Air Emission Permit No. 05300400-003 Is Issued to Covanta ...Section A - Emissions A. hdr Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 05300400 – 003

IS ISSUED TO

Covanta Energy, Inc.

COVANTA HENNEPIN ENERGY RESOURCE COMPANY LP 505 6th Avenue North

Minneapolis, Hennepin County, MN 55405 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 04/14/1995

Administrative Amendment 02/09/2001 Administrative Amendment 09/27/2001 Administrative Amendment 11/07/2001

Major Amendment 11/14/2002 This permit authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Permit Type: Federal; Part 70

Issue Date: September 10, 2004 Expiration: May 14, 2003 All Title I Conditions do not expire. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division For Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description How to Use This Document Table A: Limits and Other Requirements

Total Facility Limits and Other Requirements

A. Emissions B. Operations C. Control equipment D. Testing E. Monitors F. Recordkeeping G. Report/Submittals

GP 001 - MSW Incinerators

A. Applicability B. Limits C. Mercury Control D. Testing E. Monitors F. Recordkeeping G. Reporting H. Facility Operation I. Ash Handling J. Waste Stream K. Training L. Operator Certification M. Required Plans N. Abnormal Operation O. Definitions

GP 002 – Activated Carbon Adsorption GP 003 - Ammonia Injection GP 004 – Lime Spray Dryers GP 005 – Fabric Filters (High Temperature) GP 006 – Fabric Filters (Low Temperature) Emission Unit EU 003 - Lime Silo Emission Unit EU 005 – Lime Silo (Dolomitic Lime) Emission Unit EU 007 – Combined Ash Handling Emission Unit EU 008 – Cooling Tower

Table B: Submittals Appendix I: Insignificant Activities

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

FACILITY DESCRIPTION: The Covanta Hennepin Energy Resource Company (the Permittee) facility, located in downtown Minneapolis, is a mass-burn waste-to-energy facility with two identical process trains. Each process train has a design capacity of 606 tons per day, resulting in a total design capacity of 1212 tons per day of municipal waste. By Minnesota Law, the overall facility was limited to 365,000 tons of municipal solid waste annually. The facility may burn industrial waste if it is properly handled in accordance with their Industrial Solid Waste Management Plan. The major emission units at this facility are the two waste combustor units. The facility was permitted in 1987 and was operational in 1989. Each waste combustor unit (waterwall) was designed according to good combustion principles to minimize the emission of Carbon Monoxide (CO) and organics. An ammonia injection system was in place to control emissions of Nitrogen Oxides (NOx). Upon leaving the combustion unit, flue gases pass through a heat recovery system and enter a lime slurry dry scrubber for control of acid gases. The flue gases then pass through a fabric filter for the control of Particulate Matter (PM), including metals and dioxins. Flue gases then enter the stack, where continuous monitors measure opacity, CO, NOx, Sulfur Dioxide (SO2), and carbon dioxide. Mercury control equipment was permitted in 1993 and was operational in 1994. Mercury is controlled by adding activated carbon to the flue gases just upstream of the dry scrubber. Mercury is adsorbed onto the carbon, and the carbon is removed from the flue gases farther downstream by the fabric filter. Steam generated from combustion heat is used power a 37.5 megawatt electrical generator. Some electricity services the facility, but the majority is sold to Xcel Energy. Ferrous metals are continuously recovered from the bottom ash before it is combined with fly ash and transported away to ash monofills. AMENDMENT DESCRIPTION: This permitting action incorporates the following:

1) Currently, each combustor’s pollution control system is equipped with a dedicated

gravimetric activated carbon feed system. These systems are comprised of a gravimetric feeder and a pneumatic conveying system that deliver activated carbon to the flue gas stream. In the event one of the gravimetric feeders breaks down, the Permittee proposes to use one activated carbon feed system to feed both pollution control systems. The back-up system would utilize a single gravimetric feeder, except that the carbon would be pneumatically conveyed through a “Y” splitter to the two combustor pollution control systems.

2) The permit currently references both a 25 ppmv and 29 ppmv HCL emissions standard. With current federal and state standards now providing a 29 ppmv standard, the Permittee proposes to eliminate the now obsolete state only limit of 25 ppmv HCL emissions limit so that the permit is consistent with current rules. (see Minn. R. 7011.1227, table 1 and federal emissions guidelines provided in 40 CFR 60.33b.)

3) The Permittee proposes to “clean-up” certain items in the existing permit to conform with

current operations and rules. 4) This amendment reflects Emission Units 005-008 as being part of the overall facility. These

are all existing units that were omitted in the initial permit issuance. 5) This amendment also reflects a change in ownership. Hennepin County is now the facility

owner. Covanta Hennepin Energy Resource Co. continues to operate the facility. HOW TO USE THIS DOCUMENT: The permit language specific to waste combustor units is found in Table A under “GP 001 – MSW Incinerators.” Each requirement (or set of requirements) within GP 001 includes a bulleted list entitled “The Permittee will.” The permit requirement is satisfied by fulfilling the actions that are bulleted. An action listed in the “The Permittee Will” bulleted portion of the permit may end with a bracketed phrase referring to a section of the permit, such as “Record and maintain data from the continuous monitors [see Section F - Recordkeeping]”. By fulfilling the requirements in the bracketed section, the original requirement is also fulfilled. In this example, the “Record and maintain data from the continuous monitors” is also required under “[see Section F - Recordkeeping]”. Therefore, the “Recordkeeping” requirements in the permit satisfy the need to “Record and maintain data from the continuous monitors”. One permit condition may have several regulatory citations. The table is organized as an outline. For example, “B.01.” discusses emissions measured by stack testing, and includes the measurement requirements. Following “B.01.” are “B.01.a.” through “B.01.i.”, which list the individual pollutants subject to stack testing along with their respective limits.

TABLE A: LIMITS AND OTHER REQUIREMENTS 09/10/04

Covanta Hennepin Energy Resource Co LP

05300400 - 003

Facility Name:

Permit Number:

A-1

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

Subject Item: Total Facility

What to do Why to do itSection A - Emissions A. hdr

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. This is a state only requirement and is not federallyenforceable.

A.01Minn. R. 7011.0150

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

A.02.Minn. R. 7030.0010 - 7030.0080

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

A.03.Minn. R. 7011.0020

Section B - Operational requirements B. hdr

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment.

B.01.Minn. R. 7007.0800, subp. 14Minn. R. 7007.0800, subp. 16(J)

Operating and/or production limits will be placed on emission units based onoperating conditions during compliance testing. Limits set as a result of acompliance test (conducted before or after permit issuance) apply until newoperating/production limits are set following formal review of a performance test asspecified by Minn. R. 7017.2025.

B.02.Minn. R. 7017.2025

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

B.03.Minn. R. 7007.0800, subp. 16

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

B.04.Minn. R. 7007.0800, subp. 9(A)

Section C - Pollution Control Equipment C. hdr

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

C.01.Minn. R. 7007.0800, subp. 2Minn. R. 7007.0800, subp. 16(J)

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand record keeping specified in the control plan. The plan may be amended by thePermittee with the Commissioner's approval. If the Commissioner determines thePermittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan,then the Permittee may be required to amend the control plan and/or to install andoperate particulate matter ambient monitors as requested by the Commissioner.This is a state only requirement and is not federally enforceable.

C.02.Minn. Stat. Section 116.07, subd. 4aMinn. R. 7007.0800, subp. 2

Section D - Testing Requirements D. hdr

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

D.01.Minn. R. ch. 7017

Section E - Monitoring E. hdr

Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, install ormake needed repairs to monitoring equipment within 60 days of issuance of thepermit if monitoring equipment is not installed and operational on the date thepermit is issued.

E.01.Minn. R. 7007.0800, subp. 4(D)

Monitoring Equipment Calibration: Unless otherwise noted in Tables A, B, and/or C,annually calibrate all required monitoring equipment (any requirements applying tocontinuous emission monitors are listed separately in this permit).

E.02.Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, 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.

E.03.Minn. R. 7007.0800, subp. 4(D)

Section F - Recordkeeping F. hdr



05300400 - 003

Facility Name:

Permit Number:

A-2

Record keeping: 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.

F.01.Minn. R. 7007. 0800, subp. 5(B)

Record keeping: Unless otherwise noted in Tables A, B, and/or C, retain all recordsat 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 locationinclude all calibration and maintenance records, and copies of all reports requiredby the permit. Records must conform to the requirements listed in Minn. R.7007.0800, subp. 5(A).

F.02.Minn. R. 7007.0800, subp. 5(C)

Section G - Reports/Submittals G. hdr

Semiannual Deviations Report: due 30 days after end of each calendar half-yearfollowing Permit Issuance . The first semiannual report submitted by the Permitteeshall cover the calendar half-year in which the permit is issued. The first report ofeach calendar year covers January 1 - June 30. The second report of eachcalendar year covers July 1 - December 31. (Items submitted in the WasteCombustor Quarterly Report do not have to be resubmitted to fulfill thisrequirement.)

G.01.Minn. R. 7007.0800, subp. 6(A)

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).

G.02.Minn. R. 7007.1400, subp. 1(H)

Compliance Certification: due 30 days after end of each calendar year followingPermit Issuance (for the previous calendar year), to be submitted to theCommissioner and the U.S. EPA regional office on a form approved by theCommissioner. The report covers all deviations experienced during the calendaryear.

G.03.Minn. R. 7007.0800, subp. 6 (C)

Emissions Inventory Report: due 91 days after end of each calendar year followingPermit Issuance (April 1). To be submitted on a form approved by theCommissioner.

G.04.Minn. R. 7019.3000

Emission Fees: due 60 days after receipt of an MPCA bill. G.05.Minn. R. 7002.0005 through Minn. R. 7002.0085

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.

G.06Minn. R. 7019.1000, subp. 3

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.

G.07.Minn. R. 7019.1000, subp. 2

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

G.08Minn. R. 7019.1000, subp. 1

Fugitive Emissions Control Plan: The Permittee shall submit a fugitive emissionscontrol plan within 60 days after 05/14/98 for review and approval by theCommissioner. The plan shall identify all fugitive emission sources, primary andcontingent control measures, and record keeping. The Permitee shall follow theactions and record keeping specified in the control plan. The plan may beamended by the Permittee with the Commissioner's approval. If the Commissionerdetermines the permitee is out of compliance with Minn. R. 7011.0150 or thefugitive emission control plan, then the permittee may be required to amend thecontrol plan and/or to install and operate particulate matter ambient monitors. Thisis a state only requirement and is not federally enforceable.

G.09.Minn. Stat. Section 116.07, subd. 4aMinn. R. 7007.0800, subp. 2

Application for Permit Reissuance: due 180 days before expiration of ExistingPermit

G.10.Minn. R. 7007.0400, subp. 3



05300400 - 003

Facility Name:

Permit Number:

A-3

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

G.11.Minn. R. 7019.1000, subp. 1

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

G.12.Minn. R. 7007.1150 through Minn. R. 7007.1500

The Permittee is required to submit a Risk Management Plan (RMP) under thefederal rule, 40 CFR pt. 68. Each owner or operator of a stationary source, at whicha regulated substance is present above a threshold quantity in a process, shalldesign and implement an accidental release prevention program. A complete RMPmust be submitted to the RMP Reporting Center, PO Box 3346, Merrifield, VA22116. RMP submittal information may be obtained athttp://www.epa.gov/swercepp or by calling 1-800-424-9346. These requirementsmust be complied with no later than the latest of the following dates: (1) June 21,1999; (2) Three years after the date on which a regulated substance is first listedunder 40 CFR Section 68.130; or (3) The date on which a regulated substance isfirst present above a threshold quantity in a process.

G. 13.40 CFR pt. 68



05300400 - 003

Facility Name:

Permit Number:

A-4

Subject Item: GP 001 MSW Incinerators (All requirments apply to each emission unit.)

Associated Items: CE 001 Activated Carbon Adsorption

CE 002 Activated Carbon Adsorption

CE 003 Ammonia Injection


CE 005 Lime Spray Dryer


CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F


EU 001 MSW Incinerator


MR 001

MR 002

MR 003

MR 004

MR 005

MR 006

MR 007

MR 008

MR 009

MR 010

SV 001 MSW Combustor #1


What to do Why to do itAPPLICABILITY r

EFFECTIVE DATE: Notwithstanding any transition dates to the contrary, thePermittee has agreed to comply with Minn. R. 7011.1201 through 7011.1290,except as identified in specific conditions of this permit. The Permittee has alsoagreed to comply immediately with additional conditions contained in Minn. R.7011.1201 through 7011.1290, when effective, except as indicated in specificconditions of this permit. Therefore, unless otherwise noted elsewhere in thispermit, the conditions of this permit are effective upon permit issuance.The Permittee will:> Comply with all permit conditions upon permit issuance.

A.01.Minn. R. 7011.1215, subp. 5Minn. R. 7007.0800, subp. 2

APPLICABILITY OF LIMITS: Comply with emission limits, control device inlettemperature limits, and mercury additive feedrate limits at all times when waste isbeing continuously burned [see Section O - Definitions], except that these limits donot apply, up to a maximum of three hours, during periods of: 1. start-up (in Definitions); 2. shutdown (in Definitions); or 3. malfunction (defined in Minn. R. 7011.1215, subp. 4).

The Permittee will:> Operate continuous monitors in accordance with this permit [see Section E -Monitors];> Record times of start-up and shutdown in the Operating Record [see Section F -Recordkeeping];> Record in the Operating Record time periods, reasons, and corrective actionsregarding any malfunction [see Section F - Recordkeeping, and Section N -Abnormal Operation]

A.02.Minn. R. 7011.1215, subp. 440 CFR 60.7(b)



05300400 - 003

Facility Name:

Permit Number:

A-5

> During times when emission limits are not met, identify in the Operating Recordthose periods that occur during start-up, shutdown, and malfunction [see Section F- Recordkeeping]

CONTINUEDA.02.Minn. R. 7011.1215, subp. 440 CFR Section 60.40b(d)40 CFR Section 60.44b(h)40 CFR 60.7(b)

LIMITS B. hdr

MEASUREMENT USING PERFORMANCE TESTS: Performance tests shall beused to measure emissions for the following: 1. Front-half particulate matter 2. Total particulate matter 3. Total PCDD/PCDF 4. Hydrogen chloride 5. Mercury 6. Lead 7. VOC 8. Opacity 9. Cadmium

B.01.Minn. R. 7011.1225, subp. 1Minn. R. 7011.1265, subp. 2(A)Minn. R. 7011.1265, subp. 2(A)(1)Minn. R. 7011.1265, subp. 2(A)(2)Minn. R. 7011.1265, subp. 2(B)Minn. R. 7011.1265, subp. 3(B)

The Permittee will:> Conduct performance tests, when required [see Section D - Testing]> Submit test results indicating that emissions are within permitted limits [seeSection G - Reporting]> Report failed performance tests as required [see Section N - AbnormalOperation]

CONTINUEDB.01.Minn. R. 7011.1265, subp. 3(A)Minn. R. 7011.1265, subp. 3(C)Minn. R. 7011.1201, subp. 40Minn. R. 7007.0800, subp. 2

Particulate Matter B.01.a. hdr

Front-half Particulate Matter: less than or equal to 0.012 grains/dry standard cubicfoot corrected to seven percent oxygen.

B.01.a.(1).Minn. R. 7011.1227Minn. R. 7011.1225, subp. 1Minn. R. 7007.0800, subp. 240 CFR Section 60.5240 CFR Section 60.5440 CFR Section 60.43b(d)(1)40 CFR Section 60.43b(e)

Total Particulate Matter: less than or equal to 0.020 grains/dry standard cubic foot ,corrected to seven percent oxygen. This is a state only requirement and is notfederally enforceable.

B.01.a.(2).Minn. R. 7011.1227Minn. R. 7011.1225, subp. 1

Total Particulate Matter: less than or equal to 90 tons/year using 12-month RollingSum (including both EU 001 and 002), calculated using methods:(1) based on stack test data and hours of operation; or(2) acceptable to MPCA

B.01.a.(3).Title I Condition: Limit taken to avoid classification asa major source under 40 Section CFR 51, Appendix Sand Minn. R. 7007.4000 through 7007.4030

Muni Waste Combust Organics: less than or equal to 30 nanograms/DSCMcorrected to seven percent oxygen, measured as Total PCDD/PCDF.

B.01.b.Minn. R. 7011.1227Minn. R. 7011.1225, subp. 1

Hydrochloric acid B.01.c. hdr

Hydrochloric acid: less than or equal to 29 parts per million corrected to sevenpercent oxygenorHydrochloric acid: greater than or equal to 95 percent controlwhichever is less stringent

B.01.c.(1).Minn. R. 7011.1227

Mercury B.01.d. hdr

Mercury: less than or equal to 80 micrograms/DSCM corrected to seven percentoxygen (Short-term limit);orMercury: greater than or equal to 85 percent control efficiency (Short-term limit);whichever is less stringent.

