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STATE OF MICHIGAN 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

LANSING 

DE it 

RICK -· SNYDER 

GOVERNOR 

September 21, 2015 

Dr. Susan Hedman, Regional Administrator 

United States Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard (R-19J) 

Chicago, Illinois 60604 

Dear Dr. Hedman: 

DAN WYANT 

DIRECTOR 

SUBJECT: State Plan for Implementation and Enforcement of Emission Guidelines 

and Compliance Times for Existing Sewage Sludge Incineration (SSI) 

Units 

Through this letter, the Michigan Department of Environmental Quality (MDEQ) is 

requesting approval of Michigan's "State Plan for Implementation and Enforcement of 

Emission Guidelines and Compliance Times for Existing Sewage Sludge Incineration 

Units," included in 40 CFR Part 60, Subpart MMMM, "Emission Guidelines and 

Compliance Times for Existing Sewage Sludge Incineration Units." 

The enclosed State Plan for existing SSI units addresses the nine required elements for 

an acceptable State Plan specified in 40 CFR §60.5015, including R 336.1902, 

"Adoption of standards by reference," and R 336.1972, "Emission Standards for Existing 

Sewage Sludge Incineration Units," of the administrative rules promulgated pursuant to 

Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection 

Act, 1994 PA 451, as amended. R 336.1972 is the MDEQ rule that states the emission 

limitations, emission standards, operator training and qualification requirements, 

performance testing, monitoring, recordkeeping, and reporting requirements are as 

protective as those in Subpart MMMM. R 336.1902 incorporates by reference into the 

MDEQ rules the standards in Subpart MMMM. Though the MDEQ in R 336.1902 has 

adopted by reference all of 40 CFR Part 60, the MDEQ acknowledges that the following 

Subpart MMMM authorities are non-delegable from the United States Environmental 

Protection Agency (USEPA): 

1. Approval of alternatives to the emission limits and standards in Tables 2 and 3 of 

Subpart MMMM, and operating limits established under 40 CFR §60.5175 or 

40 CFR §60.5190. 

2. Approval of major alternatives to test methods. 

3. Approval of major alternatives to monitoring. 

4. Approval of major alternatives to record keeping and reporting. 

5. The requirements in 40 CFR §60.5175. 

6. The requirements in 40 CFR §60.5155(b)(2). 

7. Performance test and data reduction waivers under 40 CFR §60.8(b). 

CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P .0. BOX 30473 • LANSING, MICHIGAN 48909-7973 

www.michigan.gov/deq • (BOO) 662-9278 
Dr. Susan Hedman 

Page 2 

September 21, 2015 

Therefore, the MDEQ requests approval of the enclosed State Plan, with the exception 

of the above-named exclusions. 

An opportunity for public comment and hearing has been provided on this State Plan. 

The public notice addressing this State Plan was published in the July 13, 2015, MDEQ 

Environmental Calendar, located on the MDEQ Web site at: 

http://www.michigan.gov/envcalendar. A copy of the MDEQ Environmental Calendar 

excerpt is included as Attachment C. Attachment C also includes the Opening 

Statement for the August 19, 2015, MDEQ public hearing, a copy of the one comment 

received concerning this State Plan, and the MDEQ's response to it. 

If you should have any questions regarding this submittal, please contact Ms. Lynn 

Fiedler, Chief, Air Quality Division, at 517-284-6773; fiedlerl@michigan.gov; or MDEQ, 

P.O. Box 30260, Lansing, Michigan 48909-7760; or you may contact me. 

Enclosure 

=;!;i0 

Dan Wyant 

Director 

517-284-6700 

cc/enc: Ms. Margaret Sieffert, US EPA, Region 5 

Mr. Jim Sygo, Chief Deputy Director, MDEQ 

Ms. Lynn Fiedler, MDEQ 

Ms. Mary Maupin, MDEQ 

Ms. Erica Wolf, MDEQ 
Dan Wyant 

Director 

STATE PLAN FOR IMPLEMENTATION 

AND ENFORCEMENT OF EMISSION 

GUIDELINES AND COMPLIANCE TIMES 

FOR EXISTING SEWAGE SLUDGE 

INCINERATION UNITS 

September 21, 2015 

Prepared by: 

Michigan Department of Environmental Quality 

Air Quality Division 

P.O. Box 30260 

Lansing, Ml 48909-7760 

INTERNET: httpJ!www.michigan.gov/deqair 
TABLE OF CONTENTS 

Introduction 

Inventory of SSI Units and Compliance Dates 

pg. 1 

pg.2 

Emissions Inventories pg.3 

Enforceable State Mechanism and Requirements at 

Least as Protective as the Federal Emission Guidelines pg. 3-6 

Provision for State Progress Reports to the US EPA pg.6 

ATTACHMENTS: 

ATTACHMENT A Part 9, Emission Limitations and Prohibitions- Miscellaneous, 

Final form of adopted rules, effective May 20, 2015. Includes: 

R 336.1902 Miscellaneous Provisions. 

R 336.1972 Emission standards for existing sewage sludge 

incineration units. 

Secretary of State's Notice of Filing of Administrative Rules, 

May 20, 2015. 

Attorney General certification of MDEQ authority to adopt by 

reference federal emission guidelines. 

Michigan Compiled Laws 324.5512, 324.5516, 324.5526, and 

324.5530. 

ATTACHMENT B Shutdown notices for Battle Creek, East Lansing, Flint, and 

Pontiac. 

Final Plan/Renewable Operating Permit for Detroit, Warren, and 

Ypsilanti. 

ATTACHMENT C Notice of public hearing from MDEQ Environmental Calendar, 

July 13, 2015. 

Opening statement from August 19, 2015, public hearing. 

Response to comments. 
Introduction 

States must submit to the United States Environmental Protection Agency (US EPA), a 

State Plan in accordance with the requirements of Sections 111 (d) and 129 of the 

federal Clean Air Act (CAA) for implementation and enforcement of the "Emission 

Guidelines and Compliance Times for Existing Sewage Sludge Incineration Units," 

(Guidelines), Title 40, Code of Federal Regulations (CFR), Part 60, Subpart MMMM. 

The Guidelines were promulgated by the US EPA on March 21, 2011. The State Plan 

must meet the requirements of 40 CFR §60.5015, specifically. As part of Michigan's 

State Plan, the Michigan Department of Environmental Quality (MDEQ) promulgated 

R 336.1972, "Emission Standards for Existing Sewage Sludge Incineration Units," and 

R 336.1902 "Adoption of standards by reference," on May 20, 2015. These two rules 

state the requirements for existing sewage sludge incineration (SSI) units, and adopt by 

reference portions of the relevant Guidelines. 

This State Plan addresses the nine required elements specified in 40 CFR §60.5015, as 

follows: 

1. An inventory of affected SSI units in the state, including units that have ceased 

operation, but have not been dismantled (included in the State Plan section on 

Inventory of SSI Units and Compliance Dates). 

2. An inventory of emissions from affected SSI units in the state (included in the 

State Plan section on Emissions Inventories). 

3. Compliance schedules for affected SSI units (included in the State Plan section 

on Inventory of SSI Units and Compliance Dates, and included in Attachment B). 

4. Emission limitations, emission standards, operator training and qualification 

requirements, and operating limits for affected SSI units which are at least as 

protective as those in the Guidelines (included in Attachment A). 

5. Performance testing, monitoring, record keeping, and reporting requirements 

(included in Attachment A). 

6. Certification that a public hearing on the State Plan was held with a list of 

witnesses and their organizational affiliations, and a brief written summary of 

each presentation or written submission (included in Attachment C). 

7. Provision for state progress reports to the USEPA on the implementation of the 

State Plan (included in the State Plan section on Provision for State Progress 

Reports to USEPA). 

8. Identification of enforceable state mechanisms for implementing the Guidelines 

(included in the State Plan section on Enforceable State Mechanism and 

Requirements at Least as Protective as the Federal Emission Guidelines, and 

included in Attachment A). 

9. A demonstration of the state's legal authority to carry out Section 111 (d) and 

Section 129 of the State Plan (included in the State Plan section on Enforceable 

State Mechanism and Requirements at Least as Protective as the Federal 

Emission Guidelines, and included in Attachment A). 

1 
Inventory of SSI Units and Compliance Dates 

The inventory in Table 1 includes all SSI units in the state affected by the State Plan. 

This includes units that have ceased operation (or have not been operating), but are not 

totally dismantled, and sources subject to the Guidelines. Should another source be 

discovered subsequent to the date of this State Plan, the MDEQ will provide notice to 

the USEPA. There will be no need to reopen the State Plan to include that source. 

Facilities have three options to comply with the State Plan: (1) Submittal of a final 

closure notification with date of closure on or before March 21, 2016; (2) Submittal of a 

final plan by March 21, 2015, to come into full compliance by March 21, 2016; or 

(3) Submittal of a notification to the MDEQ of an exemption from R 336.1972 and the 

State Plan by March 21, 2015. 

The schedules for compliance with the State Plan for affected sources are included in 

Table 1. Correspondence pertaining to these facilities is included in Attachment B. By 

March 21, 2015, all owners or operators of SSI units in the state submitted to the MDEQ 

a final closure notification or a final plan to come into full compliance by March 21, 2016. 

The MDEQ has reviewed and approved all submitted final plans included in Attachment 

B. The compliance schedules listed in the final plans will be incorporated into each 

Renewable Operating Permit (Title V) for the three facilities with operating SSI units that 

are affected by this State Plan. These compliance schedules will become enforceable 

upon permit issuance. 

In addition, the owners or operators of SSI units scheduled to remain operational either 

have a Title V permit or have submitted an application for a Title V permit to the MDEQ. 

SRN 

B6307 

B6237 

B4150 

B2103 

B1950 

B1792 

B1598 

Table 1. Inventory of Sewage Sludge Incineration 

Units and Compliance Schedules 

NAME ADDRESS COMPLIANCE SCHEDULE 

City of Battle Creek 2000 River Rd. W., Final closure notification to 

Wastewater Treatment Plant Battle Creek, Ml 49037 decommission units by 3/21/2016 

Ypsilanti Community Utilities 2777 State St., Final compliance by 

Authority Ypsilanti, Ml 48198 3/21/2016 

East Lansing Wastewater 1700 Trowbridge Rd., 

Treatment Plant East Lansing, Ml 48823 Decommissioned on 10/17/2002 

Detroit Wastewater 9300 W. Jefferson Ave .. 

Treatment Plant Detroit, Ml 48209 Final compliance by 3/21/2016 

Final closure notification of shut down 

Pontiac Wastewater 155 N. Opdyke Rd., on 6/16/2011 and decommissioned 

Treatment Plant Pontiac, Ml 48342 on 4/30/2015 

Warren Wastewater 32360 Warkop Ave., 

Treatment Plant Warren, Ml 48093 Final compliance bv 3/21/2016 

Flint Water Pollution Control 4652 Beecher Rd .. Final closure notification to shut down 

Facility Flint, Ml 48532 units by 3/21/2016 

2 
Emissions Inventories 

The estimated emissions for SSI units affected by the State Plan and not yet dismantled 

are included in Table 2. These values were derived using "Final: Revised Estimation of 

Baseline Emissions from Existing Sewage Sludge Incineration Units Attachments," 

available at http://www.epa.gov/ttn/atw/129/ssi/ssipg.html. 

Battle 

Creek 

Units 1-2 

Detroit 

Units 1-6 

Detroit 

Units 7-14 

Flint 

Units 1-4 

Warren 

Ypsilanti 

Table 2. Sewage Sludge Incineration Unit Emissions Data 

(actual baseline emissions based on average feed rates) 

Cd, co, HCI, Pb, Hg, NOx, PM, 

*mQ/dscm **ppmvd ppmvd mQ/dscm mQ/dscm ppmvd mQ/dscm 

0.0443 864.78 0.6546 0.1141 0.1028 133.28 34.14 

0.0443 864.78 0.6546 0.1141 0.1028 133.28 34.14 

0.4428 864.78 0.6546 1.1414 0.1028 133.28 68.27 

0.4428 864.78 0.6546 1.1414 0.1028 133.28 68.27 

0.4428 864.78 0.6546 1.1414 0.1028 133.28 68.27 

0.0005 2.64 0.2824 0.0062 0.0006 29.76 2.87 

Dioxin/Furan 

Toxic 

Equivalency 

so,, Quotient, 

ppmvd ***ng/dscm 

9.1913 0.047 

9.1913 0.047 

9.1913 0.047 

9.1913 0.047 

9.1913 0.047 

2.5662 0.003 

* mg/dscm: milligrams per dry standard cubic meter; **ppmvd: part per million, dry volume; ***ng/dscm: nanogram 

per dry standard cubic meter. 

Enforceable State Mechanism and Requirements at Least as Protective as the 

Federal Emission Guidelines 

Under the CAA Section 129(f)(3), it is unlawful for any source to operate in violation of 

any standard promulgated under the Guidelines. In accordance with R 336.1972, 

sources must come into compliance with the Guidelines by March 21, 2016, the latest 

date available under federal law. The consequences for non-compliance with 

R 336.1972, or any MDEQ emissions standard, range from civil fines to injunctive relief. 

