TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO. 13700112‐009 This technical support document (TSD) is intended for all parties interested in the draft/proposed 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 preliminary determination to issue the draft/proposed 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) Western Lake Superior Sanitary District 2626 Courtland St Duluth, Minnesota 55806 Western Lake Superior Sanitary District 2626 Courtland St Duluth, St. Louis County, Minnesota 55806 Contact: Joseph M. Mayasich Phone: 218‐722‐3336 1.2 Facility Description Western Lake Superior Sanitary District (WLSSD) is a publicly owned treatment works whose primary function is to treat municipal and industrial wastewater. The facility also includes household hazardous waste collection. The facility is located in Duluth, St. Louis County, Minnesota. The wastewater treatment facility was constructed between 1975 and 1978. The plant officially began operations in January of 1979. The plant provides advanced secondary treatment to domestic and industrial wastewater from ten municipalities and three major wood product industries. Wastewater is collected by an extensive interceptor system. The municipalities serviced are in St. Louis and Carlton Counties and include the cities of Duluth, Cloquet, Carlton, Esko, (Thomson Township), Scanlon, Wrenshall, Hermantown, Proctor, and Thompson. WLSSD treats an average daily flow of wastewater of approximately 43 million gallons per day (MGD). The facility was designed to handle a peak flow of 87 MGD. Municipal customers account for 50 percent (at 43 MGD) of wastewater flow received by the facility with industry contributions accounting for the remaining inflow to the facility. The wastewater treatment facility generates an average of 200 wet tons (moisture content of approximately 94 to 95 percent) of sewage sludge each day. The sludge is currently treated with digesters. The anaerobic digesters biologically decompose the sludge, producing a product that is sufficiently stable for storage and application to land. The by‐products of anaerobic digestion are methane (CH 4 ), carbon dioxide (CO 2 ), and small amounts of nitrogen, hydrogen, hydrogen sulfide (H 2 S) and water. The permit requires the digester gas to be routed to a combustion device. Pollutants of concern are nitrogen oxides (NO x ), carbon monoxide (CO), and CO 2 from combustion and CO 2 , CH 4 , and H 2 S from anaerobic digestion. The facility is an existing major source under Federal Operating Program (40 CFR Pt. 70), an area source under Federal Operating Program (40 CFR pt. 63), and minor source New Source Review/Prevention of Significant Deterioration (NSR/PSD).
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TECHNICAL SUPPORT DOCUMENT For
DRAFT/PROPOSED AIR EMISSION PERMIT NO. 13700112‐009 This technical support document (TSD) is intended for all parties interested in the draft/proposed 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 preliminary determination to issue the draft/proposed 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)
Western Lake Superior Sanitary District2626 Courtland St Duluth, Minnesota 55806
Western Lake Superior Sanitary District 2626 Courtland St Duluth, St. Louis County, Minnesota 55806
Contact: Joseph M. Mayasich Phone: 218‐722‐3336
1.2 Facility Description Western Lake Superior Sanitary District (WLSSD) is a publicly owned treatment works whose primary function is to treat municipal and industrial wastewater. The facility also includes household hazardous waste collection. The facility is located in Duluth, St. Louis County, Minnesota.
The wastewater treatment facility was constructed between 1975 and 1978. The plant officially began operations in January of 1979. The plant provides advanced secondary treatment to domestic and industrial wastewater from ten municipalities and three major wood product industries. Wastewater is collected by an extensive interceptor system. The municipalities serviced are in St. Louis and Carlton Counties and include the cities of Duluth, Cloquet, Carlton, Esko, (Thomson Township), Scanlon, Wrenshall, Hermantown, Proctor, and Thompson.
WLSSD treats an average daily flow of wastewater of approximately 43 million gallons per day (MGD). The facility was designed to handle a peak flow of 87 MGD. Municipal customers account for 50 percent (at 43 MGD) of wastewater flow received by the facility with industry contributions accounting for the remaining inflow to the facility.
The wastewater treatment facility generates an average of 200 wet tons (moisture content of approximately 94 to 95 percent) of sewage sludge each day. The sludge is currently treated with digesters. The anaerobic digesters biologically decompose the sludge, producing a product that is sufficiently stable for storage and application to land. The by‐products of anaerobic digestion are methane (CH4), carbon dioxide (CO2), and small amounts of nitrogen, hydrogen, hydrogen sulfide (H2S) and water. The permit requires the digester gas to be routed to a combustion device.
Pollutants of concern are nitrogen oxides (NOx), carbon monoxide (CO), and CO2 from combustion and CO2, CH4, and H2S from anaerobic digestion. The facility is an existing major source under Federal Operating Program (40 CFR Pt. 70), an area source under Federal Operating Program (40 CFR pt. 63), and minor source New Source Review/Prevention of Significant Deterioration (NSR/PSD).
1.3 Description of the Activities Allowed by this Permit Action This permit action is for a Major Amendment. The amendment authorizes construction and operation of three digester gas with natural gas backup fired boilers (EUs 062‐064) at 7 MMBtu/hr each, seven natural gas with fuel oil backup fired boilers (EUs 065‐071) at 5.5 MMBtu/hr each, a digester gas treatment system (EU 072), and three digester gas fired reciprocating internal combustion engines (EUs 073‐075) at a range of 800‐1000 kilowatt of electrical capacity (kWe) each. The digester gas treatment system contains three separate parts; a bio‐filter for H2S removal, a water knock‐out system, and a siloxane removal system. The siloxane removal system contains an internal flare which fires during the regeneration cycle. Additionally, the facility will have a contractor owned temporary flare (EU 076) onsite for backup purposes during construction. The permit action also authorizes the addition of high strength waste to the current anaerobic digesters. The high strength waste addition will increase the amount of digester gas produced. All digester gas will be routed to and combusted in either the digester gas boilers, the digester gas engines, the current existing flare, or the temporary flare. These units act as control equipment for the removal of CH4 prior to atmospheric release. The existing digester gas boiler (EU 050) and two heating boilers (EUs 051‐052) will be replaced by the new boilers (EUs 062‐071). A 60 day shakedown period for EU 50, EU 51, and EU 52 begins after the startup of the new boilers. Initial equipment testing during the installation of the new boilers does not constitute startup for production purposes. During the shakedown period, EU 050 shall not be operated at the same time as EUs 062‐064 and EUs 051‐052 shall not be operated at the same time as EUs 065‐071. EU 50, EU 51, and EU 52 shall be permanently shutdown by the end of their 60 day shakedown period. 1.4 Facility Emissions: Table 2 below lists the total facility potential to emit (PTE) for the amendment due to the installation and operation of the new emission units. The emissions increases do not exceed major source NSR/112(g) thresholds.
Table 2. Title I Emissions Summary
Pollutant
Unlimited Potential Emissions from the
Modification (tpy)
Limited Potential Emissions from the Modification
(tpy)
NSR/112(g) Threshold for New Major Source
(tpy)
NSR/112(g) Review Required? (Yes/No)
PM 7.3 7.3 250 No
PM10 6.0 6.0 250 No
PM2.5 5.1 5.1 250 No
NOX 115 115 250 No
SO2 104 104 250 No
CO 226 226 250 No
Ozone (VOC) 44 44 250 No
Lead 0.0 0.0 250 No
CO2e* 57,600 57,600 100,000 No
*Carbon dioxide equivalents as defined in Minn. R. 7007.0100.
Table 3 below lists the total facility PTE prior to, after and the resulting increase from the amendment modification. Currently, the facility is operating boilers EUs 050‐052 and the existing flare EU 054. After the change, the facility will have removed boilers EUs 050‐052, and will be operating the three digester gas boilers, seven heating boilers, three digester gas engines, digester treatment flare, existing flare, and temporary flare. The PTE is limited based on total digester gas production capacity and is explained in detail in section 3.1 of this TSD. The flares PTE prior to the modification is based on current digester gas production; the PTE after the modification is based on the increased digester capacity. Since air emissions are based on digester gas production, the total facility actual emissions should increase slightly due to the addition of high strength waste to the digesters. The total potential increase for digester gas production is approximately 10%.
Table 3. Total Facility Potential to Emit Summary
Total Facility Limited PTE
PM tpy
PM10 tpy
PM2.5 tpy
SO2 tpy
NOx tpy
CO Tpy
CO2e tpy
VOC tpy
SingleHAP tpy
AllHAPs tpy
Potential Emissions Prior to Modification
6.83 5.41 4.47 108 48.6 30.4 61,600 25.5 3.6 4.9
Potential Emissions After Modification
7.54 6.34 5.44 105 127 231 66,400 48.2 4.5 8.9
Net Potential Emissions Increase from Modification
0.71 0.93 0.97 ‐3.2 78.0 200 4,800 22.7 0.9 4.0
Actual Emissions (2012)
0.52 0.52 0.51 0.60 17.5 10.7 * 20.8 *
* Not reported in MN emission inventory.
Table 4: Facility Classification
Classification Major Synthetic Minor/Area Minor/Area
PSD X
Part 70 Permit Program X
Part 63 NESHAP X
2. Regulatory and/or Statutory Basis New Source Review (NSR) The facility is a true minor source for PSD. The anaerobic digesters cannot produce enough digester gas to fire all the units at the same time. For this reason, the PTE is based on the combustion of available digester gas. The existing digester gas boiler and two heating boilers will be replaced by three digester gas boilers and seven heating boilers. After this amendment, the facility still remains below major NSR/PSD thresholds. The facility’s unrestricted PTE for greenhouse gases (measured as carbon dioxide equivalent, CO2e) is above the major source threshold for NSR/PSD. The digester gas produced in the digesters consists primarily of CO2 and CH4. All digester gas must be routed through a combustion device. After combustion of the methane, the CO2e PTE is below the major source PSD thresholds. The Supreme Court’s June 23, 2014 decision determined that the EPA will no longer apply or enforce federal regulations solely because the source emits or has the potential to emit GHG’s above the major source
NSR/PSD thresholds. Since CO2e is the only unrestricted pollutant above major NSR/PSD thresholds, the facility is still considered a minor source for NSR. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) The three digester gas engines (EUs 073‐075) are subject to 40 CFR pt. 60, subp. JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. The existing digester gas boiler EU 050 and heating boilers EUs 051‐052 are subject to 40 CFR pt. 60, subp. Dc – Standards of Performance for Small Industrial – Commercial ‐ Institutional Steam Generation Units. EUs 050‐052 will be shut‐down and replaced with EUs 065‐071. The requirements under 40 CFR pt. 60, subp. Dc will remain active in the permit until EUs 050‐052 are physically shutdown. The three digester gas boilers (EUs 062‐064) and seven heating boilers (EUs 065‐071) are not subject to 40 CFR pt. 60, subp. Dc. Applicability for the standard is based on each boiler’s heat capacity. The boiler’s heat capacity must be greater than 10 MMBtu/hr but less than 100 MMBtu/hr to be subject to the standard. EUs 062‐064 and EUs 065‐071 have heating capacities of 7 MMBtu/hr each and 5.5 MMBtu/hr each, respectively; therefore, Subpart Dc does not apply. National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is a true minor source under 40 CFR pt. 63. The three digester gas engines (EUs 073‐075) are subject to 40 CFR pt. 63, subp. ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocation Internal Combustion Engines Area Source. To comply with 40 CFR pt. 63, subp. ZZZZ, the engines shall meet the requirements of 40 CFR pt. 60, subp. JJJJ ‐ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, under 40 CFR Section 63.6590(c). The seven heating boilers (EUs 065‐071) are subject to 40 CFR pt. 63, subp. JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. There are no emission limits for the heating boilers, but a tune‐up must be completed every 2‐years for each boiler. The three digester gas boilers (EUs 062‐064) are not subject to 40 CFR pt. 63, subp. JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. Under 40 CFR Section 63.11195(e), gas‐fired boilers are exempt from requirements under 40 CFR pt. 63, subp. JJJJJJ. EUs 062‐064 only fire digester gas and natural gas, both of which are considered a gaseous fuel, therefore; 40 CFR pt. 63, subp. JJJJJJ does not apply. Compliance Assurance Monitoring (CAM) CAM does not apply to the modification allowed in this permit amendment. The anaerobic digesters are the only process units that use control at the facility. All digester gas is required to be vented to a combustion unit (boilers, engines and/or flares). Because of this, all the combustions units act as both emission units and control units. Prior to combustion, the facility is above major CO2e NSR/PSD thresholds. After the methane in the digester gas has been combusted, the facility is below the major
source CO2e NSR/PSD thresholds. The Supreme Court’s June 23, 2014, decision determined that sources cannot trigger NSR/PSD with only CO2e, therefore, CAM is not applicable. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:
Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment.
Minn. R. 7011.0570 Incorporation of New Source Performance Standard by Reference (40 CFR pt. 60, subp. Dc incorporated by reference)
Minn. R. 7011.0610 Standards of Performance for Direct Heating Equipment.
Minn. R. 7011.0715 Standards of Performance for Post‐1969 Industrial Process Equipment.
Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines.
Minn. R. 7011.2310 Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (40 CFR pt. 60, subp JJJJ incorporated by reference)
Minn. R. 7011.8150 Stationary Reciprocating Internal Combustion Engines (40 CFR pt. 63, subp ZZZZ incorporated by reference)
Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment
Subject Item* Applicable Regulations Rationale
GP 003 (Heating Boilers – 800 hp)
40 CFR pt. 60, subp. Dc; Minn. R. 7011.0570
Standards of Performance for Small Industrial‐Commercial‐Institutional Steam Generating Units. Determination of applicable limits from rule:
The units were constructed in 2000;
The heat capacity is 30 MMBtu/hr each; and
The fuel burned is natural gas or No. 2 fuel oil These requirements will remain effective in the permit until the affected units are physically shutdown.
Minn. R. 7007.0800 Limit was set on the combined heat input of the two boilers. This limit was set through a previous permit action to allow the boilers to be installed through a minor amendment process. These requirements will remain effective in the permit until the affected units are physically shutdown.
GP 005 (Anaerobic Digesters)
Minn. R. 7011.0715 Standards of Performance for Post‐1969 Industrial Process Equipment.
GP 007 (Digester Gas Boilers)
Minn. R. 7011.0515 Minnesota Standards of Performance for New Indirect Heating Equipment. The combustion units can fire natural gas and digester gas. Determination of applicable limits from rule:
All units were constructed after January 31, 1977;
Facility is within the City of Duluth and total heat input capacity is less than 250 MMBtu/yr; so only particulate matter and opacity are limited. SO2 and NOx limits do not apply.
GP 008 (Digester Gas Engines)
40 CFR pt. 63, subp. ZZZZ; Minn. R. 7011.8150
National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocation Internal Combustion Engines. EUs 073‐075 are new, spark ignition, non‐emergency engines. To comply with 40 CFR pt. 63, subp. ZZZZ, the engines will meet the requirements of 40 CFR pt. 60, subp. JJJJ
Subject Item* Applicable Regulations Rationale
40 CFR pt. 60, subp. JJJJ; Minn. R. 7011.2310
Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. EUs 073‐075 are new, spark ignition, non‐emergency engines. They fire only digester gas.
Minn. R. 7011.2300 Minnesota Standard of Performance for Stationary Internal Combustion Engines.
GP 009 (Existing and Temporary Flare)
Minn. R. 7011.0715 Standards of Performance for Post‐1969 Industrial Process Equipment.
GP 010 (Heating Boilers – 5.5 mmBtu/hr)
40 CFR pt. 63, subp. JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. There are no emission limits with this standard, but a tune‐up must be completed every 2‐years for each boiler.
Minn. R. 7011.0515 Minnesota Standards of Performance for New Indirect Heating Equipment. The combustion units can fire natural gas and No. 2 fuel oil. Determination of applicable limits from rule:
All units were constructed after January 31, 1977;
Facility is within the City of Duluth and total heat input capacity is less than 250 MMBtu/yr; so only particulate matter and opacity are limited. SO2 and NOx limits do not apply.
EU 050 (Digester Gas Boiler)
40 CFR pt. 60, subp. Dc; Minn. R. 7011.0570
Standards of Performance for Small Industrial‐Commercial‐Institutional Steam Generating Units. Determination of applicable limits from rule:
The unit was constructed in 2000;
The heat capacity is 30 MMBtu/hr; and
The fuel burned is digester gas or No. 2 fuel oil These requirements will remain effective in the permit until the affected units are physically shutdown.
EU 072 (Digester Gas Treatment Flare)
Minn. R. 7011.0610 Minnesota Standard of Performance for Direct Heating Equipment. Since total rated heat input of all indirect and direct heating equipment is less than 250 mmBtu/hr and the facility is located outside the Minneapolis‐Saint Paul Air Quality control Region, only particulate matter and opacity are limited. SOx limit does not apply.
*Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 3. Technical Information 3.1 Calculations of Potential to Emit (PTE) Attachment 1 contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. Attachment 2 to this TSD contains Form GI‐07, which summarizes the PTE of the facility. The digester gas produced in the four anaerobic digesters (EUs 058‐061) contains approximately 65% methane. All digester gas produced must be combusted prior to being vented to the atmosphere. Currently, the digester gas is combusted in the existing digester gas boiler (EU050) and the existing flare (EU 054). After construction, the digester gas boilers (EU 062‐064) and the digester gas engines (EU 073‐075) will be primary location for digester gas combustion. The gas will be combusted in the existing flare (EU 054) during malfunctions and maintenance periods of the boilers and engines and in emergencies.
