AIR EMISSION PERMIT NO IS ISSUED TO. Metropolitan Council

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Metropolitan Council SENECA WASTEWATER TREATMENT PLANT 3750 Plant Road Eagan, Dakota County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 02/29/1996 issued 10/24/2002 Major Amendment 12/19/2003 issued 06/28/2004 Major Amendment 07/01/2004 issued 12/07/2004 Administrative Amendment 06/14/2006 see below This permit supersedes permit number and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Pt 70/Limits to Avoid NSR Administrative Amendment Issue Date: 10/24/2002 Issue Date: June 19, 2008 Expiration: 10/24/2007* All Title I Conditions do not expire. * The Permittee can continue to operate this facility after the expiration date of this permit per the provision under Minn. R , subp. 3 (Seneca s Pt. 70 reissuance app received 4/27/2007 as timely). Jeff J. Smith, Manager Air Quality Permits Section Industrial Division for Brad Moore Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix A: Determination of Limits

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: The Seneca Wastewater Treatment Plant was constructed in 1972 and was designed to treat an annual average wastewater flow of 24 million gallons per day (mgd). The MPCA issued an NPDES permit in 1987 that allowed the expansion and upgrade of the wastewater treatment processes to an annual average flow of 34 mgd. An air emission permit issued in 1991 authorized the modification and rehabilitation of the existing incineration system and associated air pollution control equipment. As a result of the expansion, an agreement to address odor and emission concerns was reached between the city of Eagan and the Metropolitan Council. Two multiple hearth furnaces are used at the plant to incinerate sewage sludge produced at the facility. Seneca may also accept sewage sludge from other wastewater treatment plants for incineration. Each incinerator has seven hearths and a separate afterburner. Feed materials include sewage sludge, spent activated carbon, scum and granulated nonhazardous sorbent materials generated on-site. Auxiliary burners, located on hearths 3, 5, and 6, are used for startup and to maintain sludge combustion and incinerator temperatures. The auxiliary burners are fueled with natural gas or propane.

4 The Seneca Wastewater Treatment Plant also includes an alkaline final stabilization facility, which processes sewage sludge to produce a Class B land application product (as defined by Minnesota Rules) through the addition of alkaline admixtures. The facility includes: alkaline material storage silos and mixers, sludge dewatering equipment, product loadout area, and odor control equipment. This facility was not operating at the time of permit issuance. PERMIT ACTION 002: This permit amendment is an MPCA initiated amendment under Minn. R , subp. 1(D). It incorporates operating limits for GP001 imposed on the Facility under the performance testing rules (Minn. R , subp. 3). The permit also extends the THC monitoring and reporting requirements for GP001 emission units for an additional year to allow for the installation of new burners on the afterburners to optimize burner efficiencies. PERMIT ACTION 003: This permit amendment is an MPCA initiated amendment under Minn. R , subp. 1(D). It incorporates operating limits for GP001, GP002, CE002 and CE004 imposed on the Facility under the performance testing rules (Minn. R , subp. 3 PERMIT ACTION 004: This permit amendment is an administrative amendment to change the owner address for Seneca Wastewater Treatment Plant to 390 Robert Street North, St. Paul, Minnesota The previous owner address was 230 East Fifth Street, St. Paul, Minnesota