Included in Attachment A, is the recently adopted R 336.1972, "Emission Standards for 

Existing Sewage Sludge Incineration Units," and R 336.1902, "Adoption of standards by 

reference," along with certification of adoption of the rules by the Michigan Secretary of 

State. These rules satisfy the State Plan requirement for the following: 

1. Emission limits, emission standards, operator training and qualification 

requirements, and operating limits for affected SSI units that are at least as 

protective as the Guidelines. 

3 
2. Performance testing, recordkeeping, and reporting requirements that are at least 

as protective as those in the Guidelines. 

3. Identification of enforceable state mechanisms for ii'nplementing the Guidelines. 

Also included in Attachment A is a certification by the Michigan Department of Attorney 

General that the MDEQ has the authority to adopt by reference federal emission 

guidelines, such as those in 40 CFR, Part 60, Subpart MMMM. 

As part of the State Plan requirements, 40 CFR §60.26 requires a demonstration of 

authority by states. The MDEQ draws its authqrity to satisfy these requirements from 

Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection 

Act, 1994 PA 451, as amended, and the Air Quality Division Rules, Part 9, Emission 

Limitation and Prohibitions - Miscellaneous, included in Attachment A. The requirements 

of 40 CFR §60.26 are demonstrated as follows: 

1. Authority to adopt emission standards and compliance schedules applicable to 

designated facilities is found in Michigan Complied Law (MCL) 324.5512 and 

R 336.1972. 

324.5512 Rules. 

(1) The department shall promulgate rules for the purposes of doing 

all of the following: 

(a) Controlling or prohibiting air pollution. 

(b) Complying with the clean air act .... 

(g) Establishing suitable emission standards consistent with federal 

ambient air quality standards .... 

R 336.1972 Emission standards for existing sewage sludge 

incineration units. 

(3) By March 21, 2016, each SSI unit shall comply with the following 

provisions of "Emission Guidelines and Compliance Times for 

Existing Sewage Sludge Incineration Units," 40 C.F.R. Part 60, 

Subpart MMMM, adopted by reference in R 336. 1902 .. .. 

2. Authority to enforce applicable laws, regulations, standards, and compliance 

schedules, and seek injunctive relief is found in MCL 324.5530. 

324.5530 Commencement of civil action by attorney general; 

relief; costs; jurisdiction; defenses; fines. 

(1) The attorney general may commence a civil action against a 

person for appropriate relief, including injunctive relief, and a civil fine 

as provided in subsection (2) for any of the following: 

(a) Violating this part or a rule promulgated under this part .... 

(c) Failure to comply with the terms of a permit or an order issued 

under this part .... 

4 
3. Authority to obtain information necessary to determine whether designated 

facilities are in compliance with applicable laws, regulations, standards, and 

compliance schedules, including authority to require record keeping, and to make 

inspections and conduct tests of designated facilities is found in MCL 324.5526. 

324.5526 Investigation; inspection; furnishing duplicate of 

analytical report; powers of department or authorized 

representative; entry or access to records refused; powers of 

attorney general; "authorized representative" defined. 

(1) The department may ... enter and inspect any property at 

reasonable times for the purpose of investigating either an actual or 

suspected source of air pollution or ascertaining compliance or 

noncompliance with this part, rules promulgated under this part, the 

clean air act, a permit issued under this part, or any determination or 

order issued under this part .... In implementing this subsection, the 

department or its authorized representative may do any of the 

following: 

(a) Have access to and copy ... any records that are required to be 

maintained pursuant to this part, rules promulgated under this part, the 

clean air act, a permit issued under this part, or any determination or 

order issued under this part. 

(b) Inspect at reasonable times any facility, equipment, including 

monitoring and air pollution control equipment, practices, or operations 

regulated or required under this part, rules promulgated under this part, 

the clean air act, a permit issued under this part, or any determination 

or order issued under this part. 

(c) Sample or monitor at reasonable times substances or parameters 

for the purpose of determining compliance with this part, rules 

promulgated under this part, the clean air act, a permit issued under 

this part, or any determination or order issued under this part .... 

4. Authority to require owners or operators of designated facilities to install, 

maintain, and use emission monitoring devices and to make periodic reports to 

the state on the nature and amounts of emissions from such facilities; also 

authority for the state to make such data available to the public as reported and 

as correlated with applicable emission standards as found in R 336.1972 and 

MCL 324.5516. 

R 336.1972 Emissions standards for existing sewage sludge 

incineration units. 

(2) The owner or operator of a SSI unit that has not submitted a 

closure or exemption notification to the department shall submit an 

application for a renewable operating permit and, by March 21, 2015, 

shall submit a final control plan meeting the requirements of 40 C.F.R. 

§60.5110 that is signed by the owner or operator of the unit. 

5 
(3) By March 21, 2016, each SSI unit shall comply with the following 

provisions of "Emission Guidelines and Compliance Times for Existing 

Sewage Sludge Incineration Units," 40 C.F.R. Part 60, Subpart 

MMMM, adopted by reference in R 336.1902: ... 

(e) "Continuous Compliance Requirements," 40 C.F.R. §§60.5205 to 

60.5215. 

(f) "Performance Testing, Monitoring, and Calibration Requirements," 

40 C.F.R. §§60.5220 to 60.5225. 

(g) "Recordkeeping and Reporting," 40 C.F.R. §§60.5230 to 60.5235. 

(h) "Title V Operating Permits," 40 C.F.R. §§60.5240 to 60.5245 .... 

324.5516 Public hearing; information available to the public; use 

of confidential information. 

(2) A copy of each permit, permit application, order, compliance plan 

and schedule of compliance, emissions or compliance monitoring 

report, sample analysis, compliance certification, or other report or 

information required under this part, rules promulgated under this part, 

or permits or orders issued under this part shall be available to the 

public to the extent provided by the freedom of information act, Act No. 

442 of the Public Acts of 1976, being sections 15.231 to 15.246 of the 

Michigan Complied Laws. 

(3) .... Data on the amount and nature of air contaminants emitted from 

a source shall be available to the public. 

Provision for State Progress Reports to the USEPA 

The provision of 40 CFR §60.25(e) requires the state to submit progress reports on 

State Plan enforcement to the US EPA. The annual report from the MDEQ will include 

updates to the inventory, removing sources that have shut down, adding new sources, 

and identifying any sources that have met increments of progress. The annual report 

will also include any enforcement activities initiated against designated facilities and 

submission of technical reports on all performance testing on designated facilities, 

including updated emissions inventories. The MDEQ will work with the USEPA's 

Region 5 office regarding the format required for submission of these items. 

6 


DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

PART 9. EMISSION LIMITATIONS AND PROHIBITIONSMISCELLANEOUS 

(By authority confe!Ted on the director of the department of environmental quality by 

sections 5503 and 5512 of 1994 PA 451, MCL 324.5503 and MCL 324.5512) 

R 336.1901 Air contaminant or water vapor; prohibition. 

Rule 901. Notwithstanding the provisions of any other rule, a person shall not cause or 

permit the emission of an air contaminant or water vapor in quantities that cause, alone or in 

reaction with other air contaminants, either of the following: 

(a) Injurious effects to human health or safety, animal life, plant life of significant 

economic value, or property. 

(b) Unreasonable interference with the comfortable enjoyment of life and propetiy. 

History: 1980 AACS; 2002 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1902 Adoption of standards by reference. 

Rule 902. (1) The following standards are adopted by reference in these rules. Copies 

are available for inspection and purchase at the Air Quality Division, Depmiment of 

Environmental Quality, 525 West Allegan Street, Lansing, Michigan 48909-7760, at a cost 

as of the time of adoption of these mles (AQD price). Copies may also be obtained from 

the Superintendent of Documents, U.S. Govetnment Printing ot!lce, 732 North Capito! 

Street, NW, Washington, DC 20401, or by accessing their online bookstore at 

http://bookstore.gpo.gov at a cost as of the tinte of adoption of these rules (GPO price). The 

standards can also be viewed and/or printed free of charge at http://ecfr.gpoaccess.gov. 

(a) ''National Primary and Secondary Ambient Air Quality Standards," 40 C.F.R. 

Pati 50 (2013), AQD price $61.00/$51.00 GPO price for Pati 50 tlu·ough Pati 51. 

(b) The following sections of "Requirements for Preparation, Adoption, and Submittal 

of hnplementation Plans," 40 C.P.R. Pati 51 (2013), AQD price $61.00/$51.00 GPO price 

for Pati 50 through Part 51: 

(i) "Definitions," 40 C.F.R. §51.100. 

(ii) "Legally enforceable procedures," 40 C.F.R. §51.160. 

(iii) "Permit requirements," 40 C.P.R. §51.165. 

(iv) "Prevention of significant deterioration of air quality," 40 C.P.R. §51.166. 

(v) ''Definitions," 40 C.F.R. §51.301. 

(vi) "Sources That Would Locate in a Designated Nonattainment Area," Appendix S. 

(vii) "Reconnnended Test Methods for State hnplementation Plans," Appendix M. 

(viii) "Guideline on Air Quality Models," Appendix W. 

(ix.) "Guidelines for BART Determinations under the Regional Haze Rule," 

Appendix Y. 

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(c) "Prevention of Significant Deterioration of Air Quality," 40 C.F.R. §52,21 (2013); 

AQD pdce $74.00/$64.00 GPO price for Part 52 (52.01 through 52.1018). 

(d) "Quality Assurance Requirements for Prevention of Significant Deterioration Air 

Monitoring," 40 C.P.R. §58, Appendix B (2013); AQD price $46.00/$36.00 GPO ptice for 

Part 53 through Pmt 59. 

(e) "Standards of Performance for New Stationary Sources," 40 C.F.R. Patt 60, except 

40 C.F.R. Part 60, Subpart AAA, "Standards of Performance for New Residential Wood 

Beaters" (20 13); AQD price $74.00/$64.00 GPO price for Part 60 (60.1 to end). 

(f) "Appendices," 40 C.F.R. Pmt 60 (2013); AQD price $73.00/$63.00 GPO price for 

Part 60 Appendices. 

(g) "National Emission Standards [01' Hazardous Air Pollutants," 40 C.F.R. 

Patt 61 (2013); AQD price $61.00/$51.00 GPO price for Pmt 61 through Part 62. 

(h) "National Emission Standards for Hazardous Air Polluta11ts for Source Categories," 

40 C.F.R. Patt 63, Subpatt A to Z (2014); AQD price $74.00/$64.00 GPO price. 

(i) "National Emission Sta11dards for Hazardous Air Pollutants for Source Categories 

(Continued)," 40 C.F.R. Part 63, Subpart AA to DDD (2014); AQD price $63.00/$53.00 

GPO price. 

G) ''National Emission Standards for Hazardous Air Pollutants for Source Categories 

(Continued)," 40 C.F.R. Pmt 63, Subpart EEE to PPP (2014); AQD price $66.00/$56.00 

GPO price. 

(k) "National Emission Standards for Hazm·dous Air Pollutants for Source Categories 

(Continued)," 40 C.F.R. Part 63, Subpmt QQQ to YYYY (2014); AQD price $47.00/$37.00 

GPO price. 

(I) "National Emission Standards for Hazardous Air Pollutants for Source Categories 

(Continued)," 40 C.F.R. Part 63, Subpmt ZZZZ to MMMMM (2014); AQD price $50/$40 

GPO price. 

(m) "National Emission Standards for Hazardous Air Polluta11ts for Source Categories 

(Continued)," 40 C.F.R. Patt 63, Subpart NNNNN to end (2014); AQD price $50,00/$40.00 

GPO price. 

(n) "Compliance Assurance Monitoring," 40 C.F.R. Part 64 (2013); AQD price 

$44.00/$34.00 GPO price for Patt 64 through Part 71. 

(o) The following sections of "State Operating Permit Programs," Patt 70 (2013); 

AQD ptice $44.00/$34.00 GPO price for Part 64 through Part 71: 

(i) "Applicability," 40 C.F.R. §70.3. 

(ii) "Re-openings for cause by EPA," 40 C.F.R. §70. 7(g). 

(iii) "Transmission of information to the Administrator," 40 C.P.R. §70.8(a)(1) and 

(2). 

(iv) "EPA objection," 40 C.F.R. §70.8(c). 

(v) "Public petitions to the Administrator," 40 C.P.R. §70.8(d). 

(p) "Permit Regulations," 40 C.F.R. Pati 72 (2013); AQD price $78.00/$68.00 GPO 

price for Pmt 72 through Pmt 80. 

(q) "Sulfur Dioxide Opt-Ins," 40 C.F.R. Part 74 (2013); AQD price $78.00/$68.00 

GPO price for Patt 72 through Pat'! 80. 

(r) "Continuous Emission Monitoting," 40 C.P.R. Patt 75 (2013); AQD price 

$78.00/$68.00 GPO price for Pmt 72 through Part 80. 

(s) "Acid Rain Nitrogen Oxides Emission Reduction Program," 40 C.F.R. Part 76 

(2013); AQD price $78.00/$68.00 GPO price for Pati 72 through Patt 80. 

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(t) "Federal NOx Budget Trading Program and CAIR NOx and S02 Trading 

Programs," 40 C.F.R. Part 97 (2013); AQD price $76.00/$66.00 GPO price for 

Part 96 through Pmt 99. 

(u) "Global Warming Potentials," 40 C.F.R. Patt 98, Subpart A, Table A-1 (2013); 

AQD Price $76.00/$66.00 GPO price for Pmt 96 to Part 99. 

(v) "Federal Power Act," 16 U.S.C. §§796 (17)(C) and (18)(B) (2012); AQD Price 

$142.00/$132.00 GPO price for Section 344 through Section 856. 