With the addition of the high strength waste, the four digesters can produce a maximum of 41,633 scf/hr of digester gas. This is not enough digester gas to fire all possible units at the same time. The flares (EUs 054 and EU 076) each have the capacity to combust 42,000 scf/hr of digester gas, the three engines have a total digester gas firing capacity of 43,400 scf/hr and the three digester gas boilers have a total digester gas firing capacity of 33,000 scf/hr. The limited PTE calculations include operation of just one flare (existing or temporary) or the three engines when calculating the total facility PTE since there is only enough digester gas to completely fire one flare (temporary or existing) or the three engines at a time. The worst case emissions on a pollutant to pollutant basis were used for these units. The digester gas boilers can fire both digester gas and natural gas as a backup fuel. For PTE purposes, the digester gas boilers are assumed to be firing natural gas and the digester gas is assumed to be combusted in either the engines or the flares. 3.2 Equipment Shut Down and Removal The two existing heating boilers and the current digester gas boiler (EU 050‐052) will be permanently shut‐down/decommissioned. The boilers are subject to all applicable requirements listed in the permit until they are permanently shut‐down. A Notification of the Date of Equipment Removal/Dismantlement shall be submitted for each unit within 15 days of removal/dismantlement. For this permit, removal shall mean the same thing as shut‐down. The Permittee will be decommissioning the units by either disconnecting the water/steam lines or disconnecting the fuel lines to demonstrate that the equipment is inoperable. The final decision on whether the equipment will be removed from the site has not yet been made. The equipment will not be modified and will not be operated in the future. Once EUs 050‐052 have been shut‐down/decommissioned, they will no longer be subject to the requirements listed in the permit. The permit language and applicable requirements for EUs 050‐052 will be removed from the permit during the permit action following the shut‐down/decommission of the boilers. 3.3 Performance Testing 40 CFR pt. 60, subp. JJJJ requires performance testing to assure compliance with the NOx, CO, and VOC limits set within the standard for each of the three digester gas engines (EUs 073‐075). An initial performance test shall be completed to show compliance with each pollutant for each engine. The initial performance test shall be completed within 60 days of the engine reaching maximum capacity, but no later than 180 days after initial engine startup. As required by the standard, testing frequency after the initial performance test shall be completed before the end of each calendar 36 months following the initial performance test or every 8760 operating hours, whichever comes first. A performance test report shall be submitted for each performance test. Minnesota rule (Minn. R. 7017.2035, subp. 2) requires a performance test report to be submitted within 45 days following the completion of the performance test. Federal rule (40 CFR Section 60.4245(d)) requires a copy of each performance test to be submitted within 60 days following the completion of the performance test. Submitting the performance test within 45 days of completion of the performance test will satisfy both the state and the federal requirement.
The facility is using the NOx, CO, and VOC limits set by 40 CFR pt. 60, subp. JJJJ as emission factors for initial PTE calculations. The facility may use performance test results to determine new emission factors for each pollutant. These emission factors can be used for both the emissions inventory report and for future PTE calculations. Using an emission factor based on a performance test has a lifespan of 10 years. Emission factors should be based on the most recent performance test. 3.4 Permit Organization and Requirement Changes Group 003, Heating Boilers – 800 hp: The major amendment authorizes the removal of the existing heating boilers (EUs 051‐052). Upon shut‐down of the emission units, the limits, requirements, and submittals, including requirements under 40 CFR pt. 60, subp. Dc and limits on total combined heat input and sulfur content of fuel oil, will no longer be applicable and can be removed from the permit at the following permit action. The citations for the sulfur content of fuel limit, the total combined heat input limit and the recordkeeping for the total combined heat input limit were incorrect and were updated appropriately. Group 004, Digester Gas Combustion Units: This group has been renamed from “Flare and Waste Gas Boiler” to “Digester Gas Combustion Units”. The group includes the existing flare, temporary flare and digester gas engines. This grouping allows the PTE calculations to properly account for the digester gas production bottleneck. GP 004 PTE is based on digester gas production rate. Because of this, the PTE is assuming only 1 flare or the three engines are operating at a time, on a worst case potential pollutant to pollutant basis. Requirements for the emission units in the group are in GPs 007, 008, and 009. The major amendment allows for the addition of high strength wastes to the digesters which will increase the digester gas capacity. The production capacity increased from 38,000 scf/hr to 41,600 scf/hr. Since 41,600 scf/hr is the maximum amount of gas that can be produced by the four digesters, and one flare has the capacity to combust 42,000 scf/hr, no limit is necessary and the existing limit was removed from the permit. Flow monitors are not required to be installed on any units. GP 007, Digester Gas Boilers: This group has been created and contains requirements for the three new digester gas boilers. The new digester gas boilers are not subject to 40 CFR pt. 63, subp. JJJJJJ or 40 CFR pt. 60, subp. Dc. GP 008, Digester Gas Engines: This group has been created and contains requirements for the three new digester gas engines. The new digester gas engines are subject to 40 CFR pt. 63, subp. ZZZZ and 40 CFR pt. 60, subp. JJJJ. GP 009 Digester Gas Flares: The existing flare EU 054/CE 018 and the temporary flare EU 076/CE 021 both act as emission units and control devices. The flares combust the digester gas and receive 98% methane destruction/control efficiency. Since the digester gas is the fuel source, and PTE emissions are based on fuel type, the flares are permitted like an emission unit. The facility will have EU 076, a contractor owned flare, onsite during construction. EU 076 will be in operation during a portion of the construction process when the gas lines are out of service to the existing flare. Emissions are expected to be the same for both flares. The facility is not expected to operate both flares at the same time.
Group 010, Heating Boilers – 5 mmBtu/hr: This group has been created and contains requirements for the seven new heating boilers. The new heating boilers are not subject to requirements under 40 CFR pt. 60, subp. Dc. EU 050, Digester Gas Boiler: The emission unit is being decommissioned and removed from the permit with this major amendment. All applicable permit limits, requirements, and submittals for EU 050 will remain in the permit until shut‐down of the unit. Upon shut‐down of the emission unit, the limits, requirements and submittals will no longer be applicable and will be removed from the permit at the following permit action. The citation for the sulfur content of fuel limit was incorrect and was updated appropriately. EU 072, Digester Gas Pretreatment System: The digester gas treatment system (EU 072) purifies the digester gas prior to combustion. The treatment system consists of three separate stages; a bio‐filter to remove H2S, a water knock‐out stage, and a siloxane removal stage. During the siloxane regeneration cycle, air is blown through the siloxane treatment system which regenerates the siloxane removal media. This regenerative air flow is considered process gas. Since the process gas does not have the energy capacity to sustain combustion, either natural gas or digester gas is added to the process gas stream and is combusted in an internal flare – the digester treatment flare. 3.5 Construction Authorization and Notifications The Permittee is authorized to install and operate EUs 062‐064 (digester gas boilers), EUs 065‐071 (heating boilers), EU 072 (digester gas treatment flare and bio‐filter), EUs 073‐075 (digester gas engines), and EU 076 (temporary digester gas flare). The Permittee shall commence construction within 5 years of the issuance of permit no. 13700112‐009. An extended timeframe of five years was selected since the facility is a municipality and is planning on constructing the units in two phases over the next several years. The boilers will be installed in phase one and the engines will be installed in phase two. Notifications of commenced construction need to be submitted within 30 days of the date construction began for all units. Construction is as defined in Minn. R. 7007.01000, subp. 5. Notifications of initial startup need to be submitted within 15 days of initial startup for all units. Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testing during installation does not constitute startup for production/operation purposes. The engines require additional information in accordance with 40 CFR pt. 60, subp. JJJJ. The temporary flare will be contractor owned and only be onsite for the construction process. A notification of the date of removal of the temporary flare will be needed within 15 days of the date it was removed. 3.6 Dispersion Modeling A SCREEN 3 analysis was completed for the three digester gas engines (EUs 073‐075). All three engines were modeled as merged stack, as defined in the Minnesota Pollution Control Agency Air Quality Modeling Guidance. Since the final make and model of the engines has not been determined, the stack
diameter, exhaust temperature, exhaust concentration, and exhaust velocity used in the analysis were worst case modeled concentrations. The SCREEN 3 modeling analysis showed that the facility modeled compliance with ambient air impact target levels for all modeled pollutants. A detailed summary of the SCREEN 3 analysis can be found in Attachment 4 of this TSD. Table 6 shows SCREEN 3 ambient impact results of the three engines.
Table 6. Digester Gas Engines SCREEN 3‐ Ambient Air Impact Table
Pollutant Averaging
Time
Maximum Uncontrolled Emissions (lb/hour)
Maximum Controlled Emissions (lb/hour)
Maximum Controlled Emissions (μg/sec)
Ambient Air Impact for stated
Averaging Time (μg/m3)
Ambient Air Target Levels
(μg/m3)
PM10 24‐hr 0.56 0.56 0.07 3.6 150
PM2.5 24‐hr 0.56 0.56 0.07 3.6 35
SO2 1‐hr 7.18 7.18 0.90 115 196
NO2 1‐hr 11.21 11.21 2.35 180 188
CO 1‐hr 46.69 46.69 5.88 750 35,000
CO 8‐hr 46.69 46.69 5.88 525 10,000
Based on the SCREEN 3 screening model output provided for the Western Lake Superior Sanitary District (WLSSD) the facility should comply with all the applicable ambient air quality standards. The only pollutant that seemed high was NO2. The numeric value of the short‐term NO2 NAAQS is 188 micrograms per cubic meter (μg/m3). The NO2 modeled concentration was 179.89 μg/m3. The MPCA does not require further modeling for WLSSD at this time. The rationale for this conclusion is based on the conservative nature of the SCREEN 3 screening model. It is designed to overestimate predicted concentrations to better protect the NAAQS by providing the highest single predicted concentration under simulated meteorological conditions to generate the output. Additionally, the PTE used in the SCREEN 3 analysis was based on the engines fuel combustion capacity, rather than the digester gas production capacity. The digesters cannot produce enough gas to operate all three engines at maximum capacity at the same time, which makes the analysis even more conservative. Based on the stand‐alone value as reported for this project, the MPCA believes that the facility will comply with the applicable NAAQS. 3.7 Monitoring 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. In evaluating the monitoring included in the permit, the MPCA considered the following:
the likelihood of the facility 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.
The table below summarizes the monitoring requirements associated with this amendment.
Table 7. Monitoring
Subject Item*
Requirement (rule basis) Monitoring Discussion
GP 003 (Heating Boilers – 800hp)
Sulfur Content of Fuel: ≤ 0.50 percent by weight Opacity: ≤ 20 % with excursions (40 CFR pt. 60, subp. Dc; Minn. R. 7011.0570)
Recordkeeping: Fuel Certifications
Monitoring required by NSPS Subpart Dc is adequate to demonstrate compliance with the rule. These requirements will remain effective in the permit until the affected units are physically shutdown.
Sulfur Content of Fuel: ≤ 0.050 percent by weight Total Heat Input: ≤ 40 MMBtu/hr (Minn. R. 7007.0800)
Monitoring required by NSPS Subpart Dc is adequate to demonstrate compliance with the sulfur content rule. Recordkeeping of the hourly fuel input and calculated heat input of the boilers, on a 1 hour average basis. These requirements will remain effective in the permit until the affected units are physically shutdown.
GP 005 (Anaerobic Digesters)
PM: ≤ 0.30 grains/dry standard cubic foot of exhaust gas; Opacity: ≤ 20 % (Minn. R. 7011.0715, subp. 1)
None The anaerobic digesters are not expected to emit any particulate matter or opacity so the likelihood of exceeding either limit is very small.
GP 007 (Digester Gas Boilers)
PM: ≤ 0.40 lb/MMBtu; Opacity: ≤ 20 % with exceptions (Minn. R. 7011.0515)
Recordkeeping: Monthly Fuel records
All units use digester gas and natural gas as backup; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning digester gas and natural gas. Design based PTE for each unit, using AP‐42, is 0.034 lb/MMBtu compared to the rule limit of 0.40 lb/MMBtu. Since this is a permit condition, the semi‐annual deviations report will document any deviations from this condition
GP 008 (Digester Gas Engines)
NOX < 1.0 g/hp‐hr CO < 2.0 g/hp‐hr VOC < 0.7 g/hp‐hr (40 CFR pt. 60, subp. JJJJ; Minn. R. 7011.2310)
Initial and
subsequent
performance
testing.
Monitoring required by NSPS 40 CFR pt. 60, subp. JJJJ is
adequate to demonstrate compliance with the limits.
The requirements for 40 CFR pt. 60, subp. JJJJ are listed
at the group level. The performance testing is listed at
the individual unit level (EU 073, 074, and 075).
Subject Item*
Requirement (rule basis) Monitoring Discussion
Opacity: <20% SO2: <0.50 lbs/mmBtu heat input. (Minn. R. 7011.2300)
Recordkeeping:
Monthly Fuel
records
All units use digester gas; therefore, the likelihood of
violating either of the emission limits is very small. The
Permittee can demonstrate that these units will
continue to operate such that emissions are well below
the emission limits by only burning digester gas. Design
based PTE for each unit, is 0.25 lb/MMBtu compared to
the rule limit of 0.50 lb/MMBtu. Since this is a permit
condition, the semi‐annual deviations report will
document any deviations from this condition
GP 009 (Existing and Temporary Flare)
PM: ≤ 0.30 grains/dry standard cubic foot of exhaust gas; Opacity: ≤ 20 % (Minn. R. 7011.0715)
None Based on equipment design and fuel type (digester gas with natural gas pilot light) the likelihood of violating either limit is very small. The PTE of PM for each flare is 0.005 grains/dry standard cubic foot where the limit at maximum airflow is 0.092 grains/dry standard cubic foot.
GP 010 (Heating Boilers – 5 mmBtu/hr)
PM: ≤ 0.40 lb/MMBtu; Opacity: ≤ 20 % with exceptions (Minn. R. 7011.0515)
Recordkeeping: Monthly Fuel records
All units use natural gas and fuel oil No. 2 as backup; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas and No. 2 fuel oil. Design based PTE for each unit, using AP‐42, is 0.024 lb/MMBtu compared to the rule limit of 0.40 lb/MMBtu. Since this is a permit condition, the semi‐annual deviations report will document any deviations from this condition
Sulfur Content of Fuel: ≤ 0.050 percent by weight (Minn. R. 7005.0100, subp. 35a)
Fuel Supplier Certifications
The Permittee will obtain a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed 0.050 percent by weight.
EU 050 (Digester Gas Boiler)
Sulfur Content of Fuel: ≤ 0.50 percent by weight Opacity: ≤ 20 % with excursions (40 CFR pt. 60, subp. Dc; Minn. R. 7011.0570)
Recordkeeping: Fuel Certifications
Monitoring required by NSPS 40 CFR pt. 60, subp. Dc is adequate to demonstrate compliance with the limit. These requirements will remain effective in the permit until the affected units are physically shutdown.
Sulfur Content of Fuel: ≤ 0.050 percent by weight (Minn. R. 7007.0800)
Recordkeeping: Fuel Certifications
Monitoring required by NSPS Subpart Dc is adequate to demonstrate compliance with the sulfur content limit. These requirements will remain effective in the permit until the affected units are physically shutdown.
Subject Item*
Requirement (rule basis) Monitoring Discussion
EU 072 (Digester Gas Treatment Flare)
PM: ≤ 0.30 grains/dry standard cubic foot of exhaust gas; Opacity: ≤ 20 % (Minn. R. 7011.0610)
None Based on equipment design and fuel type (process gas, digester gas, and natural gas) the likelihood of violating either limit is very small. The flare’s PTE of PM is 0.0006 grains/dry standard cubic foot where the limit at maximum airflow is 0.10 grains/dry standard cubic foot.
*Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 3.8 Insignificant Activities Western Lake Superior Sanitary District has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix B to the permit. There are no additional insignificant activities included in this modification. 3.9 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 electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. This permit uses an appendix to list the insignificant activities. Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit. This is the case for the requirements in GP 003 (Heating Boilers‐800 hp), GP 005 (Anaerobic Digesters), GP 007 (Digester Gas Boilers), GP 008 (Digester Gas Engines), GP 009 (Flares), and GP 010 (Heating Boilers‐5.5 mm Btu/hr). 3.10 Comments Received Public Notice Period: <start date> ‐ <end date> EPA 45‐day Review Period: <start date> ‐ <end date> This section will be completed after the 30‐day public notice period and the 45‐day EPA review period. 4. Permit Fee Assessment Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action is a major amendment which includes the incorporation of 40 CFR pt. 63, subp. JJJJJJ; 40 CFR pt. 63, subp. ZZZZ; and 40 CFR pt. 60, subp. JJJJ. Each NESHAP and NSPS was worth 10 points for a total of 30 points. The SCREEN 3 modeling was completed but does not trigger any points. 5. Conclusion Based on the information provided by Western Lake Superior Sanitary District, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit
No. 13700112‐009 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Andrew Luberda (permit engineer)
Steven Palzkill (enforcement) Marc Severin (compliance) Amrill Okonkwo (peer reviewer) Beckie Olson (permit writing assistant) Sandy Simbeck (administrative support)
AQ File No. 1232A; DQ #4860 Attachments: 1. PTE Summary and Emissions Increase Calculation Spreadsheets
2. Facility Description and CD‐01 Forms 3. Points Calculator 4. Digester Gas Engines SCREEN 3 Modeling Analysis 5. Industrial Process Equipment Analysis
Western Lake Superior Sanitary District Permit No. 13700112-009 Technical Support Document
Attachment 1 PTE Summary and Emissions Increase Calculation Spreadsheets
TSD Attachment 1 Permit Number: 13700112-009 Page 1 of 30
1 The two heating boilers are limited to a total combined heat input of 40 MMBtu/hour. 2 Natural gas heat value AP-42 Section 1.4 (July 1998). No. 2 Fuel Oil heat value from AP-42, Section 1.3 (May 2010).
4 Emission factors from AP-42, Section 1.4 (07/98)5 Emission factors from AP-42, Section 1.3 (05/10)6 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98
8 Sum of all Polycyclic Organic Material emission factors in the respective AP-42 sections
Natural Gas No. 2 Fuel Oil Worst-Case Emissions
3 Maximum permitted sulfur content of No. 2 Fuel Oil. WLSSD uses ultra low sulfur diesel with a sulfur content of 0.0015%.
7 CO2e is the sum of CO2, CH4 and N2O multiplied by their respective global warming potential as listed in 40 CFR 98 Table A-1.
TSD Attachment 1 Permit Number: 13700112-009 Page 16 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Proposed Digester Gas/Natural Gas Boilers, EUs 062-064
Boilers Capacity 7 MMBtu/hr Each Boiler
Fuel Type Heat Value1 Maximum Fuel
Consumption
Rate
Maximum
Sulfur Content2
Digester Gas 663 Btu/scf 0.011 MMscf/hr 1000 PPM H2S
1 Digester gas heating value based methane content of 65%. Natural gas heating value from AP-42, Section 1.4 (July 1998).2 Maximum sulfur content based on treated digester gas, projection. Actual values will be significantly lower.
4 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98
6 Sum of all Polycyclic Organic Material emission factors in the respective AP-42 sections
5 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential as listed in Table A-1 to Subpart A of Part 98
Digester Gas Natural Gas Worst-Case Emissions
3 Emission factors, except SO2, from AP-42, Section 1.4 (07/98). Natural gas emission factors assumed representative for digester gas. No
1 Natural gas heat value AP-42 Section 1.4 (July 1998). No. 2 Fuel Oil heat value from AP-42, Section 1.3 (May 2010).2 Emission factors from AP-42, Section 1.4 (07/98)3 Emission factors from AP-42, Section 1.3 (05/10)4 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98
6 Sum of all Polycyclic Organic Material emission factors in the respective AP-42 sections
Natural Gas No. 2 Fuel Oil Worst-Case Emissions
5 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential as listed in Table A-1 to Subpart A of Part 98
TSD Attachment 1 Permit Number: 13700112-009 Page 18 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Digester Gas Engine Emissions - Each of Three Proposed Engines, EUs 073-075
Generator Size 800-1000 kW, electrical, each of three generators
Engine Size 1412 bhp maximum, obtained from Vendor Spec Sheet
Fuel Consumption 6,795 Btu/bhp, obtained from Vendor Spec Sheet
9.59 MMBtu/hr, maximum fuel use
Gas Heat Content 663.0 Btu/cf, existing facility data
Metals are assumed to be negligible in digester gas
Lead (7439-92-1) 0.0E+00 0.00 0.000
Total HAPs 3.1E-01 1.4E+001 Emission factors obtained from AP-42, Table 3.2-3, July 2000 for natural gas engine. Digester gas HAP
concentrations are not available. No metallic HAP emissions are assumed for digester gas.2 PAHs are assumed to be Polycyclic Organic Matter (POM).
AP-42 organic HAP emission factors that are based on non-detects in test data are excluded.
Greenhouse Gas Emissions
Pollutant Emission Emission Maximum
Factor 2 Rate Uncontrolled
Emissions
(lb/MMBtu) (lbs/hr) (tons/yr)
CO2 114.79 1,101 4,824
CH4 7.05E-03 0.07 0.296
N2O 1.37E-03 0.013 0.057
Biogenic CO2 1101 4824
NonBiogenic CO2e 5.60 24.53
Total CO2e 3 1,107 4,849
¹ CO2 pass through is calculated under the digesters (process) GHG calculation.
663.0 Btu/scf / 1,012.0 Btu/scf = 65.5% methane, with the remaining assumed to be CO2.2 GHG emission factors obtained from 40 CFR 98 Subpart C for biogas.
3 CO2e emissions are calculated with 40 CFR 98 Subp. A global warming potentials of 25 for CH4 and 298 for N20.
TSD Attachment 1 Permit Number: 13700112-009 Page 20 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Proposed Flare, Digester Gas Treatment System with Flare, EU 072
Flare Capacity 510 cfm, preliminary design value
Actual operation will be approximately 4 hr/day
Methane concentration 7.0% Up to 35 cfm natural gas or 50 cfm digester gas
to support combustion
VOC concentration 0.10% Based on raw digester gas concentrations,
Heat content calculated from methane and VOC concentrations and heat contents.
Remainder of gas stream assumed to be nitrogen, oxygen, or CO2.
PollutantEmission Factor3
(lb/MMscf)
Emission Rate
(lbs/hr)
Maximum
Potential
Emissions
(tons/yr)
PM 15 lb/MMscf methane 0.032 0.141
PM10 15 lb/MMscf methane 0.032 0.141
PM2.5 15 lb/MMscf methane 0.032 0.141
NOx 39 lb/MMscf methane 0.084 0.366
SO2 16.5 0.506 2.216
CO 46 lb/MMscf methane 0.099 0.432
VOC 0.14 lb/MMBtu 0.314 1.377
CO24 62.87 lb/MMBtu 141.2 618.5
CH44
0.0423 lb/scf density; 98% CE 1.81 7.94
N2O4 0.02 0.0005 0.002
CO2e5 -- 187 818
4 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 985 CH4 emissions as 0.0423 lb CH4/scfm density (40 CFR 98 Subp II) and 98% control (AP-42, Page 13.5-4, 9/91).5 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential as listed in 40 CFR 98
Table A-1.
2 Maximum sulfur content of digester gas. Actual values are significantly lower.
1 Heat content based on fraction methane and VOC, and their respective heat content. Remainder of gas assumed to be
N2, O2, or CO2.
3 VOC emission factors taken form AP-42, Section 13-5 (09/91). PM, NOx and CO emission factors from AP-42, Section 2.4
1 Digester gas heating value based methane content of 65%. 2 Maximum sulfur content of digester gas without treatment. Actual values are significantly lower.3 VOC emission factors taken form AP-42, Section 13-5 (09/91). PM, NOx and CO emission factors from AP-42, Section 2.4 (10/08).
All other emission factors from AP-42, Section 1.4 (07/98). Natural gas emission factors, where used, are assumed representative. SO2 EF=(ppm H2S/1000000)x(lb-mole H2S/387 ft3 H2S)x(lb-mole SO2 /lb-mole H2S)x(64 lbs SO2/lb-mole SO2)x(1,000,000 ft3/MMscf)4 CO2 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 985 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential as listed in 40 CFR 98 Table A-1.6 Sum of all Polycyclic Organic Material emission factors in the AP-42 sections
Methane Content of
Digester Gas
65%
7 Methane emission rate calculated from 40 CFR 98 Subpart II (not accounting for control): Volume methane or Vm (scfm – methane
fraction of the biogas) x 60 min/hr x .0423 lb/scf methane = lb/hr methane. Assumed 98% control (AP-42, Sect. 13.5).
TSD Attachment 1 Permit Number: 13700112-009 Page 22 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Wastewater Treatment GHG Emissions
GHG emissions are assumed to be split equally among all wastewater treatment processes.
CO2e6 per Digester 2.26 4,986 21,8391 Oxygen demand removal efficiency of 85%, 40 CFR 133.102 requirement for secondary treatment.2 Table 3-1 of GHG Emissions Estimation Methodology for Selected Biogenic Source Categories , EPA (12/10)3 Total Keldal Nitrogen content of the influent4 Assumed to be generated during aeration only5 CO2e is the sum of CO2, CH4 and N2O times their respective global warming potential from Table A-1 to Subpart A of Part 98.6 CO2e is assumed to be generated equally by all fours digesters
TOTAL 9.43E-03 6.66E-02 1.47E-04 4.23E-02 2.83E-04 1.19E-01 9.43E-01 4.13E+00
TSD Attachment 1 Permit Number: 13700112-009 Page 25 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014
HAP
x
x
x
x
x
x
x
x
x
x
x
4.13E+00
TSD Attachment 1 Permit Number: 13700112-009 Page 26 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Emergency Generator (EU 057)
2806 BHP
19.6 MMBtu/hr
Fuel Operating Hours
Maximum
Sulfur
Content1
Diesel 500 0.05%
Emission Factor2Emission
Rate
Potential
Emissions
Pollutant (lb/MMBtu) (lb/hr) (tpy)
PM 1.13 lb/hr 1.13 0.3
PM10 1.13 lb/hr 1.13 0.3
PM2.5 1.13 lb/hr 1.13 0.3
NOx 44.3 lb/hr 44.30 11.1
SO2 0.0505 0.992 0.248
CO 0.85 17 4.2
VOC 0.08 2 0.4
CO23
163 3,196 799
CH43
6.6E-03 0.13 0.032
N2O31.3E-03 0.026 6.5E-03
CO2e4-- 3,207 802
Acetaldehyde 2.52E-05 4.95E-04 1.24E-04
Acrolien 7.88E-06 1.55E-04 3.87E-05
Benzene 7.76E-04 1.52E-02 3.81E-03
Formaldehyde 7.89E-05 1.55E-03 3.87E-04
Toluene 2.81E-04 5.52E-03 1.38E-03
Xylenes 1.93E-04 3.79E-03 9.48E-04
Total HAPS -- 0.027 6.69E-03
1 Maximum permitted sulfur content of No. 2 Fuel Oil. 2 lb/hr emission factors from emergency generator permit amendment, issued May, 2005.
All other emission factors from AP-42, Section 3.43 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98.4 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential
as listed in Table A-1 to Subpart A of Part 98
Engine Rating
TSD Attachment 1 Permit Number: 13700112-009 Page 27 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
HHW Emergency Generator (IA)
25 BHP
0.18 MMBtu/hr
Fuel Operating Hours
Maximum
Sulfur
Content1
Diesel 500 0.05%
Emission Factor2 Emission Rate
Potential
Emissions
Pollutant (lb/MMBtu) (lb/hr) (tpy)
PM 0.31 0.054 0.014
PM10 0.31 0.054 0.014
PM2.5 0.31 0.054 0.014
NOx 4.41 0.772 0.193
SO2 0.29 0.051 0.013
CO 0.95 0.17 0.042
VOC 0.36 0.063 0.016
CO23
163 28.5 7.12
CH43
6.60E-03 1.16E-03 2.89E-04
N2O31.32E-03 2.31E-04 5.78E-05
CO2e4-- 28.57 7.14
1,3-Butadiene 3.91E-05 6.84E-06 1.71E-06
Acetaldehyde 7.67E-04 1.34E-04 3.36E-05
Acrolien 9.25E-05 1.62E-05 4.05E-06
Benzene 9.33E-04 1.63E-04 4.08E-05
Formaldehyde 1.18E-03 2.07E-04 5.16E-05
POM 1.68E-04 2.94E-05 7.35E-06
Toluene 4.09E-04 7.16E-05 1.79E-05
Xylenes 2.85E-04 4.99E-05 1.25E-05
Total HAPS -- 6.78E-04 1.69E-04
1 Maximum permitted sulfur content of No. 2 Fuel Oil. Actual values are significantly lower.2 Emission factors from AP-42, Section 3.33 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98.4 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential
as listed in Table A-1 to Subpart A of Part 98
Engine Rating
TSD Attachment 1 Permit Number: 13700112-009 Page 28 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Micro Turbine (EU 055) - RETIRED
Maximum Capacity 0.478 MMBtu/hr
Fuel Type Heat Value1 Maximum Fuel
Consumption
Rate
Maximum
Sulfur
Content2
Digester Gas 663 Btu/scf 0.0007 MMscf/hr 0.02%
Pollutant
Emission
Factor3
(lb/MMBtu)
Emission Rate
(lbs/hr)
Maximum
Potential
Emissions
(tons/yr)
PM 0.012 0.0057 0.025
PM10 0.012 0.0057 0.025
PM2.5 0.012 0.0057 0.025
NOx 0.16 0.076 0.33
SO2 0.019 0.009 0.039
CO 0.017 0.008 0.036
VOC 0.0058 0.003 0.012
CO24
117 56 244
CH44
2E-03 1E-03 5E-03
N2O42E-04 1E-04 5E-04
CO2e5-- 56 244
1,3-Butadiene 9.80E-06 4.68E-06 1.55E-06
1,4-Dichlorobenzene 2.00E-05 9.56E-06 3.17E-06
Acetaldehyde 5.30E-05 2.53E-05 8.40E-06
Arsenic 1.1E-05 5.26E-06 2.3E-05
Beryllium 3.1E-07 1.48E-07 6.5E-07
Cadmium 5.8E-07 2.77E-07 1.2E-06
Carbon Tetrachloride 2.0E-05 9.56E-06 4.2E-05
Chlorobenzene 1.6E-05 7.65E-06 3.3E-05
Chloroform 1.7E-05 8.13E-06 3.6E-05
Chromium 1.2E-06 5.74E-07 2.5E-06
Ethylene Dichloride 1.5E-05 7.17E-06 3.1E-05
Formaldehyde 1.9E-04 9.08E-05 4.0E-04
Lead 3.4E-06 1.63E-06 7.1E-06
Methylene Chloride 1.3E-05 6.21E-06 2.7E-05
Nickel 2.0E-06 9.56E-07 4.2E-06
Selenium 1.1E-05 5.26E-06 2.3E-05
Tetrachloroethylene 2.1E-05 1.00E-05 4.4E-05
Trichloroethylene 1.8E-05 8.60E-06 3.8E-05
Vinyl Chloride 3.6E-05 1.72E-05 7.5E-05
Vinylidene Chloride 1.5E-05 7.17E-06 3.1E-05
HAP Totals -- 2.26E-04 8.31E-041 Digester gas heating value based 2001 Minor Amendment. 2 Maximum sulfur content of digester gas. Actual values are significantly lower.3 Emission factors from AP-42, Section 3.1 (04/00).4 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98.
6 Polycyclic Organic Material equals sum of Polyaromatic Material and Naphthalene.
5 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential from 40 CFR 98 Table A-1.
TSD Attachment 1 Permit Number: 13700112-009 Page 29 of 30
Western Lake Superior Sanitation District
Major Amendment Application
June 2014Western Lake Superior Sanitary District
Micro Turbine (EU 056) - RETIRED
Maximum Capacity 0.478 MMBtu/hr
Fuel Type Heat Value1 Maximum Fuel
Consumption Rate
Maximum
Sulfur
Content2
Digester Gas 663 Btu/scf 0.0007 MMscf/hr 0.02%
Pollutant
Emission
Factor3
(lb/MMBtu)
Emission Rate
(lbs/hr)
Maximum
Potential
Emissions
(tons/yr)
PM 0.012 0.0057 0.025
PM10 0.012 0.0057 0.025
PM2.5 0.012 0.0057 0.025
NOx 0.16 0.076 0.33
SO2 0.019 0.009 0.039
CO 0.017 0.008 0.036
VOC 0.0058 0.003 0.012
CO24
117 56 244
CH44
2E-03 1E-03 5E-03
N2O42E-04 1E-04 5E-04
CO2e5-- 56 244
1,3-Butadiene 9.80E-06 4.68E-06 1.55E-06
1,4-Dichlorobenzene 2.00E-05 9.56E-06 3.17E-06
Acetaldehyde 5.30E-05 2.53E-05 8.40E-06
Arsenic 1.1E-05 5.26E-06 2.3E-05
Beryllium 3.1E-07 1.48E-07 6.5E-07
Cadmium 5.8E-07 2.77E-07 1.2E-06
Carbon Tetrachloride 2.0E-05 9.56E-06 4.2E-05
Chlorobenzene 1.6E-05 7.65E-06 3.3E-05
Chloroform 1.7E-05 8.13E-06 3.6E-05
Chromium 1.2E-06 5.74E-07 2.5E-06
Ethylene Dichloride 1.5E-05 7.17E-06 3.1E-05
Formaldehyde 1.9E-04 9.08E-05 4.0E-04
Lead 3.4E-06 1.63E-06 7.1E-06
Methylene Chloride 1.3E-05 6.21E-06 2.7E-05
Nickel 2.0E-06 9.56E-07 4.2E-06
Selenium 1.1E-05 5.26E-06 2.3E-05
Tetrachloroethylene 2.1E-05 1.00E-05 4.4E-05
Trichloroethylene 1.8E-05 8.60E-06 3.8E-05
Vinyl Chloride 3.6E-05 1.72E-05 7.5E-05
Vinylidene Chloride 1.5E-05 7.17E-06 3.1E-05
HAP Totals -- 2.26E-04 8.31E-041 Digester gas heating value based 2001 Minor Amendment. 2 Maximum sulfur content of digester gas. Actual values are significantly lower.3 Emission factors from AP-42, Section 3.1 (04/00).4 CO2, CH4 and N2O emission factors converted from Tables C-1 and C-2 to Subpart C of Part 98.
