San Joaquin Valley

Air Pollution Control District

PERMIT UNIT: N-2073-1-10 EXPIR f{ flD

EQUIPMENT DESCRIPTION: \J

POWER GENERATION SYSTEM: TWO 400 TONIDAY MUNICIPAL SOLID WASTE COMBUST I[ RS

PRODUCING 21.5 MW OF ELECTRICITY EQUIPPED WITH DRY LIME SCRUBBERS, FLY ASH BAGHOUSE,

AMMONIA IN,IECTION SYSTEM, LIME SLURRY INJECTION, ACTIVATED CARBON INJECTION SYSTEM, LIME AND

SODA AND CARBON SILOS WITH FILTER VENTS, WASTE RECEIVING, ASH CONVEYING, AND ASH RESIDUE

ENCLOSURE

PIERMlll' UN~l' RIEQUIIREMENTS

1. A II equipment, faci lities and systems installed or used to comply with the terms and cond itions of this Perm it to

Operate shall be maintained in good working order and be operated as required to meet the conditions of this permit.

Operator shall, on each boiler, continuously operate and maintain the following air pollution controls to minimize

emissions: baghouse for the control of particulates; lime slurry dry scrubber for t he control of S02 and acid gas

emissions; and ammonia injection system for the control of NOx emissions. [District Rule 2080 & PSD SJ 86-03]

Federally Enforceable Through Title V Permit

2. The baghouse shall be equipped with a pressure differential gauge to indicate the pressure drop across the bags. The

gauge shall be maintained in good working condition at all times and shall be located in an easily accessible location.

[District NSR Rule and 40 CFR Part 64] Federally Enforceable Through Title V Permit

3. The baghouse shall have a maximum effective air-to-cloth ratio of4:1 and shall be equipped with an automatic

cleaning mechanism. [District NSR Rule] Federally Enforceable Through Title V Permit

4. Replacement bags numbering at least 10% of the total number of bags in the largest individual combustion unit

baghouse using each type of bag shall be maintained on the premises. [District NSR Rule] Federally Enforceable

Through Title V Permit

5. There shall be no visible emissions from any location other than designated vents on refuse receiving, processing or

storage buildings at any time, except as provided in this permit to operate. Visible emissions shall be inspected

quarterly under material and environmental conditions, such as dry and windy, where high emissions are expected.

[District Rules 2520,9.3.2 and NSR] Federally Enforceable Through Title V Permit

6. Paved areas shall be kept free of visible dust at all times and shall be vacuum swept at least once every fourteen days.

Records of vacuum sweeping shall be maintained and made available to the District upon request. [District Rule 4102]

7. The NOx control system shall be in full use whenever this equipment is fired with MSW. [District NSR Rule]

Federally Enforceable Through Title V Permit

8. The ash shall be handled in such a manner as to mitigate fugitive emissions to the maximum extent possible. Enclosure

shall be completely inspected annually for evidence of palticulate matter leaks and repaired as needed. [District Rules

2520,9.3.2 and NSR] Federally Enforceable Through Title V Permit

9. The facility shall not cause visible emissions from ash conveying systems, including transfer points, in excess of 5% of

the observation period, as determined by performing EPA Method 22 on a quarterly basis. Fugitive ash emissions do

not include emissions within a building, an enclosed ash conveyor, or during periods of maintenance and repair of the

ash conveyor systems. [40 CFR 60.36b] Federally Enforceabl~roughTitle V Permit

PERMIT UNIT I'\' liJ ~N UE ON NEXT PAGE

These terms and condl ill{.'J ~~ F ility-wide Permit to Operate.

Facility Name: COVANTA STANISLAUS, INC

Location: 4040 FINK RD,CROWS LANDING, CA 95313 N-2073-1·10: Feb 212012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 2 of 10

10. Fuel Oil #2, with a sulfur content not to exceed 0.25% by weight, may be used as necessary to maintain the minimum

combustion zone temperature requirements and annual usage shall not exceed 1,108,321 gallons for each combustor.

[District NSR Rule, 40 CFR 60. 44b(c) & PSD SJ 86-03] Federally Enforceable Through Title V Permit

1 I. A furnace roof temperature of 1,100 degrees F shall be stabilized, as measured by multiple thermocouples, to ensure

that a minimum temperature of 1,800 degrees F is established above the grate prior to the ignition of MSW. [District

NSR Rule] Federally Enforceable Through Title V Permit

12. During any period of time that MSW is burning on the grates, the combustion gas retention time shall be maintained at

a minimum of one second, the combustion zone temperature shall be maintained at a minimum of 1,800 degrees F, and

the furnace roof temperature shall be maintained at an average (4 hour arithmetic block) of 1, I00 degrees F, except

during periods of start-up, shutdown, and malfunction, as defined in 40 CFR 60.58b(a). [District NSR Rule] Federally

Enforceable Through Title V Permit

13. Hazardous materials shall not be burned in this equipment. Hazardous materials are that portion ofsolid waste which,

by reason of its composition or characteristics, is: (a) hazardous waste as defined in the Solid Waste Disposal Act, 42