B.01.d.(1).Title I Condition: 1987 determination of PSD BACT inaccordance with 40 CFR 52.21Minn. R. 7011.1227Minn. Stat. 116.85, subd. 1a(e)Minn. R. 7007.0800, subp. 2Minn. R. 7011.1225, subp. 1

Mercury: less than or equal to 60 micrograms/DSCM corrected to seven percentoxygen (Long-term limit);orMercury: greater than or equal to 85 percent control efficiency (Long-term limit);whichever is less stringent.This is a state only requirement and is not federally enforceable.

B.01.d.(2).Minn. R. 7011.1227Minn. Stat. 116.85, subd. 1a(e)Minn. R. 7011.1225, subp. 1

Volatile Organic Compounds: less than or equal to 3.0 lbs/hour measured ascarbon

B.01.e.Title I Condition: Limit taken to avoid classification asa major source under 40 CFR Section 52.21.

Cadmium compounds: less than or equal to 40 micrograms/DSCM corrected toseven percent oxygen.

B.01.f.Minn. R. 7011.1227



05300400 - 003

Facility Name:

Permit Number:

A-6

Lead B.01.g. hdr

Lead: less than or equal to 440 micrograms/DSCM corrected to seven percentoxygen.

B.01.g.(1).Title I Condition: 1987 determination of PSD BACT inaccordance with 40 CFR Section 52.21Minn. R. 7011.1227

Lead: less than or equal to 300 micrograms/DSCM corrected to seven percentoxygen, based on the arithmetic average of all results from performance testsconducted in the previous 60 months. This is a state only requirement and is notfederally enforceable.

B.01.g.(2).Minn. R. 7007.0800, subp. 2

Opacity: less than or equal to 10 percent opacity using 6-minute Average . B.01.h.Minn. R. 7011.1227

MEASUREMENT USING CEMS/COMS: Continuous monitors shall be used tomeasure the following pollutants whose emission limits are listed below: 1. Sulfur dioxide 2. Carbon monoxide 3. Opacity 4. Nitrogen oxides (NOx)The Permittee will:> Have monitors present [see Section E - Monitors]> Operate the continuous monitors as required [see Section E - Monitors]> Calculate emission concentrations, including all proper averaging times andcorrections [see Section E - Monitors]> Record and maintain data from the continuous monitors [see Section F -Recordkeeping]> Report data to the Air Quality Division as required [see Section G - Reporting]> Report periods of emission limit non-compliance and monitor downtime asrequired [see Section N - Abnormal Operation]

B.02.Minn. R. 7011.1225, subp. 1Minn. R. 7011.1265, subp. 2(B)Minn. R. 7017.0100, subp. 2

Sulfur dioxide B.02.a. hdr

Sulfur Dioxide: less than or equal to 29 parts per million using 24-hour GeometricAverage corrected to seven percent oxygen.

B.02.a.(1).Minn. R. 7011.1227Minn. R. 7007.0800, subp. 2Minn. R. 7011.1225, subp. 1Minn. R. 7011.1260, subp. 4(D)

Sulfur Dioxide: less than or equal to 11.4 lbs/hour using 365-day Rolling Average B.02.a.(2).Title I Condition: Limit taken to avoid classification asa major source under 40 Section CFR 51, Appendix Sand Minn. R. 7007.4000 through 7007.4030

Sulfur Dioxide: less than or equal to 36.0 parts per million using 24-hour BlockAverage corrected to seven percent oxygen, calculated using: (1) emissions from the individual waste combustor units; or (2) the average of the emissions from both waste combustor units.

B.02.a.(3).Title I Condition: 1987 determination to meet state andfederal ambient standards.40 CFR Section 50.4Minn. R. 7009.0080

Sulfur Dioxide: less than or equal to 78.0 parts per million using 3-hour Average(Block Average) corrected to seven percent oxygen, calculated using: (1) emissions from the individual waste combustor units; or (2) the average of the emissions from both waste combustor units.

B.02.a.(4).1987 determination to meet state ambient standards(1-hour and 3-hour) and federal ambient standards(3-hour).40 CFR Section 50.5Minn. R. 7009.0080

Carbon Monoxide: less than or equal to 100 parts per million using 4-hour BlockAverage corrected to seven percent oxygen.

B.02.b.Title I Condition: 1987 determination of PSD BACT inaccordance with 40 CFR 52.21Minn. R. 7011.1227Minn. R. 7011.1225, subp. 1

Nitrogen Oxides: less than or equal to 205 parts per million using 24-hour BlockAverage corrected to seven percent oxygen.

B.02.c.Title I Condition: 1987 determination of PSD BACT inaccordance with 40 CFR Section 52.21Minn. R. 7011.1228, Table AMinn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-7

MEASUREMENT USING CONTINUOUS MONITORS: Continuous monitors shallbe used to measure the following: 1. Steam flow rate 2. Fabric filter inlet temperature 3. Mercury additive feedrateThe Permittee will:> Measure steam flow in accordance with Minn. R. 7011.1225, subp. 4> Operate continuous monitors as required [see Section E - Monitors]> Establish limits for steam flow rate and fabric filter inlet temperature followingeach PCDD/PCDF performance test demonstrating compliance [see Section D -Testing]> Establish limits for mercury additive feedrate during each mercury performancetest demonstrating compliance [see Section D - Testing]> Record and maintain data from continuous monitors [see Section F -Recordkeeping]> Report data to the Air Quality Division as required [see Section G - Reporting]> Report periods of non-compliance and monitor downtime as required [seeSection N - Abnormal Operation]

B.03.Minn. R. 7011.1265, subp. 4Minn. R. 7007.0800, subp. 2Minn. R. 7011.1272, subp. 2

Temperature: less than or equal to 30 degrees F above the highest four-hourarithmetic mean temperature measured during four consecutive hours during themost recent PCDD/PCDF performance test that demonstrated compliance, asmeasured at the inlet to the fabric filter.

B.03.a.Minn. R. 7011.1240, subp. 2Minn. R. 7007.0800, subp. 2

Mercury additive feedrate: greater than or equal to 100 percent by weight , using aSix-Hour Block Average, established at the most recent performance test thatdemonstrated compliance for mercury.

B.03.b.Minn. R. 7011.1272, subp. 2Minn. R. 7007.0801, subp. 2(G)Minn. Stat. 116.85, subd. 1a(c)

Mercury additive feedrate while utilizing the "Y" system: greater than or equal to125 percent by weight, using a Six-Hour Block Average, of the combined rate forCombustor Unit No. 1 and Combustor Unit No. 2 established at the most recentperformance test that demonstrated compliance for mercury.

B.03.c.Minn. R. 7011.1272, subp. 2Minn. R. 7007.0801, subp. 2(G)

Production: less than or equal to 110 percent by weight as measured by steam flow(in pounds per hour) of the maximum demonstrated capacity, using 4-hour BlockAverage.

B.03.d.Minn. R. 7011.1240, subp. 5Minn. R. 7011.1201, subp. 32

VISIBLE EMISSIONS OF ASH: Do not emit into the atmosphere visible emissionsof combustion ash from an ash conveying system or buildings or enclosures of ashconveying systems, including conveyor transfer points, in excess of five percent ofthe observation period (i.e. 9 minutes per three-hour period). This limit does notapply to visible emissions discharged inside buildings or enclosures of ashconveying systems.

B.04.Minn. R. 7011.1225, subp. 1(B)

FUEL USAGE: B.05. hdr

Fuel Usage: less than or equal to 230.12 million cubic feet/year using 12-monthRolling Sum natural gas.

B.05.a.40 CFR Section 60.44b(d)

Fuel Usage: less than or equal to 365,000 tons/year of waste for the total facility.An amendment to increase this fuel usage must undergo public notice andcomment. This is a state only requirement and is not federally enforceable.

B.05.b.1984 Minn. Laws ch. 654, art. 2, sect. 29Minn. R. 7007.0850, subp. 2(D)

MERCURY CONTROL C. hdr

Determine and record the average additive mass feed rate, in pounds-per-hour,during the initial and at each subsequent performance test for mercury. Submit thecalculations with the results of the mercury or PCDD/PCDF performance test.The Permittee will:> Measure the mercury additive feedrate in pounds per hour during eachperformance test for mercury, and include the results in the Performance TestReport [see Section G - Reporting]

C.01.Minn. R. 7011.1272, subp. 1

Install, maintain, and operate at all times a system for monitoring the additive'smass feed rate.The feedrate must equal or exceed that determined during the most recent mercuryperformance test that demonstrated compliance with the emission limit.

The Permittee will:> Maintain and operate a monitor to measure mercury additive feedrate in poundsper hour [see Section E - Monitors]

C.02.Minn. R. 7011.1272, subp. 2

Maintain a record of the average additive mass feed rate for each hour ofoperation. If the operating parameter is not a direct measurement of the mass feedrate of the additive, record the calculations supporting the correlation between themass feed rate and the measured operating parameter. Maintain the record on sitein a form suitable for immediate inspection.The Permittee will:> Record the hourly feedrate of mercury additive in the Operating Record [seeSection F - Recordkeeping]> Have these records available for immediate inspection [see Section F -Recordkeeping]

C.03.Minn. R. 7011.1272, subp. 3(A)



05300400 - 003

Facility Name:

Permit Number:

A-8

During each calendar quarter, estimate the total additive used at the wastecombustor in pounds by two independent means as described below:(1) the weight of additive delivered to the plant; and(2) the average additive mass feed rate in pounds per hour for each hour ofoperation for each unit, measured pursuant to Minn. R. 7011.1272, subpart 2. Sumthe results of the mass feed rates for all waste combustor units at the plant for thetotal number of hours of operation during the calendar quarter.The Permittee will:> Each calendar quarter, record the total pounds of mercury additive delivered [seeSection F - Recordkeeping]> Record the hourly feedrate in the Operating Record [see Section F -Recordkeeping]> Each calendar quarter, record the quarterly cumulative weight (in pounds) ofmercury additive consumed, based on mercury additive feedrate and summed forall waste combustor units [see Section F - Recordkeeping]

C.04.Minn. R. 7011.1272, subp. 3(B)

Prior to the initial operation of mercury additive "Y" system, conduct a test to ensureeven distribution of the mercury additive through both lines of the "Y." Maintain testrecords on-site.

C.05.Minn. R. 7011.1272, subp. 2

For each separate feeder line of the mercury additive "Y" system, one pressuregage shall be installed. The two pressure gages shall be in operation whenever themercury additive "Y" system is in operation. These pressure gages shall provideinstantanous pressure readings (in psig).

C.06.Minn. R. 7011.1272, subp. 2

Within 120 days after installation of the mercury additive "Y" system, the Permitteeshall determine, through an acceptable testing methodology, an allowableinstantanous pressure difference. Pressure readings, within this difference, willensure that an allowable mercury additive feedrate for each separate line, asspecified in B.03.a., is being delivered for both lines. The Permittee shall submitthe testing analysis and proposed limits for MPCA approval and permitincorporation.

C.07.Minn. R. 7011.1272, subp. 2

While in operation, the pressure reading between the two lines of the mercuryadditive "Y" system, shall not exceed an instantanous difference of the MPCAapproved higher value, for each reading event.

C.08.Minn. R. 7011.1272, subp. 3

While the mercury additive "Y" system is in operation, the pressure reading fromeach line of the "Y" shall by monitored and recorded, twice per operational shift.

C.09.Minn. R. 7011.1272, subps. 2 & 3

As soon as practicable, the mercury additive system shall be restored. As soon aspracticable after both mercury additive systems are back in operation, the "Y"system shall be removed. With the removal of the "Y" system, each respectivemercury additive system shall feed each respective combustor unit.

C.10.Minn. R. 7011.1272, subp. 2

TESTING D. hdr

TIMETABLES: Conduct tests and measurements for the items listed below,according to the schedule indicated:The Permittee will:> Establish an Ash Testing Schedule in the Ash Plan, consistent with Minn. R.7035.2910 (as a state only requirement not federally enforceable)> Conduct studies and performance testing in accordance with the schedulesbelow and in accordance with the approved Test Plan required in TEST METHODSAND PROCEDURES> Report results to the Air Quality Division when required [see Section G -Reporting].

D.01.Minn. R. 7011.1270Minn. R. 7011.1265, subp. 5Minn. R. 7000.7000Minn. R. 7007.0801, subp. 2(D)Minn. R. 7035.2910, subp. 3

Waste Composition Study: due before end of each 60 months starting 06/20/97 .This is a state only requirement and is not federally enforceable.

D.01.a.Minn. R. 7011.1270, subp. (A)(6)

ASH SAMPLING: completed before end of each quarter following Permit Issuance,or as specified in the approved Ash Testing Schedule. The Permittee is allowed tocharacterize their combined ash stream on an annual basis under a variancegranted on 10/18/96. This is a state only requirement and is not federallyenforceable.

D.01.b.Minn. R. 7000.7000Minn. R. 7007.0801, subp. 2(D)Minn. R. 7035.2910, subp. 3Minn. Stat. 115A.97

MERCURY PERFORMANCE TESTING D.01.c. hdr

Performance Test: due before end of each year starting 06/10/1997. A year isdefined as 12 months. The tests shall be conducted at an interval not to exceed 12months between test dates. The test shall include mercury emissions, carbondioxide, oxygen, flue gas temperatures, flue gas flow rates, and the following airpollution control equipment operating parameters:1. Spray dryer -- pressure drop, slurry flow rate;2. Fabric filter -- pressure drop;3. Mercury additive -- pounds per hour mercury additive feedrate

D.01.c.(1).Title I Condition: to determine emissions for apollutant subject to a BACT limitMinn. R. 7011.1225, subp. 1Minn. R. 7011.1265, subp. 5Minn. R. 7011.1265, subp. 6Minn. R. 7011.1272, subp. 1Minn. R. 7011.1270, subp.(A)(5)

(see above) CONTINUEDMinn. Stat. 116.85, subd. 1a

TOTAL PARTICULATE MATTER, ETC. PERFORMANCE TESTING D.01.d. hdr



05300400 - 003

Facility Name:

Permit Number:

A-9

Performance Test: due before end of each year starting 06/10/98 for Totalparticulate matter, etc. A year is defined as 12 months. The tests shall beconducted at an interval not to exceed 12 months between test dates. The testmust include Total particulate matter, Front-half particulate matter, PCDD/PCDF,Hydrogen chloride, Opacity, VOC, Lead, Cadmium, flue gas temperatures, flue gasflow rates, maximum demonstrated capacity, and the following air pollution controlequipment operating parameters:

D.01.d.(1).Title I Condition for Lead: to determine emissions for apollutant subject to a BACT limitTitle I Condition for Total particulate matter and VOC:to determine emissions for pollutants subject to Title Ilimits

1. Spray dryer -- pressure drop, slurry flow rate; 2. Fabric filter -- pressure drop, fabric filter inlet temperature (four-hour blockaverage)

CONTINUEDD.01.d.(1).Minn. R. 7011.1265, subp. 5Minn. R. 7011.1265, subp. 6Minn. R. 7011.1265, subp. 7Minn. R. 7011.1265, subp. 8Minn. R. 7011.1270, subp. (A)(2)

Performance Test Continued: If all PCDD/PCDF performance tests for all units for atwo-year period indicate that PCDD/PCDF emissions are less than or equal to 15ng/dscm corrected to seven percent 02 from each unit, then the Permittee maychoose to test one unit for PCDD/PCDF once annually, but not more than 12months following the previous performance test. Thereafter, the Permittee maycontinue to test a different unit for PCDD/PCDF each year, in sequence. If anyannual performance test demonstrates a PCDD/PCDF concentration greater than15 ng/dscm corrected to seven percent O2, performance tests thereafter shall beconducted annually on all units until all annual performance tests for all units for atwo-year period indicate a PCDD/PCDF emission concentration less than or equalto 15 ng/dscm.

The Permittee will specify what the PCDD/PCDF performance testing schedule iseach time a pretest notification is given under the conditions of part 7017.2030.

D.01.d.(2).Minn. R. 7011.1270

Fugitive Ash Testing: due before 03/31/98 D.01.e.Minn. R. 7007.0800, subp. 2

TEST METHODS AND PROCEDURES:Conduct tests using the test methods and procedures listed below, in accordancewith the respective citations. For air emissions not listed below, conduct tests inaccordance with Minn. R. ch. 7017.The Permittee will:> Submit Test Plan containing test methods as described above. [see Section G -Reporting]> Conduct tests for each item listed below, in accordance with the Test Plan.> Report results in the manner specified in the test method and Test Plan [seeSection G - Reporting].

D.02.Minn. R. 7011.1265, subp. 1Minn. R. 7011.1265, subp. 2Minn. R. 7011.1265, subp. 3Minn. R. 7011.1265, subp. 7Minn. R. 7011.1265, subp. 8Minn. R. 7011.1265, subp. 10Minn. R. 7035.2910Minn. R. 7011.1272, subp. 1

Front-half particulate matter, as specified in Minn. R. 7011.1265, subp. 2(A) andMinn. R. 7011.1265, subp. 2(A)(1).

D.02.a.Minn. R. 7011.1265, subp. 2(A)Minn. R. 7011.1265, subp. 2(A)(1)40 CFR Section 60.54

Total particulate matter, as specified in Minn. R. 7011.1265, subp. 2(A) and Minn.R. 7011.1265, subp. 2(A)(2).