6 Polycyclic Organic Material equals sum of Polyaromatic Material and Naphthalene.
5 CO2e is the sum of CO2, CH4 and N2O emissions times their respective global warming potential from 40 CFR 98 Table A-1.
TSD Attachment 1 Permit Number: 13700112-009 Page 30 of 30
Western Lake Superior Sanitary District Permit No. 13700112-009 Technical Support Document
Attachment 2 Facility Description and CD-01 Forms
TSD Attachment 2 Permit Number: 13700112-009 Page 1 of 134
ST. PAUL, MN 55155-4194
Show: Active and Pending Records
Action: PER 009
AQD Facility ID: 13700112
Facility Name:
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD
23 October, 2014 09:34
FACILITY DESCRIPTION: EMISSION UNIT (EU)
MaxFuelInput
(mil Btu)
Western Lake Superior Sanitary District
RetiredBy
(Action)
Operator DescriptionID No. EmissionUnit
Status
AddedBy
(Action)
ControlEquip.
ID No(s).
Stack/Vent
ID No(s).
OperatorID
for Item
Insignif-icant
Activity
SICManufacturer ModelNumber
Max.Design
Capacity
MaximumDesign
Capacity
Materials Units n Units d
1 Insignificant ActivityEU 001 Retired PER 008 Day DaysWastewater Waste Water4959PRC Consoer-Townsend 120 Mgal Million Gallons
2 Duplicate of EU001EU 002 Retired PER 008 Day Days 4959 120 Mgal Million Gallons
3 Insignificant ActivityEU 003 Retired PER 008 Day DaysWastewater Waste Water4959PRC Consoer-Townsend 120 Mgal Million Gallons
4 Insignificant ActivityEU 004 Retired PER 008 Day DaysWastewater Waste Water4959Vulcan B 120 Mgal Million Gallons
5 Part of EU004EU 005 Retired PER 008 Day Days 4959 120 Mgal Million Gallons
6 Grit Tanks (2)EU 006 Active PER 008 CE 020SV 005 (M)SV 006 (M)SV 097 (O)
Day DaysWastewater Waste Water4959PRC Consoer-Townsend 120 Mgal Million Gallons
7 Grit CollectorEU 007 Active PER 008 CE 020SV 005 (M)SV 006 (M)SV 097 (O)
Day DaysWastewater Waste Water4959Envirex 120 Mgal Million Gallons
8 Part of EU004EU 008 Retired PER 008 Day DaysWastewater Waste Water4959 120 Mgal Million Gallons
9 Part of EU004EU 009 Retired PER 008 Day DaysWastewater Waste Water4959 120 Mgal Million Gallons
10 Part of EU004EU 010 Retired PER 008 Day DaysWastewater Waste Water4959 120 Mgal Million Gallons
11 REMOVED Scum Ejector (4)EU 011 Removed PER 008 Day Days 4959Clow 120 Mgal Million Gallons
12 Insignificant Activity - Part ofEU004
EU 012 Retired PER 008 Day DaysWastewater Waste Water4959 120 Mgal Million Gallons
13 REMOVED OxygenationInfluent Channel and grit tankinfluent
EU 013 Removed PER 008 Day Days 4959PRC Consoer-Townsend 120 Mgal Million Gallons
14 REMOVED Grit Tank EffluentChannel
EU 014 Removed PER 008 Day Days 4959PRC Consoer-Townsend 120 Mgal Million Gallons
772 Digester Gas Boiler 1 - BoilerEU 062 Active PER 009 SV 098 (M) Hr HoursEnergy4952TBD TBD 7 Mmbtu Million British Thermal Units
773 Digester Gas Boiler 2 - BoilerEU 063 Active PER 009 SV 098 (M) Hr HoursEnergy4952TBD TBD 7 Mmbtu Million British Thermal Units
774 Digester Gas Boiler 3 - BoilerEU 064 Active PER 009 SV 098 (M) Hr HoursEnergy4952TBD TBD 7 Mmbtu Million British Thermal Units
5.575 Heating Boiler 1 - BoilerEU 065 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.576 Heating Boiler 2 - BoilerEU 066 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.577 Heating Boiler 3 - BoilerEU 067 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.578 Heating Boiler 4 - BoilerEU 068 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.579 Heating Boiler 5 - BoilerEU 069 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.580 Heating Boiler 6 - BoilerEU 070 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
5.581 Heating Boiler 7 - BoilerEU 071 Active PER 009 SV 099 (M)SV 100 (M)
Hr HoursEnergy4952TBD TBD 5.5 Mmbtu Million British Thermal Units
782 Digester Gas PretreatmentSystem Flare
EU 072 Active PER 009 SV 101 (M) 4952TBD TBD
9.5983 Digester Gas Engine 1 -Reciprocating IC Engine
EU 073 Active PER 009 SV 102 (M) Elect Energy Electrical Energy4952TBD TBD 1000 Kw Kilowatts
9.5984 Digester Gas Engine 2 -Reciprocating IC Engine
EU 074 Active PER 009 SV 103 (M) Elect Energy Electrical Energy4952TBD TBD 1000 Kw Kilowatts
9.5985 Digester Gas Engine 3 -Reciprocating IC Engine
EU 075 Active PER 009 SV 104 (M) Elect Energy Electrical Energy4952TBD TBD 1000 Kw Kilowatts
Page 5 of 6 (a)TSD Attachment 2 Permit Number: 13700112-009 Page 10 of 134
23 October, 2014 09:34
FACILITY DESCRIPTION: EMISSION UNIT (EU)
ID No. ElevatorType
BottleneckPct.Fuel/
SpaceHeat
Firing MethodAddedBy
(Action)
RemovalDate
InitialStartupDate
Comm-ence
Const.Date
EmissionUnit
Status
70 EU 061 PER 008 07/01/200109/01/1999Active
71 EU 061 PER 009 07/01/200109/01/1999Active
72 EU 062 PER 009Active
73 EU 063 PER 009Active
74 EU 064 PER 009Active
75 EU 065 PER 009Active
76 EU 066 PER 009Active
77 EU 067 PER 009Active
78 EU 068 PER 009Active
79 EU 069 PER 009Active
80 EU 070 PER 009Active
81 EU 071 PER 009Active
82 EU 072 PER 009Active
83 EU 073 PER 009Active
84 EU 074 PER 009Active
85 EU 075 PER 009Active
Page 5 of 6 (b)TSD Attachment 2 Permit Number: 13700112-009 Page 11 of 134
ST. PAUL, MN 55155-4194
Show: Active and Pending Records
Action: PER 009
AQD Facility ID: 13700112
Facility Name:
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD
23 October, 2014 09:34
FACILITY DESCRIPTION: EMISSION UNIT (EU)
MaxFuelInput
(mil Btu)
Western Lake Superior Sanitary District
RetiredBy
(Action)
Operator DescriptionID No. EmissionUnit
Status
AddedBy
(Action)
ControlEquip.
ID No(s).
Stack/Vent
ID No(s).
OperatorID
for Item
Insignif-icant
Activity
SICManufacturer ModelNumber
Max.Design
Capacity
MaximumDesign
Capacity
Materials Units n Units d
86 Temporary Digester Gas Flare(CE 021)
EU 076 Active PER 009 SV 105 (M) Hr Hours4952TBD TBD 42000 Ft3 Cubic Feet
Page 6 of 6 (a)TSD Attachment 2 Permit Number: 13700112-009 Page 12 of 134
23 October, 2014 09:34
FACILITY DESCRIPTION: EMISSION UNIT (EU)
ID No. ElevatorType
BottleneckPct.Fuel/
SpaceHeat
Firing MethodAddedBy
(Action)
RemovalDate
InitialStartupDate
Comm-ence
Const.Date
EmissionUnit
Status
86 EU 076 PER 009Active
Page 6 of 6 (b)TSD Attachment 2 Permit Number: 13700112-009 Page 13 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
Show: Active and Pending Records
Action: PER 009
AQD Facility ID: 13700112
Facility Name: Western Lake Superior Sanitary District
23 October, 2014 09:35
FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)
ID No. AddedBy
(Action)
RetiredBy
(Action)
OperatorID
for Item
ControlEquip.Type
Control Equipment Description ModelControlEquip.Status
Manufacturer PollutantsControlled
AfterburnerCombustionParameters
CaptureEfficiency
(%)
Destruction/CollectionEfficiency
(%)
1 CE 001 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F 19-8-220Retired Micro-Pul
2 CE 003 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dracco 76-30606-313Retired Fuller Company Dracco
3 CE 004 PER 006 007 Centrifugal Collector - High Efficiency 102X037Retired Emtrol Corporation
4 CE 005 PER 006 007 Centrifugal Collector - High Efficiency 102X037Retired Emtrol Corporation
5 CE 006 PER 006 007 Centrifugal Collector - High Efficiency 102X037Retired Emtrol Corporation
6 CE 007 PER 006 007 Centrifugal Collector - High Efficiency 102X037Retired Emtrol Corporation
7 CE 008 PER 006 008 Centrifugal Collector - Medium Efficiency KQ-465-42Retired Fischer-Klosterman
8 CE 009 PER 006 008 Centrifugal Collector - Medium Efficiency XQ-42-2Retired Fischer-Klosterman
9 CE 010 PER 006 008 Centrifugal Collector - Medium Efficiency XQ-42-2Retired Fischer-Klosterman
10 CE 011 PER 006 001 Wet Scrubber - High Efficiency w/Lime Slurry W20Retired Emtrol
11 CE 012 PER 006 001 Wet Scrubber - High Efficiency w/Lime Slurry W20Retired Emtrol
12 CE 013 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F 58BV161Retired Flex-Kleen, ResearchCottrell
13 CE 014 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dracco 76-30606-313Retired Fuller CompanyDraccos
14 CE 015 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dracco 76-30606-313Retired Fuller CompanyDraccos
15 CE 016 PER 008 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dracco 76-30606-313Retired Fuller CompanyDraccos
16 CE 017 PER 008 053 Venturi Scrubber 13-B-ISW-10CCW-TH-I-A30
Retired Greenheck
17 CE 018 PER 008 023 FlaringActive MethaneVOC
100100
9898
18 CE 018 PER 009 023 Flaring 244WActive Varec Vapor Control MethaneVOC
100100
9898
19 CE 019 PER 008 099 Other - Combustion in EUsActive MethaneVOC
100100
9898
20 CE 019 PER 009 099 Other - Combustion in EUsActive MethaneVOC
100100
9898
21 CE 020 PER 008 099 Other - Biofilter for odor control NAActive E&A EnvironmentalConsultants
22 CE 021 PER 009 023 Flaring TBDActive TBD MethaneVOC
100100
9898
Page 1 of 1TSD Attachment 2 Permit Number: 13700112-009 Page 14 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
Show:
Action:
AQD Facility ID:
Facility Name:
Active and Pending Records
PER 009
13700112
Western Lake Superior Sanitary District
FACILITY DESCRIPTION: GROUPS (GP)
23 October, 2014 09:35
ID No. AddedBy
(Action)
RetiredBy
(Action)
Includein EI
OperatorID
for Item
Group Description Group ItemsGroupStatus
1 GP 001 PER 006 Fluidized Bed Reactor #1 and #2 CE 003, CE 004, CE 005, CE 012, EU 038, EU 039, EU 040, EU 041, EU 042,EU 045, EU 046, SV 055, SV 056, SV 060, SV 061, SV 069
Retired
2 GP 002 PER 006 Lime Storage Silos CE 015, CE 016, EU 026, EU 027, SV 048, SV 049Retired
3 GP 003 PER 006 Heating Boilers EU 051, EU 052Active
4 GP 003 PER 009 Heating Boilers - 800 hp EU 051, EU 052Active
5 GP 004 PER 006 Flare and Waste Gas Boiler EU 050, EU 054Active
6 GP 004 PER 009 Digester Gas Combustion Units EU 054, EU 073, EU 074, EU 075, EU 076Active
7 GP 005 PER 008 Anaerobic Digesters CE 018, CE 019, EU 050, EU 054, EU 058, EU 059, EU 060, EU 061Active
8 GP 005 PER 009 Anaerobic Digesters EU 058, EU 059, EU 060, EU 061Active
9 GP 006 PER 008 WWT GHGs EU 006, EU 007, EU 017Active
10 GP 007 PER 009 Digester Gas Boilers EU 062, EU 063, EU 064Active
11 GP 008 PER 009 Digester Gas Engines EU 073, EU 074, EU 075Active
12 GP 009 PER 009 Flares CE 018, CE 021, EU 054, EU 076Active
13 GP 010 PER 009 Heating Boilers - 5.5 mmBtu EU 065, EU 066, EU 067, EU 068, EU 069, EU 070, EU 071Active
Page 1 of 1TSD Attachment 2 Permit Number: 13700112-009 Page 15 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
Show: Active and Pending Records
Action: PER 009
AQD Facility ID: 13700112
Facility Name: Western Lake Superior Sanitary District
23 October, 2014 09:36
FACILITY DESCRIPTION: STACK/VENTS (SV)
ID No. Discharge DirectionFlow Rate/Temperature
Information Source
Exit GasTemperature
at Top(ºF)
DesignFlow Rate
at Top(ACFM)
Width(feet)
Diameteror Length
(feet)
Inside DimensionsHeight ofOpening
FromGround(feet)
AddedBy
(Action)
RetiredBy
(Action)
OperatorID
for Item
Operators DescriptionStack/Vent
Status
1 SV 001 PER 008Retired
2 SV 002 HorizontalManufacturer7093257.257.257PER 008 IA Stack - Duluth influent and screw pumpsActive
3 SV 003 HorizontalManufacturer7093257.257.257PER 008 IA Stack - Duluth influent and screw pumpsActive
4 SV 004 PER 008Retired
5 SV 005 Up, With CapManufacturer7061753330PER 008 Building/Room ExhaustActive
6 SV 006 Up, With CapManufacturer7061753330PER 008 Building/Room ExhaustActive
7 SV 007 Up, With CapManufacturer7093003345PER 008 Building/Room ExhaustActive
8 SV 008 Up, With CapManufacturer7093003345PER 008 Building/Room ExhaustActive
9 SV 009 Up, With CapEstimate8070.3321.5PER 008 Oxygenation Tank 4 exhaustActive
10 SV 010 Up, With CapEstimate8070.3321.5PER 008 Oxygenation Tank 3 exhaustActive
11 SV 011 Up, With CapEstimate8070.3321.5PER 008 Oxygenation Tank 2 exhaustActive
12 SV 012 Up, With CapEstimate8070.3321.5PER 008 Oxygenation Tank 1 exhaustActive
13 SV 013 PER 008Retired
14 SV 014 PER 008Retired
15 SV 015 Up, With CapEstimate80.8314.5PER 008 Oxygenation Tank 4 exhaustActive
16 SV 016 Up, With CapEstimate80.8314.5PER 008 Oxygenation Tank 3 exhaustActive
17 SV 017 Up, With CapEstimate80.8314.5PER 008 Oxygenation Tank 2 exhaustActive
18 SV 018 Up, With CapEstimate80.8314.5PER 008 Oxygenation Tank 1 exhaustActive
19 SV 019 Up, With CapEstimate80114.5PER 008 Oxygenation Tank 4 exhaustActive
20 SV 020 Up, With CapEstimate80114.5PER 008 Oxygenation Tank 3 exhaustActive
21 SV 021 Up, With CapEstimate80114.5PER 008 Oxygenation Tank 2 exhaustActive
22 SV 022 Up, With CapEstimate80114.5PER 008 Oxygenation Tank 1 exhaustActive
23 SV 023 Up, No CapManufacturer63900536.7PER 006 Secondary settling tank 1Active
24 SV 024 Up, No CapManufacturer63900536.7PER 006 Secondary settling tank 2Active
25 SV 025 Up, No CapManufacturer63900536.7PER 006 Secondary settling tank 3Active
26 SV 026 Up, No CapManufacturer63900536.7PER 006 Secondary settling tank 4Active
Facility Name: Western Lake Superior Sanitary District
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
Volatile Organic Compounds
PER 008FS 005 0.000E+00 0.000E+00 0.000E+00
PER 008FS 006 0.000E+00 0.000E+00 0.000E+00
PER 008FS 007 0.000E+00 0.000E+00 0.000E+00
PER 008GP 003 2.200E-01 0.000E+00 9.400E-01
PER 009GP 003 0.000E+00 0.000E+00 0.000E+00
PER 008GP 004 3.550E+00 1.553E+01
PER 009GP 004 0.000E+00 4.090E+01
PER 007SV 001 0.000E+00 0.000E+00 0.000E+00
PER 007SV 002 0.000E+00 0.000E+00 0.000E+00
PER 007SV 003 0.000E+00 0.000E+00 0.000E+00
PER 007SV 004 0.000E+00 0.000E+00 0.000E+00
PER 007SV 005 0.000E+00 0.000E+00 0.000E+00
PER 007SV 006 0.000E+00 0.000E+00 0.000E+00
PER 007SV 007 0.000E+00 0.000E+00 0.000E+00
PER 007SV 008 0.000E+00 0.000E+00 0.000E+00 0.000E+00
PER 007SV 055 0.000E+00 0.000E+00 0.000E+00
PER 007SV 061 0.000E+00 0.000E+00 0.000E+00
Totals 8.391E+01 4.774E+01 0.000E+00
Page 37 of 37TSD Attachment 2 Permit Number: 13700112-009 Page 92 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 1 of 42
Subject Item: Total Facility
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Tableof Contents. The Permittee shall comply with all requirements contained in theappendices.