USC section 690 I et. seq., and the regulations thereunder, the California Health & Safety Code, Div. 20, Chs. 6.5, 6.7,

and 6.8 (section 25100 et. seq.), the California Code of Regulations, Title 22, Div. 4.5, and any similar or substituted

legislation or regulations or amendments to the foregoing; (b) any other materials which any governmental agency or

unit having appropriate jurisdiction shall determine from time to time is harmful, toxic, or dangerous, or otherwise

ineligible for disposal through the facility; and (c) any material, other than residential or commercial solid waste of the

type historically collected by the County and the City as acceptable for disposal into non-hazardous waste landfills,

which would result in process residue being hazardous waste under (a) or (b) above. [District Rule 4102]

14. The facility shall develop and annually update a site-specific operating manual in accordance with 40 CFR 60.54b(e).

[40 CFR 60.35b] Federally Enforceable Through Title V Permit

15. Each operator and all maintenance personnel shall receive initial and annual training on the site-specific operating

manual in accordance with 40 CFR 60.54b(t). [40 CFR 60.35b] Federally Enforceable Through Title V Permit

16. The site-specific operating manual and operating manual training records shall be accessible to all operations and

maintenance personnel and shall be made available to the enforcement agency upon request. [40 CFR 60.35b]

Federally Enforceable Through Title V Permit

17. The District reserves the right to require the permittee to re-evaluate the health risk assessment if there is a significant

change in population locations as projected in the currently approved health risk assessment, or new health data

becomes available. [District Rule 4102]

18. During any 3-hour periods or startup, shutdown, and malfunction, the faci lity shall be exempt from emission Iim its

identified in this permit which are based upon 40 CFR 60 Subpart Cb or Subpart Eb. This exemption shall not apply to

CO emission limits of 40 CFR 60.53b(a) if the malfunction is a loss of boiler water level control. [District NSR Rule]

Federally Enforceable Through Title V Permit

19. Opacity exhibited by the gases discharged to the atmosphere from each combustion unit, other than water vapor, shall

not exceed 10 percent based on a six minute average as measured by EPA Method 9. [40 CFR 60.33b and 40 CFR Part

64] Federally Enforceable Through Title V Permit

20. The carbon monoxide (CO) emissions from each combustion unit shall not exceed 100 ppmv, dry, corrected to 7% 02,

as measured utilizing EPA Methods 1-4 and 10. Compliance with this limit shall be determined based on a four hour

block arithmetic average as defined in 40 CFR 60.51 b. [District Rule 4352 and 40 CFR 60.34b] Federally Enforceable

Through Title V Permit

21. The NOx emissions from each combustion unit shall not exceed 200 ppmv, dry, corrected to 12% C02 as measured by

EPA Methods 1-4 and 7E. Compliance with this limit shall be determined based on an eight rolling hour average.

[District NSR Rule, District Rule 4352, and 40 CFR 60.33b] Federally Enforceable Through Title V Permit

22. Either the S02 emissions from each combustion unit shall not exceed 30 ppmv, dry, corrected to 12% C02, based on

an eight hour rolling average, or the S02 removal effiCiemnhal1 beat least 80% as measured by EPA Methods 1-4

and 6C. The S02 80% removal efficiency shall b a e 1 e measurement ofthe inlet and outlet S02

concentrations, corrected to 12% C02.~sr~{ ~1 e <ederally Enforceable Through Title V Permit

PERMIT ~~~ eo I ~\3 S NTINUE ON NEXT PAGE

These terms and U· r of t Facility-wide Permit to Operate.

FaCility Name COVANTA STANISLAUS, INC

Location 4040 FINK RD.CROWS LANDING, CA 95313 N-207J.l·10; Feb 212012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 3 of 10

23. The S02 emissions from each combustion unit shall not exceed 29 ppmv, dry, corrected to 12% C02, or the S02

removal efficiency shall be at least 75% (by weight or volume), whichever is less stringent as measured by EPA

Methods 1-4 and 6C. Compliance with this limit shall be determined based on a 24-hour daily geometric mean. EPA

method 19 shall be used to calculate the daily geometric average sulfur dioxide emission concentration and removal

efficiency. [40 CFR 60.33b] Federally Enforceable Through Title V Permit

24. Palticulate matter emissions from each combustion unit shall not exceed 0.0275 gr/dscf, corrected to 12% C02, as

measured by EPA Methods I through 5, including the condensable portion in the "back-half'. [District NSR Rule]

Federally Enforceable Through Title V Permit

25. Filterable particulate matter (i.e. front half) emissions from each combustion unit shall not exceed any of the following

emission factors: 0.0 II gr/dscf, corrected to 12% C02; 25 milligrams/dscf, corrected to 7% 02; 0.10 lb/MMBtu heat

input. Owner or operator shall conduct a performance test for palticulate matter on a calendar year basis (no less than

9 calendar months and no more than 15 calendar months following the previous performance test, and must complete

five performance tests in each 5-year calendar period) with EPA Method I; EPA Method 3, 3A, or 3B; and EPA

Method 5. The minimum sample volume shall be 1.7 cubic meters. The probe and filter holder heating systems in the

sample train shall be set to provide a gas temperature no greater than 160 degrees C. An oxygen or carbon dioxide

measurement shall be obtained simultaneously with each Method 5 run. [District NSR Rule, District Rule 4301,40

CFR 60.33b, 40 CFR 60.38b, and 40 CFR 60.43b(d)( 1)] Federally Enforceable Through Title V Permit

26. Filterable particulate matter emissions from each combustion unit shall not exceed 0.008 gr/dscf, corrected to 12%

C02, for the fraction of particles less than 2u in diameter, as measured by Andersen Cascade Impactor, Flow Sensor

Multiclone or any other equivalent measurement as validated by EPA Method 301. [District NSR Rule] Federally

Enforceable Through Title V Permit

27. Each combustion unit shall only be allowed to emit half ofthe total allowable (mass) emission rate for each pollutant.