D.02.b.Minn. R. 7011.1265, subp. 2(A)Minn. R. 7011.1265, subp. 2(A)(2)

Total PCDD/PCDF, as specified in Minn. R. 7011.1265, subp. 3(B). D.02.c.Minn. R. 7011.1265, subp. 3(B)

Hydrogen chloride, as specified in Minn. R. 7011.1265, subp. 3(A). D.02.d.Minn. R. 7011.1265, subp. 3(A)

Opacity, as specified in Minn. R. 7011.1265, subp. 2(B). D.02.e.Minn. R. 7011.1265, subp. 2(B)

Mercury, as specified in Minn. R. 7011.1265, subp. 3(C). D.02.f.Minn. R. 7011.1265, subp. 3(C)

Mercury (Short-term limit), as specified in Minn. R. 7011.1265, subp. 3(C) andMinn. R. 7011.1265, subp. 3(D)(1).

D.02.f.(1).Minn. R. 7011.1265, subp. 3(D)(1)

Mercury (Long-term limit), as specified in Minn. R. 7011.1265, subp. 3(C) and Minn.R. 7011.1265, subp. 3(D)(2).This is a state only requirement and is not federally enforceable.

D.02.f.(2).Minn. R. 7011.1265, subp. 3(D)(2)

Lead, as specified in Minn. R. 7011.1265, subp. 3(C). D.02.g.Minn. R. 7011.1265, subp. 3(C)

Cadmium, as specified in Minn. R. 7011.1265, subp. 3(C). D.02.h.Minn. R. 7011.1265, subp. 3(C)

Volatile Organic Compounds, measured as Total Volatile Organic Compounds D.02.i.Minn. R. 7007.0800, subp. 2

Ash, as specified in Minn. R. 7035.2910. This is a state only requirement and is notfederally enforceable.

D.02.j.Minn. R. 7035.2910



05300400 - 003

Facility Name:

Permit Number:

A-10

Waste composition study, as specified in Minn. R. 7007.0501, subp. 2(A). This is astate only requirement and is not federally enforceable.

D.02.k.Minn. R. 7011.1265, subp. 10Minn. R. 7007.0501, subp. 2(A)Minn. R. 7007.0801, subp. 2(C)

Maximum demonstrated capacity (see Section O - Definitions), as specified inMinn. R. 7011.1265, subp. 7.

D.02.l.Minn. R. 7011.1265, subp. 7Minn. R. 7011.1201, subp. 32Minn. R. 7011.1265, subp. 4

Fabric filter inlet temperature, as specified in Minn. R. 7011.1265, subp. 8. D.02.m.Minn. R. 7011.1265, subp. 8

Mercury additive feedrate in pounds per hour, as specified in Minn. R. 7011.1272,subp. 1.

D.02.n.Minn. R. 7011.1272, subp. 1

Fugitive Ash, Code of Federal Regulations, title 40, pt. 60, Appendix A, Method 22,as amended, shall be used. The minimum observation time shall be a series ofthree one-hour observations. The observation period shall include times when thefacility is transferring ash from the waste combustor unit to the area where ash isstored or loaded into containers or trucks. The average duration of visibleemissions per hour shall be calculated from the three one-hour observations. Theaverage shall be used to determine compliance with the emission limit.

D.02.o.Minn. R. 7011.1265, subp. 2(D)

PRE-TEST MEETINGS FOR PERFORMANCE TESTING D.03. hdr

Performance Test Pre-test Meeting: due 7 days before end of each year starting06/10/1997 (7 days before each Mercury Performance Test). This is a state onlyrequirement and is not federally enforceable.

D.03.a.Minn. R. 7017.2030, subp. 4

Performance Test Pre-test Meeting: due 7 days before end of each year starting06/10/1998 (7 days before each Performance Test measuring: Front-halfparticulate matter, Total particulate matter, Total PCDD/PCDF, Hydrogen chloride,Lead, Cadmium, VOC, and Opacity). This is a state only requirement and is notfederally enforceable.

D.03.b.Minn. R. 7017.2030, subp. 4

MONITORS E. hdr

REQUIRED MONITORS: When burning solid waste, operate monitoring systemsthat continuously read and record the outputs listed below.The Permittee will:> Have the monitors in place at the proper locations. Abide by 40 CFR pt. 60,Appendix B, where applicable> Operate the monitors in accordance with this permit.

E.01.Minn. R. 7011.1260, subp. 1Minn. R. 7011.1260, subp. 2Minn. R. 7011.1260, subp. 3

Carbon monoxide, within the stack E.01.a.Title I Condition: to monitor emissions for a pollutantsubject to a BACT limitMinn. R. 7011.1260, subp. 3(A)(1)Minn. Stat. 116.85, subd. 1

Steam flow measured at the super heater outlet. E.01.b.Minn. R. 7011.1260, subp. 3(A)(2)

Flue gas opacity, within the stack E.01.c.Minn. R. 7011.1260, subp. 3(A)(3)

Carbon dioxide, within the stack E.01.d.Minn. R. 7011.1260, subp. 3(A)(4)

Sulfur dioxide, within the stack E.01.e.Title I Condition: to monitor emissions for a pollutantsubject to a Title I limitMinn. R. 7011.1260, subp. 3(C)

Nitrogen oxides, within the stack E.01.f.Title I Condition: 1987 determination of PSD BACT inaccordance with 40 CFR Section 52.21Minn. R. 7011.1260, subp. 3(B)

Fabric Filter Inlet Temperature, at the flue gas inlet of the fabric filter E.01.g.Minn. R. 7011.1260, subp. 2

Mercury Additive Feedrate, in the mercury additive system E.01.h.Minn. R. 7011.1272, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-11

UPTIME: While the waste combustor is operating and combusting solid waste,operate the following monitors so as to measure and record data for at least 75percent of the hours per day for 90 percent of the days of the calendar quarter:1. Carbon monoxide2. Steam flow3. Flue gas opacity4. Carbon dioxide5. Sulfur dioxide6. Nitrogen oxides7. Fabric filter inlet temperature8. Mercury additive feedrateThe Permittee will:> Operate the monitors in accordance with the time specified [if uptime is notobtained, see Section N - Abnormal Operation]> Record and report the uptime information [see Section F - Recordkeeping,Section G - Reporting].

E.02.Minn. R. 7011.1260, subp. 5(B)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(e)

AVERAGING PERIODS: Unless otherwise indicated below, apply Minn. R.7017.1002 through 7017.1220 to continuous monitoring data collection, reduction,and averaging periods. All valid monitoring data shall be used to calculateemission concentrations, emission reductions, and operating parameters, even ifthe conditions described in UPTIME are not met.The Permittee will:> Record and report all operating parameters according to the averaging timesindicated [see Section F - Recordkeeping, Section G - Reporting].

E.03.Minn. R. 7011.1260, subp. 4Minn. R. 7011.1260, subp. 5(C)Minn. R. 7007.0800, subp. 2

Temperatures: Four-hour block averages (arithmetic), calculated from fourone-hour arithmetic averages.

E.03.a.Minn. R. 7011.1260, subp. 4(A)Minn. R. 7011.1260, subp. 5(C)

Steam flow: Four-hour block averages, calculated from one-hour arithmeticaverages.

E.03.b.Minn. R. 7011.1260, subp. 4(B)Minn. R. 7007.0800, subp. 2

Carbon monoxide: Four-hour block averages, calculated from one-hour arithmeticaverage concentrations.

E.03.c.Minn. R. 7011.1260, subp. 4(C)

Sulfur Dioxide E.03.d. hdr

The geometric average of the one-hour arithmetic average sulfur dioxide emissionconcentrations during each 24-hour daily period measured from midnight tomidnight, consistent with 40 CFR pt. 60, Appendix A, Method 19. At least four datapoints equally spaced in time shall be used to calculate each one-hour arithmeticaverage. During periods of calibration, quality assurance audits, and routinemaintenance, only two data points during the hour, at least 15 minutes apart, arerequired to calculate an hourly average. Each one-hour average shall be correctedto seven percent oxygen on an hourly basis using the one-hour arithmetic averageof the oxygen or carbon dioxide continuous emissions monitoring system.

E.03.d.(1).Minn. R. 7011.1260, subp. 4(D)

The 3-hour arithmetic averages of the one-hour arithmetic average sulfur dioxideemission concentrations during each 3-hour daily period measured from midnight to3 AM, 3 AM to 6 AM, etc.

E.03.d.(2).Minn. R. 7007.0800, subp. 2

The 24-hour arithmetic average of the one-hour arithmetic average sulfur dioxideemission concentrations during each 24-hour daily period measured from midnightto midnight.

E.03.d.(3).Minn. R. 7007.0800, subp. 2

The 365-day arithmetic average of the previous 24-hour arithmetic average sulfurdioxide emission concentrations (365 Day Rolling Average).

E.03.d.(4).Minn. R. 7007.0800, subp. 2

Nitrogen oxides: The arithmetic average of the one-hour arithmetic averageemission rates during each 24-hour daily period measured from midnight tomidnight. Use 40 CFR pt. 60, Appendix A, Method 19, section 4.1, as amended, todetermine the daily arithmetic average. At least four data points equally spaced intime shall be used to calculate each one-hour arithmetic average. During periodsof calibration, quality assurance audits, and routine maintenance, only two datapoints during the hour, at least 15 minutes apart, are required to calculate an hourlyaverage. Each one-hour average shall be corrected to seven percent oxygen onan hourly basis using the one-hour arithmetic average of the oxygen or carbondioxide continuous emissions monitoring system.

E.03.e.Minn. R. 7011.1260, subp. 4(E)

Opacity: Six-minute averages. E.03.f.Minn. R. 7011.1260, subp. 4(F)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(h)

Mercury additive feedrate: Six-hour block averages. E.03.g.Minn. R. 7011.1272, subp. 2

Carbon dioxide: One-hour averages. E.03.h.Minn. R. 7011.1260, subp. 4(G)

CALCULATION OF AVERAGING PERIODS: All valid monitoring data shall beused to calculate emission rates, emission reductions, and operating parameters,even if the conditions described in UPTIME are not met.

E.04.Minn. R. 7011.1260, subp. 5(C)



05300400 - 003

Facility Name:

Permit Number:

A-12

Six-Minute Averages For Opacity: COMS must complete a minimum of one cycleof sampling and analyzing in each successive 10-second period and one cycle ofdata recording in each averaging period of the emission limit. The six-minuteaverage is calculated using 36 or more data points equally spaced over asix-minute period. There are ten individual six-minute averaging periods in eachhour. The first six-minute period begins at the top of the clock-hour and ends at thetop of minute six of the clock-hour. The second six-minute period immediatelyfollows the first, and the pattern continues through the last of the ten six-minuteperiods in a clock-hour.The Permittee will:> Calculate six-minute averages by arithmetically averaging all accurate and validdata recorded at 36 or more data points equally spaced over a six-minute period.

E.04.a.Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 4(F)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(e)(1)40 CFR Section 60.13(h)

> If a six-minute average could not be calculated by the above method, calculate asix-minute average using whatever data is available over that six-minute interval,and record that six-minute interval as monitor downtime [see Section F -Recordkeeping, Section G - Reporting, Section N - Abnormal Operation].

CONTINUEDE.04.a.Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 4(F)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(e)(1)40 CFR Section 60.13(h)

One-Hour Averages: Monitor data shall be converted to hourly averages from aminimum of four equally spaced data points in each hour. During periods ofcalibration, quality assurance audits and routine maintenance, only two data pointsduring the hour, at least 15-minutes apart are required to calculate an hourlyaverage. An hourly average is the arithmetic mean of all the individual data pointscollected by a monitor in a hour. Each hourly average begins at the top of the hourand ends at the top of the succeeding hour. There are no partial hours of monitoruptime or downtime; only whole hours are used in determining data availability.The Permittee will:> Calculate one-hour averages for mercury additive feedrate, temperature, andsteam flow.> Calculate one-hour average concentrations for: carbon monoxide; sulfur dioxide;nitrogen oxides; and carbon dioxide.

E.04.b.Minn. R. 7011.1260, subp. 4Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 5(C)Minn. R. 7011.1260, subp. 5(H)Minn. R. 7011.1272, subp. 3(A)40 CFR 60.13(e)(2)40 CFR 60.13(h)

> One-hour averages, for temperature, may also be calculated using the threesteps described below. 1. Calculate 6-minute averages by arithmetically averaging all accurate and validdata recorded at 1-minute intervals over 6 consecutive minutes. If no accurate andvalid data points were obtained during those 6 consecutive minutes, no 6-minuteaverage shall be calculated. 2. Determine each one-hour average by calculating the arithmetic average from all6-minute averages within that hour if, during that hour, one of the followingconditions applies: a. At least eight 6-minute averages have been obtained. b. Calibration, quality assurance audits, or routine maintenance occurs and atleast three 6-minute averages have been obtained.

CONTINUEDE.04.b.Minn. R. 7011.1260, subp. 4Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 5(C)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(e)(2)40 CFR Section 60.13(h)

c. At least one 6-minute average is obtained within each 15-minute interval withinthat hour. 3. If a one-hour average could not be calculated by any of the above methods,record that one-hour interval as monitor downtime [see Section F - Recordkeeping,Section G - Reporting, Section N - Abnormal Operation].> For carbon monoxide, sulfur dioxide, and nitrogen oxides, each one-hour averageshall be corrected to seven percent oxygen on an hourly basis using the one-hourarithmetic average of the carbon dioxide continuous emissions monitoring system.

CONTINUEDE.04.b.Minn. R. 7011.1260, subp. 4Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 5(C)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(e)(2)40 CFR Section 60.13(h)

SPAN VALUES: Span values for continuous monitors shall be as described below.The Permittee will:> Establish the span value as indicated for each monitor.

E.05.Minn. R. 7011.1260, subp. 5(F)

The span value of the sulfur dioxide continuous monitors downstream of the outletof the dry scrubber is 50 percent of the maximum estimated hourly potential sulfurdioxide emissions of the waste combustor unit.

E.05.a.Minn. R. 7011.1260, subp. 5(F)(1)

The span value of the nitrogen oxides continuous monitors shall be 125 percent ofthe maximum estimated hourly potential nitrogen oxide emissions of the wastecombustor unit.

E.05.b.Minn. R. 7011.1260, subp. 5(F)(2)

The span value of the carbon dioxide monitor shall be 25 percent carbon dioxide. E.05.c.Minn. R. 7011.1260, subp. 5(F)(3)

The span value of the carbon monoxide shall be 125 percent of the maximumestimated hourly potential carbon monoxide emissions of the waste combustor unit.

E.05.d.Minn. R. 7011.1260, subp. 5(F)(4)



05300400 - 003

Facility Name:

Permit Number:

A-13

Calculate steam flow in accordance with the method contained in ASME PowerTest Codes: Test Codes for Steam Generating Units, PTC 4.1 (1972), section 4.Follow the recommendations of Instruments and Apparatus: Measurement ofQuantity of Materials, Interim Supplement 19.5 (1971), chapter 4, for design,construction, installation, calibration, and use of nozzles and orifices, except thatmeasurement devices such as flow nozzles and orifices are not required to berecalibrated after they are installed.The Permittee will:> Calculate steam flow as indicated> Have steam flow calculation method readily available for inspection> Permanently maintain the most recent records of design, construction,installation, calibration, and use of nozzles and orifices [see Section F -Recordkeeping].

E.06.a.Minn. R. 7011.1265, subp. 4

Install, calibrate, maintain, and operate at all times temperature monitors at the inletof each particulate matter control device.The Permittee will:> Operate, calibrate, and maintain temperature monitors at the inlet to the fabricfilter in accordance with manufacturer procedures.

E.06.b.Minn. R. 7011.1260, subp. 2Minn. R. 7007.0800, subp. 2

Follow procedures under 40 CFR Section 60.13 for installation, evaluation, andoperation of monitoring systems.The Permittee will:> As specified here and elsewhere in this permit, follow installation, evaluation, andoperation procedures under 40 CFR Section 60.13 for the monitors listed below: 1. carbon dioxide 2. opacity 3. sulfur dioxide 4. nitrogen oxides

E.06.c.Minn. R. 7011.1260, subp. 5(H)

The carbon dioxide monitor shall conform to Performance Specification 3 of 40CFR pt. 60, Appendix B, except that section 2.3 shall not apply.The Permittee will:> Conform with the above condition.

E.06.d.Minn. R. 7007.1260, subp. 5(I)

Install, maintain, and operate at all times a system for monitoring the mercuryadditive's mass feed rate, as determined by the requirements of Minn. R.7011.1272, subpart 1.The Permittee will:> Operate and maintain a gravimetric feeder to add mercury additive to the fluegases> Operate and maintain a system to measure mercury additive feedrate in poundsper hour.> During periods of malfunction of one of the mercury additive systems, a "Y"system will be utilized for the addition of the mercury additive to flue gases fromboth combustor units. The "Y" system will only be used until the malfunction iscorrected.