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.
3.0
CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution controlrule, without reducing the total amount of pollutant emitted.
4.0
CD Minn. R. 7007.0800, subp. 2;Minn. R. 7007.0800, subp. 16(J)
Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated.
5.0
CD Minn. R. 7007.0800, subps. 14and 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 meetapplicable permit conditions, a description of the employee training program forproper operation and maintenance of the control equipment and practices, and therecords kept to demonstrate plan implementation.
6.0
CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.
7.0
CD Minn. R. 7011.0150 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.
8.0
CD Minn. R. 7030.0010 - 7030.0080 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.
9.0
CD Minn. R. 7007.0800, subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).
10.0
CD Minn. R. 7007.0800, subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.
11.0
CD hdr PERFORMANCE TESTING12.0
CD Minn. R. ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A and B.
13.0
CD Minn. R. 7017.2018; Minn. R.7017.2030, subps. 1-4, Minn. R.7017.2035, subps. 1-2
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 TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest
The Notification, Test Plan, and Test Report may be submitted in an alternativeformat as allowed by Minn. R. 7017.2018.
14.0
TSD Attachment 2 Permit Number: 13700112-009 Page 93 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 2 of 42
CD Minn. R. 7017.2025, subp. 3 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.
15.0
CD hdr MONITORING REQUIREMENTS16.0
CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:
1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifications.
For each monitor, the Permittee shall maintain a record of all calibrations, includingthe date conducted, and any corrective action that resulted. The Permittee shallinclude the calibration frequencies, procedures, and manufacturer's specifications(if applicable) in the Operations and Maintenance Plan. Any requirements applyingto continuous emission monitors are listed separately in this permit.
17.0
CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A or 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.
18.0
CD hdr RECORDKEEPING19.0
CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, for a period of five (5) years from the date ofmonitoring, sample, measurement, or report. Records which must be retained atthis location include all calibration and maintenance records, all original recordingsfor continuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).
20.0
CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.
21.0
CD Minn. R. 7007.1200, subp. 4 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 bemaintained in either electronic or paper format.
22.0
CD hdr REPORTING/SUBMITTALS23.0
CD Minn. R. 7019.1000, subp. 3 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.
24.0
TSD Attachment 2 Permit Number: 13700112-009 Page 94 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 3 of 42
CD Minn. R. 7019.1000, subp. 2 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.
25.0
CD Minn. R. 7019.1000, subp. 1 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 couldendanger human health or the environment.
26.0
CD 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 beencorrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if notyet corrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.
27.0
S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearstarting 07/31/2012 . The first semiannual report submitted by the Permittee shallcover the calendar half-year in which the permit is issued. The first report of eachcalendar year covers January 1 - June 30. The second report of each calendaryear covers July 1 - December 31. If no deviations have occurred, the Permitteeshall submit the report stating no deviations.
28.0
CD Minn. R. 7007.1150 - 7007.1500 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.
29.0
S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit
30.0
CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendmentto extend 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).Performance testing deadlines from the General Provisions of 40 CFR pt. 60 andpt. 63 are examples of deadlines for which the MPCA does not have authority togrant extensions and therefore do not meet the requirements of Minn. R.7007.1400, subp. 1(H).
31.0
S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting07/31/2012 (for the previous calendar year). The Permittee shall submit this to theCommissioner on a form approved by the Commissioner. This report covers alldeviations experienced during the calendar year.
32.0
CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: due on or before April 1 of each calendar yearfollowing permit issuance, to be submitted on a form approved by theCommissioner.
33.0
CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.34.0
TSD Attachment 2 Permit Number: 13700112-009 Page 95 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 4 of 42
Subject Item: GP 003 Heating Boilers - 800 hp
Associated Items: EU 051 Heating Boiler - Boiler
EU 052 Heating Boiler - Boiler
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 003.1.0
CD Minn. R. 7007.0800, subp. 2 Shakedown Period:The Permittee shall shutdown EU 051 and EU 052 within 60 days after Startup ofthe heating boilers in GP 010 for production purposes. Initial equipment testingduring installation of GP 010 heating boilers does not constitute startup forproduction purposes. During the 60 day period, the Permittee shall not operateheating boilers in GP 010 at the same time as EU 051 and EU 052.
2.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the date of Equipment Removal/Dismantlement: due 15 days afterEquipment Removal and/or Dismantlement of EU 051. This notification shallspecify how the equipment was removed/dismantled and the date of shutdown.
The conditions in the permit applicable to unit EU 051 remain in effect untilshutdown of the unit occurs.
3.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the date of Equipment Removal/Dismantlement: due 15 days afterEquipment Removal and/or Dismantlement of EU 052. This notification shallspecify how the equipment was removed/dismantled and the date of shutdown.
The conditions in the permit applicable to unit EU 052 remain in effect untilshutdown of the unit occurs.
4.0
CD hdr OPERATING AND EMISSION LIMITS5.0
LIMIT Minn. R. 7005.0100, subp. 35a Sulfur Content of Fuel: less than or equal to 0.050 percent by weight when burningoil.
6.0
LIMIT 40 CFR Section 60.42c(d); Minn.R. 7011.0570
Sulfur Content of Fuel: less than or equal to 0.50 percent by weight when burningoil.
7.0
LIMIT 40 CFR Section 60.43c(c); Minn.R. 7011.0570
Opacity: less than or equal to 20 percent except for one 6 minute period per hourof not more than 27 percent.
8.0
LIMIT Minn. R. 7005.0100, subp. 35a The heating boilers may operate at a Total Combined Heat Input: less than orequal to 40.0 million Btu/hour using 1-Hour Average
9.0
CD Minn. R. 7007.0800, subp. 2 Fuel use limited to natural gas and distillate oil.10.0
CD hdr RECORDKEEPING AND REPORTING11.0
CD 40 CFR Section 60.42c(h)(1);Minn. R. 7011.0570
Obtain fuel supplier certifications for each shipment of oil, showing the sulfurcontent of the fuel burned.
12.0
CD Minn. R. 7005.0100, subp. 35a;Minn. R. 7007.0800, subps. 4 & 5
Calculate and record the heat input to each boiler and the total combined heatinput, in million Btu/hour using a 1-hour average, each hour.
13.0
S/A 40 CFR Section 60.48c(e); Minn.R. 7011.0570
Quarterly Report: due 30 days after end of each calendar quarter starting05/17/2005 . The reports shall include:(1) Calendar dates covered in the reporting period,(2) Records of the fuel supplier certifications, and(3) A signed statement by the owner or operator that the records submittedrepresent all of the oil combusted during the reporting period.
14.0
CD 40 CFR Section 60.48c(f)(1);Minn. R. 7011.0570
Fuel supplier certification shall include the following information:
- The name of the oil supplier;
- A statement from the supplier that the oil complies with the specifications underthe definition of distillate oil in 40 CFR Section 60.41c; and
-The actual or maximum sulfur content of the oil.
15.0
CD 40 CFR Section 60.48c(g)(3);Minn. R. 7011.0570
Record and maintain records of the amounts of each fuel delivered each month.16.0
TSD Attachment 2 Permit Number: 13700112-009 Page 96 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 5 of 42
Subject Item: GP 005 Anaerobic Digesters
Associated Items: EU 058 Anaerobic Digester 1 - Digestor
EU 059 Anaerobic Digester 2 - Digestor
EU 060 Anaerobic Digester 3 - Digestor
EU 061 Anaerobic Digester 4 - Digestor
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 0051.0
LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.
2.0
LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity3.0
CD Minn. R. 7005.0100, subp. 35a The Permittee shall vent all emissions (digester gas) from the digesters in GP 005to the boilers in GP 007, engines in GP 008 and/or flares in GP 009 whenever thedigesters operate. The Permittee shall operate and maintain the combustiondevices in GP 007, GP 008, and GP 009 at all times when any emissions arevented to them.
4.0
TSD Attachment 2 Permit Number: 13700112-009 Page 97 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 6 of 42
Subject Item: GP 007 Digester Gas Boilers
Associated Items: EU 062 Digester Gas Boiler 1 - Boiler
EU 063 Digester Gas Boiler 2 - Boiler
EU 064 Digester Gas Boiler 3 - Boiler
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 0071.0
CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate all boilers listed in GP 007. ThePermittee shall commence construction at any time within 5 years of issuance ofAir Emissions Permit No. 13700112-009. The units shall meet all the requirementsof this permit.
2.0
CD hdr OPERATING AND EMISSION LIMITS3.0
LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input usinga 3-hour rolling average.
The potential to emit from each unit is 0.034 lbs/million Btu due to equipmentdesign and allowable fuels.
4.0
LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.
5.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: Natural gas and digester gas only.6.0
CD hdr RECORDKEEPING AND REPORTING7.0
CD Minn. R. 7007.0800, subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.8.0
TSD Attachment 2 Permit Number: 13700112-009 Page 98 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 7 of 42
Subject Item: GP 008 Digester Gas Engines
Associated Items: EU 073 Digester Gas Engine 1 - Reciprocating IC Engine
EU 074 Digester Gas Engine 2 - Reciprocating IC Engine
EU 075 Digester Gas Engine 3 - Reciprocating IC Engine
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 008.
See EU 073, 074, and 075 for individual notifications, submittals, and performancetest requirements.
1.0
CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate all engines listed in GP 008. ThePermittee shall commence construction at any time within 5 years of issuance ofAir Emissions Permit No. 13700112-009. The units shall meet all the requirementsof this permit.
2.0
CD hdr OPERATING AND EMISSION LIMITS3.0
LIMIT 40 CFR Section 60.4233(e); 40CFR pt. 60, subp. JJJJ, Table 1;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
Nitrogen Oxides: less than or equal to 2.0 grams/horsepower-hour or 150 ppmvd at15% oxygen.
4.0
LIMIT 40 CFR Section 60.4233(e); 40CFR pt. 60, subp. JJJJ, Table 1;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
Carbon Monoxide: less than or equal to 5.0 grams/horsepower-hour or 610 ppmvdat 15% oxygen.
5.0
LIMIT 40 CFR Section 60.4233(e); 40CFR pt. 60, subp. JJJJ, Table 1;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
Volatile Organic Compounds: less than or equal to 1.0 grams/horsepower-hour or80 ppmvd at 15% oxygen (excluding formaldehyde).
6.0
LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatureshave been attained.
7.0
LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input using a 3-hourrolling average.
The potential to emit from each unit is 0.25 lbs/million Btu due to equipment designand allowable fuels.
8.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: Digester gas only.9.0
CD hdr RECORDKEEPING AND REPORTING10.0
CD Minn. R. 7007.0800, subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.11.0
CD 40 CFR Section 63.6585; Minn. R.7011.8150
NESHAP REQUIREMENTS: 40 CFR pt. 63, subp. ZZZZNational Emission Standards for Hazardous Air Pollutants for StationaryReciprocating Internal Combustion Engines
12.0
CD 40 CFR Section 63.6590(c)(1);Minn. R. 7011.8150
Engines in GP 008 are new affected sources as defined under 40 CFR pt. 63,subp. ZZZZ, and the facility is an area source as defined at 40 CFR Section 63.2.The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ bymeeting the requirements of 40 CFR pt. 60, subp. JJJJ. No further requirements of40 CFR pt. 63, subp. ZZZZ apply to engines in GP 008.
13.0
CD 40 CFR Section 60.4230; Minn. R.7011.8150
NSPS REQUIREMENTS: 40 CFR pt. 60, subp. JJJJ:Standards of Performance for Stationary Spark Ignition Internal CombustionEngines
14.0
CD hdr OPERATING AND EMISSION LIMITS: 40 CFR pt. 60, subp. JJJJ15.0
CD 40 CFR Section 60.4233(e); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
The Permittee shall must comply with the emission standards in 40 CFR pt. 60,subp. JJJJ, Table 1 for engines in GP 008.
16.0
CD 40 CFR Section 60.6234; Minn. R.7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
The Permittee shall operate and maintain each engine in GP 008 such that itachieves the emission standards as required in 40 CFR Section 60.4233 over theentire life of the engine.
17.0
TSD Attachment 2 Permit Number: 13700112-009 Page 99 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 8 of 42
CD 40 CFR Section 60.4243(b)(2)(ii);Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
The Permittee must keep a maintenance plan and records of conductedmaintenance and must, to the extent practicable, maintain and operate the enginein a manner consistent with good air pollution control practice for minimizingemissions. In addition, the Permittee must conduct an initial performance test andconduct subsequent performance testing every 8,760 hours or 3 years, whichevercomes first, thereafter to demonstrate compliance.
18.0
CD hdr PERFORMANCE TESTING REQUIREMENTS: 40 CFR pt. 60, subp. JJJJ19.0
CD 40 CFR Section 60.4244(a); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
Performance Test Methods:The Permittee shall conduct each performance test within 10 percent of 100percent peak (or the highest achievable) load and according to the requirements in40 CFR Section 60.8 and under the specific conditions specified 40 CFR pt. 60,subp. JJJJ, Table 2.
20.0
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
NOx Performance Test Procedures:a. For demonstrating compliance according to 40 CFR Section 60.4244 andcomplying with the requirement to limit the concentration of NOx in theexhaust from engines in GP 008, the Permittee shall;
i. Select the sampling port location and the number of traverse points usingMethod 1 or 1A of 40 CFR pt. 60, appendix A. The sampling site must be locatedat the exaust of the engine.
ii. Determine the oxygen concentration of the exhaust at the samplingport location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A or ASTMMethod D6522-00(2005). Measurements to determine oxygen concentration mustbe made at the same time as the measurements for NOx concentration.
iii. If necessary, determine the exhaust flowrate of the engine using Method 2, 2C,or 19 of 40 CFR pt. 60, appendix A.(continued below)
21.0
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
(continued from above)iv. If necessary, measure moisture content of the exhaust of the engine at thesampling port location using Method 4 of 40 CFR pt. 60, appendix A, Method 320of 40 CFR pt. 63, appendix A, or ASTM D 6348-03 (incorporated by reference, see40 CFR Section 60.17). Measurements to determine moisture must be made atthe same time as the measurement for NOx concentration.
v. Measure NOx at the exhaust of the engine using Method 7E of 40 CFR pt. 60,appendix A, Method D6522-00(2005), Method 320 of 40 CFR pt. 63, appendix A,or ASTM D 6348-03 (incorporated by reference, see 40 CFR Section 60.17).Results of this test consist of the average of the three 1-hour or longer runs.
22.0
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
CO Performance Test Procedures:b. For demonstrating compliance according to 40 CFR Section 60.4244 andcomplying with the requirement to limit the concentration of CO in the exhaustfrom engines in GP 008, the Permittee shall;
i. Select the sampling port location and the number of traverse points usingMethod 1 or 1A of 40 CFR pt. 60, appendix A. The sampling site must be locatedat the exhaust of the engine.
ii. Determine the oxygen concentration of the exhaust from the engine at thesampling port location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A orASTM Method D6522-00(2005). Measurements to determine oxygen concentrationmust be made at the same time as the measurements for CO concentration.
iii. If necessary, determine the exhaust flowrate of the exhaust from the engineusing Method 2, 2C, or 19 of 40 CFR pt. 60, appendix A.(continued below)
23.0
TSD Attachment 2 Permit Number: 13700112-009 Page 100 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 9 of 42
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
(continued from above)iv. If necessary, measure moisture content of the exhaust from the engine at thesampling port location using Method 4 of 40 CFR pt. 60, appendix A, Method 320of 40 CFR part 63, appendix A, or ASTM D 6348-03 (incorporated by reference,see 40 CFR Section 60.17). Measurements to determine moisture must be madeat the same time as the measurement for CO concentration.
v. Measure CO at the exhaust of the engine using Method 10 of 40 CFR pt. 60,appendix A, ASTM Method D6522-00(2005), Method 320 of 40 CFR pt. 63,appendix A, or ASTM D 6348-03 (incorporated by reference, see 40 CFR Section60.17). Results of this test consist of the average of the three 1-hour or longerruns.