5 TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do OPERATIONAL REQUIREMENTS Why to do it Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16 PLANS Operation and Maintenance Plan: Within 90 days of permit issuance, revise and retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment, and the records kept to demonstrate plan implementation. Fugitive Control Plan: due 30 days prior to restart of alkaline stabilization facility. The plan shall identify all fugitive emission sources, primary and contingent control measures, and recordkeeping. The permitee shall follow the actions and recordkeeping specified in the Control Plan. The plan may be amended by the permittee with the Commissioner's approval. The permittee may be required to amend the control plan and/or install and operate particulate matter ambient air monitors if the Commissioner determines that the operation of the stationary source, together with other sources of particulate matter, creates conditions under which the Minnesota ambient air standard for particulate matter might be exceeded Episode Emission Reduction Plan: The Permittee shall submit to the Commissioner an episode emission reduction plan to be implemented at the facility or stationary source in the event of a declaration by the Commissioner of an air pollution episode. The plan shall be submitted to the Commissioner within 90 days of the designation of the area as having exceeded the alert levels in Minn. R , Table 1, following all requirements found in Minn. R to POLLUTION CONTROL EQUIPMENT REQUIREMENTS Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. PERFORMANCE TESTING REQUIREMENTS Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A or B. As provided in Minn. R , subp. 2, the Permittee may conduct performance testing required by this permit as included in an approved performance test plan. Minn. R Minn. R Minn. R Minn. R , subp.16 Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Minn. R through ; Minn. R , subp. 16(J) Minn. R. ch. 7017

6 TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: The following U.S. EPA reference methods (as amended) shall be used, with any modifications required by an applicable requirement, when conducting performance tests pursuant to this permit, unless an applicable requirement specifies a different method: ; and Minn. R , subp. 1 Method 5, as amended by Minn. R , for Total Particulate Matter Method 9 for Opacity A minor change or an alternative or equivalent method may be approved by the commissioner in accordance with Minn. R , subp. 2. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. MONITORING REQUIREMENTS Monitoring Equipment: Install or make needed repairs to monitoring equipment within 60 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment which have manufacturer's calibration procedures and check the accuracy of meters and monitors which cannot be calibrated. If the accuracy of equipment that cannot be calibrated is outside of recommended manufacturers specifications, the permittee shall initiate monitor repair or replacement within five working days of the discovery of the inaccuracy. Any requirements applying specifically to continuous emission monitors are listed separately in this permit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B, monitoring a process, or control equipment connected to that process, is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recording for continuous monitoring instrumentation, electronic data, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). When the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING Compliance Certification: due 31 days after end of each calendar year following Permit Issuance (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner, and to the U.S. EPA Regional Office in Chicago. The report covers all deviations experienced during the calendar year. Emission Inventory Report: due April 1 after end of each calendar year following permit issuance. To be submitted on a form approved by the Commissioner. Operation changes. In any shutdown, breakdown, or deviation covered by Minn. R , subp. 1, 2, or 3, the owner or operator shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R , subp. 4 Minn. R , subp. 6(C)(1) Minn. R through Minn. R Minn. R , subp. 4

7 TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. MISCELLANEOUS Minn. R , subp. 1 Minn. R , subp. 1 This permit shall not alter or affect the liability of an owner or operator for any Minn. R (C)(2) violation of applicable requirements prior to or at the time of permit issuance. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R through Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H) Inspections: Upon presentation of credentials and other documents as may be Minn. R , subp. 9(A) required by law, allow the Agency, or its representative, to enter the permittee's premises to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R