(w) "Solid Waste Disposal Act, Section 3005," 42 U.S.C. §6925 (2012); AQD Price 

$68.50/$58.50 GPO price for Sections 6201 to end. 

(2) The following United States Environmental Protection Agency (U.S. EPA) 

documents are adopted by reference in these rules. A copy is available for inspection and 

purchase at the Air Quality Division, Depmtment of Environmental Quality, 525 West 

Allegan Street, Lansing, MI 48909-7760, at a cost as of the time of adoption of these roles 

of $20.00 each. A copy may also be obtained from the U.S. Environmental Protection 

Agency, Office of the Science Advisor, 1200 Pennsylvania Avenue, NW, Washington, DC 

20460 or on the U.S. EPA website, www.epa.gov, free of charge as of the time of adoption 

of these roles. 

(a) "Advances in Inhalation Gas Dosimetry for Derivation of a Reference 

Concentration (RfC) and Use in Risk Assessment," EP A/600/R-12/044, September 2012. 

(b) "Guidelines for Carcinogen Risk Assessment, and Supplemental Guidance for 

Assessing Susceptibility from Em·ly-Life Exposure to Carcinogens," 2005. 

(c) "Protocol for Determining the Daily Volatile Compound Emission Rate of 

Automobile and Light-duty Truck Topcoat Operations," EPA-450/3-88-018, December 

1988. 

(d) "Benchmark Dose Technical Guidance," EPA/100/R-12/001, June 2012. 

(e) "Control of Volatile Organic Emissions from Manufacture of Synthesized 

Pha1maceutical Products," EPA-450/2-78-029, December 1978. 

(f) "Alternative Control Techniques Document: NOx Emissions from Cement 

Manufacturing," EPA-453/R-94-004, 1994. 

(g) "Compilation of Air Pollution Emission Factors. Volume 1, Stationary Point and 

Air Sources," EPA-450/AP-425-ED, January 1995. 

(3) The following Federal Register documents are adopted by reference in these rules. 

A copy is available for inspection and purchase at the Air Quality Division, Depaltment of 

Enviro1llllental Quality, 525 West Allegan Street, Lansing, MI 48909-7760, at a cost as of 

the tllne of adoption of these rules of$10.00: 

(a) U.S. EPA Emissions Trading Policy statement, 51 F.R. 43814, December 4, 1986. 

(b) U.S. EPA Recommended Policy on Control of Volatile Organic Compounds, 

42 FR 35314, July 8, 1977. 

( 4) The following standards m·e adopted by reference in these roles. Copies are 

available for inspection and purchase at the Air Quality Division, Department of 

Enviromnental Quality, 525 West Allegan Street, Lansing, Michigan 48909-7760, at the 

cost as of the time of adoption of these rules (AQD price). Copies may also be obtained 

from ASTM Intemational, P.O. Box C700, West Conshohocken, Pennsylvania 19428-2959 

or on the ASTM website, www.astm.org, at a cost as of the time of adoption of these rules 

(ASTM price): 

(a) Standard Test Method for Distillation of Petroleum Products at Atmospheric 

Pressure, ASTM method D86, 2012; AQD price $60.00/$50.00 ASTM price. 

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(b) Standard Test Method for Pour Po:int of Petroleum Products, ASTM D97, 2012; 

AQD price $52.00/$42.00 ASTM price. 

(c) Standard Test Method for Vapm· Pressure of Petroleum Products, ASTM D323, 

2008; AQD price $52.00/$42.00 ASTM price. 

(d) Standard Specification for Fuel Oils, ASTM D396, 2013; AQD price 

$52.00/$42.00 ASTM price. 

(e) Standard Test Method for Distillation of Cutback Asphaltic (Bitum:inous) Products, 

ASTM D402, 2008; AQD price $52.00/$42.00 ASTM price. 

(f) Standard Specification for Aviation Gasol:ines, ASTM D910, 2013; AQD price 

$52.00/$42.00 ASTM price. 

(g) Standard Specification for Diesel Fuel Oils, ASTM D975, 2014; AQD price 

$70.00/$60.00 ASTM price. 

(h) Standard Specification for Aviation Turbine Fuels, ASTM Dl655, 2013; AQD 

price $58.00/$48.00 ASTM price. 

(i) Standard Specification for Gas Turb:ine Fuel Oils, ASTM D2880, 2013; AQD price 

$49.00/$39.00 ASTM price. 

(j) Standard Test Method for Detennination of Nitrogen Oxides, Carbon Monoxide, 

and Oxygen Concentration in Emissions fi·om Natural Gas-Fired Reciprocating Engines, 

Combustion Turbines, Boilers, and Process Heaters Using Portable Analyzers, ASTM 

D6522, 2011; AQD price $52.00/$42.00 ASTM price. 

(k) Standard Specification for Biodiesel Fuel Blend Stock (B 1 00) for Middle Distillate 

Fuels, ASTMD6751, 2012; AQD price $52.00/$42.00 ASTM price. 

(I) Standard Test Method for Elemental, Oxidized, Pruticle-Bound and Total Mercury 

in Flue Gas Generated from Coal-Fired Stationary Sources, ASTM D6784, 2008; AQD 

price $58.00/$48.00 ASTM price. 

(m) Standru·d Guide for Packaging and Shipping Environmental Sample for Laboratory 

Analysis, ASTM D6911, 2010; AQD price $52.00/$42.00 ASTM price. 

(n) Standard Test Method for Distillation of Emulsified Asphalt, ASTM D6997, 2012; 

AQD price $47.00/$37.00 ASTM price. 

(o) Standard Specification for Diesel Fuel Oil, Biodiesel Blend (B6 to B20), ASTM 

D7467, 2013; AQD price $58.00/$48.00 ASTMprice. 

(p) Standard Practices for General Techniques of Infi·ared Quantitative Analysis, 

ASTM El68, 2006; AQD price $58.00/$48,00 ASTM price. 

(q) Standard Practices for General Techniques of Ultraviolet-Visible Quantitative 

Analysis, ASTM E169, 2009; AQD price $58.00/$48.00 ASTM price, 

(1) Standard Practice for Packed Column Gas Chromatography, ASTM E260, 2011; 

AQD price $58.00/$48.00 ASTM price. 

(5) The following standards are adopted by reference in these rules. Copies ru·e 

available for inspection and purchase at the Air Quality Division, Depa1tment of 

Environmental Quality, 525 West Allegan Street, Lansing, Michigan 48909-7760, at the 

cost as of the time of adoption of these rules (AQD price). Copies may also be obtained 

Jl'om the American Association of State Highway and Transportation Officials, AASHTO 

Publication Order Deprutment, P.O. Box 933538, Atlanta, Georgia, 31193-3538, at a cost as 

ofthe time of adoption of these rules (AASHTO price): 

(a) Standard Method of Test for Testing Emulsified Asphalts, AASHTO T59, 2013; 

AQD price $86.00/$76.00 AASHTO price. 

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(b) Standard Method of Test for Cutback Asphalt Products, AASHTO T78, 2014; 

AQD price $70.00/$60.00 AASHTO price. 

(6) "2014 TLVs and BEis. Threshold Limit Values for Chemical Substances and 

Physical Agents, and Biological Exposure Indices,'' is adopted by reference in these rules. 

A copy is available for inspection and pmchase at the Air Quality Division, Department of 

Environmental Quality, 525 West Allegan Street, Lansing, MI 

48909-7760, at a cost as of the tin1e of adoption of these mles of $69.95. A copy may also 

be obtained from the American Conference of Governmental Industrial Hygienists, 1330 

Kemper Meadow Drive, Cincinnati, Ohio 45240, or on the American Conference of 

Govemmental Industrial website, www.acgih.org, at a cost as of the time of adoption of 

thesetules of$49.95. 

(7) "NIOSH Pocket Guide to Chemical Hazards," 2010, is adopted by reference in 

these tules. A copy on CD-ROM is available for inspection and purchase at the Air Quality 

Division, Department of Environmental Quality, 525 West Allegan Street, Lansing, MI 

48909-7760, for $20.00 as of the time of adoption of these rules. A copy on CD-ROM may 

also be obtained from the Centers for Disease Control website, www.cdc.gov/nioshlnpg/, 

for free as of the time of adoption of these rules. 

(8) "American Petroleum Institute Manual of Petroleum Measurement Standards Cl9 

S2," is adopted by reference in these rules. A copy is available for inspection and purchase 

at the Air Quality Division, Department of Environmental Quality, 525 West Allegan 

Street, Lansing, MI 48909-7760, at a cost as of the time of adoption of these rules of 

$139.00. A copy may also be obtained from American Petroleum Institute, Techstreet, 

3916 Ranchero Drive, Ann Arbor, MI 48108-2775, or at the American Petroleum Institute 

website at http://www.techsh·eet.com/api/products/2409, at a cost as of the time of adoption 

of these rules of$129.00. 

(9) "OTC Model Ru1e for Consumer Products," 2009 is adopted by reference in these 

mles, A copy is available for inspection and purchase at the Air Quality Division, 

Department of Environmental Quality, 525 West Allegan Street, Lansing, MI 

48909-7760, at a cost as of the time of adoption of these mles of $10.00. A copy may also 

be obtained fi·om the Ozone Transport Commission website, www .otcair.org, for fi·ee as of 

the time of adoption of these tules. 

History: 2008 AACS; 2013 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1906 Diluting and concealing emissions. 

Rule 906. Unless prior written approval is obtained fi·om the department, a person shall 

not build, erect, install, or use any ruticle, machine, equipment, or other conh·ivance if the 

sole purpose of the article, machine, equipment, or other conh·ivance is to dilute or conceal 

an emission without resulting in a reduction in the total release of air contaminants into the 

ahnosphere. This mle does not apply to the control of odors. 

Histmy: 1980 AACS; 2002 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1910 Air-cleaning devices. 

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Rule 910, An air-cleaning device shall be installed, maintained, and operated in a 

satisfactory manner and in accordance with these rules and existing law. 

History: 1980 AACS, 

R 336.1911 Malfunction abatement plans. 

Rule 911. (1) Upon request of the department, a person responsible for the operation of 

a source of an air contaminant shall prepare a malfunction abatement plan to prevent, 

detect, and correct malfunctions m· equipment failures resulting in emissions exceeding any 

applicable emission limitation. 

(2) A malfunction abatement plan required by submle (1) of this rule shall be in 

w1·iting and shall, at a minimum, specity all of the following: 

(a) A complete preventative maintenance program, including identification of the 

supervisory persom1ell'esponsible for overseeing the inspection, maintenance, and repair of 

air-cleaning devices, a desCJiption of the items or conditions that shall be inspected, the 

frequency of the inspections or 1·epairs, and an identification of the majol' replacement parts 

that shall be maintained in inventory for quick replacement. 

(b) An identification of the source and air-cleaning device operating variables that 

shall be monitored to detect a malfunction or failure, the n01mal operating range of these 

vmiables, and a description of the method of monitoring or surveillance procedures, 

(c) A description of the conective procedures or operational changes that shall be 

taken in the event of a malfunction or failure to achieve compliance with the applicable 

emission limits. 

(3) A malfunction abatement pla11 required by subrule (1) of this mle shall be 

submitted to the department and shall be subject to review and approval by the department. 

If, in the opinion of the department, the plan does not adequately carry out the objectives as 

set forth :in subrules (1) and (2) of this rule, then the department may disapprove the plan, 

state its reasons for disapproval, and order the preparation of an amended plan within the 

time period specified in the order. If, within the time pe1iod specified in the order, an 

amended plan is submitted which, in the opinion of the department, fails to meet the 

objective, then the department, on its own initiative, may amend the plan to cause it to 

meet the objective. 

( 4) Within 180 days after the depa11ment approves a malfunction abatement plan, a 

person responsible for the preparation of a malfunction abatement plan shall implement the 

maltinlction abatement pla11 required by subrule (1) of this mle. 

History: 1980 AACS; 2002 AACS; 2015 MR ll,Eff. May 20,2015. 

R 336.1912 Abnormal conditions, start-up, shutdown, and malfunction of a 

source, process, or process equipment, operating, notification, and reporting 

requirements. 

Rule 912. (1) The owner or operator of a somce, process, o1· process equipment shall, 

to the extent reasonably possible, operate a source, process, or process equipment in a 

mmmer consistent with good air pollution control practices for minimizing emissions during 

periods of abn01mal conditions, stmt-up, shutdown, and malfimctions, A source, process, 

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or process equipment that complies with all applicable emission standards and limitations 

during periods of abnmmal conditions, sta1t-up, shutdown, and malfunction shall be 

presumed to have been operated in a manner consistent with good air pollution control 

practices for minimizing emissions. 

(2) The owner or operator of a source, process, or process equipment shall provide 

notice of an abnormal condition, stmt-up, shutdown, or a malfunction that results in 

emissions of a hazardous air pollutant which continue for more than l hour in excess of any 

applicable standaJ"d or limitation established by the clean air act or the emissions of a toxic 

air contaminant which continue for more than 1 hour in excess of an emission standm·d 

established by a mle promulgated under the air pollution act or an emission limitation 

specified in a pe1mit issued Ol' Ol'der entered under the air pollution act. 