[District NSR Rule] Federally Enforceable Through Title V Permit

28. The CO emissions shall not exceed 800 pounds in anyone day. [District NSR Rule] Federally Enforceable Through

Title V Permit

29. The CO emissions shall not exceed 121.9 tons/yr. [District NSR Rule & PSD SJ 86-03] Federally Enforceable

Through Title V Permit

30. The NOx emissions shall not exceed 2,260 pounds in anyone day. [District NSR Rule] Federally Enforceable Through

Title V Permit

31. The NOx emissions shall not exceed 344.4 tons/year. [District NSR Rule & PSD SJ 86-03] Federally Enforceable

Through Title V Permit

32. The S02 emissions shall not exceed 800 pounds in anyone day. [District NSR Rule] Federally Enforceable Through

Title V Permit

33. The S02 emissions shall not exceed 121.9 tons/year. [District NSR Rule & PSD SJ 86-03] Federally Enforceable

Through Title V Permit

34. The PM emissions shall not exceed 475 pounds in anyone day. Particulate matter emissions shall not exceed the

hourly rate as calculated in District Rule 4202 using the equation E=3.59xPI\0.62 if P is less than or equal to 30 tons

per hour, or E= 17.37xP1\0. 16 if P is greater than 30 tons per hour. Particulate emissions shall be no more than O. I Ibs

per 100 Ibs of combustible refuse charged. [District Rules NSR, 4202, and 4203, 4.3] Federally Enforceable Through

Title V Permit

35. The PM emissions shall not exceed 72.4 tons/year. [District NSR Rule] Federally Enforceable Through Title V Permit

PERMIT~_I?NTINUE ON NEXT PAGE

These terms and . r ~~ Facility-wide Permit to Operate.

Facility Name: COVANTA STANISLAUS, INC

location: 4040 FINK RD,CROWS LANDING, CA 95313 N-2073-1-10: Feb 212012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 4 of 10

36. Emissions of combustion contaminants from each fuel burning equipment unit shall not exceed 10 Ib/h... Combustion

contaminants are defined as total PM (filterable plus condensable) minus the ammonium salts (e.g. ammonium

chloride, ammonium sulfate, ammonium bisulfate, etc.) present in the condensable PM fraction. A "fuel burning

equipment unit" is the minimum number offuel burning equipment required to operate simultaneously for the

production of useful heat. Compliance with this emission limit shall be demonstrated annually by source test

conducted according to EPA Methods 5 and 202 (or other APCO approved methods). Ammonium salts in the

condensable PM fraction shall be determined by analysis ofthe condensable PM fraction by ion chromatography (or

other APCO approved method). [District Rule 4301] Federally Enforceable Through Title V Permit

37. The THC emissions shall not exceed 96 pounds in anyone day. [District NSR Rule] Federally Enforceable Through

Title V Permit

38. The THC emissions shall not exceed 14.6 tons/year. [District NSR Rule] Federally Enforceable Through Title V

Perm it

39. The THC emissions (as CH4) from each combustion unit shall not exceed 70 ppmv, dIy, corrected to 12% C02 as

measured by EPA Methods 1-4 and 25A. [District NSR Rule] Federally Enforceable Through Title V Permit

40. Ammonia (N H3) breakthrough of the exhaust shall not exceed 50 ppmv, dry, as measured by BAAQM D Method ST1B. The facility shall be exempt from this condition for periods ofstart-up, shutdown, and malfunction as defined in

40 CFR 60.58b(a). [District Rule 4102]

41. The Antimony emissions from each combustion unit shall not exceed 0.0315 g/s as measured by CARB Method 436.

[District Rule 4102]

42. The Arsenic emissions from each combustion unit shall not exceed 0.0005 g/s as measured by CARB Method 436.

[District Rule 4102]

43. The Beryllium emissions from each combustion unit shall not exceed 0.00005 g/s as measured by CARB Method 436.

[District Rule 4102]

44. The Cadmium emissions from each combustion unit shall not exceed either ofthe following: 0,0013 g/s; 0.035

milligrams/dscf, corrected to 7% 02; each as measured by EPA Methods 1,3, and 29 [40 CFR 60.33b and District

Rule 4102] Federally Enforceable Through Title V Permit

45. The Chromium +6 emissions from each combustion unit shall not exceed 0.00005 g/s as measured by CARS Method

436 (5% of the total chromium shall be considered to be hexavalent chromium). [District Rule 4102]

46. The Copper emissions from each combustion unit shall not exceed 0.155 g/s as measured by CARB Method 436.

[District Rule 4 102]

47. The Dioxin/Furan emissions from each combustion unit shall not exceed 30 ng/dscm (total mass), corrected to 7% 02,

as measured by EPA Method 23. [40 CFR 60.33b] Federally Enforceable Through Title V Permit

48. The Dioxin/Furan emissions from each combustion unit shall not exceed 50 ng/s, based on the Department of Health

Services toxic equivalent calculation. [District Rule 4102]