E.06.e.Minn. R. 7011.1272, subp. 2

PERIODIC MONITOR PERFORMANCE CHECKS: Comply with the requirementsof pt. 7017.1035, except as indicated below.The Permittee will:> Conduct the checks and tests as indicated> Record the results in the Operating Record [see Section F - Recordkeeping]> Submit summaries, reports, etc., as required by the Quarterly Report [see SectionG - Reporting].

E.07.Minn. R. 7017.1035

Daily E.07.a. hdr

COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recordedat zero (low-level) and upscale (high-level) opacity at least once daily. The COMSmust be adjusted whenever the calibration drift (CD) exceeds twice thespecification of PS-1 of 40 CFR pt. 60, Appendix B.

E.07.a.(1).Minn. R. 7011.1260, subp. 5(E)Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(d)

CEMS Daily Calibration Drift (CD) Test: CEMS (sulfur dioxide, carbon monoxide,nitrogen oxides, carbon dioxide) shall be checked at least once daily and CDquantified and recorded at zero (low-level) and upscale (high-level) gasconcentrations. The CEMS shall be adjusted whenever the CD exceeds twice thespecification of 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall beused to determine out-of-control periods for CEMS.

E.07.a.(2).Minn. R. 7007.0800, subp. 2Minn. R. 7011.1260, subp. 5(G)Minn. R. 7011.1260, subp. 5(E)

Quarterly E.07.b. hdr

Perform quarterly accuracy determinations in accordance with procedures in Codeof Federal Regulations, Title 40, pt. 60, Appendix F, as amended, for the sulfurdioxide, nitrogen oxides, carbon dioxide, and carbon monoxide CEMS.

E.07.b.(1).Minn. R. 7011.1260, subp. 5(G)Minn. R. 7007.0800, subp. 2

Cylinder Gas Audit: due before end of each calendar quarter following CEMCertification Test but in no more than three calendar quarters per calendar year, forthe sulfur dioxide, nitrogen oxides, carbon dioxide, and carbon monoxide CEMS.The RATA shall be conducted during the calendar quarter in which a CGA is notperformed.

E.07.b.(2).Minn. R. 7011.1260, subp. 5(G)Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-14

Semi-annually E.07.c. hdr

COMS Calibration Error Audit: due before end of each calendar half-year followingCOMS Certification Test . Conduct audits at least 3 months apart but no greaterthan 8 months apart.

E.07.c.(1).Minn. R. 7011.1260, subp. 5(H)40 CFR Section 60.13(d)

Annually E.07.d. hdr

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar yearfollowing CEM Certification Test . Follow the procedure in 40 CFR pt. 60, AppendixF, for sulfur dioxide, nitrogen oxides, carbon dioxide, and carbon monoxide. TheRATA shall be conducted during the calendar quarter in which a CGA is notperformed.

E.07.d.(1).Minn. R. 7011.1260, subp. 5(G)

All signal conversion elements associated with steam flow measurements must becalibrated according to the manufacturer's instructions before each PCDD/PCDFtest, and at least once per year.

E.07.d.(2).Minn. R. 7007.0800, subp. 2

DILUENT GASES: Establish a relationship between carbon dioxide and oxygen, inaccordance with 40 CFR Appendix A, Method 3B, 3.4.1.1. Use this relationship totransform carbon dioxide CEM concentrations to equivalent oxygen concentrationsto measure emissions as corrected to seven percent oxygen.The Permittee will:> Annually establish the relationship between carbon dioxide and oxygenconsistent with the above requirement, using all available carbon dioxide andoxygen data acquired during each performance test conducted during the previoustwelve months.> Record and report all CEM emissions data corrected to an equivalent sevenpercent oxygen basis, using this relationship [see Section F - Recordkeeping,Section G - Reporting].

E.08.Minn. R. 7011.1225, subp. 1Minn. R. 7011.1265, subp. 4b

RECORDKEEPING F. hdr

ARCHIVING: Retain records as indicated below.The Permittee will:> Store records at the facility> Make the records available upon request> Make the mercury additive feedrate records available immediately upon request.

F.01.Minn. R. 7011.1285, subp. 1Minn. R. 7011.1260, subp. 6Minn. R. 7011.1265, subp. 4Minn. R. 7007.0800, subp. 2Minn. R. 7011.1272, subp. 3(A)

Maintain a permanent record of continuously measured parameters. F.01.a.Minn. R. 7011.1260, subp. 6

Regarding steam flow monitoring, permanently retain current records of design,construction, installation, calibration, signal conversion, and use of nozzles andorifices.

F.01.b.Minn. R. 7011.1265, subp. 4Minn. R. 7007.0800, subp. 2

Retain all other records for a minimum of five years. F.01.c.Minn. R. 7011.1285, subp. 1

Maintain on site all final air emission permit submittals made to MPCA as papercopies for five years.

F.01.d.Minn. R. 7007.0800, subp. 2

CONTINUOUS MONITOR DATA: Maintain a permanent record of the calendardate and the corresponding continuously measured parameters described below.The Permittee will:> Maintain records of the parameters described below, consistent with theaveraging times given.> Record the corresponding calendar date.

F.02.Minn. R. 7011.1260, subp. 6Minn. R. 7011.1260, subp. 6(A)

CONTINUOUS MONITOR AVERAGED DATA: 1. all 24-hour daily geometric average sulfur dioxide emissions; 2. all 3-hour block average sulfur dioxide emissions; 3. all 24-hour daily arithmetic average sulfur dioxide emissions; 4. all 365-day rolling average sulfur dioxide emissions; 5. all 24-hour daily arithmetic average nitrogen oxides emissions; 6. all four-hour block average carbon monoxide emission rates 7. all four-hour block arithmetic average steam flow levels 8. all four-hour block arithmetic average fabric filter inlet temperatures 9. all six-minute opacity readings 10. all six-hour block arithmetic average mercury additive feedratesThe Permittee will:> Record mercury additive feedrates in the Operating Record [see the OperatingRecord portion of Section F - Recordkeeping]

F.02.a.Minn. R. 7011.1260, subp. 6(B)Minn. R. 7011.1260, subp. 6(C)Minn. R. 7011.1260, subp. 4Minn. R. 7011.1272, subp. 2

> Record the other above information in the Operating Record, calculated inaccordance with Minn. R. 7011.1260, subp. 4 [see the Operating Record portion ofSection F - Recordkeeping].

CONTINUEDF.02.a.Minn. R. 7011.1260, subp. 6(B)Minn. R. 7011.1260, subp. 6(C)Minn. R. 7011.1260, subp. 4Minn. R. 7011.1272, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-15

CONTINUOUS MONITOR ONE-HOUR DATA: Maintain a paper record of theinformation listed below1. one-hour averages of sulfur dioxide emissions at the outlet of the acid gascontrol device2. one-hour average carbon monoxide emissions3. one-hour averages of nitrogen oxide emissions4. one-hour averages of steam flow5. one-hour averages of fabric filter inlet temperatures6. one-hour mercury additive feedratesThe Permittee will:> Record, in a manner suitable for immediate inspection, one-hour mercury additivefeedrates in the Operating Record [see the Operating Record portion of Section F -Recordkeeping]> Record all other one-hour averages in the Operating Record, calculated asdescribed in Monitors

F.02.b.Minn. R. 7011.1260, subp. 6(B)Minn. R. 7011.1260, subp. 4Minn. R. 7011.1272, subp. 3(A)

CONTINUOUS MONITOR ELECTRONIC DATA: Maintain a computer record ofthe corresponding information listed below: 1. all one-hour averages of: (a) sulfur dioxide emission rates at the outlet of the acid gas controldevice (b) carbon monoxide emission rates (c) nitrogen oxide emission rates (d) steam flow (e) particulate matter control device temperatures 2. all six-minute opacity readings;The Permittee will:> Maintain electronic records of the above data that can be readily printed uponrequest, calculated in accordance with Minn. R. 7011.1260, subp. 4.

F.02.c.Minn. R. 7011.1260, subp. 6(B)Minn. R. 7011.1260, subp. 4

TRAINING RECORDS: Maintain a record of the identity of all personnel who havereceived training and the number of training hours. Indicate who has completedinitial and subsequent review of the Operating Manual. Provide to thecommissioner on demand.The Permittee will:> Record the above information in the Operating Record [see the OperatingRecord portion of Section F - Recordkeeping]> Create a separate page for each person who receives training> Record the title of the training, the location, the dates, and the contact hours> Identify all training received that was required by the Operating Manual.

F.03.Minn. R. 7011.1275, subp. 4Minn. R. 7011.1285, subp. 2(I)

OPERATING RECORD: The following items, with corresponding calendar dates,must be recorded, each calendar day for the previous day, as an operating record,and compiled 15 days after the end of each calendar month:The Permittee will:> Maintain the Operating Record that includes the items listed below> Include calendar dates with all entries> Update the items within the timeframes indicated below

This is a state only requirement and is not federally enforceable.

F.04.Minn. R. 7011.1285, subp. 1Minn. R. 7011.1285, subp. 2Minn. R. 7011.1285, subp. 2(A)Minn. R. 7011.1215, subp. 4Minn. R. 7011.1240, subp. 1Minn. R. 7011.1272, subp. 3(A)Minn. R. 7011.1272, subp. 3(B)

1. the hours of operation, including times of start-up, shutdown, and the cessationof waste combustion;

F.04.a.Minn. R. 7011.1285, subp. 2(B)40 CFR Section 60.5340 CFR 60.7(b)

2. the weight of solid waste combusted (based on steam flow, scale tickets, and/orpit inventory);

F.04.b.Minn. R. 7011.1285, subp. 2(C)40 CFR Section 60.53

3. as a state only requirement not federally enforceable, the weight of solid wasterequiring disposal at a solid waste land disposal facility, including separatednoncombustibles, excess solid waste, and ash;

F.04.c.Minn. R. 7011.1285, subp. 2(D)

4. as a state only requirement not federally enforceable, the amount anddescription of industrial solid waste received each day, the generator's name, andthe method of handling;

F.04.d.Minn. R. 7011.1285, subp. 2(E)

5. the measurements and determination of emissions averages in accordancewith the CONTINUOUS MONITOR DATA portion of Recordkeeping;

F.04.e.Minn. R. 7011.1285, subp. 2(F)

6. dates and results of performance tests conducted on the waste combustor unit,including the average mercury additive feedrate (pounds per hour) during eachperformance tests for mercury. The results shall be submitted to the MPCA forformal review.

F.04.f.Minn. R. 7011.1285, subp. 2(G)Minn. R. 7011.1272, subp. 1

7. the names of persons who have completed initial review or subsequent annualreview of the operating manual, in accordance with TRAINING RECORDS of thispermit (This requirement can be updated annually);

F.04.g.Minn. R. 7011.1285, subp. 2(I)



05300400 - 003

Facility Name:

Permit Number:

A-16

8. the reasons for exceeding any of the average emission rates, opacity limit,percent reductions, or operating parameters specified under CONTINUOUSMONITOR AVERAGED DATA of this permit, and a description of corrective actionstaken;

F.04.h.Minn. R. 7011.1285, subp. 2(J)

9. reasons for not obtaining the minimum number of hours of sulfur dioxide ornitrogen oxides emissions or operational data (carbon monoxide emissions, steamflow, particulate matter control device temperature) and a description of correctiveactions taken.

F.04.i.Minn. R. 7011.1285, subp. 2(K)

10. as a state only requirement not federally enforceable, certified operator shiftchanges;

F.04.j.Minn. R. 7011.1240, subp. 1

11. as a state only requirement not federally enforceable, copies of certificates ofcertified operators, including certificates that expired within the previous five years(updated within one week of each occurrence);

F.04.k. Minn. R. 7011.1240, subp. 1

12. time periods, reasons, and corrective actions regarding any othermalfunctions;

F.04.l.Minn. R. 7011.1215, subp. 4Minn. R. 7007.0800, subp. 240 CFR 60.7(b)

13. as a state only requirement not federally enforceable, records of all periodicchecks of monitor performance

F.04.m.Minn. R. 7007.0800, subp. 2

14. for mercury additive, reasons for not maintaining additive system operatingparameters and descriptions of corrective actions taken;

F.04.n.Minn. R. 7011.1285, subp. 2(M)

15. for mercury additive, reasons for not maintaining mercury additive flow anddescriptions of corrective actions taken;

F.04.o.Minn. R. 7011.1285, subp. 2(N)

16. the date of the calibration of all signal conversions elements associated withsteam flow monitoring;

F.04.p.Minn. R. 7011.1285, subp. 2(L)

OPERATING RECORD: The following items, with corresponding calendar dates,must be calculated and recorded, 15 days after the end of each calendar month:The Permittee will:> Maintain the Operating Record that includes the items listed below> Include calendar dates with all entries> Update the items within the timeframes indicated below

F.05Limit taken to avoid classfication as a major sourceunder 40 CFR 51, Appendix S and Minn. R. 7007.4000through 7007.4030; 40 CFR Section 60.44b(d)

1. the 12-month Rolling Sum of Total Particulate Matter, in tons per year for theprevious month (including both EU 001 and 002)

F.05.a.Title I Condition: Limit taken to avoid classification asa major source under 40 CFR 51, Appendix S andMinn. R. 7007.4000 through 7007.4030

2. the 12-month Rolling Sum of natural gas combusted, in cubic feet/year for theprevious month;

F.05.b.40 CFR Section 60.44b(d)

OPERATING RECORD: The following items, with corresponding calendar dates,must be calculated and recorded, 30 days after the end of each calendar quarter:The Permittee will:> Maintain the Operating Record that includes the items listed below> Include calendar dates with all entries> Update the items within the timeframes indicated below

F.06Limit taken to avoid classfication as a major sourceunder 40 CFR 51, Appendix S and Minn. R. 7007.4000through 7007.4030; 40 CFR Section 60.44b(d)

1. Recordkeeping of mercury additive delivered. Record the weight (in pounds ortons) of mercury additive delivered to the facility.

F.06.a.Minn. R. 7011.1272, subp. 3(B)(1)

2. Recordkeeping of the quarterly cumulative weight (in pounds) of the mercuryadditive consumed, bsed on the mercury additive feedrate and summed for allwaste combustor units.

F.06.b.Minn. R. 7011.1272, subp. 3(B)(2)

3. Hourly recordkeeping of mercury additive feedrate. Record the hourly mercuryadditive consumed, based on the mercury additive feedrate (in pounds per hour),for each waste combustor in operation. The record shall be maintained on-site in aform suitable for immediate inspection.

F.06.c.Minn. R. 7011.1272, subp. 3(A)

REPORTING G. hdr

Waste Combustor Quarterly Report: due 30 days after end of each calendar quarterfollowing Permit Issuance. The report shall contain a compliance certification andthe corresponding items A through J listed below.The Permittee will:> Submit the quarterly reports on or before January 30, April 30, July 30, andOctober 30 of each year. [see also Table B: Submittals]> Include all requirements listed in items A through J below

G.01.Minn. R. 7011.1285, subp. 1Minn. R. 7011.1285, subp. 3

A. the calendar datesThe Permittee will:> Include the calendar date with the corresponding items B through J below

G.01.a.Minn. R. 7011.1285, subp. 3(A)



05300400 - 003

Facility Name:

Permit Number:

A-17

B. a graphic representation of the emissions and parameters listed below. Thegraphs shall be prepared as follows: 1. the graph shall represent one operating parameter or pollutant 2. the applicable limit of the parameter or pollutant shall be indicated on the graph 3. data shall be expressed in the same units as the applicable operating parameteror emission limitThe Permittee will:> Include graphs of the emissions and parameters, as instructed above.