(3) The owner or operator of a source, process, or process equipment shall provide 

notice and a written repmt of an abnmmal condition, start-up, shutdown, or a malfunction 

that results in emissions of any air contaminant continuing for more than 2 hours in excess 

of a standard or limitation established by any applicable requirement. 

( 4) The notices requil'ed by this rule shall be provided to the department as soon as 

reasonably possible, but not later than 2 business days after the stmt-up or shutdown or after 

discovery of the abn01mal conditions or malfunction. Notice shall be by any reasonable 

means, including electronic, telephonic, or oral communication. 

(5) The written repmts required under this mle shall be submitted within 10 days after 

the stmt-up or shutdown occuned, within 10 days after the abnormal conditions or 

malfunction has been conected, or within 30 days of discovery of the abnormal conditions 

or malfunction, whichever is first. The written reports shall include all of the following 

infmmation: 

(a) The time and date, the probable causes m· reasons for, and the duration of the 

abnormal conditions, stmt-up, shutdown, or malfunction. 

(b) An identification of the source, process, or process equipment that experienced 

abnormal conditions, was stmted up or shut down, or which malfunctioned and all other 

affected process or process equipment that have emissions in excess of an applicable 

requirement, including a description of the type and, where known or where it is reasonably 

possible to estimate, the quantity or magnitude of eJnissions in excess of applicable 

requirements. 

(c) Information describing the measures taken and air pollution control practices 

followed to minimize emissions. 

(d) For abnmmal conditions and malfunctions, the report shall also include a summary 

of the actions taken to correct and to prevent a reoccurrence of the abnmmal conditions or 

malfunction and the time taken to correct the malfunction. 

( 6) Actions taken to conect and to prevent a reoccuJTence of an abnormal condition or 

a malfunction shall become a pat'! of any preventative maintenance and malfunction 

abatement plan requil'ed by R 336.1911. 

(7) The tmth, accuracy, and completeness of the Wlitten reports required under this 

rule for a stationary source subject to the requirements ofR 336.1210 shall be certified by a 

responsible official in a manner consistent with the clean ail' act. 

ffistory: 1980 AACS; 1995 AACS; 2015 MR 11, Eff. May 20,2015. 

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R 336.1913 Rescinded. 

History: 1995 AACS; 2001 AACS. 

R 336.1914 Rescinded. 

Histmy: 1995 AACS; 2001 AACS, 

R 336.1915 Enforcement discretion in instances of excess emissions resulting from 

malfunction, start-up, or sh11tdown. 

Rule 915. (1) In determining whether the depa1tment will pursue enforcement against a 

person, the depmtment shall consider evidence that the emission violations resulted from a 

malfunction, sta1t-up, or shutdown. 

(2) If the depattment detenuines that the emission violations resulted from a 

malfunction, stmt-up, or shutdown, then the depmtment may use enforcement discretion 

when resolving the emission violations based upon submles (3) and (4) of this rule, as 

applicable. 

(3) A person may submit evidence to the depmtment for its consideration in 

detetmining that the emission violations resulted from a malfunction. The evidence shall 

demonstrate all of the following, as applicable: 

(a) The excess emissions were a result of a sudden and unavoidable breakdown of 

process or control equipment, beyond the reasonable control of the person. 

(b) The air pollution control equipment, process equipment, and processes were 

maintained and operated in a manner consistent with good practice for mininlizing 

emissions, to the maximum extent practicable. 

(c) The excess emissions caused by a bypass (an intentional diversion of control 

equipment) were unavoidable to prevent loss of life, personal injury, or severe property 

damage. 

(d) Repairs were made in an expeditious fashion when the person knew or should have 

known that applicable emission limitations were being exceeded. To the extent practicable, 

off-shift labor and overtinle shall have been utilized to ensure that the repairs were made 

expeditiously. 

(e) The amount and duration of excess emissions, including any bypass, were 

mininlized to the maximum extent practicable during periods of the emissions. 

(f) All reasonably possible steps were taken to minimize the inlpact of the excess 

emissions on ambient air quality. 

(g) The excess emissions resulting from the malfunction were not pmt of a recumng 

pattern indicative of inadequate design, operation, or maintenance. 

(h) The malfunction was an infrequent event and was not reasonably preventable. 

(i) All emission monitoring systems were kept in operation if at all possible, 

G) The person responsible for operating the source of air contaminants has a 

malfunction abatement plan, consistent with the requirements set fmth in R 336.1911(2) 

and with both of the following provisions: 

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(i) Any malfunction abatement plan developed in accordance with R 336.1911(2) shall be 

maintained onsite and available for inspection, upon request, by the depmiment for the life 

of the emission unit 01' units. The department may require that the person responsible for the 

malfunction abatement plan make revisions to the plan. The person shall revise the 

malfunction abatement plan within 45 days after a request by the department. The revised 

malfunction abatement plan shall be developed in accordance with R 336.1911(2). 

(ii) If the malfunction abatement plan fails to address or inadequately addresses an event 

that meets the characteristics of a malfunction at the time the plan is initially developed, 

then the person shall revise the malfunction abatement plan within 45 days after the event 

occurs. The revised malfunction abatement plan shall be developed in accordance with R 

336.1911(2). 

(k) The excess emissions presenting an imminent threat to human health, safety, or the 

envimmnent were reported to the department as soon as possible. Unless otherwise 

specified in the facility's pennit, other excess emissions were repotied as provided in R 

336.1912. If requested by the department, a person shall submit a full written report that 

includes the !mown causes, the conective actions taken, and the preventive measures to be 

taken to minimize or eliminate the chance of recurrence. 

(I) The actions during the petiod of excess emissions were documented by 

contempomneous operating logs or other relevant evidence as provided by R 336.1912. 

(m) Any information submitted to the depmiment under this subrule shall be properly 

certified in accord811ce with the provisions ofR 336.1912. 

( 4) A person may submit evidence to the department for its consideration in determining 

that the emission violations resulted from a stati-up or shutdown. The evidence shall be 

based upon submles (3)(b), (c), (e), (f), (i), (k), (1), and (m) of this mle; subdivisions (a), 

(b), (c) of this subrule; andR 336.1912, as applicable. 

(a) The periods of excess emissions that occurred during start-up or shutdown were sh01t 

811d infrequent and could not have been prevented through careful planning and design. 

(b) The excess emissions that occmTed during stmt-up or shutdown were not part of a 

recunllig pattern indicative of inadequate design, operation, or maintenance. 

(c) The person responsible for operating the source of air cont8111inants has a preventative 

maintenance plan, consistent with the requirements set f01th in R 336.1911(2)(a). 

(5) For an emission unit or units subject to standards and limitations promulgated 

pursuant to section 111 or 112 of the clean air act, the strut-up, shutdown, 01' malfunction 

provisions of the applicable requirements within section 111 or 112 shall apply. 

(6) Nothing in this mle shall be consttued to limit the authmity of the department to 

seek injunctive relief or to enforce the provisions of the act and the regulations promulgated 

under the act. 

History: 2002 AACS. 

R 336.1916 Affirmative defense for excess emissions during start-up or shutdown. 

Rule 916. (1) The person operating a source with emissions in excess of an applicable 

emission limitation due to start-up or shutdown may claim an affrrmative defense to an 

enforcement pmceeding, excluding a judicial action seeking injunctive relief, if the person 

has complied with the reporting requirements ofR 336.1912 and has demonstrated all of the 

following: 

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(a) The periods of excess emissions that occurred during start-up or shutdown were 

shmt and infrequent and could not have been prevented through careful planning and 

design. 

(b) The excess emissions that occurred during start-up or shutdown were not part of a 

recurring pattem indicative of inadequate design, operation, or maintenance. 

(c) The excess emissions caused by a bypass (an intentional diversion of conu·ol 

equipment) were unavoidable to prevent loss of life, personal injury, or severe propetty 

damage. 

(d) The facility was operated at all times in a manner consistent with good practice for 

minimizing emissions. 

(e) The fi·equency and duration of operating in stmt-up or shutdown mode were 

minimized to the maximum extent practicable. 

(f) All reasonably possible steps were taken to minimize the impact of the excess 

emissions on mnbient air quality. 

(g) All emission monitoring systems were kept in operation if at all possible. 

(h) The actions during the period of excess emissions were documented by 

contemporaneous operating logs or other relevant evidence as provided by R 336.1912. 

(i) Excess emissions presenting an imminent threat to human health, safety, or the 

environment were repmted to the depattment as soon as possible. 

(j) Unless otherwise specified in the facility's petmit, other excess emissions were 

reported as provided in R 336.1912. If requested by the department, a person shall submit a 

full written report that includes the known causes, the corrective actions taken, and the 

preventive measures to be taken to minimize or eliminate the chance of recurrence. 

(k) Any information submitted to the depattment unde1· this snbmle shall be properly 

cettified in accOl'dance with the provisions ofR 336.1912. 

(2) This affirmative defense does not apply when a single emission unit, m· multiple 

emission units at a stationmy source, causes an exceedance of the national ambient air 

quality standards m· any applicable prevention of significant deterioration increment. 

(3) If the proximate cause of the excess emissions which occurred during routine 

start-up or shutdown periods was due to a malfunction, then, absent any intervening acts or 

superseding causes, the instances shall be treated as malfunctions in accordance with R 

336.1915. 

(4) Nothing in this mle shall be construed to limit the authority of the department to 

seek injunctive relief or to enforce the provisions ofthe act atld the regulations promulgated 

under the act 

History: 2002 AACS, 

R 336.1930 Emission of carbon monoxide from ferrous cupola operations. 

Rule 930. (1) It is unlawful for a person to operate a ferrous cupola that has a melting 

capacity of 20 or more tons per hour located within any area listed in Table 91, unless the 

ferrous cupola is equipped with an afterbumer control system, or equivalent, which reduces 

the carbon monoxide emissions from the fen·ous cupola by 90%. 

(2) The emission rate of carbon monoxide from a fen·ous cupola shall be determined 

by using reference test method 1 0, unless otherwise specified by the depmtment. 

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TABLE91 

Areas Subject toR 336,1930 

County Area 

Wayne TOlS, R09E to Rl2E 

T02S, R09E to RilE 

T03S, R09E to RIDE 

History: I995 AACS; 2001 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1931 Rescinded. 

Hist01y: 1999 AACS; 2002 AACS; 20I5 MR I I, Eff. May 20, 2015. 

R 336.1932 Rescinded. 

History: 1999 AACS; 2002 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1933 Rescinded. 

History: 2000 AACS; 2013 AACS. 

R 336.1940 Ethylene Oxide Emissions Standards for Sterilization Facilities. 

Rule 940. (1) The provisions of 40 C.F.R. Part 63, Subpart 0, are adopted by reference 

in R 336.1902. A person responsible for the operation of a facility subject to the provisions 

of "Ethylene Oxide Emissions Standards for Sterilization Facilities," 40 C.F.R. Part 63, 

Subpart 0, shall comply with those provisions. 

(2) For the purpose of this rule, the terms "administrator" and "EPA" as used in 

40 C.F.R. Part 63, Subpart 0 mean the department. 

History: 2000 AACS; 2008 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1941 Emission standards for chromium emissions from ha1·d and 

decorative chromium electroplating and chromium anodizing tanks. 

Rule 941. (1) The provisions of 40 C.F.R. Part 63, subpart N, are adopted by reference 

in R 336.1902. A person responsible for the operation of a facility that is subject to the 

provisions of "National Emission Standards for Chromium Emissions from Hard and 

Decorative Chromium Electroplating and Chromium Anodizing Tanks," 40 C.F.R. 

Part 63, Subpart N, shall comply with those provisions. 

(2) For the purpose of this rule, the terms "administrator" and "EPA" as used in 

40 C.F.R. Part 63, Subpart N mean the department. 

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I 

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History: 2000 AACS; 2008 AACS; 2015 MR 11, Eff. May 20, 2015, 

R 336.1942 Emission standards for asbestos. 

Rule 942. (I) The provisions of 40 C.P.R. Part 61, Subpart M, are adopted by 

reference in R 336.1902. A person that is subject to the provisions of "National Emission 

Standards for Asbestos," 40 C.P.R. Pmt 61, Subpart M, shall comply with those provisions. 

(2) For the purpose of this mle, the terms "administrator" and "EPA" as used in 

40 C.P.R. Pa:tt 61, Subpart M mean the department. 

History: 2000 AACS; 2008 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1943 General provisions for emission standard. 

Rule 943. (1) The provisions of 40 C.P.R. Pmt 63, Subpmt A, are adopted by reference 

in R 336.1902. The owner or operator of a facility subject to the provisions of "General 

Provisions," 40 C.P.R. Pmt 63, Subpa1t A, shall comply with those provisions. 

(2) For pmposes of this rule, the terms "administrator" and "EPA" as used in 40 C.P.R. 

Part 63, Subpart A mean the department. 

History: 2008 AACS;2015 MR 11,Eff. May 20,2015. 

R 336.1944 Emission standards for Portland cement manufacturing. 

Rule 944. (I) The provisions of 40 C.P.R. Prut 63, Subpmt LLL, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standards fOl' Hazardous Air Pollutants fi·om the Portland Cement 

Manufacturing Industry," 40 C.P.R. Part 63, Subpmt LLL, shall comply with those 

provisions. 

(2) For purposes of this rule, the tetms "administrator" and "EPA" as used in 40 C.F.R. 

Pmt 63, Subpmt LLL mean the department. 

History: 2008 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1945 Emission standards for publicly owned treatment works. 