8 TABLE A: LIMITS AND OTHER REQUIREMENTS A-4 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: Subject Item: Associated Items: GP 001 Multiple Hearth Sludge Incinerators CE 001 Direct Flame Afterburner CE 002 Venturi Scrubber CE 003 Direct Flame Afterburner CE 004 Venturi Scrubber EU 001 Multiple Hearth Sludge Incinerator 1 EU 002 Multiple Hearth Sludge Incinerator 2 SV 001 Common Incinerator Stack SV 002 Relief Stack SV 003 Relief Stack EMISSION LIMITS What to do Why to do it At the time of permit issuance the Stack Vents (SV) and Control Equipment (CE) listed above are associated with each Emission Unit (EU) as shown in the following table: Emission Unit Stack Vents Control Equipment EU001 Incinerator #1 SV001 & 002 CE 001 & 002 EU002 Incinerator #2 SV001 & 003 CE 003 & 004 Total Particulate Matter: less than or equal to 1.30 lbs/ton dry sludge input for EU001 measured at SV001 according to procedures in Table A and Appendix A. Total Particulate Matter: less than or equal to 1.30 lbs/ton dry sludge input for EU002 measured at SV001 according to procedures in Table A and Appendix A. Total Particulate Matter: less than or equal to 7.31 lbs/ton using 24-hour Block Average dry sludge input for EU001 which includes emissions from SV001 plus emissions from SV002 to account for periods of relief stack opening. Emissions shall be calculated according to procedures in Appendix A. Total Particulate Matter: less than or equal to 7.31 lbs/ton using 24-hour Block Average dry sludge input for EU002 which includes emissions from SV001 plus emissions from SV003 to account for periods of relief stack opening. Emissions shall be calculated according to procedures in Appendix A. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 33 percent opacity. An exceedance of this opacity standard occurs whenever any one-hour period contains two or more six-minute periods during which the average opacity exceeds 20 percent or whenever any one-hour period contains one or more six-minute periods during which the average opacity exceeds 33 percent. Mercury: less than or equal to 3200 grams per 24-hour period for all incineration units combined MERCURY TRIGGER LEVEL Mercury: less than or equal to 1.5 ppm average dry centrifuge sludge concentration using a 12 month rolling average. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section If the mercury trigger level is exceeded the permittee shall submit and begin implementing a mercury reduction plan within 60 days of the exceedance. The plan shall include the reasons for increased mercury loading (sewer cleaning or construction activities, changes in in-plant activities) and the pollution prevention and other relevant mercury reduction activities to minimize the effects of the above. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section OPERATIONAL LIMITS Materials Incinerated: only sewage sludge, spent activated carbon, scum, and granulated nonhazardous sorbent materials generated on-site may be fed to the incinerators ; (most stringent, meets limits set by Minn. R ) Minn. R , Subp. 2; (most stringent, meets limits set by Minn. R ) Minn. R C Minn. R C Minn. R C 40 CFR section 61.52; 40 CFR section 61.54; Minn. R Minn. R , Subp. 2