24.0
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
VOC Performance Test Procedures:c. For demonstrating compliance according to 40 CFR Section 60.4244 andcomplying with the requirement to limit the concentration of VOC in the exhaustfrom engines in GP 008, the Permittee shall;
i. Select the sampling port location and the number of traverse points usingMethod 1 or 1A of 40 CFR pt. 60, appendix A. The sampling site must be locatedat the exhaust of the engine.
ii. Determine the oxygen concentration of the exhaust from the engine at thesampling port location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A orASTM Method D6522-00(2005). Measurements to determine oxygen concentrationmust be made at the same time as the measurements for VOC concentration.
iii. If necessary, determine the exhaust flowrate of the exhaust from the engineusing Method 2, 2C, or 19 of 40 CFR pt. 60.(continued below)
25.0
CD 40 CFR Section 60.4244(a); 40CFR pt. 60, subp. JJJJ, Table 2;Minn. R. 7011.2310; 40 CFRSection 63.6590(c)(1); Minn. R.7011.8150
(continued from above)iv. If necessary, measure moisture content of the exhaust from the engine at thesampling port location using Method 4 of 40 CFR pt. 60, appendix A, Method 320of 40 CFR part 63, appendix A, or ASTM D 6348-03 (incorporated by reference,see 40 CFR Section 60.17). Measurements to determine moisture must be madeat the same time as the measurement for VOC concentration.
v. Measure VOC at the exhaust of the engine using Methods 25A and 18 of 40 CFRpt. 60, appendix A, Method 25A with the use of a methane cutter as described in40 CFR 1065.265, Method 18 or 40 CFR pt. 60, appendix A, Method 320 of 40CFR pt. 63, appendix A, or ASTM D 6348-03 (incorporated by reference, see 40CFR Section 60.17). Results of this test consist of the average of the three 1-houror longer runs.
26.0
CD 40 CFR Section 60.4244(b); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
Performance Test Methods:The Permittee shall not conduct performance tests during periods of startup,shutdown, or malfunction, as specified in 40 CFR Section 60.8(c). If the engine isnon-operational, the Permittee does not need to startup the engine solely toconduct a performance test; however, a performance test shall be conductedimmediately upon startup of the engine.
27.0
CD 40 CFR Section 60.4244(c); Minn.R. 7011.2310; 40 CFR Section60.8(f); 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
Performance Test Methods:The Permittee shall conduct three separate test runs for each performance test, asspecified in 40 CFR Section 60.8(f). Each test run must be conducted within 10percent of 100 percent peak (or the highest achievable) load and last at least onehour.
28.0
TSD Attachment 2 Permit Number: 13700112-009 Page 101 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 10 of 42
CD 40 CFR Section 60.4244(d); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
NOx Compliance Demonstration:The Permittee must determine compliance with the nitrogen oxides (NOx) massper unit output emission limit by converting the concentration of NOx in the engineexhaust using Equation 1 of 40 CFR Section 60.4244(d), as shown below:
Equation 1:ER = [Cd x (1.912 x 10^-3) x Q x T] / HP-hr
Where:ER = Emission rate of NOx in g/HP-hr.Cd = Measured NOx concentration in parts per million by volume (ppmv).1.912 x10^-3 = Conversion constant for ppm NOx to grams per standard cubicmeter at 20 degrees Celsius.Q = Stack gas volumetric flow rate, in standard cubic meter per hour, dry basis.T = Time of test run, in hours.HP-hr = Brake work of the engine, horsepower-hour (HP-hr).
29.0
CD 40 CFR Section 60.4244(e); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
CO Compliance Demonstration:The Permittee must determine compliance with the CO mass per unit outputemission limit by converting the concentration of CO in the engine exhaust usingEquation 2 of 40 CFR Section 60.4244(e), as shown below:
Equation 2:ER = [Cd x (1.164 x 10^-3) x Q x T] / HP-hr
Where:ER = Emission rate of CO in g/HP-hr.Cd = Measured CO concentration in ppmv.1.164 x10^-3 = Conversion constant for ppm CO to grams per standard cubicmeter at 20 degrees Celsius.Q = Stack gas volumetric flow rate, in standard cubic meters per hour, dry basis.T = Time of test run, in hours.HP-hr = Brake work of the engine, in HP-hr.
30.0
CD 40 CFR Section 60.4244(f); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
VOC Compliance Demonstration:The Permittee must determine compliance with the VOC mass per unit outputemission limit by converting the concentration of VOC in the engine exhaust usingEquation 3 of 40 CFR Section 60.4244(f), as shown below. When calculatingemissions of VOC, do not include emissions of formaldehyde.
Equation 3:ER = [Cd x (1.833 x 10^-3) x Q x T] / HP-hr
Where:ER = Emission rate of VOC in g/HP-hr.Cd = VOC concentration measured as propane in ppmv.1.833 x10^-3 = Conversion constant for ppm VOC measured as propane, to gramsper standard cubic meter at 20 degrees Celsius.Q = Stack gas volumetric flow rate, in standard cubic meters per hour, dry basis.T = Time of test run, in hours.HP-hr = Brake work of the engine, in HP-hr.
31.0
CD 40 CFR Section 60.4244(g); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
VOC Alternative Compliance Demonstration:If the Permittee chooses to measure VOC emissions using either Method 18 of 40CFR part 60, appendix A, or Method 320 of 40 CFR part 63, appendix A, then thePermittee has the option of correcting the measured VOC emissions to account forthe potential differences in measured values between these methods and Method25A. The results from Method 18 and Method 320 can be corrected for responsefactor differences using Equations 4 and 5 of 40 CFR Section 60.4244(g). Thecorrected VOC concentration can then be placed on a propane basis usingEquation 6 of 40 CFR Section 60.4244(g).(continued below)
32.0
TSD Attachment 2 Permit Number: 13700112-009 Page 102 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 11 of 42
CD 40 CFR Section 60.4244(g); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
(continued from above)Equation 4:RFi = CMi / CAiWhere:RFi = Response factor of compound i when measured with EPA Method 25A.CMi = Measured concentration of compound i in ppmv as carbon.CAi = True concentration of compound i in ppmv as carbon.
Equation 5:Cicorr = RFi x CimeasWhere:Cicorr = Concentration of compound i corrected to the value that would have beenmeasured by EPA Method 25A, ppmv as carbon.Cimeas = Concentration of compound i measured by EPA Method 320, ppmv ascarbon.
Equation 6:CPeq = 0.6098 x CicorrWhere:CPeq = Concentration of compound i in mg of propane equivalent per DSCM.
33.0
CD hdr RECORDKEEPING: 40 CFR pt. 60, subp. JJJJ34.0
CD 40 CFR Section 60.4245(a); Minn.R. 7011.2310; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
Recordkeeping:The Permittee shall keep records of the following information:1. All notifications submitted to comply with 40 CFR pt. 60, subp. JJJJ and alldocumentation supporting any notification.2. Maintenance conducted on the engines in GP 008.3. Documentation that the engine meets the emission standards.
35.0
CD hdr GENERAL REQUIREMENTS: 40 CFR pt. 60, subp. JJJJ36.0
CD 40 CFR Section 60.4246; Minn. R.7011.2310; 40 CFR pt. 60, subp.JJJJ, Table 3; 40 CFR Section63.6590(c)(1); Minn. R. 7011.8150
General Provisions:The Permittee shall comply with the applicable General Provisions in 40 CFRSection 60.1 through 60.19, as shown in 40 CFR pt. 60, subp JJJJ, Table 3.
37.0
CD 40 CFR Section 60.8(c); Minn. R.7017.2015
Performance tests shall be conducted under such conditions as the Administratorshall specify to the plant operator based on representative performance of theaffected facility. The Permittee shall make available to the Administrator suchrecords as may be necessary to determine the conditions of the performancetests. Operations during periods of startup, shutdown, and malfunction shall notconstitute representative conditions for the purpose of a performance test nor shallemissions in excess of the level of the applicable emission limit during periods ofstartup, shutdown, and malfunction be considered a violation of the applicableemission limit unless otherwise specified in the applicable standard.
38.0
CD 40 CFR Section 60.8(e); Minn. R.7017.2015
The Permittee shall provide, or cause to be provided, performance testing facilitiesas specified in 40 CFR Section 60.8(e)(1) through (4), as follows:
(1) Sampling ports adequate for test methods applicable to such facility. Thisincludes (i) constructing the air pollution control system such that volumetric flowrates and pollutant emission rates can be accurately determined by applicable testmethods and procedures and (ii) providing a stack or duct free of cyclonic flowduring performance tests, as demonstrated by applicable test methods andprocedures.(2) Safe sampling platform(s).(3) Safe access to sampling platform(s).(4) Utilities for sampling and testing equipment.
39.0
CD 40 CFR Section 60.12; Minn. R.7011.0050
Circumvention: No owner or operator shall build, erect, install, or use any article,machine, equipment or process, the use of which conceals an emission whichwould otherwise constitute a violation of an applicable standard.
40.0
TSD Attachment 2 Permit Number: 13700112-009 Page 103 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 12 of 42
Subject Item: GP 009 Flares
Associated Items: CE 018 Flaring
CE 021 Flaring
EU 054 Existing Digester Gas Flare (CE 018)
EU 076 Temporary Digester Gas Flare (CE 021)
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 009.1.0
CD hdr OPERATING AND EMISSION LIMITS2.0
LIMIT Minn. R. 7011.0715, subp. 1(B) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.
3.0
LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity4.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: Digester gas only, with a natural gas pilot light.5.0
CD Minn. R. 7007.0800. subp. 2 The flare shall be operated with a flame present (pilot light) at all times thatemissions are vented to it. The presence of a flare pilot flame shall be monitoredusing a thermocouple or any other equivalent device to detect the presence of aflame.
6.0
CD hdr RECORDKEEPING AND REPORTING7.0
CD Minn. R. 7017.2020, subp. 1 Performance Test Methods: Upon the request of the Commissioner testing shallbe done in accordance with Minn. R. 7017.2001 through 7017.2060.
8.0
TSD Attachment 2 Permit Number: 13700112-009 Page 104 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 13 of 42
Subject Item: GP 010 Heating Boilers - 5.5 mmBtu
Associated Items: EU 065 Heating Boiler 1 - Boiler
EU 066 Heating Boiler 2 - Boiler
EU 067 Heating Boiler 3 - Boiler
EU 068 Heating Boiler 4 - Boiler
EU 069 Heating Boiler 5 - Boiler
EU 070 Heating Boiler 6 - Boiler
EU 071 Heating Boiler 7 - Boiler
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The following requirements apply individually to each emission unit in GP 0031.0
CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate all boilers listed in GP 010. ThePermittee shall commence construction at any time within 5 years of issuance ofAir Emissions Permit No. 13700112-009. The units shall meet all the requirementsof this permit.
2.0
CD hdr OPERATING AND EMISSION LIMITS3.0
LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input usinga 3-hour rolling average.
The potential to emit from each unit is 0.024 lbs/million Btu due to equipmentdesign and allowable fuels.
4.0
LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.
5.0
LIMIT Minn. R. 7005.0100, subp. 35a Sulfur Content of Fuel: less than or equal to 0.050 percent by weight for No. 2diesel fuel oil.
6.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: Natural gas and No. 2 Fuel Oil only.7.0
CD hdr RECORDKEEPING AND REPORTING8.0
CD Minn. R. 7007.0800, subps. 4 and5
Fuel Supplier Certification: The Permittee shall obtain a fuel supplier certificationfor each shipment of No. 2 fuel oil, certifying that the sulfur content does notexceed 0.050 percent by weight.
9.0
CD Minn. R. 7007.0800, subp. 5 Fuel Type Recordkeeping: The Permittee shall keep records of fuel type andusage on a monthly basis.
10.0
CD 40 CFR Section 63.11193 NESHAP REQUIREMENTS: 40 CFR pt. 63, subp. JJJJJJ:National Emission Standards for Hazardous Air Pollutants for Industrial,Commercial and Institutional Boilers Area Sources
Enforcement not delegated to MPCA.
11.0
CD hdr OPERATIONAL REQUIREMENTS: 40 CFR pt. 63, subp. JJJJJJ12.0
CD 40 CFR Section 63.11196(c) Compliance Date:The Permittee must achieve compliance with the provisions of 40 CFR pt. 63,subp. JJJJJJ upon startup of the affected source.
13.0
CD 40 CFR Section 63.11205(a) Operation Requirements:At all times, the Permittee shall operate and maintain the affected boilers, includingassociated air pollution control equipment and monitoring equipment, in a mannerconsistent with safety and good air pollution control practices for minimizingemissions. Determination of whether such operation and maintenance proceduresare being used will be based on information available to the Administrator that mayinclude, but is not limited to, monitoring results, review of operation andmaintenance procedures, review of operation and maintenance records, andinspection of the source.
14.0
CD 40 CFR Section 63.11210(f) Biennial Tune-up Initial Compliance:The Permittee shall complete the applicable biennial tune-up as specified in 40CFR Section 63.11223 no later than 25 months after the initial startup of the boiler.
15.0
TSD Attachment 2 Permit Number: 13700112-009 Page 105 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Biennial Tune-up:The Permittee must conduct a biennial performance tune-up according to 40 CFRSection 63.11223(b) and keep records as required in 40 CFR Section 63.11225(c)to demonstrate continuous compliance. The Permittee must conduct the tune-upwhile burning the type of fuel (or fuels in the case of boilers that routinely burn twotypes of fuels at the same time) that provided the majority of the heat input to theboiler over the 12 months prior to the tune-up.
16.0
CD 40 CFR Section 63.11223(b) Biennial Tune-up:The Permittee must conduct a biennial tune-up of each boiler, as specified in (1)through (7) below, to demonstrate continuous compliance. Each biennial tune-upmust be conducted no more than 25 months after the previous tune-up. For a newor reconstructed boiler, the first biennial tune-up must be no later than 25 monthsafter the initial startup of the new or reconstructed boiler:
(1) As applicable, inspect the burner, and clean or replace any components of theburner as necessary (the Permittee may delay the burner inspection until the nextscheduled unit shutdown, not to exceed 36 months from the previous inspection).
(2) Inspect the flame pattern, as applicable, and adjust the burner as necessary tooptimize the flame pattern. The adjustment should be consistent with themanufacturer's specifications, if available.(continued below)
17.0
CD 40 CFR Section 63.11223(b) (continued from above)(3) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensurethat it is correctly calibrated and functioning properly (the Permittee may delay theinspection until the next scheduled unit shutdown, not to exceed 36 months fromthe previous inspection).
(4) Optimize total emissions of CO. This optimization should be consistent with themanufacturer's specifications, if available, and with any nitrogen oxide requirementto which the unit is subject.
(5) Measure the concentrations in the effluent stream of CO in parts per million, byvolume, and oxygen in volume percent, before and after the adjustments are made(measurements may be either on a dry or wet basis, as long as it is the samebasis before and after the adjustments are made). Measurements may be takenusing a portable CO analyzer.(continued below)
18.0
CD 40 CFR Section 63.11223(b) (continued from above)(6) Maintain on-site and submit, if requested by the Administrator, a reportcontaining the information in (i) through (iii) as follows:(i) The concentrations of CO in the effluent stream in parts per million, by volume,and oxygen in volume percent, measured at high fire or typical operating load,before and after the tune-up of the boiler.(ii) A description of any corrective actions taken as a part of the tune-up of theboiler.(iii) The type and amount of fuel used over the 12 months prior to the tune-up ofthe boiler, but only if the unit was physically and legally capable of using more thanone type of fuel during that period. Units sharing a fuel meter may estimate the fueluse by each unit.
(7) If the unit is not operating on the required date for a tune-up, the tune-up mustbe conducted within 30 days of startup.
19.0
CD 40 CFR Section 63.11201(d) The standards in 40 CFR Section 63.11201 apply at all times the affected boilersare operating, except during periods of startup and shutdown as defined in 40 CFRSection 63.11237, during which time the Permittee must comply only with Table 2to 40 CFR pt. 63, subp. JJJJJJ.
20.0
CD hdr RECORDKEEPING: 40 CFR pt. 63, subp. JJJJJJ21.0
TSD Attachment 2 Permit Number: 13700112-009 Page 106 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 15 of 42
CD 40 CFR Section 63.11225(c) Recordkeeping:The Permittee must maintain the following records:(1) A copy of each notification and report that was submitted to comply with 40CFR pt. 63, subp. JJJJJJ, including all documentation supporting any InitialNotification or Notification of Compliance Status that was submitted, as required by40 CFR Section 63.10(b)(2)(xiv);
(2) Records to document conformance with 40 CFR Sections 63.11214 and63.11223 as specified below:(2)(i) Records must identify each boiler, the date of tune-up, the proceduresfollowed for tune-up, and the manufacturer's specifications to which the boiler wastuned.
(4) Records of the occurrence and duration of each malfunction of each boiler.
(5) Records of actions taken during periods of malfunction to minimize emissionsin accordance with the general duty to minimize emissions in 40 CFR Section63.11205(a), including corrective actions to restore the malfunctioning boiler to itsnormal or usual manner of operation.