Rule 945. (1) The provisions of 40 C.P.R. Prut 63, Subpmt VVV, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standm·ds for Hazardous Air Pollutants: Publicly Owned Treatment 

Works," 40 C.P.R. Pmt 63, S11bpart VVV, shall comply with those provisions. 

(2) For pmposes of this rule, the tetms "administrator" and "EPA" as used in 40 C.P.R. 

Part 63, Subpart VVV mean the department. 

History: 2008 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1946 Emission standards for secondary aluminum production. 

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Rule 946. (1) The provisions of 40 C.F.R. Part 63, Subpart RRR, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum 

Production," 40 C.P.R. Pmt 63, Subpart RRR, shall comply with those provisions. 

(2) For purposes of this rule, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Part 63, Subpatt RRR mean the depattment. 

Histoq: 2008 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1947 Emission standards for site remediation. 

Rule 947. (1) The provisions of 40 C.F.R. Pmt 63, Subpart GGGGG, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standards fm· Hazardous Ait· Pollutants: Site Remediation," 

40 C.P.R. Part 63, Subpart GGGGG, shall comply with those provisions. 

(2) For purposes of this mle, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Pmt 63, Subpart GGGGG mean the department. 

History: 2008 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1948 Emission standards for area sources: electric arc furnace steelmaking 

facilities. 

Rule 948. (1) The provisions of 40 C.F.R. Part 63, Subpmt YYYYY, are adopted by 

reference in R 336.1902. The owner or operato'r of a facility subject to the provisions of 

"National Emission Standards for Hazardous Air Pollutants for Area Sources: Electric Arc 

Furnace Steelmaking Facilities," 40 C.P.R. Part 63, Subpart YYYYY, shall comply with 

those provisions. 

(2) For purposes of this rule, the tetms "administrator" and "EPA" as used in40 C.F.R. 

Pmt 63, Subpatt YYYYY mean the depattment. 

History: 2013 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1949 Emissions standards for iron and steel foundry area sources. 

Rule 949. (1) The provisions of 40 C.F.R. Part 63, Subpart ZZZZZ, are adopted by 

reference iu R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries 

Area Sources," 40 C.P.R. Part 63, Subpart ZZZZZ, shall comply with those provisions. 

(2) For purposes of this rule, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Pmt 63, Subpmt ZZZZZ mean the department. 

Histoq: 2013 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1950 Emissions standards for aluminum, copper, and other nonferrous 

foundry area sources. 

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I 

I I 

I 

• 
Rule 950. (1) The provisions of 40 C.F.R. Pati 63, Subprut ZZZZZZ, are adopted by 

reference ia R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emission Standards for Hazardous Air Pollutants: Area Source Standards for 

Aluminum, Copper, and Other Nonferrous Foundries," 40 C.F.R. Patt 63, Subpart 

ZZZZZZ, shall comply with those provisions. 

· (2) For purposes of this rule, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Part 63, Subpart ZZZZZZ mean the deprutment. 

History: 2013 AACS; 2015 MR 11, Eff. May 20, 2015. 

R 336.1951 Emissions standards for secondary lead smelting. 

Rule 951. (1) The provisions of 40 C.P.R. Pa1t 63, Subpmt X, are adopted by reference 

in R 336.1902. The owner ot· operator of a facility subject to the provisions of ''National 

Emissions Standru·ds for Hazardous Air Pollutants from Secondary Lead Smelting," 

40 C.P.R. Pmi 63, Subprut X, shall comply with those provisions. 

(2) For purposes of this rule, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Prut 63, Subpati X mean the depatiment. 

Histol'y: 2015 MR 11, Eff. May 20,2015. 

R 336.1952 Emissions standards for hazardous waste combustors. 

Rule 952. (1) The provisions of 40 C.P.R. Pati 63, Subpart BEE, are adopted by 

reference ia R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards for Hazardous Air Pollutants fi·om Hazardous Waste 

Combustors," 40 C.F.R. Patt 63, Subpatt EEE, shall comply with those provisions. 

(2) For purposes of this rule, thetetms "administrator" and "EPA" as used in40 C.F.R. 

Patt 63, Subpati BEE mean the depmtment. 

History: 2015 MR 11, Eff.May 20,2015. 

R 336.1953 Emissions standards for mercury cell chlor-alkali plants. 

Rule 953. (1) The provisions of 40 C.P.R. Pat1 63, Subpart IIID, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards fo1· Hazardous Air Pollutants: Mercury Emissions from 

Mercmy Cell Chlor-Alkali Plants," 40 C.P.R. Part 63, Subpart Hill, shall comply witb those 

provisions. 

(2) For purposes of this rule, the tetms "administrator" and "EPA" as used in 40 C.P.R. 

Pmt 63, Subpati ill!I mean the depatiment. 

History: 2015 MR 11, Eff. May 20,2015. 

R 336.1954 Emissions standards for primary copper smelting area sources. 

Rule 954. (1) The provisions of 40 C.P.R. Pmt 63, Subpatt EEEEEE, m·e adopted by 

reference ia R 336.1902. The owner m· operator of a facility subject to the provisions of 

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"National Emissions Standards for Hazardous Air Pollutants for Primary Copper Smelting 

Area Sources," 40 C.F.R. Pmt 63, Subpart EEEEEE, shall comply with those provisions. 

(2) For purposes of this mle, the terms "administrator" and "EPA" as used in40 C.P.R. 

Pmt 63, Subpart EEEEEE mean the department. 

History: 2015 MR 11, Eff. May 20,2015. 

R 336.1955 Emissions standards for secondary copper smelting area sources. 

Rule 955. (I) The provisions of 40 C.F.R. Part 63, Subpmt FFFFPF, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standm·ds for Hazardous Air Pollutants fDl' Secondary Coppe1· 

Smelting Area Sources," 40 C.F.R. Pmt 63, Subpart FPPFPF, shall comply with those 

provisions. 

(2) For purposes of this mle, the terms "administrator" and "EPA" as used in 40 C.P.R. 

Part 63, Subpmt PPFFFP mean the depmtment. 

History: 2015 MR 11, Elf. May 20, 2015. 

R 336.1956 Emissions standards for primary nonferrous metals area sources -

zinc, cadmium, and beryllium. 

Rule 956. (I) The provisions of 40 C.P.R. Part 63, Subpmt GGGGGG, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards for Hazardous Air Pollutants for Primary Nonferrous Metals 

Area Sources- Zinc, Cadmium, and Beryllium," 

40 C.P.R. Part 63, Subpmt GGGGGG, shall comply with those provisions. 

(2) For purposes of this rule, the tenus "administrator" and "EPA" as used in 40 C.P.R. 

Patt 63, Subpart GGGGGG mean the depmiment. 

History: 2015 MR ll,Eff. May20, 2015. 

R 336.1957 Emissions standards for carbon black production area sources. 

Rule 957. (1) The provisions of 40 C.F.R. Pmt 63, Subpmt MMMMMM, are adopted 

by reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards fOl' Hazardous Air Pollutants for Carbon Black Production 

Area Sources," 40 C.F.R. Part 63, Subpart MMMMMM, shall comply with those 

provisions. 

(2) For purposes of this mle, the terms "administrator" and "EPA" as used in 40 C.F.R. 

Part 63, Subpart MMMMMM mean the depattment. 

History: 2015 MR 11, Elf. May 20, 2015. 

R 336.1958 Emissions standards for chemical manufacturing area sources for 

chromium compounds. 

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Rule 958. (1) The provisions of 40 C.P.R. Part 63, Subpart NNNNNN, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards for Hazardous Air Po11utants for Chemical Manufacturing 

Area Sources: Chromium Compounds," 40 C.P.R. Pmt 63, Subpmt NNNNNN, shall 

comply with those provisions. 

(2) For purposes of this rule, the tetms "administrator" and "EPA" as used in 40 C.F.R 

Part 63, SubpartNNNNNN mean the department. 

History: 2015 MR 11, Eff. May 20,2015. 

R 336.1959 Emissions standards for glass manufacturing area sources. 

Rule 959. (!)The provisions of 40 C.P.R. Pmt 63, Subpart SSSSSS, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the pmvisions of 

"National Emissions Standards for Hazardous Air Pollutants for Glass Manufacturing Area 

Sources," 40 C.P.R. Pmt 63, Subpart SSSSSS, sha11 comply with those provisions. 

(2) For pmposes of this mle, the tetms "administrator" and "EPA" as used in 40 C.P.R. 

Pmt 63, Subpa1t SSSSSS mean the department. 

History: 2015 MR 11, Eff. May 20,2015. 

R 336.1960 Emissions standards for chemical manufactoring area sources. 

Rule 960, (I) The provisions of 40 C.P.R. Pmt 63, Subpmt VVVVVV, are adopted by 

reference in R 336.1902. The owner or operator of a facility subject to the provisions of 

"National Emissions Standards for Hazardous Air Pollutants for Chemical Manufach1ring 

Area Sources," 40 C.P.R. Patt 63, Subpati VVVVVV, shall comply with those provisions. 

(2) For purposes of this rule, the tetms "administrator" and "EPA" as used in 40 C.P.R. 

Patt 63, Subpart VVVVVV mean the department. 

History: 2015 MR 11, Eff. May 20,2015. 

R 336.1970 Rescinded. 

HistOJ'y: 2008 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1971 Best available retrofit technology or BART program. 

Rule 971. (!) The department shall detetmine applicability of best available retrofit 

technology based on the provisions of 40 C.P.R. Pmt 51, Subpa1t P, adopted by reference in 

R 336.1902 .. 

(2) The owner or operator of a unit subject to BART shall perform an engineering 

analysis as described in the provisions of 40 C.P.R. Patt 51, Subpmt P and shall provide the 

results of the analysis to the depmtment within 60 days of the effective date of this mle. 

(3) If an electric generating unit (EGU) subject to BART is subject to the trading 

programs ofthe Clean Air Interstate Rule under 40 C.P.R. Part 97, the owner or operator of 

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the EGU is not required to conduct a BART analysis for sulfur dioxide and oxides of 

nitrogen emissions under this rule. 

(4) An engineeting analysis required by submle (2) of this mle shall be submitted to 

the department and shall be subject to review and approval by the depatiment. If the 

depruiment determines additional information is required, the department shall provide to 

the owner or operator additional information requests and comments in writing. The owner 

or operator shall provide the requested inf01mation within 60 days from receipt of wtitten 

requests and comments from the department. The department may delelmine that more 

than 60 days will be allowed. 

(5) The department shall detetmine the BART level of control for each unit subject to 

BART based on the engineeting analysis referenced in subrule (2) of this rule, the 

provisions of 40 C.F.R. Part 51, Subpart P and other infmmation which the department 

determines to be relevant. 

(6) The owner or operator of a unit subject to BART shall enter into a petmit to install 

or consent order with the depatiment to make the BART provisions legally enforceable 

within 90 days of the depatiment's approval of the engineeting analysis, unless the 

depatiment determines that more than 90 days will be allowed. BART conh·ols shall be in 

place and operating not later than 1 year from an approved engineeting analysis. 

(7) An owner or operator subject to this rule shall measure oxides of nitrogen and 

sulfur dioxide emissions with 1 or more of the following: 

(a) A continuous emission monitoring system. 

(b) An altemate method as described in 40 C.F.R. Part 60 or 75, adopted by reference 

in R 336.1902, as applicable and acceptable to the depatiment. 

(c) A method currently in use or a future method developed for use and acceptable to 

the department, including methods contained in existing permit conditions. 

(8) An owner or operator of an emission unit that measures oxides of nitrogen or sulfur 

dioxide emissions by a continuous emission monitoring system shall do either of the 

following: 

(a) Use procedures set forth in 40 C.F.R. Patt 60, Subpart A and appendix B, and 

comply with the quality assUl'ance procedures in appendix F, adopted by reference in R 

336.1902, as applicable and acceptable to the department. 

(b) Use procedures set forth in 40 C.P.R. Patt 75, and associated appendices, adopted 

by reference in R 336.1902, as applicable and acceptable to the depmiment. 

(9) An owner or operator of an emission unit who uses a continuous emission 

monitoting system to demonsh·ate compliance with this rule and who has already installed a 

continuous emission monitming system for oxides of nitrogen or sulfur dioxide pursuant to 

other applicable federal, state, or local rules shall meet the installation, testing, operation, 

quality assurance, and repotting requirements specified by the department. 

(1 0) An owner or operator of an emission unit that is subject to this rule and has a 

petmit or consent order issued under subrule (6) of this mle shall submit at a mininmm 

semi-at111ual summary reports, in an acceptable format, to the depatiment by March 15 for 

the reporting period July 1 to December 31 and September 15 for the reporting period 

January 1 to June 30 of each calendar year. The reports shall include all of the following 

intbtmation: 

(a) The date, time, magnihlde of emissions, and emission rates where applicable, of the 

specified emission unit or utility system. 

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(b) If emissions or emission rates exceed the emissions or emission rates allowed by 

the applicable emission limit, the cause, if known, and any conective action taken. 

(c) The total operating time of the emission unit dudng the time period. 

(d) For continuous emission monitoring systems, system perfonnance infmmation 

shall include the date and time of each period during which the continuous monitoring 

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

repairs or adjustu1ents. When the continuous monitoring system has not been inoperative, 

repaired, or adjusted, the infmmation shall be stated in the repmt. 