G.01.b.Minn. R. 7011.1285, subp. 3(B)Minn. R. 7007.0800, subp. 2

all 24-hour daily geometric average sulfur dioxide emission rates as required byMinn. R. 7011.1260, subp. 6(C)

G.01.b.(1).Minn. R. 7011.1285, subp. 3(B)

all 24-hour daily arithmetic average nitrogen oxides emission rates as required byMinn. R. 7011.1260, subp. 6(C)

G.01.b.(2).Minn. R. 7011.1285, subp. 3(B)

all four-hour block average carbon monoxide emission rates as required by Minn.R. 7011.1260, subp. 6(C)

G.01.b.(3).Minn. R. 7011.1285, subp. 3(B)

the waste combustor four-hour block arithmetic average steam flow levels asrequired by Minn. R. 7011.1260, subp. 6(C)

G.01.b.(4).Minn. R. 7011.1285, subp. 3(B)

the four-hour block arithmetic average fabric filter inlet temperatures as required byMinn. R. 7011.1260, subp. 6(C)

G.01.b.(5).Minn. R. 7011.1285, subp. 3(B)

the daily maximum opacity readings as required by Minn. R. 7011.1260, subp.6(B)(1)

G.01.b.(6).Minn. R. 7011.1285, subp. 3(B)

C. the identification of operating days when any of the following items werenon-compliant with the applicable limits. The report shall include the emissionlevels recorded during the periods of non-compliance, reasons for the periods ofnon-compliance as well as a description of corrective actions taken: 1. 24-hour daily geometric average sulfur dioxide emission concentrations; 2. 24-hour daily arithmetic average nitrogen oxides emission concentrations; 3. four-hour block average carbon monoxide emission concentrations 4. four-hour block arithmetic average steam flow levels 5. four-hour block arithmetic average fabric filter inlet temperatures 6. six-minute opacity readings 7. six-hour block average mercury additive feedrate 8. 12-month Rolling Sum of natural gas usage 9. 12-month Rolling Sum of Total Particulate Matter emissions D. the percent of the operating time for the quarter that the opacity monitor wasoperating and collecting valid data

G.01.c.Minn. R. 7011.1285, subp. 3(D)Minn. R. 7007.0800, subp. 2Minn. R. 7011.1285, subp. 3(E)Minn. R. 7011.1285, subp. 3(F)Minn. R. 7011.1260, subp. 5(B)40 CFR Section 60.44b(d)

E. the identification of operating days for which the minimum number of hours thatemission concentrations, percent reductions, opacity level, and operatingparameters have not been obtained, including reasons for not obtaining sufficientdata and a description of corrective actions taken: 1. sulfur dioxide emissions 2. nitrogen oxides emissions 3. carbon monoxide emissions 4. steam flow 5. fabric filter inlet temperature 6. mercury additive feedrate 7. opacityThe Permittee will:> Include the documents listed below

CONTINUEDG.01.c.Minn. R. 7011.1285, subp. 3(D)Minn. R. 7007.0800, subp. 2Minn. R. 7011.1285, subp. 3(E)Minn. R. 7011.1285, subp. 3(F)Minn. R. 7011.1260, subp. 5(B)40 CFR Section 60.44b(d)

Deviation Reporting Forms (DRFs): due 30 days after end of each calendar quarterfollowing Permit Issuance. (Submit Deviations Reporting Forms DRF-1 and DRF-2,as amended). The DRF shall indicate all periods of exceedances of the limitincluding exceedances allowed by an applicable standard, i.e. during startup,shutdowns, and malfunctions.

G.01.c.(1)Minn. R. 7007.0800, subp. 6(A)

Data and results for each monitor listed below, showing that valid monitoring datawas obtained for at least:(a) 2148 hours (per calendar quarter), or(b) 75 percent of the hours per day for 90 percent of the days of the calendarquarter that the waste combustor was combusting solid waste.1. carbon monoxide2. steam flow3. opacity4. carbon dioxide5. sulfur dioxide6. nitrogen oxides7. fabric filter inlet temperature8. mercury additive feedrate

G.01.c.(2)Minn. R. 7011.1260, subp. 5(B)Minn. R. 7011.1285, subp. 3(E)Minn. R. 7011.1285, subp. 3(F)Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-18

F. the results of daily drift tests and accuracy assessments for the followingmonitors: 1. sulfur dioxide 2. nitrogen oxides 3. carbon monoxide 4. carbon dioxide 5. opacityThe Permittee will:> Include the documents listed below. [see also Table B: Submittals].

G.01.d.Minn. R. 7011.1285, subp. 3(G)Minn. R. 7007.0800, subp. 2

Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of eachcalendar quarter following Permit Issuance.

G.01.d.(1)Minn. R. 7011.1285, subp. 3(G)

COMS Calibration Error Audit Report: due 30 days after end of each calendarquarter following Permit Issuance . Reports are required for each quarter when atest was completed.

G.01.d.(2)Minn. R. 7007.0800, subp. 2

Relative Accuracy Test Audit (RATA) Report: due 30 days after end of eachcalendar year following CEMS Relative Accuracy Test Audit (RATA) or 30 daysafter the quarter in which the CEMS RATA was conducted. This report consists ofa results summary of the RATA.

G.01.d.(3)Minn. R. 7011.1285, subp. 3(G)

CEMS Daily Calibration Drift (CD) Test Log. due 30 days after end of eachcalendar quarter following Permit Issuance.

G.01.d.(4)Minn. R. 7011.1285, subp. 3(G)

G. Quarterly totals of the weights of: 1. solid waste combusted (based on steam flow, scale tickets, and/or pit inventoryas appropriate) 2. excess solid waste disposed of at a landfill 3. separated noncombustibles disposed of at a landfill 4. ash disposed of at a landfill 5. any other solid waste disposed of at a landfill 6. industrial solid waste receivedThe Permittee will:> Include quarterly totals of the weights of each of the above items.> Draft these totals as a detachable section to the Quarterly Report


G.01.e.Minn. R. 7011.1285, subp. 3(H)

H. a compliance certification as required in pt. 7007.0800, subp. 6, item C.The Permittee will:> Include a completed COMPLIANCE CERTIFICATION REPORT form, but includeinformation from only the previous quarter.

G.01.f.Minn. R. 7011.1285, subp. 3(I)Minn. R. 7007.0800, subpart 6(C)

I. the quarterly weight (in pounds) of mercury additive:1. delivered to the facility;2. consumed, based on mercury additive feedrateThe Permittee will:> Include quarterly totals of the weights of each of the above items, with supportingcalculations for additive consumed.

G.01.g.Minn. R. 7011.1285, subp. 3(J)

J. 12-Month Rolling Sums of natural gas usage and Total Particulate MatteremissionsThe Permittee will:> Include the 12-Month Rolling Sums of natural gas usage, in cubic feet/year.> Include the 12-Month Rolling Sums of Total Particulate Matter emissions(including both EU 001 and 002), in tons per year.

G.01.h.40 CFR Section 60.44b(d)Title I Condition: Limit taken to avoid classification asa major source under 40 CFR 51, Appendix S andMinn. R. 7007.4000 through 7007.4030

REPORTS REGARDING AIR EMISSION PERFORMANCE TESTS G.02. hdr

PERFORMANCE TEST PLAN AND NOTIFICATION: due 30 days before eachPerformance Test.The Permittee will:> Draft Performance Test Notification and Performance Test Plan in accordancewith Minn. R. 7017.2030, subp. 1, 2, and 3> Include provisions for determining and calculating mercury additive feedrateduring mercury testing, consistent with Minn. R. 7011.1272, subp. 1> In the PCDD/PCDF Performance Test Notification, specify the PCDD/PCDFtesting schedule> At least 30 days prior to each Performance Test date, submit Performance TestNotification and Performance Test Plan [see also Table B: Submittals]

G.02.a.Minn. R. 7011.1272, subp. 1Minn. R. 7017.2030, subp. 1Minn. R. 7017.2030, subp. 2Minn. R. 7017.2030, subp. 3

PERFORMANCE TEST REPORT: after each performance test conducted todetermine compliance with waste combustor unit emission limits, a report shall bepostmarked or received 45 days following completion of the performance test. TheCommissioner may approve a request that the submittal deadline be extended byup to 15 days if the complexity of the test schedule or the laboratory analysis issuch that the submittal within 45 days is impractical.The report shall include the results of all parameters required by the Test Plan.The Permittee will:> Submit Performance Test Report as indicated above [see also Table B:Submittals].> Date-stamp the receipt of all Performance Test Reports.

G.02.b.Minn. R. 7011.1285, subp. 1Minn. R. 7011.1285, subp. 6Minn. R. 7011.1265, subp. 6Minn. R. 7017.2035, subp. 1



05300400 - 003

Facility Name:

Permit Number:

A-19

PERFORMANCE TEST REPORTS: postmarked or received within 60 days of thedeadline for submittal of the test report. This is a state only requirement and is notfederally enforceable.The Permittee will:> Submit Performance Test Report in a Microfiche Copy or in a Alternative Format(such as a computer disk or CD-ROM), provided that the commissioner has givenprior approval for the use of the Alternative Format, as indicated above

G.02.c.Minn. R. 7017.2035, subp. 2; Minn. R. 7017.2018

ASH TESTING SUBMITTALS G.03. hdr

ASH TESTING SCHEDULE: submit for approval the ash testing schedule that isrequired by this permit, as well as any amendments to that schedule. This is astate only requirement and is not federally enforceable.The Permittee will:> Submit all unapproved schedules and amendments to the Ground Water andSolid Waste Division for approval.

G.03.a.Minn. R. 7007.0801, subp. 2(D)Minn. R. 7035.2910, subp. 3Minn. R. 7000.7000

ASH TEST REPORT: Submit report as required by Minn. R. 7035.2910, subp. 10.This is a state only requirement and is not federally enforceable.The Permittee will:> Submit Ash Test Report, as indicated above, to the Ground Water and SolidWaste Division [see also Table B: Submittals].

G.03.b.Minn. R. 7035.2910, subp. 10

WASTE COMPOSITION STUDY G.04. hdr

Waste Composition Study and Sample Analysis Plan and Notification: due 30 daysbefore each Waste Composition Study, if the plan deviates from the samplingmethods prescribed in ôTest Methods for Evaluating Solid Wasteö, SW-846. Thisis a state only requirement and is not federally enforceable.The Permittee will:> At least 30 days prior to each Waste Composition Study date, submit TestNotification and Test Plan, if required [see also Table B: Submittals]

G.04.a.Minn. R. 7007.0501, subp. 2(A)Minn. R. 7007.0800, subp. 2

Waste Composition Study and Sample Analysis Report: due 45 days after eachWaste Composition Study. Report the results of the waste composition study andanalysis required by Minn. R. 7007.0501, subp. 2(A). This is a state onlyrequirement and is not federally enforceable.The Permittee will:> Submit the report as indicated above. [see also Table B: Submittals]

G.04.b.Minn. R. 7007.0800, subp. 2

Relative Accuracy Test Audit (RATA) Notification: due 30 days before end of eachcalendar year starting 01/01/97 (but no later than 30 days before CEMS RelativeAccuracy Test Audit (RATA))The Permittee will:> Submit the notification as indicated above.

G.05.Minn. Stat. 116.07, subd. 4a

EXCEEDANCES OF LIMITS: If emission limits are exceeded, report the following: G.06.Minn. R. 7011.1260, subp. 7Minn. Stat. 116.85, subd. 2

Report the exceedance as soon as reasonably possible giving consideration tomatters of plant or worker safety, or access to communications.The Permittee will:> Report the exceedance orally to the Hotline (as instructed) as soon as possible.At the time of permit issuance, the Hotline number was (651)296-7300.

G.06.a.Minn. R. 7011.1260, subp. 7(A)Minn. Stat. 116.85, subd. 2

Report any shutdown as soon as possible. Notice may be oral.The Permittee will:> Report orally to the Supervisor of the Compliance Determination Unit.

G.06.b.Minn. R. 7011.1260, subp. 7(C)Minn. R. 7007.0800, subp. 2

Submit notice of shutdown within 14 days of shutdownThe Permittee will:> Report in writing to the Supervisor of the Compliance Determination Unit.

G.06.c.Minn. R. 7011.1260, subp. 7(C)Minn. R. 7007.0800, subp. 2

MODIFIED INDUSTRIAL WASTE MANAGEMENT PLAN: submit the amendedplan for approval. This is a state only requirement and is not federally enforceable.The Permittee will:> Submit the amended plan both to the Supervisor, Compliance DeterminationUnit, Air Quality Division, and to the Manager, Solid Waste Section, Groundwaterand Solid Waste Division

G.07.Minn. R. 7011.1250, subp. 3

FACILITY OPERATION H. hdr

PARAMETERS OF OPERATION: Operate the waste combustor consistent withconditions during the most recent test. (These conditions may be more stringentthan those allowed by permit.)The Permittee will:> Include the current operating parameters in the Operating Manual> Train staff on current operating parameters as soon as the conditions apply> Operate the waste combustor consistent with the conditions established in thispermit> Operate the waste combustor consistent with the current operating parametersestablished in Limits and Testing

H.01.Minn. R. 7017.2025, subp. 3



05300400 - 003

Facility Name:

Permit Number:

A-20

CERTIFIED OPERATOR PRESENT: Comply with the certified operatorrequirements below.The Permittee will:> Display documents of certification prominently at the facility> Keep copies of the certificates in the Operating Record [see Section F -Recordkeeping]> Record certified operator shift changes in the Operating Record [see Section F -Recordkeeping]

H.02.Minn. R. 7011.1240, subp. 1

A certified operator who holds a certificate for a Class A Waste Combustor inaccordance with Minn. R. 7011.1281 must be present at the waste combustorfacility at all times when solid waste is being combusted.

H.02.a.Minn. R. 7011.1240, subp. 1

COLD STARTUP: During start-up from a cold furnace, natural gas (not waste)shall be used to achieve combustion chamber operating temperature.The Permittee will:> Record the temperature and the time of the first charge in the Operating Record[see Section F - Recordkeeping]

H.03.Minn. R. 7011.1240, subp. 3

SECURITY: Comply with security requirements in Minn. R. 7035.2535, subpart 3.This is a state only requirement and is not federally enforceable.The Permittee will:> Draft a plan in accordance with Minn. R. 7035.2535, subp. 3> Implement the plan upon permit issuance

H.04.Minn. R. 7011.1245, subp. A

GENERAL INSPECTION: Comply with general inspection and repair requirementsin Minn. R. 7035.2535, subpart 4. This is a state only requirement and is notfederally enforceable.The Permittee will:> Draft a plan in accordance with Minn. R. 7035.2535, subp. 4> Implement the plan upon permit issuance

H.05.Minn. R. 7011.1245, subp. B

EMERGENCY PREPAREDNESS AND PREVENTION: Comply with emergencypreparedness and prevention requirements in Minn. R. 7035.2595. This is a stateonly requirement and is not federally enforceable.The Permittee will:> Draft a plan in accordance with Minn. R. 7035.2595> Implement the plan upon permit issuance

H.06.Minn. R. 7011.1245, subp. D

OPERATING MANUAL: Develop and update a site-specific operating manual, inaccordance with Minn. R. 7011.1275, subp. 3. Update any operational changesresulting from the most recent performance testing results. Update all otherportions at least yearly. Keep the manual in a location which is easily accessible byplant personnel.The Permittee will:> Develop and maintain the Operating Manual in accordance with Minn. R.7011.1275, subp. 3> Include the revision dates within the Operating Manual.> Store the Operating Manual in a location easily accessed by staff, and describethe location in the Operating Manual. Make all attempts to have this location bepermanent.

H.07.Minn. R. 7011.1275, subp. 3

ASH HANDLING I. hdr

REDUCING ASH TOXICITY: Abide by a plan to reduce the level of toxiccontaminants in ash, consistent with Minn. R. 7007.0501, subp. 6(A). This is astate only requirement and is not federally enforceable.The Permittee will:> Draft conditions in the Ash Plan in accordance with Minn. R. 7007.0501, subp.6(A)> Implement the plan

I.01.Minn. R. 7007.0501, subp. 6(A)

ASH MANAGEMENT: Abide by a plan for the utilization and disposal of ash,consistent with Minn. R. 7007.0501, subp. 7. The plan must also include the propertreatment of quench water. This is a state only requirement and is not federallyenforceable.The Permittee will:> Draft conditions in the Ash Plan in accordance with Minn. R. 7007.0501, subp. 7> Implement the plan

I.02.Minn. R. 7007.0501, subp. 7

CONSTRUCTION BAN: Construction of a waste combustor unit is prohibitedwithout an approved ash management method. Operation of such a unit isprohibited until the ash management facility is available to accept ash.The Permittee will:> Construct and operate new units within regulatory requirements.

I.03.Minn. R. 7007.0801, subp. 2(A)Minn. R. 7007.0801, subp. 2(B)

WASTE STREAM J. hdr



05300400 - 003

Facility Name:

Permit Number:

A-21

INDUSTRIAL WASTE MANAGEMENT PLAN: Implement the Industrial WasteManagement Plan required by Minn. R. 7011.1250. This is a state onlyrequirement and is not federally enforceable.The Permittee will:> Address industrial solid waste issues, including those listed below, in theIndustrial Waste Management Plan.> Implement the plan.> Record industrial solid waste data as required by the Operating Record [seeSection F - Recordkeeping]> Report all amendments to the plan [see Section G - Reporting]

J.01.Minn. R. 7007.0801, subp. 2(E)Minn. R. 7011.1250

TIRES: Tires may be burned at this facility. J.01.a.Minn. R. 7011.1220, subp. 2

YARD WASTE: Yard waste may not knowingly be burned at this facility. Yardwaste is to be addressed in the Industrial Waste Management Plan.

J.01.b.Minn. R. 7011.1220, subp. 2

SORBANTS AND MEDIA CONTAMINATED WITH OIL: Sorbants contaminatedwith used or waste oil (including, but not limited to, oily rags and floor dry) may beburned at this facility, provided that they are approved as required by otherregulatory agencies. Oil filters may also be burned, provided that the facilityrecovers ferrous metal after incineration for recycling as part of its operation.Address the combustion of sorbants in the Industrial Waste Management Plan.This is a state only requirement and is not federally enforceable.

J.01.c.Minn. R. 7011.1250, subp. 2(C)Minn. Stat. 115A.916

INFECTIOUS WASTE: Address infectious and pathological waste issues,including the Infectious Waste Management Plan, as applicable, and itsrequirements, as part of the Industrial Waste Management Plan. This is a stateonly requirement and is not federally enforceable.