22.0
CD 40 CFR Section 63.11225(d) Recordkeeping:Records must be in a form suitable and readily available for expeditious review.The Permittee must keep each record for 5 years following the date of eachrecorded action. The Permittee must keep each record on-site or be accessiblefrom a central location by computer or other means that instantly provide access atthe site for at least 2 years after the date of each recorded action. The Permitteemay keep the records off site for the remaining 3 years.
23.0
CD hdr REPORTING AND NOTIFICATION REQUIREMENTS: 40 CFR pt. 63, subp.JJJJJJ
24.0
CD 40 CFR Section 63.11225(g) Fuel or Physical Change Notification:If the Permittee switches fuels or makes a physical change to the boiler and thefuel switch or change results in the applicability of a different subcategory within 40CFR pt. 63, subp. JJJJJJ, (the boiler becoming subject to, the boiler switching outof, or a permit limit that resulted in the boiler being subject to 40 CFR pt. 63, subp.JJJJJJ) the Permittee must provide notice of the date upon which the Permitteeswitched fuels, made the physical change, or took a permit limit within 30 days ofthe change. The notification must identify:
(1) The name of the owner or operator of the affected source, the location of thesource, the boiler(s) that have switched fuels, were physically changed, or took apermit limit, and the date of the notice.(2) The date upon which the fuel switch, physical change, or permit limit occurred.
25.0
CD 40 CFR Section 63.11214(b) Tune-up Notification:The Permittee must conduct a performance tune-up according to 40 CFR Section63.11223(b) and submit a signed statement in the Notification of ComplianceStatus report that indicates that the Permittee conducted a tune-up of the boiler.
26.0
CD 40 CFR Section 63.11225(a)(1) General Notifications:The Permittee must submit all of the notifications in 40 CFR Sections 63.7(b);63.8(e) and (f); 63.9(b) through (e), (g) and (h) that apply by the dates specified inthose sections except as specified in 40 CFR Section 63.11225(a)(2) and (4).
27.0
CD 40 CFR Section 63.11225(a)(2) Initial Notification:The Permittee must submit an Initial Notification no later than 120 calendar daysafter the source becomes subject to 40 CFR pt. 63, subp. JJJJJJ.
28.0
CD 40 CFR Section 63.11225(a)(4) Notification of Compliance Status:Due 120 days after the applicable compliance date. The notification must includethe certifications of compliance in 40 CFR Section 63.11225(a)(4)(i) through (v), asapplicable, and signed by a responsible official.
(i) The Permittee must submit the information required in 40 CFR Section63.9(h)(2), except the information listed in 40 CFR Section 63.9(h)(2)(i)(B), (D), (E)and (F).
(vi) The notification must be submitted electronically using the Compliance andEmissions Data Reporting Interface (CEDRI) that is accessed through EPA'sCentral Data Exchange (CDX). However, if the reporting form specific to 40 CFRpt. 63, subp. JJJJJJ is not available in CEDRI at the time that the report is due, thewritten Notification of Compliance Status must be submitted to the Administrator atthe appropriate address listed in 40 CFR Section 63.13.
29.0
TSD Attachment 2 Permit Number: 13700112-009 Page 107 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 16 of 42
CD 40 CFR Sections 63.11225(b) Compliance Certification Report:The Permittee must prepare, by March 1 of each year, and submit to theAdministrator upon request, a 2-year compliance certification report for theprevious calendar year containing the information specified below:
(1) Company name and address.
(2) Statement by a responsible official, with the official's name, title, phonenumber, email address, and signature, certifying the truth, accuracy andcompleteness of the notification and a statement of whether the source hascomplied with all the relevant standards and other requirements of 40 CFR pt. 63,subp. JJJJJJ. The notification must include the following certifications ofcompliance, as applicable, and signed by a responsible official.
(2)(i) "This facility complies with the requirements in 40 CFR Section 63.11223 toconduct a biennial tune-up of each boiler."
30.0
CD hdr GENERAL REQUIREMENTS: 40 CFR pt. 63, subp. JJJJJJ31.0
CD 40 CFR Section 63.4(b); Minn. R.7011.7000
Circumvention: The Permittee shall not build, erect, install, or use any article,machine, equipment, or process to conceal an emission that would otherwiseconstitute noncompliance with a relevant standard. Such concealment includes,but is not limited to:
(1) The use of diluents to achieve compliance with a relevant standard based onthe concentration of a pollutant in the effluent discharged to the atmosphere or
(2) The use of gaseous diluents to achieve compliance with a relevant standard forvisible emissions.
32.0
CD 40 CFR Section 63.6(f)(2); Minn.R. 7011.7000
Methods for determining compliance will be, in part, based on the results ofperformance tests, conformance with operation and maintenance requirements,review of records, and inspection of the source as specified in 40 CFR Section63.6(f)(2)
The Permittee may use the results of performance testing conducted previously ifit meets the requirements of 40 CFR Section 63.6(f)(iii).
33.0
CD 40 CFR Section 63.6(f)(3); Minn.R. 7011.7000
Finding of compliance: The Commissioner or the Administrator will make a findingconcerning an affected source's compliance with a non-opacity emission standardupon obtaining all the compliance information required by the relevant standard.
34.0
CD 40 CFR Section 63.6(g); Minn. R.7011.7000
The Permittee may establish the use of an alternative nonopacity emissionstandard by following the procedure specified in 40 CFR Section 63.6(g).
35.0
CD 40 CFR Section 63.6(i); Minn. R.7011.7000
The Administrator may grant an extension of compliance with an emissionstandard, as specified in 40 CFR Section 63.6(i).
36.0
CD 40 CFR Section 63.6(i)(1); Minn.R. 7011.7000
Until an extension of compliance has been granted by the Administrator, thePermittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A.
37.0
CD 40 CFR Section 63.10(a); Minn.R. 7019.0100
The Permittee shall submit reports to the Commissioner and shall send a copy ofeach report to the Administrator.
38.0
CD 40 CFR Section 63.10(b)(1); Minn.R. 7019.0100, subp. 2(B)
Recordkeeping: The Permittee shall maintain files of all information required by 40CFR pt. 63 in a form suitable and readily available for expeditious inspection andreview. The files should be retained for at least 5 years following the date of eachoccurrence, measurement, maintenance, corrective action, report, or record. Onlythe most recent two years of information must be kept on site.
39.0
CD 40 CFR Section 63.10(d)(1); Minn.R. 7019.0100
Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), thePermittee shall submit reports to the Commissioner and the Administrator inaccordance with the reporting requirements in the relevant standard.
40.0
TSD Attachment 2 Permit Number: 13700112-009 Page 108 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 17 of 42
Subject Item: EU 049 Backup Generator HHW - Reciprocating IC Engine
Associated Items: SV 076 HHW Emergency generator
NC/CA
Type Citation Requirement
LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity . The permittee shall not cause orpermit the emission of visible air contaminants from the engine in excess of 20percent opacity for more than ten consecutive seconds once operatingtemperatures have been obtained.
1.0
LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input2.0
CD hdr OPERATING CONDITIONS3.0
LIMIT Minn. R. 7005.0100, subp. 35a Sulfur Content of Fuel: less than or equal to 0.05 percent by weight4.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only, by design.5.0
CD hdr RECORDINGKEEPING REQUIREMENTS6.0
CD Minn. R. 7007.0800, subp. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency diesel generator by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.
7.0
CD Minn. R. 7007.0800, subps. 4 & 5 Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.05% by weight.
8.0
CD hdr SUBPART ZZZZ REQUIREMENTS9.0
CD 40 CFR Section 63.6595(a)(1);Minn. R. 7011.8150
Comply with the applicable emission limitations and operating requirements of 40CFR pt. 63, subp. ZZZZ.
10.0
CD 40 CFR Section 63.6603(a); Minn.R. 7011.8150
The Permittee shall meet the following requirements, except during periods ofstartup:
a. Change oil and filter every 1000 hours of operation or annually, whichevercomes first;
b. Inspect air cleaner every 1000 hours of operation or annually, whichever comesfirst; and
c. Inspect all hoses and belts every 500 hours of operation or annually, whichevercomes first, and replace as necessary.
11.0
CD 40 CFR Section 63.6605(a); Minn.R. 7011.8150
The Permittee must be in compliance with the applicable emission limitations andapplicable operating limitations of 40 CFR pt. 63, subp. ZZZZ, at all times.
12.0
CD 40 CFR Section 63.6605(b); Minn.R. 7011.8150
The Permittee must at all times operate and maintain any affected source,including associated air pollution control equipment and monitoring equipment, in amanner consistent with safety and good air pollution control practices forminimizing emissions. The general duty to minimize emissions does not requirethe Permittee to make any further efforts to reduce emissions if levels required by40 CFR pt. 63, subp. ZZZZ have been achieved. Determination of whether suchoperation and maintenance procedures are being used will be based oninformation available to the Administrator which may include, but is not limited to,monitoring results, review of operation and maintenance procedures, review ofoperation and maintenance records, and inspection of the source.
13.0
CD 40 CFR Section 63.6625(e); 40CFR Section 63.6655(d); Minn. R.7011.8150
The Permittee must operate and maintain the stationary RICE and after-treatmentcontrol device (if any) according to the manufacturer's emission-related writteninstructions.
14.0
CD 40 CFR Section 63.6625(f); Minn.R. 7011.8150
The Permittee must install a non-resettable hour meter if one is not alreadyinstalled.
15.0
CD 40 CFR Section 63.6625(h); Minn.R. 7011.8150
The Permittee must minimize the time spent at idle during startup and minimizethe engine's startup time to a period needed for appropriate and safe loading of theengine, not to exceed 30 minutes.
16.0
TSD Attachment 2 Permit Number: 13700112-009 Page 109 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 18 of 42
CD 40 CFR Section 63.6655(a); Minn.R. 7011.8150
The Permittee must keep the following records:(1) A copy of each notification and report submitted to comply with 40 CFR pt. 63,subp. ZZZZ, including all documentation supporting any Initial Notification orNotification of Compliance Status submitted, according to the requirement in 40CFR Section 63.10(b)(2)(xiv).
(2) Records of the occurrence and duration of each malfunction of operation (i.e.,process equipment) or the air pollution control and monitoring equipment.
(3) (does not apply)
(4) Records of all required maintenance performed on the air pollution control andmonitoring equipment.
(5) Records of actions taken during periods of malfunction to minimize emissionsin accordance with 40 CFR Section 63.6605(b), including corrective actions torestore malfunctioning process and air pollution control and monitoring equipmentto its normal or usual manner of operation.
17.0
CD 40 CFR Section 63.6655(e); Minn.R. 7011.8150
The Permittee must keep records of the maintenance conducted on the stationaryRICE in order to demonstrate that the stationary RICE and after-treatment controldevice (if any) are operated and maintained according to the maintenance plan.
18.0
CD 40 CFR Section 63.6655(f); Minn.R. 7011.8150
The Permittee must keep records of the hours of operation of the engine asrecorded through the non-resettable hour meter. The owner or operator mustdocument how many hours are spent for emergency operation, including whatclassified the operation as emergency and how many hours are spent fornon-emergency operation. If the engine is used for demand response operation,the owner or operator must keep records of the notification of the emergencysituation, and the time the engine was operated as part of demand response.
19.0
CD 40 CFR Section 63.6660; Minn. R.7011.8150
a. Records must be in a form suitable and readily available for expeditious reviewaccording to 40 CFR Section 63.10(b)(1).
b. As specified in 40 CFR Section 63.10(b)(1), keep each record for 5 yearsfollowing the date of each occurrence, measurement, maintenance, correctiveaction, report, or record.
c. Keep each record readily accessible in hard copy or electronic form for at least 5years after the date of each occurrence, measurement, maintenance, correctiveaction, report, or record, according to 40 CFR Section 63.10(b)(1).
20.0
TSD Attachment 2 Permit Number: 13700112-009 Page 110 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 19 of 42
Subject Item: EU 050 Digester Gas Boiler (CE 019) - Boiler
Associated Items: SV 079 Waste gas boiler stack
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the date of Equipment Removal/Dismantlement: due 15 days afterEquipment Removal and/or Dismantlement of EU 050. This notification shallspecify how the equipment was removed/dismantled and the date of shutdown.
The conditions in the permit applicable to unit EU 050 and associated itemsremain in effect until shutdown of the unit occurs.
1.0
CD Minn. R. 7007.0800, subp. 2 Shakedown Period:The Permittee shall shutdown EU 050 within 60 days after Startup of the boilers inGP 007 for production purposes. Initial equipment testing during installation of GP007 boilers does not constitute startup for production purposes. During the 60 dayperiod, the Permittee shall not operate boilers in GP 007 at the same time as EU050.
2.0
CD hdr OPERATING AND EMISSION LIMITS3.0
LIMIT Minn. R. 7005.0100, subp. 35a Sulfur Content of Fuel: less than or equal to 0.050 percent by weight when burningNo. 2 fuel oil.
4.0
LIMIT 40 CFR Section 60.42c(d); Minn.R. 7011.0570
Sulfur Content of Fuel: less than or equal to 0.50 percent by weight when burningNo. 2 fuel oil.
5.0
LIMIT 40 CFR Section 60.43c(c); Minn.R. 7011.0570
Opacity: less than or equal to 20 percent except for one 6 minute period per hourof not more than 27 percent.
6.0
CD Minn. R. 7007.0800, subp. 2 Fuels limited to bio-gas and distillate oil.7.0
CD hdr RECORDKEEPING AND REPORTING8.0
CD 40 CFR Section 60.42c(h)(1);Minn. R. 7011.0570
Obtain fuel supplier certifications for each shipment of oil, showing the sulfurcontent of the fuel burned.
9.0
S/A 40 CFR Section 60.48c(e); Minn.R. 7011.0570
Quarterly Report: due 30 days after end of each calendar quarter starting05/17/2005 . The reports shall include:(1) Calendar dates covered in the reporting period,(2) Records of the fuel supplier certifications, and(3) A signed statement by the owner or operator that the records submittedrepresent all of the oil combusted during the reporting period.
10.0
CD 40 CFR Section 60.48c(f)(1);Minn. R. 7011.0570
Fuel supplier certification shall include the following information:
- The name of the oil supplier;
- A statement from the supplier that the oil complies with the specifications underthe definition of distillate oil in 40 CFR Section 60.41c; and
-The actual or maximum sulfur content of the oil.
11.0
CD 40 CFR Section 60.48c(g)(3);Minn. R. 7011.0570
Record and maintain records of the amounts of each fuel delivered each month.12.0
TSD Attachment 2 Permit Number: 13700112-009 Page 111 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 20 of 42
Subject Item: EU 057 Emergency Generator - Reciprocating IC Engine
Associated Items: SV 084 Emergency Generator
NC/CA
Type Citation Requirement
CD hdr EMISSION LIMITS1.0
LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity . The permittee shall not cause orpermit the emission of visible air contaminants from the engine in excess of 20percent opacity for more than ten consecutive seconds once operatingtemperatures have been attained.
2.0
LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input3.0
CD hdr OPERATING CONDITIONS4.0
LIMIT Minn. R. 7005.0100, subp. 35a Sulfur Content of Fuel: less than or equal to 0.05 percent by weight5.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only, by design.6.0
CD hdr RECORDINGKEEPING REQUIREMENTS7.0
CD Minn. R. 7007.0800, subp. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency diesel generator by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.
8.0
CD Minn. R. 7007.0800, subps. 4 & 5 Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.05% by weight.
9.0
CD hdr 40 CFR pt. 63, subp. ZZZZ REQUIREMENTS10.0
CD 40 CFR Section 63.6595(a)(1);Minn. R. 7011.8150
Comply with the applicable emission limitations and operating requirements of 40CFR pt. 63, subp. ZZZZ.
11.0
CD 40 CFR Section 63.6603(a); Minn.R. 7011.8150
The Permittee shall meet the following requirements, except during periods ofstartup:
a. Change oil and filter every 1000 hours of operation or annually, whichevercomes first;
b. Inspect air cleaner every 1000 hours of operation or annually, whichever comesfirst; and
c. Inspect all hoses and belts every 500 hours of operation or annually, whichevercomes first, and replace as necessary.
12.0
CD 40 CFR Section 63.6605(a); Minn.R. 7011.8150
The Permittee must be in compliance with the applicable emission limitations andapplicable operating limitations of 40 CFR pt. 63, subp. ZZZZ, at all times.
13.0
CD 40 CFR Section 63.6605(b); Minn.R. 7011.8150
The Permittee must at all times operate and maintain any affected source,including associated air pollution control equipment and monitoring equipment, in amanner consistent with safety and good air pollution control practices forminimizing emissions. The general duty to minimize emissions does not requirethe Permittee to make any further efforts to reduce emissions if levels required by40 CFR pt. 63, subp. ZZZZ have been achieved. Determination of whether suchoperation and maintenance procedures are being used will be based oninformation available to the Administrator which may include, but is not limited to,monitoring results, review of operation and maintenance procedures, review ofoperation and maintenance records, and inspection of the source.