49. The Hydrogen Fluoride (HF) emissions from each combustion unit shall not exceed 0.05 g/s as measured by EPA

Method 26. [District Rule 4102]

50. The Hydrogen Chloride (HCI) emissions from each combustion unit shall not exceed either of the following: IA g/s;

29 ppmv or the HCI removal efficiency shall be at least 95% (by weight or volume), whichever is less stringent,

corrected to 7% 02; each as measured by EPA Method 26. [40 CFR 60.33b and District Rule 4102] Federally

Enforceable Through Title V Permit

51. The Lead emissions from each combustion unit shall not exceed either of the following: 0.014 g/s; OAOO

milligrams/dscf, corrected to 7% 02; each as measured by EPA Methods 1,3, and 29. [40 CFR 60.33b and District

Rule 4102] Federally Enforceable Through Title V Permit

52. The Manganese emissions from each combustion unit Sha~1t exceed 0.055 g/s as measured by CARS Method 436.

IDistrict Rule 4102] _

PERMIT I S NTINUE ON NEXT PAGE

These terms and \J' . r of t Facility-wide Permit to Operate.

FaCIlity Name COVANTA STANISLAUS, INC

Location 4040 FINK RD,CROWS LANDING, CA 95313 N-2073-1-10: Feb 212012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 5 of 10

53. The Mercury emissions from each combustion unit shall not exceed 0.050 mg/dscm, corrected to 7% 02, or the

mercury removal efficiency shall be at least 85% by weight, whichever is less stringent, as measured by EPA Methods

1,3, and 29. [40 CFR 60.33b] Federally Enforceable Through Title V Permit

54. The Mercury emissions from each combustion unit shall not exceed 0.0025 g/s (3-hour average). [PSD ATC SJ 86-03

and District Rule 4102] Federally Enforceable Through Title V Permit

55. The Nickel emissions from each combustion unit shall not exceed 0.025 g/s as measured by CARB Method 436.

[District Rule 4102]

56. The Selenium emissions from each combustion unit shall not exceed 0.055 g/s as measured by CARB Method 436.

[District Rule 4102]

57. The Vanadium emissions from each combustion unit shall not exceed 0.15 g/s as measured by CARB Method 436.

[District Rule 4102]

58. The Zinc emissions from each combustion unit shall not exceed 0.315 g/s as measured by CARB Method 436. [District

Rule 4102]

59. The mass emission rates shall be calculated from the hourly stack concentrations and the volumetric flow rate using

municipal solid waste Carbon Dioxide based F-factor of 1820 dscf/MMBtu (EPA Method 19, Table 19-2). [District

NSR Rule & PSD SJ 86-03] Federally Enforceable Through Title V Permit

60. The total steam generated from each boiler shall not exceed 110% of the maximum demonstrated combustion unit load

achieved in the most recent Dioxin/Furan performance test, as defined in 40 CFR 60.51 b. [40 CFR 60.34b(b)]

Federally Enforceable Through Title V Permit

61. The maximum flue gas temperature, measured at the particulate matter control device inlet from each boiler, shall not

be higher than 17 deg. C (3 I deg. F) above the maximum demonstrated particulate matter control device temperature

as defined in 40 CFR 60.5\ b. [40 CFR 60.34b(b)] Federally Enforceable Through Title V Permit

62. The steam load and particulate matter control device inlet flue gas temperature limitations shall apply at all times

except during the annual Dioxin/Furan performance test, the two weeks preceding the annual Dioxin/Furan

performance test, and when the facility obtains a waiver in accordance with permission granted by the Administrator or

the Air Pollution Control Officer. [40 CFR 60.53b(b)] Federally Enforceable Through Title V Permit

63. The ammonia (NH3) injection rate shall be measured and recorded continuously. [District NSR Rule] Federally

Enforceable Through Title V Permit

64. The facility shall install, calibrate, maintain, and operate a carbon dioxide CEM at the economizer and stack locations

of each combustion unit, in accordance with 40 CFR 60.58b(b) and Appendices Band F. [40 CFR 60.38b and District

Rule 4352] Federally Enforceable Through Title V Permit

65. The facility shall install, calibrate, maintain, and operate a continuous opacity monitoring system in accordance with

40 CFR 60.13 and Appendix B. [40 CFR 60.38b and 40 CFR Part 64] Federally Enforceable Through Title V Permit

66. The facility shall install, calibrate, maintain, and operate a sulfur dioxide CEM at the stack locations in accordance

with 40 CFR 60.58b(e) and Appendices Band F. [40 CFR 60.38b] Federally Enforceable Through Title V Permit

67. The facility shall install, calibrate, maintain, and operate a nitrogen oxides CEM at the stack locations in accordance

with 40 CFR 60.58b(h) and Appendices Band F. [40 CFR 60.38b and District Rule 4352] Federally Enforceable

Through Title V Permit

68. The facility shall install, calibrate, maintain, and operate a carbon monoxide CEM at the stack locations in accordance

with 40 CFR 60.58b(i) and Appendices Band F. [40 CFR 60.38b] Federally Enforceable Through Title V Permit

69. The facility shall install, calibrate, maintain, and operate a continuous steam flow monitoring and recording device and

a device to measure temperature at the inlet of each particulate matter control device in accordance with 40 CFR

60.58b(i). [40 CFR 60.38b] Federally Enforceable Through Title V Permit

PERMIT~-_,?NTlNUE ON NEXT PAGE

The,e lem" and I'J' . , :r Fac;';ly-w;de Penn;llo Ope,ale.