J.01.d.Minn. R. 7011.1250, subp. 2(B)Minn. R. 7011.1245(H)

UNACCEPTABLE WASTES: The following wastes may not knowingly be chargedinto the waste combustor unit at this facility until the wastes are properly addressedin an approved Industrial Solid Waste Management Plan.1. empty pesticide containers2. asbestos3. waste containing polychlorinated biphenyls at a concentration less than 50 ppm4. spilled nonhazardous materials, including fossil fuels (except as noted above)5. rendering and slaughterhouse wastes6. wastes that could spontaneously combust or that could ignite other wastebecause of high temperatures7. foundry waste8. ash from incinerators, resource recovery facilities, and power plants9. paint residues, paint filters, and paint dust10. sludges, including ink sludges, lime sludge, wood sludge, and paper sludge11. fiberglass, urethane, polyurethane, and epoxy resin waste12. spent activated carbon filtersThis is a state only requirement and is not federally enforceable.

J.01.e. Minn. R. 7011.1250

HOUSEHOLD HAZARDOUS WASTE MANAGEMENT PLAN: Comply withhousehold hazardous waste management requirements in Minn. R. 7035.2535,subpart 6. This is a state only requirement and is not federally enforceable.The Permittee will:> Draft a plan in accordance with Minn. R. 7035.2535, subp. 6> Implement the plan

J.02.Minn. R. 7011.1245(C)

FERROUS METAL RECOVERY: recover at least 75 percent by weight of theferrous metals present in the processible waste. This is a state only requirementand is not federally enforceable.The Permittee will:> Establish and follow procedures to recover at least 75 percent by weight of theferrous metals present in the processible waste

J.03.Minn. R. 7001.0800, subp. 2

TRAINING K. hdr

TRAINING PROGRAM: Implement a training program, based on the OperatingManual, designed to maintain compliance with this permit and Minn. R. 7011.1201to 7011.1290. Individual training must be specific to the position held. The trainingprogram must include the situations listed below:The Permittee will:> Implement the required training> Document the nature and length of training for each individual [see Section F -Recordkeeping]> Report the names of those who have been trained [see Section G - Reporting]

K.01.Minn. R. 7011.1275, subp. 1

Persons with job-related activities affecting air emission must: 1. initially review the operating manual prior to assumption of any job-relatedactivities affecting air emissions 2. annually review the operating manual

K.01.a.Minn. R. 7011.1275, subp. 1(A)Minn. R. 7011.1275, subp. 1(D)

Persons with newly-assigned job-related activities affecting air emission mustreview the portions of the operating manual relevant to the newly-assigned positionbefore assumption of the new job-related activities.

K.01.b.Minn. R. 7011.1275, subp. 1(B)



05300400 - 003

Facility Name:

Permit Number:

A-22

Persons without waste combustor or boiler operation experience must work underthe direct supervision of a certified operator or a certified operator's designee for 40hours before assuming job-related activities affecting air emissions.

K.01.c.Minn. R. 7011.1275, subp. 1(C)Minn. R. 7011.1275, subp. 1(C)(1)

PERSONNEL WHO SHALL BE TRAINED: Train waste combustor personnel whohave responsibilities which affect the operation of the waste combustor. Thesepersonnel include, but are not limited to, chief facility operators, shift supervisors,control room personnel, ash handlers, maintenance personnel, and crane/loadhandlers.The Permittee will:> Identify all people described above who must be trained, and include a separatepage for each of these people in the Operating Record [see Section F -Recordkeeping]> Report the names of those who have been trained [see Section G - Reporting]

K.02.Minn. R. 7011.1275, subp. 1Minn. R. 7011.1275, subp. 2

OPERATOR CERTIFICATION L. hdr

TIMETABLES:Operators shall be certified within the time frames described below.The Permittee will:> Display documents of certification prominently at the facility> Display documents of full certification prominently at the facility> Keep copies of the certificates in the Operating Record [see Section F -Recordkeeping]

L.01.Minn. R. 7011.1280, subp. 10Minn. R. 7007.0800, subp. 2

The chief facility operator, control room operators, and shift supervisors shall becertified through the process established in Minn. R. 7011.1280. Chief facilityoperators and shift supervisors shall be certified upon permit issuance. Controlroom operators shall be certified by June 30, 1998.

L.01.a.Minn. R. 7011.1280, subp. 2(A)Minn. R. 7011.1280, subp. 10Minn. R. 7007.0800, subp. 2Minn. R. 7011.1240, subp. 1a

All chief facility operators and shift supervisors shall have obtained full certificationas described in Minn. R. 7011.1281.

L.01.b.Minn. R. 7007.0800, subp. 2

If changes are made in equipment and/or operating procedures which the initial fullcertification did not address, full certificate holders shall demonstrate to the facility'scertified examiner detailed knowledge of these changes within six months after thechange is made. If the demonstration of knowledge has not been made within sixmonths, the certificate shall expire.

L.01.c.Minn. R. 7011.1284, subp. 2

FULL CERTIFICATION PROGRAM: Comply with the Fully Certified Operatorprogram requirements below.The Permittee will:> Display documents of full certification prominently at the facility> Allow the Commissioner to review all records

L.02.Minn. R. 7007.0800, subp. 2

If changes are made in equipment and/or operating procedures which the initial fullcertification did not address, fully-certified operators shall demonstrate detailedknowledge of these changes according to the conditions of the certificate held.

L.02.a.Minn. R. 7007.0800, subp. 2

Allow the commissioner to review all records related to the full certification ofoperators, including the facilityÆs program for the examination and certification ofoperators, the required records, the content of examinations, and the results of anindividual's examination.

L.02.b. Minn. R. 7011.1284, subp. 4

REQUIRED PLANS M. hdr

Possess the documents listed below.The Permittee:> Possess documents that abide by the corresponding rule citation(s)> In the plans required by Minn. R. 7011.1245, identify those required portions ofthe corresponding rule which are not applicable> Keep the plans in the Operating Manual

M.Minn. R. 7011.1245Minn. R. 7011.1275, subp. 3Minn. R. 7007.0501, subp. 6Minn. R. 7007.0501, subp. 7Minn. R. 7007.0801, subp. 2(D)Minn. R. 7011.1250

Operating Manual, in accordance with Minn. R. 7011.1275, subp. 3 [see Section H- Facility Operation]

M.01.Minn. R. 7011.1275, subp. 3

Ash Plan, comprising the following items: 1. The methods of reducing the level of toxic contaminants in ash and otherissues, in accordance with Minn. R. 7007.0501, subp. 6 [see Section I - AshHandling] 2. Ash Management Plan, in accordance with Minn. R. 7007.0501, subp. 7 [seeSection I - Ash Handling] 3. Ash Testing Schedule, in accordance with Minn. R. 7035.2910, subp. 3 [seeSection D - Testing, Section G - Reporting]This is a state only requirement and is not federally enforceable.

M.02.Minn. R. 7007.0501, subp. 6Minn. R. 7007.0501, subp. 7Minn. R. 7007.0801, subp. 2(D)Minn. R. 7035.2910, subp. 3

Security Plan, in accordance with Minn. R. 7035.2535, subp. 3 [see Section H -Facility Operation]. This is a state only requirement and is not federallyenforceable.

M.03.Minn. R. 7011.1245, subp. A

General Inspection Plan, in accordance with Minn. R. 7035.2535, subp. 4 [seeSection H - Facility Operation]. This is a state only requirement and is not federallyenforceable.

M.04.Minn. R. 7011.1245, subp. B



05300400 - 003

Facility Name:

Permit Number:

A-23

Household Hazardous Waste Management Plan, in accordance with Minn. R.7035.2535, subp. 6 [see Section J - Waste Stream]. This is a state onlyrequirement and is not federally enforceable.

M.05.Minn. R. 7011.1245, subp. C

Emergency Preparedness And Prevention Plan, in accordance with Minn. R.7035.2595 [see Section H - Facility Operation]. This is a state only requirementand is not federally enforceable.

M.06.Minn. R. 7011.1245, subp. D

Emergency Procedures Plan, in accordance with Minn. R. 7035.2605. This is astate only requirement and is not federally enforceable.

M.07.Minn. R. 7011.1245, subp. D

Contingency Action Plan, in accordance with Minn. R. 7035.2615. This is a stateonly requirement and is not federally enforceable.

M.08.Minn. R. 7011.1245, subp. E

Closure Plan, in accordance with Minn. R. 7035.2625. This is a state onlyrequirement and is not federally enforceable.

M.09.Minn. R. 7011.1245, subp. F

Industrial Solid Waste Management Plan, in accordance with Minn. R. 7011.1250[see Section J - Waste Stream]. This is a state only requirement and is notfederally enforceable. The plan must incorporate any plans listed below:

M.10.Minn. R. 7011.1250, subp. 1

Infectious Waste Management Plan (if applicable), in accordance with Minn. R.7035.9150 [see Section J - Waste Stream]. This is a state only requirement and isnot federally enforceable.

M.10.a.Minn. R. 7011.1245, subp. H

ABNORMAL OPERATION N. hdr

MONITOR DOWNTIME N.01. hdr

INSUFFICIENT UPTIME FOR SO2, CO, AND NOx MONITORS: Provide validemission data in order to meet the monitor uptime requirements when continuousemissions data for sulfur dioxide, carbon monoxide, or nitrogen oxide emissionrates are not obtained because of: monitor breakdowns; repairs; calibrationchecks; and zero and span adjustments. Emission data calculations to determinecompliance shall be made using other monitoring systems or other data collectionmethods as approved by the commissioner or Code of Federal Regulations, Title40, pt. 60, Appendix A, as amended: 1. Method 19 for SO2 and NOx; and 2. Method 10 for CO.The Permittee will:> Record downtime in the Operating Record [see Section F - Recordkeeping]> Include an alternative method of acquiring data (as approved by MPCA, ifrequired) in the Operating Manual, in the event of insufficient monitoring data [seeSection H - Facility Operation]

N.01.a.Minn. R. 7011.1260, subp. 5(D)Minn. R. 7011.1285, subp. 2(K)Minn. R. 7007.0800, subp. 2.

INSUFFICIENT UPTIME FOR OTHER MONITORING: Record reasons andcorrective actions when monitor uptime is not obtained for: steam flow; mercuryadditive feedrate; fabric filter inlet temperature; carbon dioxide; or opacityThe Permittee will:> Record downtime in the Operating Record [see Section F - Recordkeeping]

N.01.b.Minn. R. 7011.1285, subp. 2(K)Minn. R. 7007.0800, subp. 2

SHUTDOWN OR BREAKDOWN: In the event of a shutdown or breakdown,comply with Minn. R. 7019.1000.The Permittee will:> Abide by the shutdown/breakdown requirements of this permit [see Total Facilityrequirements]

N.02.Minn. R. 7011.1240, subp. 8

SOLID WASTE MANAGEMENT ISSUES: This is a state only requirement and isnot federally enforceable. Abide by the following plans as appropriate for the givensituations:The Permittee will:> Implement the appropriate plan(s) upon permit issuance

N.03.Minn. R. 7011.1245

Emergency Procedures Plan [see Section M - Required Plans]. This is a state onlyrequirement and is not federally enforceable.

N.03.a.Minn. R. 7011.1245(D)

Contingency Action Plan [see Section M - Required Plans]. This is a state onlyrequirement and is not federally enforceable.

N.03.b.Minn. R. 7011.1245(E)

Closure Plan [see Section M - Required Plans]. This is a state only requirementand is not federally enforceable.

N.03.c.Minn. R. 7011.1245(F)

EXCEEDANCES OF CONTINUOUSLY MONITORED EMISSION LIMITS. Ifaccurate and valid data results collected from continuous monitors for sulfurdioxide, nitrogen oxides, or carbon monoxide exceed emission limits, undertake thefollowing actions:

N.04.Minn. R. 7011.1260, subp. 7Minn. Stat. 116.85, subd. 2

Report the exceedance as soon as possible, giving consideration to matters ofplant or worker safety, or access to communications.The Permittee will:> Report the exceedance as soon as possible [see Section G - Reporting]

N.04.a.Minn. R. 7011.1260, subp. 7(A)Minn. R. 7011.1240, subp. 8Minn. Stat. 116.85, subd. 2



05300400 - 003

Facility Name:

Permit Number:

A-24

Immediately either: 1. commence appropriate repairs or modifications to return the waste combustor tocompliance; or 2. initiate shutdown procedures.The Permittee will:> Log the exceedance in the Operating Record [see Section F - Recordkeeping]> Initiate repairs or initiate shutdown, and log the activities in the Operating Record[see Section F - Recordkeeping]

N.04.b.Minn. R. 7011.1260, subp. 7(B)Minn. Stat. 116.85, subd. 2

Commence shutdown of the noncompliant emission unit within 72 hours if: 1. the waste combustor cannot be returned to compliance, or 2. the modifications to return the waste combustor to compliance require a permitamendmentThe Permittee will:> Commence shutdown of the waste combustor unit within 72 hours of theexceedance> Record the time of shutdown [see Section F - Recordkeeping]> Report the shutdown [see Section G - Reporting]

N.04.c.Minn. R. 7011.1260, subp. 7(C)Minn. Stat. 116.85, subd. 2

Returning to compliance: Abide by Minn. R. 7011.1260, subp. 7(D) for startup.The Permittee will:> Regarding startup or noncompliance, comply with the instructions provided by theAir Quality Division

N.04.d. Minn. R. 7011.1260, subp. 7(D)Minn. Stat. 116.85, subd. 2

FAILING A PERFORMANCE TEST. If accurate and valid data results of aperformance test demonstrate an exceedance of a standard of performance,undertake the following actions:

N.05.Minn. R. 7011.1265, subp. 11Minn. Stat. 116.85, subd. 3

Report the exceedance as soon as possible.The Permittee will:> Report the exceedance as soon as possible [see Section G - Reporting]

N.05.a.Minn. R. 7011.1265, subp. 11(A)Minn. R. 7011.1240, subp. 8Minn. Stat. 116.85, subd. 3

Within 30 days of the report of the exceedance, undertake repairs and either: 1. retest the unit within the same 30 days for the purpose of demonstratingcompliance with the emission limit; or 2. shut the unit down on the 31st day if the waste combustor cannot be returned tocompliance (or a permit amendment is needed)The Permittee will:> Within 30 days of the exceedance discovery, conduct retesting in compliancewith Minnesota Rules; or> Shut down the unit on the 31st day following the exceedance discovery

N.05.b.Minn. R. 7011.1265, subp. 11(B)Minn. R. 7011.1265, subp. 11(C)Minn. Stat. 116.85, subd. 3

Report of shutdown of the noncompliant emission unit: 1. the waste combustor cannot be returned to compliance, or 2. the modifications to return the waste combustor to compliance require a permitamendmentThe Permittee will:> Shut down the waste combustor unit within 31 days of the exceedance> Record the time of shutdown [see Section F - Recordkeeping]> Report the shutdown [see Section G - Reporting]

N.05.c.Minn. R. 7011.1265, subp. 11(C)Minn. Stat. 116.85, subd. 3

Returning to compliance: Abide by Minn. R. 7011.1265, subp. 11(D) for startup.The Permittee will:> Regarding startup and non-compliance, comply with Minn. R. 7011.1265, subp.11(D).

N.05.d.Minn. R. 7011.1265, subp. 11(C)Minn. R. 7011.1265, subp. 11(D)Minn. Stat. 116.85, subd. 3

INADEQUATE MERCURY ADDITIVE FLOW OBSERVED: If monitoring indicatesinadequate flow of mercury additive, restore the mercury additive flow as soon aspossible. This determination is based upon an observed change in mercuryadditive feedrate characteristics from that observed when the pollution controlequipment is properly operated and maintained.The Permittee will:> Immediately upon discovery of inadequate mercury additive flow, initiatemeasures to restore proper mercury additive flow as soon as possible.> Record in the Operating Record the time periods, reasons, and corrective actionsregarding the inadequate flow [see Section F - Recordkeeping]> If the inadequate flow cannot be corrected within the 3-hour allowance period formalfunction (Minn. R. 7011.1215, subp. 4), report the incident as a Breakdown inaccordance with the shutdown/breakdown requirements of this permit [see TotalFacility requirements]

N.06.Minn. R. 7007.0800, subp. 16(J)



05300400 - 003

Facility Name:

Permit Number:

A-25

> If the inadequate flow cannot be corrected within the 3-hour allowance period formalfunction (Minn. R. 7011.1215, subp. 4), record the incident as a mercuryadditive feedrate limit violation in the operating record [see Section F -Recordkeeping]> During periods of malfunction of one of the mercury additive systems, a "Y"system will be utilized for the addition of the mercury additive to flue gases fromboth combustor units. In this scenario, inadequate flow will be observed to one ofthe gravimetric feed systems, however, mercury additive equal to or greater than125 percent, by weight, of the combined rate for Combustor Unit No. 1 andCombustor Unit No. 2 determined during the most recent mercury performance testthat demonstrated compliance with the emission limit will be added to the fluegases through the "Y" system and observed on the functioning gravimetric feedsystem.> A deviation from the 12.5% reading shall be considered a deviation in themercury additive feedrate

CONTINUEDN.07.Minn. R. 7007.0800, subp. 16(J)

DEFINITIONS O. hdr

CEMS: The total equipment required for the determination of a gas concentrationor emission rate. The sample interface, pollutant analyzer, diluent analyzer, anddata recorder are the major subsystems of the CEMS.