9 TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: Process Throughput: less than or equal to 27,156 tons/year using 12-month Rolling Sum of sewage sludge, spent activated carbon, scum, and granulated nonhazardous sorbent materials generated on-site in Incinerators 1 and 2, (EU001 and EU002) combined. Process Throughput: less than or equal to 1.51 tons/hour using 24-hour Block Average is the average sludge feed rate limit in dry tons per hour for Incinerator 1 (EU001) as demonstrated during the most recent MPCA-approved performance test demonstrating compliance. Process Throughput: less than or equal to 1.68 tons/hour using 24-hour Block Average is the average sludge feed rate limit in dry tons per hour for Incinerator 2 (EU002) as demonstrated during the most recent MPCA-approved performance test demonstrating compliance. Temperature: greater than or equal to 1200 degrees F using 1-Hour Block Average measured in the hottest hearth. Fuel Usage: only natural gas or propane may be used as a fuel in the incinerator auxiliary burners OPERATIONAL REQUIREMENTS TO MINIMIZE EMISSIONS FROM RELIEF STACKS Good operating practices include, but are not limited to, the following operating requirements. ID Fan Alarms: The Permittee shall develop and implement a procedure for: Minn. R , subp. 4; Minn. R , subps. 2.B, 3.C and 3a.(B) Minn. R , subp. 4; Minn. R , subps. 2.B, 3.C and 3a.(B) Minn. R C Minn R , subp. 2 (1) maintaining alarms in the Seneca WWTP multiple hearth incinerator control room so that the incinerator operator is alerted when the revolutions per minute (RPM) for the ID Fans reaches 1950 RPM; and (2) immediately taking appropriate corrective action in order to attempt to prevent an emergency damper opening when ID Fan speed reaches 1950 RPM. (3) maintain a record of each occurence of the speed of the ID fans reaching 1950 RPM, the corrective measures taken in response to the alarm and the results of the action. Operator Training: The permittee shall implement a training schedule to provide training to Seneca WWTP multiple hearth incinerator operators. Such training shall be designed to train operators in assessing and responding to conditions that may lead to an emergency damper opening. The operator training schedule shall be submitted to MPCA for approval no later than 30 days after Permit Issuance. Once approved, the training schedule shall become an enforceable part of the permit. Emergency Damper Openings: For each emergency damper opening during operation of the multiple hearth incinerators at the Seneca WWTP, the permittee shall notify MPCA in writing by the end of the following calendar quarter as part of the excess emissions report (EER). This notification shall describe the incident and indicate the reason for the emergency damper opening and shall also describe corrective measures taken by the permittee to prevent future occurrences. Notwithstanding the preceding sentences of this paragraph, the permittee shall not be prohibited from activating the emergency dampers during a situation of imminent or actual significant threat to the safety of on-site personnel. NESHAP MERCURY TESTING REQUIREMENTS Sludge Sampling: Sludge cake shall be sampled, handled, prepared and analyzed for mercury content on a monthly basis in accordance with the procedures described in 40 CFR 61.54(c)(1), Method 105 in appendix B - Determination of Mercury in Wastewater Treatment Plant Sewage Sludges. The maximum 24-hour period sludge incineration rate shall be determined by use of a flow rate measurement device that can measure the mass rate of sludge charged to the incinerators with an accuracy of plus or minus 5 percent over its operating range. Mercury emissions shall be determined by using the equation in 40 CFR 61.54(d) Report: due 30 days after end of each calendar half-year following Permit Issuance. (The report shall contain the monthly mercury sample analysis of the mixed sludge charged to the incinerators) STATE STATUTE MERCURY TESTING REQUIREMENTS 40 CFR Section 61.54(c)(3); Minn. R , subp CFR Section 61.54(c)(2); Minn. R , subp CFR 61.54(d) Minn. R , subp. 4 This permit provides approval of a method other than stack testing for determining mercury in air emissions. Monthly sludge sampling and analysis will be used to determine mercury emissions as an alternative to quarterly stack testing. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section Minn. Stat , paragragh (b), alternative sampling method