Facility Name: COVANTA STANISLAUS, INC

Location: 4040 FINK RD,CROWS LANDING, CA 95313 N-2073·' ·10: Feb 21 2012 4;31PM·· THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 6 of 10

70. The permittee shall be responsible for providing the District access, via telemetry, to the stored computerized data

associated with the continuous emission monitoring system. [District Rule 1080,7.0] Federally Enforceable Through

Title V Permit

71. Continuous monitoring and recording equipment shall be provided for the following: No.2 fuel oil burning rate and

temperature. Each combustion unit shall have sufficient monitors to demonstrate combustion unit temperature profile

as required in condition 12 and tlue gas temperature into the pal1iculate matter control device as required by condition

61. [District Rule 1080, 7.0] Federally Enforceable Through Title V Permit

72. In the event that monitoring or test data show that emissions from the facility exceed any emission limitation

conditions of this Permit to Operate, the permittee shall take immediate corrective action to bring the plant's emissions

within these limitations. [District NSR Rule] Federally Enforceable Through Title V Permit

73. Emissions in excess ofthose allowed by this permit shall be cause for the District to order an immediate reduction in

fuel feed rate or to take other appropriate abatement action. [District Rule 2080] Federally Enforceable Through Title

V Permit

74. The permittee shall notify the District of any emission violation by the next working day after such violation has

occulTed. [District Rule 2080] Federally Enforceable Through Title V Permit

75. Performance testing to demonstrate compliance with permit conditions shall be conducted annually (at least every

calender year but no later than 12 months from previous performance testing). The main exhaust stack shall be

equipped with permanent provisions to allow collection of stack gas samples using approved test methods. [District

Rule 1081,3.0,4.0 & PSO SJ 86-03] Federally Enforceable Through Title V Permit

76. Performance testing shall be conducted using the methods and procedures approved by the District. The District must

be notified 30 days prior to any performance test, and a test plan must be submitted for approval 15 days prior to

testing. [District Rule 1081, 7.1] Federally Enforceable Through Title V Permit

77. The results of each performance test shall be submitted to the District within 60 days thereafter. [District Rule 1081,

7.3] Federally Enforceable Through Title V Permit

78. Performance tests shall include a test of both combustion unit exhausts following the baghouse for the following

parameters, corrected to 12% C02 on a dry basis: Oxides of nitrogen emissions; Total hydrocarbons, as methane;

Carbon monoxide; Sulfur dioxide; Concentrations of gaseous ammonia (NH3); and Exhaust flow rate, wet and dlY.

[District Rule 1081,4.0]

79. Performance tests shall include: Total pm1iculate matter emission concentration corrected to 12% C02 and shall be

conducted including the condensable pOl1ion in the "back half'; and Filterable pal1iculate matter emission

concentration corrected to 12% C02 and shall be conducted including only "front-half". If the measured Filterable

pal1iculate matter emission concentration is greater than 0.008 gr/dscf, corrected to 12% C02, testing shall be

conducted to verify compliance with condition 26. [District Rule 1081,4.0] Federally Enforceable Through Title V

Permit

80. Performance tests shall include a test of both combustion unit exhausts following the baghouse for the following

parameters, corrected to 12% C02 on a dry basis: Polynuclear aromatic hydrocarbons (Benzo-A-Pyrene, Benzo-EPyrene, Benzo-A-Anthracene, and Coronene and PCB); and Dioxins and Furans. [District Rule 1081, 4.0] Federally

Enforceable Through Title V Permit

81. The following Dioxin isomers & homologues shall be measured in both the combustion unit exhausts: 2,3,7,8 tetra

CDD; total tetra COD; 1,2,3,7,8 penta CDO; total penta CDD; 1,2,3,4,7,8 hexa COD; 1,2,3,6,7,8 hexa CDD;

1,2,3,7,8,9 hexa COD; total hexa COD; 1,2,3,4,6,7,8 hepta COD; total hepta COD; total octa COD. [District Rule

1081,4.0] Federally Enforceable Through Title V Permit

82. The following Furan isomers & homologues shall be measured in both the combustion unit exhausts: 2,3,7,8 tetra

CDF; total tetra COF; 1,2,3,7,8 penta COF; 2,3,4,7,8 penta CDF; total penta CDF; 1,2,3,4,7,8 hexa COF; 1,2,3,6,7,8

hexa COF; 1,2,3,7,8,9 hexa COF; 2,3,4,6,7,8 hexa CDF; total hexa CDF; 1,2,3,4,6,7,8 hepta CDF; 1,2,3,4,7,8,9 hepta

CDF; total hepta COF; total octa COF. IDistrict Rule I08~'O] Federally Enforceable Through Title V Permit

PERMIT~_IS NTINUE ON NEXT PAGE

These terms and . r of t Facility-wide Permit to Operate.