(11) Quarterly summary repmts, if required by the depa1tment pursuant toR 336.1213, 

shall be submitted within 30 days following the end of the calendar qumter and may be 

used in place of the semi-ammal reports required pursuant to subrule (1 0) of this 1ule. 

History: 2008 AACS; 2015 MR 11, Eff. May 20,2015. 

R 336.1972 Emissions standards for existing sewage sludge incineration units. 

Rule 972. (1) Except as provided in subdivisions (c) to (e) of this subrule, by 

March 21,2016, each sewage sludge incineration (SSI) unit for which construction was 

commenced on or before October 14, 2010, defined under "Emission Guidelines and 

Compliance Times for Existing Sewage Sludge Incineration Units," 40 C.F.R. §60.5250, 

shall achieve final compliance with the requirements of this rule. Final compliance means 

all process changes and control devices, as specified in the fmal control plan, are completed 

and operating as designed and the department receives notification of compliance, including 

a signature of the owner or operator of the unit. 

(a) The SSI unit remains subject to the requirements and deadlines of this rule if any of 

the following apply: 

(i) The owner or operator of a SSI unit makes physical or operation changes to the unit 

primarily to comply with this mle and the unit commenced constmction on or before 

September 21, 2011. 

(ii) The SSI unit closes and restarts prior to March 21, 2016. 

(b) If the SSI unit closes and restarts after March 21, 2016, then the owner or operator 

of the unit shall meet the emission limits, emission standards, and operating limits in this 

mle on the date the unit restarts operations. 

(c) A combustion unit that incinerates sewage sludge and is not located at a wastewater 

treallnent facility designed to u·eat domestic sewage sludge is exempt from this rule upon 

notification to the dcpm1ment. 

(d) If the owner or operator of a SSJ unit makes changes that meet the definition of 

modification under 40 C.P.R. §60.5250 after September 21, 2011, the unit is subject to 

"Standards of Performance for New Sewage Sludge Incineration Units," 40 C.F.R. Part 60, 

Subpart LLLL. Such unit is exempt fi·om this rule upon notification to the depmtment. 

(e) If an owner or operator chooses to cease operation of the SSI unit rather than 

comply with this rule, a closure notification shall be submitted to the deparllnent by March 

21,2015. 

(2) The owner or operator of a SSI unit that has not submitted a closure or exemption 

notification to the department shall submit an application for a renewable operating pe1mit 

and, by March 21, 2015, shall submit a final conu·ol plan meeting the requirements of 40 

C.F.R. §60.5110 that is signed by the owner or operator of the unit. 

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(3) By March 21, 2016, each SSI unit shall comply with the following provisions of 

"Emission Guidelines and Compliance Times for Existing Sewage Sludge Incineration 

Units," 40 C.P.R. Pali 60, Subpali MMMM, adopted by reference in 

R 336.1902: 

(a) "Increments of Progress," 40 C.P.R. §60.5110. 

(b) "Operator Training and Qualifications," 40 C.P.R. §§60.5130 to 60.5160. 

(c) "Emission Limits, Emission Standards, and Operating Limits arid Requirements," 

40 C.P.R. §§60.5165 to 60.5180. 

(d) "Initial Compliance Requirements," 40 C.P.R. §§60.5185 to 60.5200. 

(e) "Continuous Compliance Requirements," 40 C.P.R. §§60.5205 to 60.5215. 

(f) "Performance Testing, Monitoring, and Calibration Requirements," 40 C.F .R. 

§§60.5220 to 60.5225. 

(g) "Recordkeeping and Reporting," 40 C.P.R. §§60.5230 to 60.5235. 

(h) "Title V Operating Permits," 40 C.P.R. §§60.5240 to 60.5245. 

(i) "Definitions," 40 C.P.R. §60.5250. 

(j) Tables 2 to 6. 

(4) For purposes of this mle the term "administrator" as used in 40 C.P.R. Prut 60, 

Subpali MMMM means the depattment. 

History: 2015MR ll,Eff. May 20,2015. 

Page 19. 

Courtesy of lt'Wlv.michigan. govlorr 
To: Secretary of the Senate 

Sl:A.'IE oF MJ:cmoAN 

Ru·m JoHNSoN, SECRE'l'ARY OF S·rATE 

DEPARTMENT OF STATE 

LANSING 

May 20,2015 

NOTICE OF FILING 

ADMINISTRATIVE RULES 

Clerk of the House of Representatives 

Joint Committee on Administrative Rules 

State Office of Regulatory Reinvention (Administrative Rule #2013-109-EQ) 

Legislative Service Bureau (Secretary of State Filing #15·05·1 0) 

Department of Environmental Quality · 

In accordance with the provisions of Section 46(1) of Act 306, Public Acts of 1969, as amended, 

and Executive Order 1995·6, this is to advise you that the Michigan Department of Licensing 

and Regulatory Mfairs and the State Office of Regulatory Reinvention filed Admi11istrative Rule 

#2013-109-EQ (Secretary of State Filing #15-05-10) on this date at4:09 P.M. for the Department 

ofEnvironmental Quality, entitled "Pact 9, Emission Linlltations and l'rohibitionsMiscellaneous", 

These rules becom~ effective immediately upon filing with the Secretary of State unless adopted 

under sections 33, 44 or 45a(6) of 1969 PA 306. Rules adopted under these sections become 

effective 7 ~ays after filing with the Secretary of State. 

Sincerely, 

Ruth Johnson 

Secretary of State 

f{~v ~ -/zY?/4-tJ 

Robin 1. Houston, Departmental Supervisor 

Office of the Great Seal 

Enclosure 

OFFICE OF THE GREAT SoAL 

100 SOUTH WASHINGTON SQUARE, SUITE 1• LANSING, MICHIGAN 40~16 

1·6BB·SOS·MIGH (1-800·767·6424) 

www, Ml oh Jgan.gov/Go.s 
niLL SCHUE'r'l'E 

AT'rORNEY GENEEAL 

Certification of Authority for the 

P.O. Box 30766 

LANSING, MICHIGAN 48909 

Michigan Department of Environmental Quality to Adopt 

by Reference the Emission Guidelines and Compliance 'l'imes for 

Existing Sewage Sludge Incinerators, 40 C.F.R. Part 60, Subpart MMMM 

I hereby ce1•tizy that the Michigan De}lartment of Environmental Quality 

(MDEQ) has adopted by reference the Emission Guidelines and Compliance Times 

for Existing Sewage Sludge Iucineratm· Units, 40 C.F.R. Part 60, Subpart MMMM, 

§§ 60.5000 et seq., in Rule 902 of the Michigan Ail' Pollution Control Rules, 2015 

A.A.C.S., R 336.1902, pmsuant to its authority under Michigan law. I further 

certify that the adoption by reference is valid and enforceable. 

Michigan's Adminiatt·ative Procedures Act, M.C.L. §§ 24.201 et seq., 

authorizes the MDEQ to adopt by reference in its rules all or any part of a 

regulation adopted by an agency of the United States. Section 32(4) of the 

Administrative Procedures Act, M.C.L. § 24.232(4), states in relevant part: 

(4) An agency may adopt, by 1•eference in its rules ancl without 

pt1blisl1ing the adopted matter in full, all or any pa1·t of a code, standard or 

regulation which has been adopted by an agency of tJ1e United States or by a 

nationally recognized organization or association. The reference shall fully 

identify the adopted matte1• by date and otherwise. 

On May 20, 2015, the MDEQ adopted by reference all of 40 C.F.R. Part 60 

(2013), including the emission guidelines for existing sewage sludge incinerator 

units, in Rule 902(1)(e) of the Michigan Ai1• Pollution Control Rules. 2015 A.A.C.S., 

R 836.1902(1)(e). Also on May 20, 2015, the MDEQ promulgated Rule 972 of the 

Aix Pollution Control Rules, 2015 A.A.C.S., R 336.1972. Rule 972 establishes 

emission standards for existing sewage sludge incineration units aml requires that 

such units comply with the modelt·ule provisions in the emission guidelines. Rule 

9?2 also states that for purposes of the rule the te1·m "administrator" as used in 40 

C.F.R. Part 60, Subpart MMMM means the MDEQ. 
'flle MDEQ's adoption by reference of EPA's Emission Gtiidelines and 

Compliance Times for Existing Sewage Sludge Incinerator Units i11 R11le 902(1)(e) of 

the Michigan Ail' Pollution Control Rules is lawft1l and enforceable. 

Date: May 27, 2015 

N ei! D, Gordon 

Assistant Attm:ney General 

Environment, Natural Resources 

and Agriculture Division 

(517) 373-7540 

Lf•': ENRA Gordon, Neil (Ah·lssnes) AG/12007·3000lJ8-MCertit:ication ~ ofAnUJOl'i!.y 2015·05·27 

2 
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION ACT (EXCERPT) 

Act 451 of 1994 

324.5512 Rules. 

Sec. 5512. (1) Subject to section 5514, the depatiment shall promulgate rules for purposes of doing all of 

the following: 

(a) Controlling or prohibiting air pollution. 

(b) Complying with the clean air act. 

(c) ControlHng any mode of transportation that is capable of causing or conhibuting to air pollution. 

(d) Reviewing proposed locations of stationary emission sources, 

(e) Reviewing modifications of existing emission sources. 

(f) Prohibiting locations or modifications of emission sources that impair the state1

S ability to meet federal 

ambient air quality standards. 

(g) Establishing suitable emission standards consistent with federal ambient air quality standards and 

factors including1 but not limited to, conditions of the terrain, wind velocities and directions, land usage of the 

region, and the anticipated characteristics and quantities of potential air pollution sources. This part does not 

prohibit the <iepartment from denying or revoking a pem1it to operate a source, process, or process equipment 

that would adversely affect human health or other conditions important to the life of the community. 

(h) Implementing sections 5505 and 5506. 

(2) Unless otherwise provided in this part, each rule, pennit, or administrative order promulgated or issued 

under this part prior to November 131 1993 shall remain in effect according to its tenns unless the rule or 

order is inconsistent with tills pa1t or is revised, amended, or repealed. 

(3) Section 11522 applies to open burning. 

Illstnry: 1994, Act45J, Eff. Mnr. 30, 1995;-Am. 2012, Act 102, lmd. Eff. Apr. 19,2012;-Am, 2014, Act 417, Eff. Mar. 31,2015. 

Pop11lar name: Acl451 

Popular name: NREPA 

Admlntstrative rules: R 336.1101 et seq,; R 336.1122; and R 336.1201 et seq. of the Michigan Administrative Code. 

Rendered Tuesday, June 2, 2015 

© Legislative Councll, State of Michigan 

Page 1 Michigan Complied Laws Complete Through PA 39 of 2015 

Courtesy ofwww./egis/ature.migov 
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION ACT (EXCERPT) 

Act 451 of 1994 

324.5516 Public hearing; Information available to the public; use of confidential information. 

Sec. 5516. (1) A public hearing with reference to pollution control may be held before the deparhnent. 

Persons designated to conduct the hearlng shall be described as presiding officers and shall be disinterested 

and technically qualified persons. 

(2) A copy of each pemtit, pem1it application, order, compliance plan and schedule of compliance, 

emissions or compliance monitoring report, sample analysis, compliance certification, or other report or 

infonnation required under this part, rules promulgated ·under this part, or permits or orders issued under this 

part shall be available to the public to the extent provided by the freedom of information act, Act No. 442 of 

the Public Acts ofl976, being sections 15.231 to 15.246 of the Michigan Compiled Laws. 

(3) A person whose activities are regulated under this pmt may designate a record or other infonnation, or 

a portion of a record, pennit application, or other information fi.ll'nished to or obtained by the department or its 

agents, as being only for the confidential use of the department. The department shall notifY the person 

asserting confidentiality of a request for public records under section 5 of the freedom of infOnnation act, Act 

No. 442 of the Public Acts of 1976, being section 15.235 of the Michigan Compiled Laws, the scope of which 

includes infonnation that has been designated by the regulated person as being confidential. The person 

asserting confidentiality has 25 days after the receipt of the notice to demonstrate to the department that the 

information designated as confidential should not be disclosed beca11se the infonnation is a trade secret or 

secret process, or is production, commercial, or financial infonnation the disclosure of which would 

jeopardize the competitive position of the person from whom the information was obtained, and make 

available infonnation not otherwise publicly available, The department shall grant the request for the 

infonnation unless the person regulated under this part demonstrates to the satisfaction of the department that 

the information should not be disclosed, If there is a dispute between the person asserting confidentiality and 

the person requesting infonnation under Act No. 442 of the Public Acts of 1976, the department shall make 

the decision to grant or deny the request. After the department makes a decision to grant a request, the 

information requested shall not be released unti18 business days after the regulated person1

s receipt of notice 

of the departments decision. This does not prevent the use of the infonnation by the department in compiling 

or publishing analyses or summaries relating to ambient air quality if the analyses or summaries do not 

identifY the person or reveal infmmation which is othenvise confidential under this section. This section does 

not render data on the quantity, composition, or quality of emissions from any source confidential. Data on 

the amount and nature of air contaminants emitted from a source shall be available to the public. 

History: 1994, Act 451, Etf. Mar. 30, 199S, 

Popular name: Ac~ 45 I 

Popular name: NREPA 

Rendered Tuesday, June 2, 2015 

© Legislative Council, State of Michigan 

Page 1 Michigan Compiled laws Complete Through PA 39 of 2015 

Courtesy of www.leglslalure.mi.gov 
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION ACT (EXCERPT) 

Act 451 of 1994 

324.5526 Investigation; Inspection; furnishing duplicate of analytical report; powers of 

department or authorized representative; entry or access to records refused; powers of 

attorney general; "authorized representative" defined. 

