions have resulted in increasingly stringent discharge limits for the industrial users of the metropolitan area sewer system.


However, the MPCA identified the need to reduce mercury emissions from all sources. To determine what policies could further reduce mercury emissions using the lowest-cost approaches that most effectively would lead to reduced mercury contamination in the environment, the MPCA conducted a "Mercury Contamination Reduction Initiative." The initiative process called for creating a detailed list of all the ways that sources could reduce their use and release of mercury. A system of strategies which would create incentives or requirements for mercury reduction options to be implemented, e.g., education, regulatory approaches, etc., will then be identified, along with a timeline for implementation. The permittee participated actively in the initiative as a member of the Advisory Council. As part of the mercury reduction initiative, the permittee has agreed to include voluntary mercury requirements in the permit. These requirements include increased monitoring and a trigger level to provide data for tracking mercury emissions, prevent any increase in mercury emissions, and to provide incentive to further reduce emissions. In addition, the permittee has received MPCA approval of its Voluntary Mercury Reduction Agreement, which focuses on the reduction and prevention of mercury discharges to the Metropolitan Disposal System.

3.1 Calculations of Potential to Emit

Attachment to this TSD contains the facility’s PTE summary.

3.2 Periodic Monitoring and CAM

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found attached to this TSD. Further discussion of decisions about CAM can be found in Table 4.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already

available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere.

Table 6 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.


Table 6. Periodic Monitoring Level* Requirement (basis

– see also the attached CD-01)

Additional Monitoring Discussion

GP 001 a) PM ≤ 1.30 lbs/ton dry sludge input ((Minn. R. 7007.0800, subp. 2; (most stringent, meets limits set by Minn. R. 7011.1305)) b) PM ≤ 7.31 lbs/ton using 24-hour Block Average (Minn. R. 7007.0800, subp. 2; (most stringent, meets limits set by Minn. R. 7011.1305)) c) Opacity ≤ 20 except for on six-minute period per hour of not more than 33 percent (Minn. R. 7011.1305 C) d) Mercury ≤ 3200 grams per 24-hour period (40 CFR section 61.52; 40 CFR section 61.54; Minn. R. 7011.9950) e) Process Throughput ≤ 27,156 tons/year using 12month rolling sum (Minn. R. 7007.0800, subp. 2) f) Process Throughput ≤ 1.44 tons/hour using 24 block average (Minn.

Monthly Sludge sampling Continuous temperature Monitors Continuous fuel flow monitoring Continuous oxygen monitoring Continuous sludge feed rate monitoring Continuous Opacity Monitor Continuous flow rate measurement of sludge charged to the incinerators

Requires the operation of continuous monitors and monthly sludge sampling. Quarterly stack emission test for mercury, or alternative method if approved by the MPCA Commissioner. The permittee has accepted additional sludge sampling and analysis in the permit.


Level* Requirement (basis – see also the

attached CD-01)


R. 7007.0800, subp. 4; Minn. R. 7017.2025, subps. 2.B, 3.C and 3a.(B)) g) Process Throughput ≤ 1.46 tons/hour using 24 block average (Minn. R. 7007.0800, subp. 4; Minn. R. 7017.2025, subps. 2.B, 3.C and 3a.(B))

GP 003 PM ≤ 0.3 grains/dscf (Minn. R. 7011.0715, subp. 1(A)) Opacity ≤ 20 percent (Minn. R. 7011.0715, subp. 1(B))

Standards of Performance for Industrial Process Equipment; establishes limits on emission of particulate matter and opacity

The particulate limit is a generous general requirement that applies to all industrial process equipment. These units do not generate particulate matter in any appreciable amounts and therefore periodic monitoring is not required.

SV 001 PM and Opacity testing (Minn. R. 7017.2020)

Performance Testing/COMS Performance testing requirements and COMS ensure compliance with PM and Opacity limits.

CE 001 and

CE 003

Temperature ≥ 1050 degrees F using 1-hour block average (Minn. R. 7011.1305, C; Minn. R. 7007.0800, subp. 2)

Temperature monitoring and recordkeeping Continuous temperature monitoring verifies

compliance with temperature requirement.

CE 002 and

CE 004

HCL ≥ 80% control efficiency (Minn. R. 7007.0800 subp. 16J) Total PM ≥ 90% control efficiency (Minn. R. 7007.0800 subp. 16J)

Pressure drop, water flow rate Continuous pressure drop and water flow rate monitoring verifies compliance with those parameters established during the most recent performance test showing compliance.


Level* Requirement (basis – see also the

attached CD-01)


PM10 ≥ 90% control efficiency (Minn. R. 7007.0800 subp. 16J) Pressure drop ≥ 15 inches of water column (Minn. R. 7007.0800 subp. 2) Water flow rate gallons/minute using 1-hour average (Minn. R. 7007.0800 subp. 2)

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3.3 Insignificant Activities

The facility name has several operations that are classified as insignificant activities. These are listed in the Appendix to the permit.

3.4 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.5 Comments Received

Public Notice Period: August 01, 2009 – August 31, 2009 EPA 45-day Review Period: February 26, 2010 – April 12, 2010

Comments were received during the public notice period. Attached are the comments as well as the MPCA’s response to those comments. The revised permit was sent to EPA for their 45-day review on February 26, 2010. Comments were not received from EPA during their review period.


4. Conclusion

Based on the information provided by the facility, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03700043-005 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. This permitting action is being completed under Title V reissuance timelines.

Staff Members on Permit Team: Steven Gorg, M.S., P.E. (permit writer/engineer) Steve Palzkill (enforcement) Curt Stock (stack testing) Bruce Braaten (peer reviewer) Anne Jackson (Hg peer reviewer) Laurie O’Brien (support staff) Beckie Olson (support staff)

AQ File No. 879A; DQ 1493, 1959 and 2400 Attachments: 1. PTE Summary

2. CD-01 Forms 3. CAM Submittal 4. Comments Received


Attachment 1: PTE Summary


Attachment 2: CD-01 Forms


Attachment 3:

CAM Submittal


Attachment 4:

Comments Received

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