10 TABLE A: LIMITS AND OTHER REQUIREMENTS A-6 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant The permittee shall sample, handle, prepare and analyze the sludge cake for mercury content once per month in accordance with the procedures described in 40 CFR 61.54(c)(1), Method 105 in appendix B - Determination of Mercury in Wastewater Treatment Plant Sewage Sludges. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section Report: due 30 days after end of each calendar half-year following Permit Issuance (The report shall contain the monthly mercury sample analysis of the mixed sludge charged to the incinerators). This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section STACK TESTING REQUIREMENTS Minn. Stat , paragragh (b), alternative sampling method Minn. Stat , paragragh (b), alternative sampling method Performance Tests: Performance testing for EU001 shall be conducted at SV001 according to Appendix A Performance Tests: Performance testing for EU002 shall be conducted at SV001 according to Appendix A Performance Test: due 180 days after 10/24/2002 to measure particulate matter emissions for EU001. For additional applicable performance test requirements, see 'General Performance Test Requirements" in Table A, Subject Item "Total Facility". Performance Test: due 545 days after 10/24/2002 to measure particulate matter emissions for EU002. Minn. R Minn. R Minn. R , subp. 1 Minn. R , subp. 1 For additional applicable performance test requirements, see 'General Performance Test Requirements" in Table A, Subject Item "Total Facility". Performance Tests: Incinerator 1 (EU001) will be limited to the average sludge feed rate demonstrated during the most recent performance test conducted for compliance purposes. Incinerator 2 (EU002) will be limited to the average sludge feed rate demonstrated during the most recent performance test conducted for compliance purposes as shown in the following requirement. Where test results are less than or equal to 80 percent of the value of the applicable emission limit for all of the air pollutants that were required to be tested, the new limit shall be set at 110 percent of the tested rate except as otherwise provided in Minn. R , subp. 3a.(B). Performance Test Notification (written): due 30 days before Performance Test (30 days before the first Performance Test scheduled for each calendar year of testing) Performance Test Plan: due 30 days before Performance Test (30 days before the first Performance Test scheduled for each calendar year of testing). A single test plan can be submitted for all testing required in each calendar year. This includes all PM and Opacity testing requirements listed at the EU level for each incinerator unit. Performance Test Pre-test Meeting: due 7 days before Performance Test (7 days before the first Performance Test scheduled for each calendar year of testing). See Table B for additional performance testing requirements. Minn. R , subp. 4; Minn. R , subps. 2.B, 3.C and 3a.(B) Minn. R , subp. 1 Minn. R , subp. 2 and 3 Minn. R subp. 4 Performance Test Report: due 45 days after Performance Test Minn. R , subp. 1 Performance Test Report - Microfiche Copy: due 105 days after Performance Test Minn. R , subp. 2 MONITORING REQUIREMENTS Install, calibrate, maintain and operate temperature measuring devices at every hearth on each incinerator. A minimum of one thermocouple shall be installed in each hearth in the cooling and drying zones, and a minimum of two thermocouples shall be installed in each hearth in the combustion zone. Each temperature measuring device shall be certified by the manufacturer to have an accuracy of +/- 5% over its operating range. The temperature monitoring device shall be operated continuously and data recorded during all periods of operation of the incinerator. Install, calibrate, maintain and operate a monitoring device on each incinerator that continuously measures and records the oxygen content of the incinerator exhaust gas. The oxygen monitor shall be located upstream of any rabble shaft cooling air inlet into the incinerator exhaust gas stream, fan, ambient air recirculation damper, or any other source of dilution air. The oxygen monitoring device shall be certified by the manufacturer to have a relative accuracy of +/-5% over its operating range and shall be calibrated according to method(s) prescribed by the manufacturer at least once each 24-hour operating period. Minn. R , subp, 4 Minn. R , subp. 4

11 TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: Sludge Feedrate Monitoring: Install, calibrate, maintain and operate a flow measuring device for recording & determining the mass or volume of sludge charged to each incinerator. The weighing device shall be certified by the manufacturer to have an accuracy of +/- 5 % over its operating range. Sludge flow to each incinerator shall be measured continuously and data recorded during all periods of operation of the incinerators. Monitor: The Permittee shall install, calibrate, maintain and operate a device for measuring the fuel flow to each incinerator. The flow measuring device shall be certified by the manufacturer to have an accuracy of +/- 5% over its operating range. The fuel flow measuring device shall be operated continuously and data recorded during all periods of operation of each incinerator. Install, operate, and maintain a Continuous Opacity Monitoring System (COMS) to measure opacity from the common stack. Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit startup, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Acceptable monitor downtime includes reasonable periods due to the following causes: A. damage to the monitoring system due to Acts of God such as lightning strikes, tornadoes, or floods which render the monitor inoperative; B. sudden and not reasonably preventable breakdowns; C. scheduled monitor maintenance based upon equipment manufacturer's recommended maintenance schedule which cannot reasonably be conducted when the emission unit is not operating ; or D. unavoidable monitor downtime in order to conduct daily drift check, calibration error audits, relative accuracy test audits, linearity checks, and cylinder gas audits required by a compliance document, applicable requirement, or by request of the Commissioner. COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) opacity at least once daily. The COMS must be adjusted whenever the calibration drift (CD) exceeds twice the specification of PS-1 of 40 CFR pt. 60, Appendix B. COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar half-year following COMS Calibration Error Audit. COMS Calibration Error Audit: due before end of each calendar half-year starting 10/24/2002. Conduct three point calibration error audits at least 3 months apart but no greater than 8 months apart. Filter values used shall correspond to approximately 11%, 20%, and 37% opacity. COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to 6 minute averages. Compliance must be calculated from all data points collected in the averaging period by the COMS. A six-minute average is valid only if it contains at least five of the minutes within the averaging period. RECORDKEEPING 40 CFR 61.54(c)(2) Minn. R , subp, 4 Minn. R Minn. R , subp. 1 Minn. R , subp. 1 CONTINUED Minn. R , subp. 2 Minn. R Minn. R , subp. 3 Minn. R , subp. 1, 2, & 3 Recordkeeping: Retain all records at the stationary source for a period of five (5) Minn. R , subp. 5(C) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, electronic data and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Emergency Relief Stack Use: the permittee shall record in the operating log all time Minn. R , subp. 4(B) and 5(C) periods of use of the emergency relief stack when sludge is being combusted. This includes the burnout period after charging has stopped and sludge is being burned out of the unit. Recordkeeping: Maintain records of the measured temperature for each hearth in Minn. R , subp, 4 each incinerator Recordkeeping: Maintain records of the fuel use for each incinerator. Recordkeeping: Maintain records of materials charged to each incinerator including the mass or volume of sludge and other materials charged to each incinerator and the total solids and volatile solids content of sludge and other materials charged to the incinerators. Recordkeeping: by the 30th day of each month calculate and record the tons of materials charged to the incinerators for the previous month, and the previous 12-month period (by summing monthly material tonnage data for the previous 12 months).