14.0
CD 40 CFR Section 63.6625(e); 40CFR Section 63.6655(d); Minn. R.7011.8150
The Permittee must operate and maintain the stationary RICE and after-treatmentcontrol device (if any) according to the manufacturer's emission-related writteninstructions.
15.0
CD 40 CFR Section 63.6625(f); Minn.R. 7011.8150
The Permittee must install a non-resettable hour meter if one is not alreadyinstalled.
16.0
CD 40 CFR Section 63.6625(h); Minn.R. 7011.8150
The Permittee must minimize the time spent at idle during startup and minimizethe engine's startup time to a period needed for appropriate and safe loading of theengine, not to exceed 30 minutes.
17.0
TSD Attachment 2 Permit Number: 13700112-009 Page 112 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 21 of 42
CD 40 CFR Section 63.6655(a); Minn.R. 7011.8150
The Permittee must keep the following records:(1) A copy of each notification and report submitted to comply with 40 CFR pt. 63,subp. ZZZZ, including all documentation supporting any Initial Notification orNotification of Compliance Status submitted, according to the requirement in 40CFR Section 63.10(b)(2)(xiv).
(2) Records of the occurrence and duration of each malfunction of operation (i.e.,process equipment) or the air pollution control and monitoring equipment.
(3) (does not apply)
(4) Records of all required maintenance performed on the air pollution control andmonitoring equipment.
(5) Records of actions taken during periods of malfunction to minimize emissionsin accordance with 40 CFR Section 63.6605(b), including corrective actions torestore malfunctioning process and air pollution control and monitoring equipmentto its normal or usual manner of operation.
18.0
CD 40 CFR Section 63.6655(e); Minn.R. 7011.8150
The Permittee must keep records of the maintenance conducted on the stationaryRICE in order to demonstrate that the stationary RICE and after-treatment controldevice (if any) are operated and maintained according to the maintenance plan.
19.0
CD 40 CFR Section 63.6655(f); Minn.R. 7011.8150
The Permittee must keep records of the hours of operation of the engine asrecorded through the non-resettable hour meter. The owner or operator mustdocument how many hours are spent for emergency operation, including whatclassified the operation as emergency and how many hours are spent fornon-emergency operation. If the engine is used for demand response operation,the owner or operator must keep records of the notification of the emergencysituation, and the time the engine was operated as part of demand response.
20.0
CD 40 CFR Section 63.6660; Minn. R.7011.8150
a. Records must be in a form suitable and readily available for expeditious reviewaccording to 40 CFR Section 63.10(b)(1).
b. As specified in 40 CFR Section 63.10(b)(1), keep each record for 5 yearsfollowing the date of each occurrence, measurement, maintenance, correctiveaction, report, or record.
c. Keep each record readily accessible in hard copy or electronic form for at least 5years after the date of each occurrence, measurement, maintenance, correctiveaction, report, or record, according to 40 CFR Section 63.10(b)(1).
21.0
TSD Attachment 2 Permit Number: 13700112-009 Page 113 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 22 of 42
Subject Item: EU 062 Digester Gas Boiler 1 - Boiler
Associated Items: GP 007 Digester Gas Boilers
SV 098 Boilers Stack 1 (Digester Gas Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 062. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
1.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 062. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 062 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 114 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 23 of 42
Subject Item: EU 063 Digester Gas Boiler 2 - Boiler
Associated Items: GP 007 Digester Gas Boilers
SV 098 Boilers Stack 1 (Digester Gas Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 063. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
1.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 063. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 063 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 115 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 24 of 42
Subject Item: EU 064 Digester Gas Boiler 3 - Boiler
Associated Items: GP 007 Digester Gas Boilers
SV 098 Boilers Stack 1 (Digester Gas Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 064. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
1.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 064. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 064 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 116 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 25 of 42
Subject Item: EU 065 Heating Boiler 1 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 065. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 065. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 065 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 117 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 26 of 42
Subject Item: EU 066 Heating Boiler 2 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 066. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 066. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 066 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 118 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 27 of 42
Subject Item: EU 067 Heating Boiler 3 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 067. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 067. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 067 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 119 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 28 of 42
Subject Item: EU 068 Heating Boiler 4 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 068. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 068. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 068 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 120 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 29 of 42
Subject Item: EU 069 Heating Boiler 5 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 069. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 069. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 069 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 121 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 30 of 42
Subject Item: EU 070 Heating Boiler 6 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 070. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 070. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 070 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 122 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 31 of 42
Subject Item: EU 071 Heating Boiler 7 - Boiler
Associated Items: GP 010 Heating Boilers - 5.5 mmBtu
SV 099 Boilers Stack 2 (Heating Boilers)
SV 100 Boilers Stack 3 (Heating Boilers)
NC/CA
Type Citation Requirement
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 071. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 071. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 071 and associated itemsbecome effective on the date initial startup of the unit occurs.
2.0
TSD Attachment 2 Permit Number: 13700112-009 Page 123 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 32 of 42
Subject Item: EU 072 Digester Gas Pretreatment System Flare
Associated Items: SV 101 Digester Gas Pretreatment System Flare
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate EU 072. The Permittee shallcommence construction at any time within 5 years of issuance of Air EmissionsPermit No. 13700112-009. The units shall meet all the requirements of this permit.
1.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 072. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
2.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 072. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 072 and associated itemsbecome effective on the date initial startup of the unit occurs.
3.0
LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.
4.0
LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent except for one six-minute period per hourof not more than 60 percent opacity.
5.0
CD Minn. R. 7005.0100, subp. 35a Fuel type: Process gas, Digester gas, and/or natural gas only.6.0
CD Minn. R. 7007.0800, subp. 2 The flare shall be operated with a flame present (pilot light) at all times thatemissions are vented to it. The presence of a flare pilot flame shall be monitoredusing a thermocouple or any other equivalent device to detect the presence of aflame.
7.0
TSD Attachment 2 Permit Number: 13700112-009 Page 124 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 33 of 42
Subject Item: EU 073 Digester Gas Engine 1 - Reciprocating IC Engine
Associated Items: GP 004 Digester Gas Combustion Units
GP 008 Digester Gas Engines
SV 102 Digester Gas Engine 1
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 Refer to GP 008 for additional requirements for EU 073 and FC for additionalperformance testing requirements.
1.0
CD hdr PERFORMANCE TESTING2.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU073, but no later than 180 days after Initial Startup to measure NOx emissions.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
3.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for NOx emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Initial Performance Test: due 60 days after achieving maximum capacity of EU073, but no later than 180 days after Initial Startup to measure CO emissions.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
5.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for CO emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
6.0
TSD Attachment 2 Permit Number: 13700112-009 Page 125 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 34 of 42
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU073, but no later than 180 days after Initial Startup to measure VOC emissions.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
7.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for VOC emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Notification of the Date Construction Began: due 30 days after Start OfConstruction as required in 40 CFR Section 60.7(a)(1).
The notification must include the information below:(1) Name and address of the owner or operator;(2) The address of the affected source;(3) Engine information including make, model, engine family, serial number, modelyear, maximum engine power, and engine displacement;(4) Emission control equipment; and(5) Fuel used.
10.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 073. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
The conditions in the permit applicable to unit EU 073 and associated itemsbecome effective on the date initial startup of the unit occurs.
11.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure NOx emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
12.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure CO emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
13.0
TSD Attachment 2 Permit Number: 13700112-009 Page 126 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 35 of 42
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure VOC emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
14.0
TSD Attachment 2 Permit Number: 13700112-009 Page 127 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 36 of 42
Subject Item: EU 074 Digester Gas Engine 2 - Reciprocating IC Engine
Associated Items: GP 004 Digester Gas Combustion Units
GP 008 Digester Gas Engines
SV 103 Digester Gas Engine 2
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 Refer to GP 008 for additional requirements for EU 074 and FC for additionalperformance testing requirements.
1.0
CD hdr PERFORMANCE TESTING2.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU074, but no later than 180 days after Initial Startup to measure NOx emissions.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
3.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for NOx emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Initial Performance Test: due 60 days after achieving maximum capacity of EU074, but no later than 180 days after Initial Startup to measure CO emissions.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
5.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for CO emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
6.0
TSD Attachment 2 Permit Number: 13700112-009 Page 128 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 37 of 42
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU074, but no later than 180 days after Initial Startup to measure VOC emissions.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
7.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for VOC emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Notification of the Date Construction Began: due 30 days after Start OfConstruction as required in 40 CFR Section 60.7(a)(1).
The notification must include the information below:(1) Name and address of the owner or operator;(2) The address of the affected source;(3) Engine information including make, model, engine family, serial number, modelyear, maximum engine power, and engine displacement;(4) Emission control equipment; and(5) Fuel used.
10.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 074. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
The conditions in the permit applicable to unit EU 074 and associated itemsbecome effective on the date initial startup of the unit occurs.
11.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure NOx emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
12.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure CO emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
13.0
TSD Attachment 2 Permit Number: 13700112-009 Page 129 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 38 of 42
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure VOC emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
14.0
TSD Attachment 2 Permit Number: 13700112-009 Page 130 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 39 of 42
Subject Item: EU 075 Digester Gas Engine 3 - Reciprocating IC Engine
Associated Items: GP 004 Digester Gas Combustion Units
GP 008 Digester Gas Engines
SV 104 Digester Gas Engine 3
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 Refer to GP 008 for additional requirements for EU 075 and FC for additionalperformance testing requirements.
1.0
CD hdr PERFORMANCE TESTING2.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU075, but no later than 180 days after Initial Startup to measure NOx emissions.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
3.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for NOx emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the NOx limit under 40 CFRpt. 60, subp. JJJJ (less than 2.0 g/HP-hr or less than or equal to 150 ppmvd at15% oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Initial Performance Test: due 60 days after achieving maximum capacity of EU075, but no later than 180 days after Initial Startup to measure CO emissions.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
5.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for CO emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the CO limit under 40 CFR pt.60, subp. JJJJ (less than 5.0 g/HP-hr or less than or equal to 610 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
6.0
TSD Attachment 2 Permit Number: 13700112-009 Page 131 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 40 of 42
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 60.8(a); Minn. R.7017.2015; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Initial Performance Test: due 60 days after achieving maximum capacity of EU075, but no later than 180 days after Initial Startup to measure VOC emissions.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
7.0
S/A 40 CFR Section 60.4243(b)(2)(ii);40 CFR pt. 60, subp. JJJJ Table2; Minn. R. 7011.2310; 40 CFRSection 63.6590(c); Minn. R.7011.8150
Performance Test: due before end of each calendar 36 months following InitialPerformance Test or 8760 operating hours, whichever comes first, to demonstratecompliance for VOC emissions. Each performance test date starts a new 36calendar months or 8760 operating hours period which testing shall be performed.The Permittee shall not exceed 36 calendar months or 8760 operating hours,whichever comes first, between tests.
The performance test shall confirm compliance with the VOC limit under 40 CFRpt. 60, subp. JJJJ (less than 1.0 g/HP-hr or less than or equal to 80 ppmvd at 15%oxygen).
The Performance test shall comply with the performance testing methods andprocedures of 40 CFR pt. 60, subp. JJJJ and 40 CFR pt. 60, subp. JJJJ, Table 2or other method approved by MPCA in the performance test plan approval.
Notification of the Date Construction Began: due 30 days after Start OfConstruction as required in 40 CFR Section 60.7(a)(1).
The notification must include the information below:(1) Name and address of the owner or operator;(2) The address of the affected source;(3) Engine information including make, model, engine family, serial number, modelyear, maximum engine power, and engine displacement;(4) Emission control equipment; and(5) Fuel used.
10.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 075. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
The conditions in the permit applicable to unit EU 075 and associated itemsbecome effective on the date initial startup of the unit occurs.
11.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure NOx emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
12.0
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure CO emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
13.0
TSD Attachment 2 Permit Number: 13700112-009 Page 132 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 41 of 42
S/A Minn. R. 7017.2035, subp. 2; 40CFR Section 60.4245(d); Minn. R.7011.2310; 40 CFR Section63.6590(c); Minn. R. 7011.8150
Performance Test Report: due 45 days after Performance Test has beencompleted to measure VOC emissions as conducted in 40 CFR Section 60.4244.
Minn. R. 7017.2035, subp. 2 requires the Performance Test Report to besubmitted within 45 days following the completion of the performance test. 40 CFRSection 60.4245(d) requires a copy of each performance test to be submittedwithin 60 days following the completion of the performance test. Submitting theperformance test within 45 days of completion of the performance test will satisfyboth requirements.
14.0
TSD Attachment 2 Permit Number: 13700112-009 Page 133 of 134
MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194
COMPLIANCE PLAN CD-01Facility Name: Western Lake Superior Sanitary District
Permit Number: 13700112 - 009
22 Oct, 2014 14:41Page 42 of 42
Subject Item: EU 076 Temporary Digester Gas Flare (CE 021)
Associated Items: GP 004 Digester Gas Combustion Units
GP 009 Flares
SV 105 Temporary Flare (EU 076/CE 021)
NC/CA
Type Citation Requirement
CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate EU 076. The Permittee shallcommence construction at any time within 5 years of issuance of Air EmissionsPermit No. 13700112-009. The units shall meet all the requirements of this permit.
1.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start OfConstruction of EU 076. Submit the name, number, equipment manufacturer andmodel number, and the date construction began.
2.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofEU 076. Submit the name, number, equipment manufacturer and model number,and the actual date of initial startup for the unit.
Startup is as defined in Minn. R. 7005.0100, subp. 42a. Initial equipment testingduring installation does not constitute startup for production/operation purposes.
The conditions in the permit applicable to unit EU 076 and associated itemsbecome effective on the date initial startup of the unit occurs.
3.0
S/A Minn. R. 7007.0800, subp. 2 Notification of the date of Equipment Removal/Dismantlement: due 15 days afterEquipment Removal and/or Dismantlement of EU 076. This notification shallspecify how the equipment was removed/dismantled and the date of shutdown.
The conditions in the permit applicable to unit EU 076 and associated itemsremain in effect until shutdown of the unit occurs.
4.0
TSD Attachment 2 Permit Number: 13700112-009 Page 134 of 134
Western Lake Superior Sanitary District Permit No. 13700112-009 Technical Support Document
Attachment 3 Points Calculator
TSD Attachment 3 Permit Number: 13700112-009 Page 1 of 2
Points Calculator
1) AQ Facility ID No.: 13700112 Total Points 55
2) Facility Name: Western Lake Superior Sanitary District
3) Small business? y/n? no
4) DQ Numbers (including all rolled) : 4860
5) Date of each Application Received: July 8, 2014
6) Final Permit No. 13700112-009
7) Permit Staff Andrew Luberda
8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)? na
Total
Application Type DQ No. Qty. Points Points Details
Administrative Amendment 0 1 0
Minor Amendment 0 4 0
Applicability Request 0 10 0
Moderate Amendment 0 15 0
Major Amendment 4860 1 25 25
Individual State Permit (not reissuance) 0 50 0
Individual Part 70 Permit (not reissuance) 0 75 0
Additional Points
Modeling Review 0 15 0
BACT Review 0 15 0
LAER Review 0 15 0
CAIR/Part 75 CEM analysis 0 10 0
NSPS Review 4860: JJJJ 1 10 10
NESHAP Review 4860: ZZZZ, JJJJJJ 2 10 20
Case-by-case MACT Review 0 20 0
Netting 0 10 0
Limits to remain below threshold 0 10 0
Plantwide Applicability Limit (PAL) 0 20 0
AERA review 0 15 0
Variance request under 7000.7000 0 35 0
Confidentiality request under 7000.1300 0 2 0
EAW review
Part 4410.4300, subparts 18, item A; and 29 0 15 0
Part 4410.4300, subparts 8, items A & B; 10, items
A to C; 16, items A & D; 17, items A to C & E to G;
and 18, items B & C
0 35 0
Part 4410.4300, subparts 4; 5 items A & B; 13; 15;
16, items B & C; and 17 item D
0 70 0
Add'l Points 30
NOTES:
Major amendment to install and operate 3 new digester gas boiler, 7 new heating boiler and 3 new digester gas engines. The heating
boilers are subject to 40 CFR pt. 63, subp. JJJJJJ. The engines are subject to 40 CFR pt. 63, subp. ZZZZ and 40 CFR pt. 60, subp. JJJJ.
The amendment is also increasing digester gas capacity and installing a temporary flare for use during construction.
Exit gas temperatures were approximated. Digesters operate at 98o F at the end of the process. Flares operating range 1000-2000o F
Digester gas can exit multiplpe stacks, airflow was assumed to be total digester gas production
Process Weight Rate: the amount of material that is processed by the equipment (paint/gelcoat/fuel), in pounds per hour.
IPER Limit: Whichever Limit from Table 1 or Table 2 is less stringent is the limit. However, if Table 1 is the less stringent limit, but results in a load of more
than 0.3 grains per dry standard cubic foot, then the limit is 0.3 grain per dry standard cubic foot
EU Process Weight Rate is assuming digester gas is 65% methane and 35% CO2. density of methane and CO2 used is 0.0417 lc/scf and 0.1150 lb/scf,
IPER WLSSD
TSD Attachment 5 Permit Number: 13700112-009 Page 2 of 2