O.01.Minn. R. 7017.1002, subp. 440 CFR Part 60, Appendix B, Spec. 2, Section 3.3

CHIEF FACILITY OPERATOR: "the person in direct charge and control of theoperation of a waste combustor who is responsible for daily on-site supervision,technical direction, management, and overall performance of the facility."

O.02.Minn. R. 7011.1201, subp. 8

COMS: The total equipment required for the determination of the opacity thatmeets the specifications of ASTM D 6216-98, including a suitable data recorder orautomated data acquistion handling system.

O.03.Minn. R. 7017.1002, subp. 540 CFR Part 60, Appendix B, Spec. 1, Section 6.1

CONTINUOUS BURNING is the continuous, semicontinuous, or batch feeding ofsolid waste for purposes of waste disposal, energy production, or providing heat tothe combustion system in preparation for waste disposal or energy production.

O.04.Minn. R. 7011.1215. subp. 4

FOUR-HOUR BLOCK AVERAGE: "the average of all hourly emission rates whenthe emissions unit is operating and combusting solid waste measured over sixdiscrete four-hour periods beginning at midnight."

O.05.Minn. R. 7011.1201, subp. 23

MAXIMUM DEMONSTRATED CAPACITY: The maximum four-hour integratedaverage load for each waste combustor unit achieved during four consecutivehours during the most recent test during which compliance with the PCDD/PCDFlimit is achieved, as measured by steam flow. (Steam flow is measured inaccordance with Minn. R. 7011.1265.)

O.06.Minn. R. 7011.1201, subp. 32Minn. R. 7007.0800, subp. 2

MERCURY ADDITIVE: The material added to the flue gas stream for the purposesof controlling mercury emissions. At the time of permit issuance, the "mercuryadditive" was activated carbon.

O.07.Minn. R. 7011.1272, subp. 2

PCDD/PCDF: "the total of tetra- through octa-polychlorinated dibenzo-p-dioxinsand polychlorinated dibenzofurans."

O.08.Minn. R. 7011.1201, subp. 40

SHIFT SUPERVISOR: "the person in direct charge and control of the operation ofa waste combustor and who is responsible for on-site supervision, technicaldirection, management, and overall performance of the facility during an assignedshift."

O.09.Minn. R. 7011.1201, subp. 44

SHUT-DOWN: The shut-down period of the waste combustor unit commences onehour after the feed chute damper is closed.

O.10.Minn. R. 7007.0800, subp. 2

SIX-HOUR BLOCK AVERAGE: For mercury additive feedrate, the average of allone-hour feedrate measurements when the emissions unit is operating andcombusting solid waste measured over four discrete six-hour periods beginning atmidnight.

O.11.Minn. R. 7007.0800, subp. 2

START-UP: The start-up period commences when the waste combustor beginsthe continuous burning of solid waste and does not include any warm-up periodwhen the waste combustor is combusting fossil fuel or other solid fuel.

O.12.Minn. R. 7011.1215, subp. 4

VOC: Volatile Organic Compounds O.13.Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-26

Subject Item: GP 002 Activated Carbon Adsorption (All requirements apply to each control equipment unit.)

Associated Items: CE 001 Activated Carbon Adsorption

CE 002 Activated Carbon Adsorption





What to do Why to do itOperation of Control Equipment: The Permittee shall operate the Activated CarbonAdsorption Control Equipment whenever operating the waste combustor unit. incompliance with parts 7011.0060 to 7011.0080. The Activated Carbon AdsorptionControl Equipment shall at all times be operated within the operating parametersset by the commissioner as the result of the most recent performance testconducted to determine control efficiency under parts 7017.2001 to 7017.2060.

Minn. R. 7007.0800, subp. 14

Maintenance of Control Equipment: The Permittee shall maintain the ActivatedCarbon Adsorption Control Equipment according to the control equipmentmanufacturer's specifications, shall comply with source specific maintenancerequirements specified in the part 70 permit, and shall perform the maintenancetasks listed in Minn. R. 7011.0075, subp. 2 for the Activated Carbon AdsorptionControl Equipment except for Items D and E. The Item D and Item E flue gasductwork inspections may be conducted during outages at intervals ofapproximately 6 months.

Minn. R. 7007.0800, subp. 14



05300400 - 003

Facility Name:

Permit Number:

A-27

Subject Item: GP 003 Ammonia Injection (All requirements apply to each control equipment unit.)

Associated Items: CE 003 Ammonia Injection






What to do Why to do itOperation of Control Equipment: The Permittee shall operate the AmmoniaInjection System on an as needed basis to comply with NOx emission limits whenoperating the waste combustor unit.

Minn. R. 7007.0800, subp. 14

Maintenance of Control Equipment: The Permittee shall maintain the AmmoniaInjection System according to the control equipment manufacturer's specifications,shall comply with source specific maintenance requirements specified in the part 70permit, and shall perform the maintenance tasks listed in Minn. R. 7011.0075,subp. 2 for the Ammonia Injection System except for Items D and E. The Item Dand Item E flue gas ductwork inspections may be conducted during outages atintervals of approximately 6 months.

Minn. R. 7007.0800, subp. 14



05300400 - 003

Facility Name:

Permit Number:

A-28

Subject Item: GP 004 Lime Spray Dryers (All requirements apply to each control equipment unit.)

Associated Items: CE 005 Lime Spray Dryer






What to do Why to do itOperation of Control Equipment: The Permittee shall operate the Lime Spray Dryerwhenever operating the emission units controlled by the Lime Spray Dryer. TheLime Spray Dryer shall at all times be operated within the operating parameters setby the commissioner as the result of the most recent performance test conducted todetermine control efficiency under parts 7017.2001 to 7017.2060.

Minn. R. 7007.0800, subp. 14

Maintenance of Control Equipment: The Permittee shall maintain the Lime SprayDryer according to the control equipment manufacturer's specifications, shallcomply with source specific maintenance requirements specified in the part 70permit, and shall perform the maintenance tasks listed in Minn. R. 7011.0075,subp. 2 for the Lime Spray Dryer except for Items D and E. The Item D and Item Eflue gas ductwork inspections may be conducted during outages at intervals ofapproximately 6 months.

Minn. R. 7007.0800, subp. 14



05300400 - 003

Facility Name:

Permit Number:

A-29

Subject Item: GP 005 Fabric Filters - High Temperature (All requirements apply to each control equipment unit.)

Associated Items: CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F






What to do Why to do itPressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 16.0 inches of water column across the entire baghouse. The Permitteeshall record the pressure drop once every 24 hours when in operation.

Minn. R. 7007.0800, subp. 2 and 14

Six-minute block averaging readings of greater than 10 percent opacity fromemissions leaving the Fabric Filter shall trigger an automatic alarm, whereupon thePermittee shall initiate procedures to check the Fabric Filter system for problems ormalfunctions.

Minn. R. 7007.0800, subp. 2 and 14

Inspect quarterly, or as required by manufacturing specifications, all componentsthat are not subject to wear or plugging including structural components, housings,ducts, and hoods except for Items D and E. The Item D and Item E flue gasductwork inspections may be conducted during outages at intervals ofapproximately 6 months. Maintain a written record of the inspection and any actionresulting from the inspection.

Minn. R. 7007.0800, subp. 2 and 14

Inspect during outages at intervals of approximately 6 months, or as required bymanufacturing specifications, all components that are subject to wear or pluggingfor example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. Maintain awritten record of the inspection and any action resulting from the inspection.

Minn. R. 7007.0800, subp. 2 and 14

Calibrate the pressure gauge annually, or as often as required by manufacturingspecifications, and maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subp. 2 and 14

If necessary, the Permittee shall apply for an amendment to update the pressuredrop range given for this control device once vendor data is available or after actualnormal operating data has been obtained. If necessary, the Permittee shall applyfor the amendment no later than 60 days after permit issuance.

Minn. R. 7007.1500, subp. 1



05300400 - 003

Facility Name:

Permit Number:

A-30

Subject Item: GP 006 Fabric Filters - Low Temperature (All requirements apply to each control equipment unit.)

Associated Items: CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 003 Lime Silo - Pebble Lime

EU 005 Lime Silo - Dolomitic Lime

SV 003 Lime Silo - Pebble Lime

SV 005 Lime Silo - Dolomitic Lime

What to do Why to do itThe Permittee shall operate and maintain the control equipment any time that theprocess equipment that it controls is in operation.

Minn. R. 7007.0800, subp. 2

Visible Emissions: Once during each operation of the fabric filter, the Permitteeshall check the outlet of each operating fabric filter during daylight hours for anyvisible emissions (VEs).

Minn. R. 7007.0800, subp. 4

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall eliminate the visible emission and/or include completion ofnecessary repairs identified during the inspection, as applicable. Corrective actionsinclude, but are not limited to, those outlined in the O & M Plan for the fabric filter.The Permittee shall keep a record of the type and date of any corrective actiontaken for each filter.The Permittee shall take corrective actions, as soon as possible, as based on theoperation and maintenance plan to eliminate any visible emissions.

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

Recordkeeping of Visible Emissions. The Permittee shall record the time and dateof each visible emission inspection and whether or not any visible emissions wereobserved.

Minn. R. 7007.0800, subps. 4 and 5

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

Minn. R. 7007.0800, subp. 14

Inspect quarterly, or as required by manufacturing specifications, all componentsthat are not subject to wear or plugging including structural components, housings,ducts, and hoods. Maintain a written record of the inspection and any actionresulting from the inspection.

Minn. R. 7007.0800, subp. 2 and 14

Inspect at intervals of approximately 6 months, or as required by manufacturingspecifications, all components that are subject to wear or plugging for example:bearings, belts, hoses, fans, nozzles, orifices, and ducts. Maintain a written recordof the inspection and any action resulting from the inspection.

Minn. R. 7007.0800, subp. 2 and 14

Baghouse filter shall be checked monthly and replaced as necessary. Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-31

Subject Item: EU 003 Lime Silo - Pebble Lime


GP 006 Fabric Filters - Low Temperature (All requirements apply to each control equipment unit.)

SV 003 Lime Silo - Pebble Lime

What to do Why to do itThe Permittee shall not cause or permit avoidable amounts of particulate matter tobecome airborne from operations conducted at the facility. All persons shall takereasonable measures to prevent the discharge of visible fugitive dust emissionsbeyond the property line.

Minn. R. 7011.0150

Opacity: less than or equal to 20 percent opacity 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.

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

Fabric filters shall be operated, at all times, during filling operation. See GP 006 forFabric Filter requirements.

Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-32

Subject Item: EU 005 Lime Silo - Dolomitic Lime


GP 006 Fabric Filters - Low Temperature (All requirements apply to each control equipment unit.)

SV 005 Lime Silo - Dolomitic Lime

What to do Why to do itTotal 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.

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

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

Fabric filters shall be operated, at all times, during filling operation. See GP 006 forFabric Filter requirements.

Minn. R. 7007.0800, subp. 2

The Permittee shall not cause or permit avoidable amounts of particulate matter tobecome airborne from operations conducted at the facility. The Permittee shalltake reasonable precautions to prevent the discharge of visible fugitive dustemissions beyond the Permittee's lot line.

Minn. R. 7011.0150



05300400 - 003

Facility Name:

Permit Number:

A-33

Subject Item: EU 007 Combined Ash Handling

Associated Items: CE 013 6% or Greater Moisture Content

SV 007 Combined Ash Handling

What to do Why to do itTotal 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.

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

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

The Permittee shall not cause or permit avoidable amounts of particulate matter tobecome airborne from operations conducted at the facility. The Permittee shalltake reasonable precautions to prevent the discharge of visible fugitive dustemissions beyond the Permittee's lot line.

Minn. R. 7011.0150

The combined ash moisture content shall be maintained at 6% or greater. Minn. R. 7007.0800, subp. 2

The Permittee shall test a representative combined ash sample for moisturecontent, on an annual basis.

Minn. R. 7007.0800, subp. 2



05300400 - 003

Facility Name:

Permit Number:

A-34

Subject Item: EU 008 Cooling Tower

Associated Items: SV 008 Cooling Tower

SV 009 Cooling Tower

SV 010 Cooling Tower

What to do Why to do itOpacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

Compliance with the 20% opacity value will be demonstrated by either processcalculations or a visible emissions method performed on a day when there is notany interference from water vapor.

Minn. R. 7007.0800, subp. 2

TABLE B: SUBMITTALSFacility Name: Covanta Hennepin Energy Resource Co LP

Permit Number: 05300400 - 003

09/10/04B-1

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

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

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

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

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

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Send any application for a permit or permit amendment to:

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

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Covanta Hennepin Energy Resource Co LP


09/10/04B-2

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

PermitTotal Facility

Deviations Report due before 05/14/1998. (Submit DeviationsReporting Forms DRF-1 and DRF-2, asamended) .

GP001

TABLE B: RECURRENT SUBMITTALSFacility Name: Covanta Hennepin Energy Resource Co LP


09/10/04B-3

What to send When to send Portion of Facility AffectedCEMS Daily Calibration Drift (CD) Test Log due 30 days after end of each calendar

quarter starting 05/14/1998 .GP001

COMS Calibration Error Audit ResultsSummary

due 30 days after end of each calendarquarter starting 05/14/1998 . Reports arerequired for each quarter when a test wascompleted.

GP001

Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendarquarter starting 05/14/1998 .

GP001

Waste Combustor Quarterly Report due 30 days after end of each calendarquarter starting 05/14/1998 WasteCombustor

GP001

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 05/14/1998 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. (Itemssubmitted in the Waste Combustor QuarterlyReport do not have to be resubmitted to fulfillthis requirement.)

Total Facility

Compliance Certification due 30 days after end of each calendar yearstarting 05/14/1998 (for the previous calendaryear), to be submitted to the Commissionerand the U.S. EPA regional office in Chicagoon a form approved by the Commissioner.The report covers all deviations experiencedduring the calendar year.

Total Facility

Emissions Inventory Report due 91 days after end of each calendar yearstarting 05/14/1998 (April 1). To be submittedon a form approved by the Commissioner.

Total Facility

Performance Test Notification (written) due 30 days before end of each year starting06/10/97 (30 days before each MercuryPerformance Test)

GP001

Performance Test Notification (written) due 30 days before end of each year starting06/10/98 (30 days before each PerformanceTest measuring Front-half particulate matter,Total particulate matter, Total PCDD/PCDF,Hydrogen chloride, Lead, Cadmium, VOC,and Opacity)

GP001

Performance Test Plan due 30 days before end of each year starting06/10/97 (30 days before each MercuryPerformance Test)

GP001

Performance Test Plan due 30 days before end of each year starting06/10/98 (30 days before each PerformanceTest to measure Front-half particulate matter,Total particulate matter, Total PCDD/PCDF,Hydrogen chloride, Lead, Cadmium, VOC,and Opacity)

GP001

Relative Accuracy Test Audit (RATA)Notification

due 30 days before end of each calendaryear starting 01/01/97 (but no later than 30days before CEMS Relative Accuracy TestAudit (RATA))

GP001

Relative Accuracy Test Audit (RATA) ResultsSummary

due 30 days after end of each calendar yearfollowing CEMS Relative Accuracy Test Audit(RATA) or 30 days after the quarter in whichthe CEMS RATA was conducted. This reportconsists of a results summary of the RATA.

GP001

As a state only requirement not federallyenforceable, Waste Composition Study andAnalysis Plan (if needed) and Notification

due 30 days before end of each 60 monthsstarting 06/20/97

GP001

As a state only requirement not federallyenforceable, Waste Composition Study andSample Analysis Report

due 45 days after end of each 60 monthsstarting 06/20/97

GP001

APPENDIX MATERIAL Facility Name: Covanta Hennepin Energy Resource Co LP Permit Number: 05300400-003

INSIGNIFICANT ACTIVITIES Unit: Applicable Requirements: EU 004 – Fly Ash Bin Minn. R. 7011.0715, subp. 1 A. & B. EU 006 – Activated Carbon Silo Minn. R. 7011.0715, subp. 1 A. & B.