Facility Name, COVANTA STANISLAUS, INC

Location' 4040 FINK RD,CROWS LANDING, CA 95313 N·2073-1·10: Feb 21 2012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 7 of 10

83. The facility may elect to alternate Dioxin/Furan testing on each stack, if the previous two years indicate Dioxin/Furan

emissions levels are less than or equal to 15 ng/dscm total mass, corrected to 12% C02. [40 CFR 60.38b and District

Rule 4102] Federally Enforceable Through Title V Permit

84. Performance tests of both combustion unit exhausts shall be performed for HCI, corrected to 12% C02 on a dry basis,

and for the following heavy metals, corrected to 12% C02 on a dry basis: Antimony, Arsenic, Belyllium, Cadmium,

Total Chromium (5% of the total chromium shall be considered to be hexavalent chromium), Copper, Lead,

Manganese, Mercury, Nickel, Selenium, Vanadium, and Zinc. [District Rule 1081,4.0] Federally Enforceable Through

Title V Permit

85. A performance test of both combustion unit exhausts shall be performed for HF, corrected to 12% C02 on a dry basis.

[District Rule 4102]

86. Cooling tower drift shall not exceed 0.005 percent of the circulating water flow or a maximum annual drift emission

rate of 1,090,000 kg/year as demonstrated by design calculations. Chromium compounds shall not be used as an

additive in the cooling tower water. [District Rule 4] 02]

87. Soot blowers or super heater rappers shall be operated in a mode consistent with normal cleaning requirements ofthe

system during the performance tests. [District Rule 1081,4.0] Federally Enforceable Through Title V Permit

88. The facility shall submit an annual report in accordance with 40 CFR 60.59b(g) by February I of each year following

the calendar year in which the data were collected. [40 CFR 60.39b] Federally Enforceable Through Title V Permit

89. The facility shall submit semiannual rep0l1s within 31 days following the end of each 6 month period in accordance

with 40 CFR 60.59b(h). [40 CFR 60.39b] Federally Enforceable Through Title V Permit

90. A monthly report summarizing the quantity of pollutant emissions of S02, NOx, and CO, based on data from the CEM

system, shall be included in the information required by following condition. Copies of the monthly repol1s prepared

pursuant to this condition shall be sent to the district office by the] 5th day of the following month. [District Rule

1070,4.0] Federally Enforceable Through Title V Permit

91. Permittee shall maintain a complete file containing all measurements, records, required monitoring data and suppol1

information. Supp0l1 information includes copies of all reports required by this permit and for continuous monitoring

instrumentation, and all calibration and maintenance records. This me shall include, but not be limited to: (a) Data

collected from in-stack monitoring instruments; (b) Input rate records for all fuels burned; (c) Purchase records that

indicate the sulfur content, by weight, of all fuel oil #2 purchased; (d) Resu Its of all source tests; (e) All other air

pollution system performance evaluations and records of cal ibration checks, calibration gas cylinder changes,

adjustments and maintenance performed on all equipment (including CEM adjustment or maintenance). [District Rule

1070,4.0 & PSD SJ 86-03] Federally Enforceable Through Title V Permit

92. Records shall be kept for each unit with the following: (a) Specific time of operation of each combustion unit; (b)

Specific time of operation of the auxiliary burners; (c) Equipment breakdowns or malfunctions; (d) Exceedances of

emission standards. [District Rule 1070,4.0] Federally Enforceable Through Title V Permit

93. The permittee shall follow all written maintenance procedures and schedules for the following: all emissions control

equipment, combustion units, and monitoring equipment for measuring emission levels. [District Rule 1070,4.0]

Federally Enforceable Through Title V Permit

94. Operating and maintenance manuals, subject to District review, shall be provided for the equipment covered by this

permit. The permittee's operators shall be trained in the operation and maintenance of both fuel burning and pollution

control equipment. [District Rule 1070,4.0] Federally Enforceable Through Title V Permit

95. If the Fuel Oil #2 is Air Resources Board regulated diesel fuel, with a supplier certitied sulfur content less than 0.25%

by weight, the operator shall maintain copies of all fuel invoices and supplier certifications. [District Rule 2520, 9.3.2]

Federally Enforceable Through Title V Permit

96. If the Fuel Oi I #2 is non-certified for sui fur content of less than 0.25% by weight, then the owner or operator shall

determine the sulfur content of each del ivery of Fuel Oi I being fired. The su Ifur content shall be determined using

ASTM method D 2880. [District Rule 2520, 9.3.2] Fe ~'~nforceable Through Title V Permit

S NTINUE ON NEXT PAGE

of t Facility-wide Permit to Operate.
Permit Unit Requirements for N-2073-1-10 (continued) Page 8 of 10

97. Permittee shall provide access to all sampling POlts and platforms on boiler exhaust stacks in accordance with 40 CFR

60. 8(e) and District Rule 1081 (as amended 12/16/93). [District Rule 1081, 3.3; & PSD SJ 86-03] Federally

Enforceable Through Title V Permit

98. The S02 emissions from both combustion units shall be more stringent of 35.6 Ib/hr or 42 ppm, dry, corrected to 12%

C02, averaged over three hour period and more stringent of33.3 Ib/hr or 40 ppm, dry, corrected to 12% C02,

averaged over a 24 hour period. [PSD SJ 86-03] Federally Enforceable Through Title V Permit

99. The NOx emissions from both combustion units shall be more stringent of 107 Ib/hr or 175 ppm, dry, corrected to 12%

C02, averaged over three hour period and more stringent of 100 Ib/hr or 165 ppm, dry, corrected to 12% C02,

averaged over a 24 hour period. lPSD SJ 86-03] Federally Enforceable Through Title V Permit