Sec. 5526. (1) The department may, upon the presentation of credentials and other documents as may be 

required by law, and upon stating the authority and purpose of the investigation, enter and inspect any 

property at reasonable times for the purpose of investigating either an actual or suspected source of air 

pollution or ascertaining compliance or noncompliance with this part, mles promulgated under this part, the 

clean air act~ a permit issued under this pa1i, or any detennination or order issued under this part. If in 

connection with an investigation or inspection, samples of air contaminants are taken for analysis, a duplicate 

of the analytical report shall be furnished promptly to the person who is suspected of causing the air pollution. 

In implementing this subsection, the department or its authorized representative may do any of the following: 

(a) Have access to and copy, at reasonable times, any records that are required to be maintained pursuant to 

this part, rules promulgated under this part, the clean air act, a permit issued under this part, or any 

detennination or order issued under this part. 

(b) Inspect at reasonable times any facility, equipment, including monitoring and air pollution control 

equipment, practices, or operations regulated or required under this part, mles promulgated under this part, the 

cle(ln air act, a permit issued under this part, or any dctennination or order issued under this part. 

(c) Sample or monitor at reasonable times substances or parameters for the pmpose of detennining 

compliance with this part, rules promulgated under this part, the clean air act, a permit issued under this part, 

or any detetmination or order issued under this part. The department may enter into a contract with a person 

to sample and monitor as authorized under this subdivision. 

(2) If the department, or an authorized representative of the department~ is refused entry or access to 

records and samples under subsection (1) for the purposes of utilizing .this section, the attorney general, on 

behalf of the state, may do either of the following: 

(a) Petition the court of appropriate jurisdiction for a wan·ant authorizing entty or access to records and 

samples p11rsuant to this section. 

(b) Commence a civil action to compel compliance with a request for entry and access to records and 

samples pursuant to this section, to authorize ently and access to records and samples provided for in this 

section, and to enjoin interference with the utilization of this section. 

(3) ABused in this section, "authorized representative" means any ofthe following: 

(u) A full- or part-time employee of the department of natural resources or other state department or 

agency to which the department delegates certain duties under this section. 

(b) A county to which authority is delegated under section 5523. 

(c) For the pmpose of utilizing the powers confened in subsection (l)(c), a conh·actot· retained by the state 

or a county to which authority is delegated under section 5523, 

History: 1994, Act 451, Eff. Mar. 30, 1995. 

Popular name: Act451 

Popular name: NREPA 

Rendered Tuesday, June 2, 2015 Page 1 

© Legislative Council, State of Michigan 

Michigan Complied Laws Complete Through PA 39 of2015 

Courtesy ofwww.leglslature.mi.gov 

I I 
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION ACT (EXCERPT) 

Act 451 of 1994 

324.5530 Commencement of civil action by attorney general; relief; costs; jurisdiction; 

defenses; fines. 

Sec. 5530, (1) The attorney general may commence a civil action against a person for appropriate relief, 

including injunctive relief, and a civil fine as provided in subsection (2) for any of the following: 

(a) Violating this part or a rule promulgated under this part. 

(b) Failure to obtain a permit nnder this part. 

(c) Failure to comply with the terms of a pennit or an order issued under this part. 

(d) Failure to pay an air quality fee or comply with a filing requirement under this part. 

(e) Failure to comply with the inspection~ entry, and monitoring requirements of this part. 

(f) A violation described in section 5518(2). 

(2) In addition to any other relief authorized under this section, the court may impose a civil fine of not 

more than $10,000,00 for each instance of violation and, if the violation continues, for each day of continued 

violation. 

(3) In addition to other relief authorized under this section, the attorney general may, at the request of the 

department, file an action in a court of competent jurisdiction to recover the full value of the injuries done to 

the nahual resources of the state. 

( 4) In issuing a fmal order in an action brought pursuant to this section, the court may award costs of 

litigation, including, but not limited to, reasonable attorney and expert witness fees, to the prevailing or 

substantially prevailing party if the court determines that such an award is appropriate. 

(5) A civil action brought under this section may be brought in the county in which the defendant is 

located, resides, or is doing business, or iu the circuit court for the county of lngham, or in the county in 

which the registered office of a defendant corporation is located, or in the county where the violation 

occurred. 

(6) General defenses and affinnative defenses 1 that may otherwise apply under state law may apply in an 

action brought under this section as determined to be appropriate by a court of competent jurisdiction. 

(7) Fines imposed under this section shall be assessed for each instance of violation and1 if the violation is 

continuous, shall be assessable up to the maximum amount for each day of violation. 

History: 1994, Act 451, Eff. Mar. 30, 1995. 

Popular name: Act451 

Popular Dl\me: NREPA 

Rendered Tuesday, June 2, 2015 

© Legislative Council, State of Michigan 

Page 1 Michigan Complied Laws Complete Through PA 39 of2015 

Courtesy ofwww.legislature.mi.gov 

CITY OF BATTLE CREEK 

DEPARTMENT OF PUBLIC WORKS • WASTEWATER DIVISION 

Mr. Rex Lane 

Senior Environmental Quality Analyst 

Air Quality Division 

Kalamazoo District Office 

Dear Mr. Lane: 

Subject: Closure Date for SSJ Units Jn Battle creek 

Pursuant to the request by the Department of Environmental Quality to notify of Battle creek 

Wastewater Treatment Plant's Intent on future lnclneratlon, we hereby submit formal notification of 

Closure. The City of Battle Creek Michigan will no longer incinerate waste municipal solids, and will 

decommission the two Sewage Sludge Incinerators by March 21, 2016, 

If you have any further questions or concerns regarding our Intentions please feel free to contact me at 

anytime. 

Wastewater Superintendent RECEI:VED 

E2~'l City of Battle Creek Michigan 269-966-3599 

AQD-l<ALAMAZOO 

2000 River Road West • BaLtle C1•eek, MichlgEm • 49037-7481 

(269) 966-8513 • Fax {269) 865-3280 • Web· www.bottlee~~cckmi.gov 
( 

DEPARTMENT OF NATURAL RESOURCES AND ENVIRONMENT 

AIR QUALITY DIVISION 

ACTIVITY REPORT: Scheduled Inspection 

Page 1 of2 

E;ast Lansing Waste Water Treatment is a Minor Source of both Criteria Pollutants and Hazardous Air Pollutants 

(HAP). The Minor Source status was verified in 1997 when a Potential to Emit (PTE) demonstration was 

submitted and reviewed by AQD staff. 

The Incinerators are currently subject to the following: 

40 CFR 61 subpart E, NESHAP for Mercury. Emissions to the atmosphere from sludge lnclneratlon plants, 

sludge dl)ling plants, or a combination of these that process wastewater treatment plant sludge, shall not exceed 

3.2 kg (7.1 lb) of mercury per 24-hour period, 

40 CFR 61 subpart C, NESHAP for Beryllium. Extraction P.lants, ceramic plants, foundries, incinerators, and 

propellant plants which process beryllium ore, beryllium, beryllium oxide, beryllium alloys, or beryllium-containing 

waste. Emissions to the atmosphere from stational)' sources subject to the provisions of this subpart shall not 

exceed 10 grams (0.022lb) Qf beryllium over a 24-hour period. 

40 CFR 60 Subpart MMMM--Emission Guidelines and Compliance Times for Existing 

Sew<~ge Sludge Incineration Units. These requirements are to be Included in an approved State Plan, It is my 

understanding that the. rule does not come into effect until May of this year and compliance In another three 

years. Citation 60.5125 states that If a source plans to close its SSI unit rather than comply with the state plan, 

they need to submit a closure notification, Including the date of closure, to the Administrator by the date their. 

final control plan Is. due. 

The Incinerators are not subject to: 

40 CFR 61 subpart FF, NESHAP for Benzene. East Lansing Waste Water Treatment is not a permitted 

hazardous waste storage or disposal facility, so Is not subject to this subpart. 

40 CFR 63 subpart FF, MACT NESHAP for Publicly Owned Waste Water Treatment plants. East Lansing Waste 

Water Treatment Is not a Major Source of HAP, so is not subject to this subpart. 

The Incinerators were last used on October 17, 2002. 

' I arrived at 2:30. I met with Jeff Johnston; Superintendent of the source. We discussed !he advantages of voiding 

the permits. I stated that It was my opinion that they could not operated the boilers without extensive repairs and 

replacements and that In making those repairs,;.. a mpditlcatlon permit would likely be required. 

l~"'"''-"'\V\ . 1 was joined on the !nsp;ict!Oili with Catherine &rahatn, Process Control Supervisor, an<Milla\1.-lllO. 

2 Sludge Incinerators 

Permits 247-71 and 102-72 were issued to East Lansing Waste Water for the installation of two Multiple Hearth 

Inc. Incinerators. The Incinerators were permitted with scrubbers and low velocity mist eliminators. It Is my 

understanding that the Incinerators are 6 hearth units. Two hearths dry, two Incinerated, and two cool. Ash 

disposal for the original Incinerator design included ash quenching and pumping the slurry to two lagoons 

situated east of the plant. 

During my Inspection I identified the two incinerators. They were not operating and appeared to be 

v ''"St3/20 11 

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Page 2 of2 

decommissioned. Analyzer components for the CEM/COMs were missing as were the computer components for 

Data Acquisition and Storage (DAS). Instrumentation in the control room was out of repair. Wayne slated lhat 

the gas supply to the units had been disconnected. I also noticed from a photograph that the east ash lagoon 

had been filled ln. The west lagoon still exists but was reduced in size. · 

At present the sludge Is being dewatered, loaded on trucks, and sent to Granger landfill. 

The remaining waste water treatment equipment appeared to be exempt by rule 285 (m). 

J. Johnston did indicate that two small naturill gas boilers are used to provide comfort heat and hot water. Rule 

282 (b) exempts these u\1\s from the need for an air use permit. 

"~ [ft--t~, MS+col/ ~-•oo" ~··· 

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CJTY OF EAST LANSING 1 

EAST LANSING. MICR!OAN 

Wwolt}Wilter Trentmcnt Plant 

517·311-2240 

517-311·2243 p,,.p;;<,_~, 

CITY OF EAST LANSING 

\Vastawtt!er Tr~ntment P!tmt 

517-37!-2240 

5lN11·2243 FAX 

EAST LANSING, MICH!OAN 

1700 Trowbridge Road 

Et'ISt L11nslng, tvll•~382J 

_ __,_i;<:·a,.twa®cityofenstlmmlng:.com 

.. ····--·- ....• 

5/3/2011 

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CITY OF FLINT 

DEPARTMENT OF PUBLIC WORKS 

WATER POLLUTION CONTROL DIVISION 

Dayne Walling 

Mayor 

DARNELL EARLEY Robert J. Case 

EMERGENcYMANAG~~Q·AQD LANSING o.(YPC Supervisor 

Mr. G. Vinson Hellwig 

Chief, Air Quality Division . 

Michigan Department of Environmental Quality 

P.O. Box 30260 

525 West Allegan Street 

Lansing, Michigan 48909-7760 

APR 03 2014 March 19,2014 

RECEIVED 

MAR 2 6 2014 

AIR QUALITY DIV. 

Re: Title V Renewable Operating Permit, City of Flint Water Pollution Control 

Dear Mr. Culham: 

As we discussed last week, a submission date is approaching this week which may require tbat 

tbe City of Flint submit an application for a Renewable Operating Permit (ROP) for its four 

sewage sludge incinerators (SSI). Our SSis are not a majoJ• source, but in recent years, 40 CFR 

Part 60, Subpart MMM,M, has been pwmulgated to regulate all existing SSis. 

The compliance date for Subpart MMMM is March 21,2016. The City ofFlinfhas evaluated its 

sludge management options accordingly, and decided that incineration is no l<mger cost 

effective. Therefore, we plan to phase them out prior to the compliance date. It makes little 

sense for either the City or tbe State DEQ to expend the significant resources that would be 

needed to draft and negotiate an ROP when the City intends to shut down tbese SSls in the near 

fi.rture, and cettainly well before the March 21, 2016 compliance date. 

Although the City of Flint h&s in the recent past made significant improvements to its 

incinerators and feed .systems, and the emissions performance has been excellent, the new 

MMMM emission standards and numerous other new Part 60 requirements mandate new capital 

expenses beyond affordabilii:y. Flint continues to generate a shrinking amount of sludge as a 

result of continued losses of industry and population, a trend not expected to change in the 

foreseeable future. The City has significant financial challenges, and is operating under an 

Emergency Manager. It is not in a position to expend its ve1y limited resources fm an ROP 

application. · · · 

It also plans to more cost-effectively manage its sludge by Iandfilling it, rather than incinerating 

it. Currently, design for a new loadout building and conveyance system to enable the landfilling 

Water Pollution Control Dlvlslon • G-4652 Beecher .Rond • Fllnf1 Michigan 48532 ' (810} 766-7210 (phone) • (810} 230-3154 (fax) 

TnolnShutdownPianDEiQhq.DOC 

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is undetway. The City has engaged the engineering fitm of Hubbell, Roth, and Clark to perform 

the work. The projected schedule is to :finish the design, prepare bid specifications, procure DEQ 

approval, bid and award the contract, and begin construction this summer. Construction should 

be complete by early next year. Once the initial operations and adjustments have been made, and 

the facility is considered to be running reliably, the incinerators will be shut down indefinitely. 