12 TABLE A: LIMITS AND OTHER REQUIREMENTS A-8 06/19/08 Facility Name: Seneca Wastewater Treatment Plant Permit Number: Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. REPORTING Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Permit Issuance. The EER shall indicate all periods of emission limit exceedences, including any exceedences due to startup, shutdown, or malfunctions. An EER shall be submitted for each COMS. The EER shall also indicate all periods of monitor bypasses and emergency relief stack useage when sludge or other materials are being combusted (this includes periods of sludge burnout) in the incinerators. QA Plan Required: Develop and implement a written quality assurance plan which covers each COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain the written procedures listed in Minn. R , subp. 1. Submit: due 30 days after end of each quarter following Equipment Installation and startup of the new burners on the afterburners or achieving reduced afterburner temperatures, a THC monitoring report (a 30-day startup period is allowed). This report shall include a THC monitoring summary sufficient to show trends in THC concentration as correlated to combustion zone temperature and afterburner temperature and residence time. Actual THC monitoring data and temperature data shall be maintained on site. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section Notification: due 30 days after the first full year following installation and startup of the new burners on the afterburners or achieving reduced afterburner temperatures, the Permittee shall notify the MPCA permit engineer assigned to the facility that the THC monitoring report requirement has been completed. The Permittee shall also arrange a meeting with the MPCA permit engineer to review the results of the one year of THC monitoring. Minn. R Minn. R , subp. 1 & 2 Minn. R Following one year of THC and temperature reporting and meeting to discuss results of the reports, MPCA may reopen the permit as allowed by the reference rule provision to amend the temperature requirements to address odor concerns. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section Following one year of THC and temperature reporting and meeting to discuss the results of the reports, MPCA reserves the right to reopen the permit as permitted by the reference rule provision to amend the temperature requirements to address odor concerns. This is a state-only requirement and is not enforceable by the EPA Administrator, nor subject to the citizen suit provisions of section 304 of the Clean Air Act, 42 U.S.C. section Minn. R , subp. 2. C.