100. The CO em issions from both combustion units shall be 33.3 Ib/hr or 400 ppm, dry, corrected to 12% C02 (3-hour

average). [PSD SJ 86-03] Federally Enforceable Through Title V Permit

10 I. The Mercury emissions from both combustion units shall not exceed 0.083 Ib/hr (3-hour average) as measured by EPA

Method 101. Upon EPA approval ofa change to the facility PSD permit allowing Method 29 to be used in place of

Method 10 I, Method 29 may be used to measure Mercury emissions. (40 CFR Part 61, Appendix B). [PSD SJ 86-03]

Federally Enforceable Through Title V Permit

102. Permittee shall submit a written report of all excess emissions to EPA (Attn: A-3-3) for every calendar quarter. The

report shall include the following: (a) the magnitude of excess emissions computed in accordance with 40 CFR

60.13(h), any conversion factors used, and the date and time of commencement and completion of each time period of

excess emissions. (b) Specific identitication of each time period of excess emissions that occurs during startups,

shutdowns, and malfunctions of furnace/boiler system. The nature and cause of mal function (if known) and corrective

action taken or preventive measures adopted shall be repOlted. (c) The date and time identifying each period during

which continuous monitoring system was inoperative except for zero and span checks, and the nature of the system

repairs and adjustments. (d) When no excess emissions have occurred or the continuous monitoring system has not

been inoperative, repaired, or adjusted, such in formation shall be stated in report. (e) Excess emissions shall be defined

as any three-hour period during which the average emissions of NOx, S02, and/or CO, as measured by continuous

monitoring system exceeds the NOx, S02, and/or CO emission limit set for each of the pollutants. (I) Excess

emissions indicated by the CEM system shall be considered violations ofthe applicable emission limit for purposes of

PSD permit. [PSD SJ 86-03] Federally Enforceable Through Title V Permit

103. The calcu lation of annual emissions shall commence with the submission of the first fourth-quarter report, and wi II

continue to be calculated and submitted with each successive quarterly report. The annual emissions shall be computed

on a daily (i.e. 24 hours) basis and shall be running total of the latest 8,760 hours. The quarterly reports shall contain

highest annual emissions computed for each week in the quarter, as well as all excesses of the annual emissions limits.

[PSD SJ 86-03] Federally Enforceable Through Title V Permit

104. Permittee shall meet all applicable requirements of Subparts A, Db, and E of 40 CFR 60. [PSD SJ 86-03] Federally

Enforceable Through Title V Permit

105. Permittee shall comply with following activated carbon mass feed requirements: (1) During the initial performance test

and each subsequent performance test for dioxins/furans and mercury, as applicable, the permittee shall calculate and

record an average carbon mass feed rate in pounds per hour being employed based on load cell measurements of

carbon feed during the test; (2) During operation of the facility, the carbon injection mass feed rate must be measured

using load cells, calculated and recorded on an eight (8) hour block average basis, and must equal or exceed the

level(s) documented during the most recent performance tests for dioxins/furans and mercury. When calculating the

eight (8) hour block average, exclude the hours when the combustion unit is not operational and include the hours

when the combustion unit is operating but the carbon feed system is not working properly. [40 CFR 60.38b & 40 CFR

60.58b(m)(1), (2)] Federally Enforceable Through Title V Permit

106. The permittee shall estimate the total carbon usage ofthe plant (kilograms or pounds) for each calendar quarter by two

independent methods, according to the following procedures: (I) The weight of carbon del ivered to the plant. (2) The

permittee shall estimate the average carbon mass feed rate for each during the operation of each combustion unit, and

sum the results for both un its at the plant for the total e of hours of operation during the calendar quarter. [40

CFR 60.38b & 40 CFR 60.58b(m)] Federal 11 'Hough Title V Permit

PERMIT~ MI NTINUE ON NEXT PAGE

These terms and . r Facility-wide Permit to Operate.

Facility Name: COVANTA STANISLAUS, INC

Location 4040 FINK RD,CROWS LANDING, CA 95313 N-2013·'·10: Feb 21 2012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 9 of 10

107. Should additional guidance related to the June 3, 1986 PSD remand, applicable to PSD permit action, be developed,

the Permittee shall provide to EPA any such analysis, data, or demonstration of compl iance with the other

requirements within the time required by the guidance. [PSD SJ 86-03] Federally Enforceable Through Title V Permit

108. The Regional Administrator shall be notified by telephone within 48 hours following any failure of air pollution

control equipment, process equipment, or ofa process to operate in a normal manner which results in an increase in

emissions above any allowable emissions limit stated in Section V III of these conditions. In addition, the Regional

Administrator shall be notified in writing within fifteen (15) days of any such failure. This notification shall include a

description of the malfunctioning equipment or abnormal operation, the date of the initial failure, the period oftime

over which emissions were increased due to the failure, the cause ofthe failure, the estimated resultant emissions in

excess of those allowed under Section IX of these conditions, and the methods utilized to restore normal operations.