Technical Support Document, Permit Action Number: 01700006-001 Page 1 of 11 Date: 1/28/2008

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 05300400-003 This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal regulations and Minn. R. (40 CFR, Section 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 permit. 1. General Information

1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 4953)

Covanta Hennepin Energy Resource Company, L.P. (CHERC)

505 6th Avenue North Minneapolis Hennepin County

Contact: Shannon Forss 612-332-9428

1.2. Description of the Permit Action The facility, located in downtown Minneapolis, is a waste combustion facility capable of burning 1212 tons per day of municipal waste in its two identical combustion units. By Minnesota Law, the overall facility was limited to 365,000 tons of waste annually, and the permit was drafted accordingly. The Permittee may burn industrial waste in accordance with their Industrial Solid Waste Management Plan. Steam generated from combustion heat is used power a 37.5 megawatt electrical generator. Some electricity services the facility, but the majority is sold to Xcel Energy. Ferrous metals are continuously recovered from the bottom ash before it is combined with fly ash and transported away to ash monofills. The facility was originally permitted in 1987, becoming operational in 1989. Mercury control equipment was added in 1994, with changes to carbon measurement equipment made in 2000. Each waste combustor unit (waterwall) is designed according to good combustion principles to minimize the emission of Carbon Monoxide (CO) and organics. Nitrogen Oxide (NOx) is controlled on an as-needed basis by injecting ammonia into the combustion chamber. Flue gases, upon leaving the combustion unit, first pass through a heat recovery system and then through ductwork where activated carbon is injected for the control of mercury. Flue gases then enter a lime slurry dry scrubber for control of acid gases, followed by a fabric filter for the


control of Particulate Matter (PM) (including metals and dioxins). Temperature in the fabric filter is limited, to prevent the formation of dioxins within the fabric filter. Flue gases lastly enter the stack, where continuous monitors measure opacity, CO, NOx, Sulfur Dioxide (SO2), and carbon dioxide. Operators, in turn, use the data from the monitors to determine real-time adjustments to the equipment. Limits exist on ash to prevent it from becoming airborne. The Permittee’s ash is wetted, which keeps emissions within this limit. 1.3 Description of the Activities Allowed by this Permit Action

This permitting action incorporates the following submitted by the Permittee:

1) Currently, each combustor’s pollution control system is equipped with a dedicated gravimetric activated carbon feed system. These systems are comprised of a gravimetric feeder and a pneumatic conveying system that deliver activated carbon to the flue gas stream. In the event one of the gravimetric feeders breaks down, the Permittee proposes to use one activated carbon feed system to feed both pollution control systems. The back-up system would utilize a single gravimetric feeder, except that the carbon would be pneumatically conveyed through a “Y” splitter to the two combustor pollution control systems.

2) The permit currently references both a 25 ppmv and 29 ppmv HCL emissions standard. With current federal and state standards now providing a 29 ppmv standard, the Permittee proposes to eliminate the now obsolete state only limit of 25 ppmv HCL emissions limit so that the permit is consistent with current rules. (see Minn. R. 7011.1227, table 1 and federal emissions guidelines provided in 40 CFR 60.33b.)

3) The Permittee proposes to “clean-up” certain items in the existing permit to conform with current operations and rules.

4) This permit reflects the Emission Units 005-008 as being part of the overall facility. These are units that were existing when the initial permit was issued, but were omitted.

5) This amendment also reflects a change in ownership. Hennepin County is now the facility owner. Covanta Hennepin Energy Resource Co. continues to operate the facility.

1.4. Permitting History Permit Number and Action Authorized


Issuance Date 2125-87-OT-1 January 27, 1987

Original total facility permit, authorizing construction.

Amendment No. 1 May 20, 1987

Extends by three months due dates for the Monitoring Plan, Ash Evaluation Plan, Ash Disposal Plan, and Unprocessed Waste Disposal Plan.

Amendment No. 2 December 1, 1988

Extends by 6 months the due date for the Emergency Response Plan.

Amendment No. 3 October 12, 1989

Rated heat input for auxiliary burners increased from 15 mmBtu to 40 mmBtu. Changes to fabric filter designs. “Tesisorb” bin added as an emission source. NOx control equipment added. Dioxin emission limit tightened. Facility startup prohibited until background environmental samples taken.

Amendment 4 December 18, 1989

“U.S. Trust Company” and “Blount Energy Resource Corp.” added as Permittees.

Amendment 5 June 4, 1991

Fabric filter design change. Hydrogen chloride stack sampling replaces the hydrogen chloride monitor requirement.

Pronto Permit September 27, 1993

Installation of mercury control equipment.

Permit No. 05300400-001 May 15, 1998

Title V Permit

Permit No. 05300400-002 June 7, 2002

Administrative Amendment deletes a redundant monitoring requirement; adds text to clarify the meanings of permit terms; deletes temperature-monitoring requirements because the applicable

requirement that has been repealed; updates citations to an applicable requirement where the

corresponding permit condition is not changed; name change deletes requirements for the mercury additive (carbon) measuring

system that has been removed; and adds requirements for the mercury additive (carbon) measuring

system that has been added.

1.5. Facility Emissions:


Table 1. Total Facility Potential to Emit Summary:

EU #

SV# Emission Unit Description

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Pb tpy

Single HAP tpy

All HAP

s tpy

001 001 MSW incinerator 42.5 42.5 49.9 440.6 130.8 13.1 0.55 42.6 43.3

002 002 MSW incinerator 42.5 42.5 49.9 440.6 130.8 13.1 0.55 42.6 43.3

003 003 Lime Silo 0.20 0.10 - - - - - - -

004 004 Fly Ash Bin1 Neg. Neg. - - - - - - -

005 005 Lime Silo-Dolomitic 0.70 0.40

006 006 Activated Carbon Silo1 Neg. Neg.

007 007 Combined Ash Handling 1.1 0.3

008 008, 009

Cooling Tower 4.9 4.2

PM

tpy PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Pb tpy

Single HAP tpy

All HAP

s tpy

Total Facility Limited Potential Emissions3

91.92 90.0 99.8 881 262 26.2 1.1 85.2 86.6

Total Facility Actual Emissions4 16.8 16.7 13.8 430.2 65.2 2.57 0.011 29.4 29.5 1 The Insignificant Activities accounted for in this permit action were previously installed.

2 Incinerator (both units) PM restricted to 90.0 tpy. It is noted that the incinerator emission calculations were based on 1998 P. Torkleson’s calculations (which were based on the permit limit of 0.020 gr/dscf). The 0.020gr/dscf limit is an unchanged, existing permit limit. The 0.020 gr/dscf limited PTE is 42.28 tpy per incinerator. The initial permit also had a 98.0 tpy PM limit for the two incinerators. This permit reduces the overall limit from 98.0 tpy to 90.0 tpy for the two incinerators. It is recognized that 0.020 gr/dscf limit is more restrictive. The Permittee requested the 90.0 tpy limit as a carryover from the initial permit. 3 These are the limited potential emissions from column 3 in GI-07 from Delta. For EU 001 – EU 003, they differ from those in the permit application sent by the company (for the 1998 permit) in that they have been verified and corrected as need be by MPCA staff. These are the potential emissions that would appear in a public notice.

4 Actual criteria pollutants are based on 2002 data. EU 005 – EU 008 are existing units. This amendment incorporates these units into this permit action. Hence, the potential PM PTE increases by 6.1 tpy and the PM10 PTE increases by 3.7


tpy. The overall existing facility wide front-half PM and total PM emission limits remain in place. These existing units have been accounted for within the past actual emission inventories.

Table 2. Permit Amendment Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD PM PM10 Part 70 Permit Program PM PM10 2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under Prevention of Significant Deterioration (PSD) New Source Review regulations. No NSR changes are authorized by this permit amendment.

Part 70 Permit Program

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

New Source Performance Standards (NSPS)

There are no New Source Performance Standards requirements triggered by this permit amendment.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

There are no NESHAP requirements triggered by this permit action.

Minnesota State Rules

The existing units (EU 005 – EU 008) are included in this permit. Proposed amendment changes are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

Table 4. Regulatory Overview of Units Affected by the Modification


Regulatory Overview

*EU, GRP, or SV

#

Applicable Regulations **Comments:

EU001 through EU008

Minn. R. 7007 Minnesota Rules for Air Emission Permits

EU001 and EU002

Minn. R. 7009 Minnesota Rules for Ambient Air Quality Standards

EU001 and EU002

Minn. R. 7011.1201ff Minnesota Rules for Waste Combustors

EU001 and EU002

Minn. R. 7035 Minnesota Rules for Solid Waste

EU001 and EU002

Minn. R. 7017 Minnesota Rules for Monitoring and Testing Requirements

EU001 and EU002

Minn. R. 7019 Minnesota Rules for Emission Inventory Requirements

EU001 and EU002

Minn. R. 7000.7000 Minnesota Rules for Variances

EU001 and EU002

Minn. Stat. 116.85 Minnesota Statutes for Monitors for Incinerators

EU001 and EU002

Minn. Stat. 116.07 Minnesota Statutes for Pollution Control Agency Powers and Duties

EU005 through EU008

Minn. R. 7011.0715 Minnesota Industrial Process Rule

EU001 and EU002

Minn. Stat. 115A Minnesota Statutes for Waste Management

EU001 and EU002

40 CFR pt. 50 National Primary and Secondary Ambient Air Quality Standards. Limits set for SO2.

EU001 and EU002

40 CFR § 52.21 Prevention of Significant Deterioration. BACT limits set in the 1987 permit for NOx, Lead, and Mercury.

EU001 and EU002

40 CFR pt. 60, subp. A General Provisions

EU001 and EU002

40 CFR pt. 60, subp. Db Standards of Performance for Industrial-Commercial- Institutional Steam Generating Units

EU001 and EU002

40 CFR pt. 60, subp. E Standards of Performance for Incinerators

EU001 and EU002

1984 Minn. Laws ch. 654, art. 2, sect. 29

Law limiting waste feed rate


3. Technical Information The Permittee proposed numerous changes in this permit amendment. Many of the proposed changes were to “clean-up” certain items in the existing permit to conform with current operations and rules. The existing total facility permit expired in May 18, 2003. Most of the Permittee’s proposed changes were addressed in this permit action. However, it was decided that some of the Permittee’s proposed changes would be better addressed during the total facility permit reissuance. The Permittee’s proposed amendment changes are attached. The following describe a number of the changes that were made in this amendment (-003).

Risk Management Plan (Total Facility, Item 39)

The requirement to submit a Risk Management Plan was specifically added to the general requirements. The Permittee has indicated that it has previously submitted a Risk Management Plan.

Lime Spray Dryers (GP004)

The initial permit, referred to the Lime Spray Dryers as scrubbers. The following from AP-42 provides:

In the spray drying process, lime slurry is injected into the spray dryers through dual-fluid nozzles. The water in the slurry evaporates to cool the flue gas, and the lime reacts with acid gases to form calcium salts that can be removed by a PM control device.

This permit action (-003) identifies CE 005 and CE 006 as lime spray dryers.

Name Change

In this permit action (-003), the specific requirement references to the facility’s owners have been replaced by “the Permittee.” Boiler Malfunction – CO Limit (GP 001, Item 3) The Permittee proposes to incorporate the new Federal Standards relating to malfunction exemptions (40 CFR 60.58b(1)(iii)). This regards CO limits during times of malfunction resulting in loss of boiler water level control or combustion air control. At this time, the MPCA recognizes NSPS Cb as guidance. Hence, the Minnesota rules need to be amended prior to facilities being able to adopt this exemption. At this time, the MPCA intends to adopt this exemption. Addition of Mercury Additive “Y” Splitter (GP 001, Items 36, 43, 46-49, 93, 106, 123,& 292)


Currently, each combustor’s pollution control system is equipped with a dedicated gravimetric activated carbon feed system. These systems are comprised of a gravimetric feeder and a pneumatic conveying system that deliver activated carbon to the flue gas stream. In the event one of the gravimetric feeders breaks down, the Permittee proposes to use one activated carbon feed system to feed both pollution control systems. The back-up system would utilize a single gravimetric feeder, except that the carbon would be pneumatically conveyed through a “Y” splitter to the two combustor pollution control systems. HCL Emission Limit (GP 001, Item 14) The permit currently references both a 25 ppmv and 29 ppmv HCL emissions standard. With current federal and state standards now providing a 29 ppmv standard, the Permittee proposes to eliminate the now obsolete state only limit of 25 ppmv HCL emissions limit so that the permit is consistent with current rules. (see Minn. R. 7011.1227, table 1 and federal emissions guidelines provided in 40 CFR 60.33b.) Operating Records (GP 001, Items 149 – 171) The operating recording requirements were clarified. In general, these provisions require that a record be made of the required items by the following day. This “operating record” will be kept by the particular facility person who is responsible for “logging” in the appropriate information. It is recognized that operating records may be located at different locations. But all operating records are to be available for a MPCA inspection. At the end of the appropriate month or quarter, the operating records are then to be compiled into one central location. In the 1998 Title V permit, the Permittee’s concern was that the term “Daily Operating Record” that appears in the rule. Many of these items do not occur daily (i.e., performance testing, training) and the facility wanted some clarification on how often the operating record needed to be changed for a given action.

PCDD/PCDF Performance Testing This permit reflects the most recent rule provisions allowing for less frequent PCDD/PCDF Performance Testing. Minn. R. 7011.1270. Compliance Certification Report (GP 001, Item 198)

The requirement was clarifed due to the Permittee’s inquiry as to whether the Compliance Certification Report is due quarterly. The report contains Annual report items, but is updated quarterly.

EU004 EU 004 (fly ash) is an insignificant activity. It has a dust collector, not a fabric filter. Hence, the CE 010 requirements were eliminated. The fly ash is conveyed by a drag chain. There is no air


pressure moving the ash. The conveyor drags the fly ash into a silo. The dust collector is non-pressurized.

Additional Unit Listing (EU 005 - 008)

This amendment reflects Emission Units 005 – 008 as being part of the overall facility. These are all existing units that are being included in this permit amendment. These emission units are:

EU 005 – Dolomitic Lime Silo

EU 006 – Activated Carbon Silo

EU 007 - Combined Ash Handling

EU 008 – Cooling Tower

EU 005 (dolomitic lime silo) is added to this permit amendment. It is estimated that this silo filling duration is about 2 hours per week.

EU 006 (activated carbon silo) is added as an insignificant activity to this permit amendment. It is estimated that this silo filling duration is about 2 hours per 6 week period.

EU 007 (combined ash handling) is added to this permit amendment. It is noted that 6% moisture content is imposed by the Permittee. This moisture content applies to control the fugitives while loading in the shed (i.e., after the baghouse).

EU 008 (cooling tower) is added to this permit amendment.

Dumpstacks

The initial facility design had a puppet installed prior to the baghouse. The concern was that during startups high moisture could be present that could adversely impact the baghouse. The baghouse has been able to accommodate the moisture levels. Hence, this feature was never used. Subsequently, it has been wielded shut. There are no other mechanisms to bypass this baghouse. Hence, these requirements were removed.

GP 006

The GP 006 fabric filters are allowed to be inspected at a 6 month interval. This is consist with the previous GP 005 fabric filters inspection frequency. This is for components subject to wear or plugging. The GP 006 fabric filters are utilized on a less frequent basis then the GP 005 fabric filters.

State Only Requirements


At the Permittee’s request, the following language was added “This is a state only requirement and is not federally enforceable.” This language was added to permit items: Total Facility items: 1, 12, and 34; GP 001 items: 40, 53, 83, 84, 150, 161, 178, and 199.

E.03.a

The one-hour arithmetic average consisting of 10 data points was deleted. The underlying rule basis for this requirement had been previously eliminated. This change is also reflected in E.04.b.

Incinerator Units’ PM Calculations

The emission calculations were based on 1998 P. Torkleson’s calculations which were based on the permit limit of 0.020 gr/dscf. The previous individual incinerator PTE was 49.0 tpy. The 0.020 gr/dscf limited PTE is 42.28 tpy per incinerator.

PM Limit The previous permit had a 98.0 tpy facility-wide limit for the two incinerators. With the inclusion of the existing units (EU 005 – 008) and the utilization of the 49.0 tpy PTE per incinerator, this caused the facility to go over 100 tpy. The facility chose to take a 90.0 tpy limit on the 2 incinerators. The PTE from EU 003- EU 008 and natural gas burning is less than 8 tpy. Hence, it is an equivalent limit. Incinerator PM10 The facility elected to equate PM to PM10 for the incinerator units. Previously, the facility was a 47% ratio between PM and PM10.

3.1 Calculations of Potential to Emit Attached are the Permittee’s emission calculations for EU 003 – EU 008. 3.2 Periodic 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 considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;


• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere:

This permit amendment does not alter any of the previously permitted periodic monitoring requirements. 3.3 Insignificant Activities

The Permittee has several operations which are classified as insignificant activities. These are listed in Appendix I to the permit. Both emission units are subject to the Minnesota Industrial Process Equipment Rule. 3.4 Permit Organization

The initial total facility permit was issued in 1998. At that time, Delta rules did not allow for the use of Groups. The combustor units as well as a number of the control equipment units had duplicative requirements. This permit action groups such units together. It is noted that GP 001 – B.03.c is entered as a CD in Delta. It is a limit. However, Delta did not allow it to be entered as a limit. 3.5 Comments Received If comments were received during the public notice period from the public or if comments are received from EPA, they should be described briefly here, as well as any changes made to the permit as a result of the comments. Generally, the comment letters should also be provided as attachments to the TSD. 4. Conclusion Based on the information provided by Covanta Hennepin Energy Resource Company, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 05300400-003, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Bruce Braaten (permit writer/engineer) Tom Sinn (enforcement) Peter Torkelson (peer reviewer) Attachments: 1. Calculations 2. Permittee’s Proposed Amendment Revisions

Documents

Air Emission Permit No. 05300400-003 Is Issued to Covanta ...Section A - Emissions A. hdr Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of