13 TABLE A: LIMITS AND OTHER REQUIREMENTS A-9 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: EU 003 CFS-1060 Ash Receiver for Incinerators 1& 2 Associated Items: CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 004 Ash Receivers Stack What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B)

14 TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: EU 004 CFS-1061 Ash Receiver for Incinerators 1& 2 Associated Items: CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 004 Ash Receivers Stack What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B)

15 TABLE A: LIMITS AND OTHER REQUIREMENTS A-11 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: EU 005 T-1060 Ash storage silo for incin. 1& 2 Associated Items: CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 005 Ash Silo Stack What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B)

16 TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: EU 006 T-1061 Ash storage silo for incin. 1& 2 Associated Items: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 006 Ash Silo Stack What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B)

17 TABLE A: LIMITS AND OTHER REQUIREMENTS A-13 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: CE 001 Direct Flame Afterburner Associated Items: EU 001 Multiple Hearth Sludge Incinerator 1 GP 001 Multiple Hearth Sludge Incinerators What to do Temperature: greater than or equal to 1050 degrees F using 1-Hour Block Average with a 0.3 second retention in the afterburner combustion zone. The Commissioner has approved the alternate temperature of 1050 degrees F. Install, calibrate, maintain and operate a temperature measuring device(s) on the afterburner. A minimum of one thermocouple shall be installed in the combustion zone of the afterburner. Each temperature measuring device shall be certified by the manufacturer to have an accuracy of +/-5% over its operating range. The temperature monitoring device shall be operated continuously and data recorded during all periods of operation of the incinerator. ("Continuously" is defined as determining at least one data point in each 15-minute time interval) Recordkeeping: Maintain permanent records for a period of five years of the operating temperature as measured in the afterburner. ("Permanent records" means records that are in a form that is retrievable and readable such as a hard copy or a computer disk) Fuel Usage: only natural gas or propane may be used as a fuel in the incinerator afterburner Why to do it Minn. R , C; Minn. R , subp. 4 Minn. R , subp. 4

18 TABLE A: LIMITS AND OTHER REQUIREMENTS A-14 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: CE 002 Venturi Scrubber Associated Items: EU 001 Multiple Hearth Sludge Incinerator 1 GP 001 Multiple Hearth Sludge Incinerators What to do Hydrochloric acid: greater than or equal to 80 percent control efficiency Total Particulate Matter: greater than or equal to 90 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency Pressure Drop: greater than or equal to 15 inches of water column using a 15-minute block average as determined during the April 15, 2003 performance test. Pressure Drop shall be greater than or equal to 30 percent below the average scrubber pressure drop measured during the most recent performance test showing compliance for each venturi scrubber with a minimum pressure drop not less than 15 inches of water column. Water flow rate: greater than or equal to 576 gallons/minute using 1-Hour Average as measured during the most recent MPCA-approved performance test dated April 15, Water flow rate shall be greater than or equal to 10 percent below the average water flow rate measured during the most recent performance test showing compliance for each wet scrubber system (venturi flow plus the subcooler flow) but not less than a minimum water flow rate of 380 gallons per minute using a 1-hour block average Install, calibrate, maintain and operate a monitoring device on each wet scrubber that continuously measures and records the pressure drop of the gas flow through the wet scrubbing device. The device used to monitor scrubber pressure drop shall be certified by the manufacturer to be accurate within +/- 250 pascals (+/- 1 inch water gauge) and shall be calibrated on an annual basis in accordance with the manufacturer's instructions. Install, calibrate, maintain and operate a monitoring device on each wet scrubber that continuously measures and records the water flow rate of the water flow through the wet scrubbing device. The device used to monitor scrubber water flow rate shall be certified by the manufacturer to be accurate within +/- 5% and shall be calibrated on an annual basis in accordance with the manufacturer's instructions. Recordkeeping: Maintain records of the measured pressure drop of the gas flow through each wet scrubbing system Recordkeeping: Maintain records of the measured water flow rate through each wet scrubbing system. Submittal: due 30 days after end of each calendar half-year starting 01/01/2002 the Permittee shall submit a Semiannual Deviations Report to the MPCA containing a record of the average scrubber pressure drop measurements of each period of 15 minute duration or more during which the pressure drop of the scrubber was less than a value that is 30% below the average scrubber pressure drop measured during the most recent performance test. Why to do it Minn. R subp. 16J Minn. R subp. 16J Minn. R subp. 16J Minn. R , subp, 4 Minn. R , subp, 4 Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 6