Compliance with this malfunction notification provision shall not excuse or otherwise constitute a defense to any

violations ofthis permit or of any law or regulations which such malfunction may cause. [PSD SJ 86-03] Federally

Enforceable Through Title V Permit

109. Facility shall operate only when a fully certified chief facility operator or fully certified shift supervisor is on duty,

except as allowed under 40 CFR 60.54b(c)(2). [40 CFR 60.35b] Federally Enforceable Through Title V Permit

110. All chief facility operators, shift supervisors, and control room operators shall have completed the EPA or State

municipal waste combustor operator training course. [40 CFR 60.35b] Federally Enforceable Through Title V Permit

II I. Owner or operator shall conduct a performance test for opacity on a calendar year basis (no less than 9 calendar

months and no more than 15 calendar months following the previous performance test, and must complete five

performance tests in each 5-year calendar period) using EPA Method 9 and the average of three test runs to determine

compliance. [40 CFR 60.38b] Federally Enforceable Through Title V Permit

I 12. Permittee shall establish parameters for the differential pressure across the baghouse filter, which provides a

reasonable assurance of ongoing compliance with emission limitations stated in this permit. The initial parameters

shall be established using manufacturer/supplier recommendations and by correlating with opacity readings and source

test results. These parameters shall be reviewed annually and rev ised if necessary based on PM 10 source test result

data, historical operating data and manufacturer/supplier recommendations. [40 CFR Part 64] Federally Enforceable

Through Title V Permit

I 13. The baghouse differential operating pressure shall be monitored and recorded on each day the solid waste

combustors/boilers operate. The permittee shall compare the readings with the acceptable range. Upon detecting any

excursion from the acceptable range pressure readings, the permittee shall investigate the excursion and take corrective

action to minimize excessive emissions and prevent recurrence of the excursion as expeditiously as practicable. [40

eFR Part 64] Federally Enforceable Through Title V Permit

114. The permittee shall comply with the compliance assurance monitoring operation and maintenance requirements of 40

CFR part 64.7. [40 CFR 64] Federally Enforceable Through Title V Permit

115. If the District or EPA determine that a Quality improvement Plan is required under 40 eFR 64.7(d)(2), the permittee

shall develop and implement the Quality Improvement Plan in accordance with 40 CFR 64.8. [40 CFR Part 64]

Federally Enforceable Through Title V Permit

116. The permittee shall comply with the recordkeeping and reporting requirements of 40 eFR 64.9 [40 CFR Part 64]

Federally Enforceable Through Title V Permit

117. During any 96-hour periods of startup or 12-hour periods of shutdown, the facility shall be exempt from emission

limits identified in this permit which are based upon District Rule 4352. [District Rule 4352] Federally Enforceable

Through Title V Permit

118. Within 6 months of the renewed Title V permit being issued, permittee shall apply for an Authority to Construct

(ATC) and fully implement one of the following: I) modify post-control PM 10 emissions rate to less than 70 tons/yr or

2) insta lIon the baghouse an air leak detection system or continuous PM I0 emissions mon itor. [40 CFR Part 64]

Federally Enforceable Through Title V Permit

PERMIT~_I?NTINUEONNEXTPAGE

These terms and \f. , ~~~ Fac;Uly-w;de Pelm;l!o Operate.

Facility Name: COVANTA STANISLAUS. INC

Location: 4040 FINK RD.CROWS LANDING. CA 95313 N·207;}.1·10: Feb 212012 4:31PM - THAOC
Permit Unit Requirements for N-2073-1-10 (continued) Page 10 of 10

119. Upon detecting any excursion from the 10% opacity limit, the permittee shall investigate the excursion and take

corrective action to minimize excessive emissions and prevent recurrence ofthe excursion as expeditiously as

practicable. Corrective action shall include the following: inspecting the dust collector system for any tears, abrasions,

or holes in the filters; inspecting closed duct systems for damage; and repairing or replacing any defective or damaged

material. [40 CFR Part 64] Federally Enforceable Through Title V Permit

120. The baghouse shall operate at all times with a minimum di fferential pressure of 2 inches water column and a maximum

differential pressure of 10 inches water column [40 CFR Part 64] Federally Enforceable Through Title V Permit

121. The baghouse differential operating pressure shall be monitored and recorded on each day the solid waste

combustors/boilers operate. The permittee shall compare the readings with the acceptable range. Upon detecting any

excursion from the acceptable range pressure readings, the permittee shall investigate the excursion and take corrective

action to minimize excessive emissions and prevent recurrence ofthe excursion as expeditiously as practicable.

Corrective action shall include the following: inspecting the dust collector system for any tears, abrasions, or holes in

the filters; inspecting closed duct systems for damage; and repairing or replacing any defective or damaged material.

[40 CFR Pa1164] Federally Enforceable Through Title V Permit

122. On and after January 1,2013, permittee shall demonstrate compliance with Table I emission limits and all applicable

requirements of District Rule 4352 (December 15,20 II). [District Rule 4352] Federally Enforceable Through Title V

Perm it

123. Each time S02 emissions from each combustion unit exceeds 30 ppmv, dry, corrected to 12% C02, based on an eighthour rolling average, facility shall demonstrate that S02 removal efficiency is at least 80% as measured by EPA

Methods 1-4 and 6C, based on the measurement ofthe inlet and outlet S02 concentrations. [40 CFR Par164]

These termsandWJ~· ;Q, ~~ F.c;;;;y-w;de Penn;; 10 Ope,.le.

Facility Name: COVANTA STANISLAUS. INC \\f Location: 4040 FINK RD.CROWS LANDING. CA 95313 N-2073-1-10: Feb 212012 4:31PM - TKAOC