19 TABLE A: LIMITS AND OTHER REQUIREMENTS A-15 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: CE 003 Direct Flame Afterburner Associated Items: EU 002 Multiple Hearth Sludge Incinerator 2 GP 001 Multiple Hearth Sludge Incinerators What to do Temperature: greater than or equal to 1050 degrees F using 1-Hour Block Average with a 0.3 second retention in the afterburner combustion zone. The Commissioner has approved the alternate temperature of 1050 degrees F. Install, calibrate, maintain and operate a temperature measuring device(s) on the afterburner. A minimum of one thermocouple shall be installed in the combustion zone of the afterburner. Each temperature measuring device shall be certified by the manufacturer to have an accuracy of +/-5% over its operating range. The temperature monitoring device shall be operated continuously and data recorded during all periods of operation of the incinerator. ("Continuously" is defined as determining at least one data point in each 15-minute time interval) Recordkeeping: Maintain permanent records for a period of five years of the operating temperature as measured in the afterburner. ("Permanent records" means records that are in a form that is retrievable and readable such as a hard copy or a computer disk) Fuel Usage: only natural gas or propane may be used as a fuel in the incinerator afterburner Why to do it Minn. R C.; Minn. R , subp. 4 Minn. R , subp. 4

20 TABLE A: LIMITS AND OTHER REQUIREMENTS A-16 06/19/08 Facility Name: Permit Number: Seneca Wastewater Treatment Plant Subject Item: CE 004 Venturi Scrubber Associated Items: EU 002 Multiple Hearth Sludge Incinerator 2 GP 001 Multiple Hearth Sludge Incinerators What to do Hydrochloric acid: greater than or equal to 80 percent control efficiency Total Particulate Matter: greater than or equal to 90 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency Pressure Drop: greater than or equal to 15 inches of water column using a 15-minute block average as determined during the April 7, 2004 performance test. Pressure Drop shall be greater than or equal to 30 percent below the average scrubber pressure drop measured during the most recent performance test showing compliance for each venturi scrubber with a minimum pressure drop not less than 15 inches of water column. Water flow rate: greater than or equal to 584 gallons/minute using 1-Hour Average as measured during the most recent MPCA-approved performance test dated April 7, Water flow rate shall be greater than or equal to 10 percent below the average water flow rate measured during the most recent performance test showing compliance for each wet scrubber system (venturi flow plus the subcooler flow) but not less than a minimum water flow rate of 380 gallons per minute using a 1-hour block average Install, calibrate, maintain and operate a monitoring device on each wet scrubber that continuously measures and records the pressure drop of the gas flow through the wet scrubbing device. The device used to monitor scrubber pressure drop shall be certified by the manufacturer to be accurate within +/- 250 pascals (+/- 1 inch water gauge) and shall be calibrated on an annual basis in accordance with the manufacturer's instructions. Install, calibrate, maintain and operate a monitoring device on each wet scrubber that continuously measures and records the water flow rate of the water flow through the wet scrubbing device. The device used to monitor scrubber water flow rate shall be certified by the manufacturer to be accurate within +/- 5% and shall be calibrated on an annual basis in accordance with the manufacturer's instructions. Recordkeeping: Maintain records of the measured pressure drop of the gas flow through each wet scrubbing system Recordkeeping: Maintain records of the measured water flow rate through each wet scrubbing system. Submittal: due 30 days after end of each calendar half-year starting 01/01/2002 the Permittee shall submit a Semiannual Deviations Report to the MPCA containing a record of the average scrubber pressure drop measurements of each period of 15 minute duration or more during which the pressure drop of the scrubber was less than a value that is 30% below the average scrubber pressure drop measured during the most recent performance test. Why to do it Minn. R subp. 16J Minn. R subp. 16J Minn. R subp. 16J Minn. R , subp, 4 Minn. R , subp, 4 Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 6