There is no CJll1'ent plan to use them again after they are shut down, although restart is a 

possibility (but an unlikely possibility). A notice will be sent to both DEQ and USEPA when the 

shutdown date is known. 

The City of Flint therefore will not submit an ROP application. In the unlikely event that the City 

ever considers resuming incinerator operation, you will be notified. The incinerators would not 

resume· operation until the appropriate retrofits, improvements, and air use permits were in place. 

I thank you for your attention in this matter. Should you need any further information, 

you may contact me by phone at (810) 577-6703 or email at rcase@cityoffiint.com. 

cc: M. Robinson, WNJ. 

J. Thaler, FTCH 

Brian Cuiham, MDEQ 

laoinShutdowuPliUlOBQhq.DOC 

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WRC 

March 6, 2015 

Mr. Christopher Ethridge 

Southeast Michigan District Supervisor 

Air Quality Division 

Southeast Michigan District 

27700 Donald Court 

Warren, Michigan 48092-2793 

Re: Deconunissioning Existing Sewage Sludge Incineration Units located at Pontiac 

Wastewater Treatment Plant 155 N. Opdyke Road, Pontiac MI 

Dear Mr. Ethridge: 

The Pontiac Wastewater Treatment Facility Chapter 20 Drainage District (COPWWTFDD) is 

in receipt of your letter dated February 10,2015. The operation of the existing sewage sludge 

incineration (SSI) ceased on June 16, 2011 when the City of Pontiac entered into an 

agreement with United Water for ope1·ation and maintenance of the wastewater treatment 

facility. 

This letter is to serve as an official closme notification to the Michigan Department of 

Environmental Quality for the deconnnissioning ol'the existing Pontiac Wastewater 

Treatment Facility Sewage Sludge Incineration Unit. The COPWWTFDD plans to isolate and 

discom1ect the natural gas feed line and the sludge feed conveyor to the sewage sludge 

incinerator by no later than May 1, 2015. 

Please do not hesitate to contact me if you have any questions or concems. 

Navid Meln·am, P.E. 

Operation Engineer 

cc: Michael Daniels, United Water 

Laura Verona, MDEQ 

~- - - - ~ ' ' . ' ' - ' \ - ~ ' ~ - - - - - - - ' : - - ', - ' . 

" t_~\ " One Public Worl<s Drivo • BuiiWng 95 West • Waterford, MI4832B·1907 , ~{l\0 

•+t Phone: 248.858.0958 • Fax:,248.B56.1066 • ww,w.oakgov.com!water 9000 ' 

" 1~000 

"',_.=; - -- - ' - - ' 
Navid Mehram, PE 

Oakland County WRC 

1 Public Works Dr. 

Waterford, MI 48328 

April 30, 2015 

Dear Mr. Mehram, 

As you requested we permanently decommissioned the sludge incinerator at the Pontiac (Aubum) 

Wastewater Treatment Plant. We perfmmed the decommissioning by shutting off the gas supply, 

removing a section of the gas piping and installing blind flanges to both ends of the pipe. To 

assure that no sludge will be fed to the incinerator both feed hatches were capped with steel and 

welded shut. There was a north feed hatch and a south feed hatch. 

I have attached pictures of the modifications that were made to verifY the decommissioning. The 

pictures are labeled for your convenience. 

If you have questions, please contact me at yom· convenience. 

Sincerely, 

Jeanette M. Best 

Project Manager 

United Water 
Michigan Department of Environmental Quality 

Air Quality Division 

EFFECTIVE DATE: January 31,2014 

REVISION DATE: June 13, 2014 

ISSUED TO 

Detroit Water and Sewerage Department 

Detroit Wastewater Treatment Plant 

State Registration Number (SRN): B2103 

LOCATED AT 

9300 W. Jefferson Avenue, Detroit, Michigan 48209-2696 

RENEWABLE OPERATING PERMIT 

Permit Number: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

Administratively Complete ROP Renewal Application Due 

· Between July 31, 2017 and July 31, 2018 

This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of 

Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, 

as amended (Act 451). Pursuant to Michigan Air Pollution Control Rule 210(1), this ROP constitutes the 

permittee's authority to operate the stationary source identified above in accordance with the general 

conditions, special conditions and attachments contained herein. Operation of the stationary source and 

all emission units listed in the permit are subject to all applicable future or amended rules and regulations 

I pursuant to Act451 and the federal Clean Air Act. 

SOURCE-WIDE PERMIT TO INSTALL 

Permit Number: MI-PTI-B21 03-2014a 

This Permit to Install (PTI) is issued in accordance with and subject to Section 5505(5) of Act 451. 

Pursuant to Michigan Air Pollution Control Rule 214a, the terms and conditions herein, identified by the 

underlying applicable requirement citation of Rule 201(1)(a), constitute a federally enforceable PTI. The 

PTI terms and conditions do not expire and remain in effect unless the criteria of Rule 201 (6) are met. 

Operation of all emission units identified in the PTI is subject to air applicable future or amended rules and 

regulations pursuant to Act 451 and the federal Clean Air Act. 

Michigan Department of Environmental Quality 

Wilhemina Mclemore, Detroit District Supervisor 

1 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

TABLE OF CONTENTS 

ROP No: MI-ROP-B2103-2014a 

Expiration Dale: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

AUTHORITY AND ENFORCEABILITY ................................................................................................... 4 

A. GENERAL CONDITIONS ................................................................................................................... 5 

Permit Enforceability ................................................................................................................................ 5 

General Provisions ................................................................................................................................... 5 

Equipment & Design ................................................................................................................................ 6 

Emission Limits ........................................................................................................................................ 6 

Testing/Sampling ..................................................................................................................................... 6 

Monitoring/Recordkeeping ....................................................................................................................... 6 

Certification & Reporting .......................................................................................................................... 7 

Permit Shield ........................................................................................................................................... 8 

Revisions ................................................................................................................................................. 9 

Reopenlngs .............................................................................................................................................. 9 

Renewals ............................................................................................................................................... 1 0 

Stratospheric Ozone Protection ............................................................................................................. 1 0 

Risk Management Plan .......................................................................................................................... 10 

. Emission Trading ................................................................................................................................... 10 

Permit To Install (PTI} ............................................................................................................................ 11 

Consent Orders ..................................................................................................................................... 11 

B. SOURCE-WIDE CONDITIONS ........................................................................................................ 12 

C. EMISSION UNIT CONDITIONS ....................................................................................................... 16 

EMISSION UNIT SUMMARY TABLE ..................................................................................................... 16 

EULIMEPAD .......................................................................................................................................... 23 

D. FLEXIBLE GROUP CONDITIONS ................................................................................................... 25 

FLEXIBLE GROUP SUMMARY TABLE ................................................................................................. 25 

FGC1ASH .............................................................................................................................................. 27 

FGC2ASH .............................................................................................................................................. 30 

FGCOMPLEX1 ...................................................................................................................................... 33 

FGCOMPLEX2 ...................................................................................................................................... 39 

FGLIMESTORAGE ................................................................................................................................ 42 

FGENGINES .......................................................................................................................................... 44 

FGC/ENG/NES ...................................................................................................................................... 47 

FGNSPSBO/LERS ................................................................................................................................. 51 

FGCOLDCLEANERS ............................................................................................................................. 53 

FGAQCJ ................................................................................................................................................. 55 

FG4M-INCIN .......................................................................................................................................... 62 

FGDryerTrains ....................................................................................................................................... 67 

FGDryerFacility ...................................................................................................................................... 71 

FG2013Project. ........................................... _ ........................................................................................... 75 

E. NON-APPLICABLE REQUIREMENTS ............................................................................................ 78 

APPENDICES ....................................................................................................................................... 79 

Appendix 1: Abbreviations and Acronyms ............................................................................................. 79 

Appendix 2. Schedule of Compliance .................................................................................................... 80 

Appendix 3. Monitoring Requirements .................................................................................................. 80 

Appendix 4. Recordkeeping .................................................................................................................. 82 

Appendix 4.1: Recordkeeping (continued) ...................................................................................... 83 

Page 2 of 106 
Detroit Department of Water & Sewerage ROP No: Mt-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: Ml-PT/-B2103-2014a 

Appendix 5. Testing Procedures ........................................................................................................... 84 

Appendix 6. Permits to Install ................................................................................................................ 85 

Appendix 7. Emission Calculations ....................................................................................................... 86 

Appendix 8. Reporting .......................................................................................................................... 86 

Appendix 9. Preventative Maintenance Summary ................................................................................. 87 

Page 3 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

AUTHORITY AND ENFORCEABILITY 

For the purpose of this permit, the permittee is defined as any person who owns or operates an 

emission unit at a stationary source for which this permit has been issued. The department is defined in 

Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her 

designee. 

The permittee shall comply with all specific details in the permit terms and conditions and the cited 

underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable 

and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most 

stationary sources for which an ROP has been issued. These general conditions are included in Part A 

of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units 

which are represented as a flexible group, or the entire stationary source which is represented as a 

source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices. 

In accordance with Rule 213{2)(a), all underlying applicable requirements will be identified for each ROP 

term or condition. All terms and conditions that are included in a PTI, are streamlined or subsumed, or is 

state only enforceable will be noted as such. 

In accordance with Section 5507 of Act 451, the permittee has included in the ROP application a 

compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements 

with which the source is in compliance, the source will continue to comply with these requirements. For 

applicable requirements with which the source is not in compliance, the source will comply with the 

detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. 

Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the 

stationary source will meet the requirements on a timely basis, unless the underlying applicable 

requirement requires a more detailed schedule of compliance. 

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law. 

Page 4 of 106 

I II 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

A. GENERAL CONDITIONS 

Permit Enforceability 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5)) 

• Those conditions that are hereby incorporated in a state-only enforceable Source-Wide PTI pursuant to 

Rule 201(2)(d) are designated by footnote one. (R 336.1213(5)(a), R 336.1214a(5)) 

• Those conditions that are hereby incorporated in a federally enforceable Source-Wide PTI pursuant to 

Rule 201(2)(c) are designated by footnote two. (R 336.1213(5)(b), R 336.1214a(3)) 

General Provisions 

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of 

Act 451, and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of 

the ROP. All terms and conditions of this ROP that are designated as federally enforceable are enforceable by 

the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the 

provisions of the federal Clean Air Act (CAA). Any terms and conditions based on applicable requirements 

which are designated as "state only'' are not enforceable by the USEPA or citizens pursuant to the CAA. 

(R 336.1213(1)(a)) 

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or 

reduce the permitted activity In order to maintain compliance with the conditions of this ROP. 

(R 336.1213( 1 )(b)) 

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit 

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make 

changes, at the permittee's own risk, pursuant to Rule 215 and Rule 216. (R 336.1213(1)(c)) 

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation 

of credentials and other documents as may be required by law and upon stating the authority for and purpose 

of the investigation, to perform any of the following activities (R 336.1213(1)(d)): 

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity Is 

conducted or where records must be kept under the conditions of the ROP. 

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

ROP. 

c. Inspect, at reasonable times, any of the following: 

I. Any stationary source. 

li. Any emission unit. 

Iii. Any equipment, including monitoring and air pollution control equipment. 

iv. Any work practices or operations regulated or required under the ROP. 

d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the ROP or applicable requirements. 

5. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, In writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to 

determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies 

of any records that are required to be kept as a term or condition of this ROP. For information which is claimed 

by the permittee to be confidential, consistent with the requirements of the 1976 PA 442, MCL §15.231 et seq., 

Page 5 of 106 
Delran Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

and known as the Freedom of Information Act, the person may also be required to furnish the records directly 

to the USEPA together with a claim of confidenllallty. (R 336.1213(1)(e)) 

6. A challenge by any person, the Administrator of the USEPA, or the department to a particular condition or a 

part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any 

other condition or part of this ROP. (R 336.1213(1)(1)) 

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of 

Act451. (R 336.1213(1)(9)) 

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h)) 

Equipment & Design 

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collecllon and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370) 

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and In accordance 

with the Michigan Air Pollution Control rules and existing law. (R 336.191 0) 

Emission Limits 

11. Except as provided in Subrules 2, 3, and 4 of Rule 301, states in part; "a person shall not cause or permit to be 

discharged into the outer air from a process or process equipment a visible emission of a density greater than 

the most stringent of Rule 301(1)(a) or (b) unless otherwise specified In this ROP." The grading of visible 

emissions shall be determined In accordance with Rule 303. (R 336.1301(1) in pertinent part): 

a. A 6-minute average of 20 percent opacity, except for one 6-minute average per hour of not more than 27 

percent opacity. 

b. A limit specified by an applicabl.e federal new source performance standard. 

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or In reaction with other air contaminants, either of the following: 

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.1 

(R 336.1901(a)) 

b. Unreasonable interference with the comfortable enjoyment of life and property. 1 (R 336.1901 (b)) 

Testing/Sampling 

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner's or operator's expense, In accordance with Rule 1001 and Rule 1003, under 

any of the conditions listed in Rule 1001 (1 ). (R 336.2001) 

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and 

Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1)) 

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days following the last date of the test. (R 336.2001(4)) 

Monitoring/Recordkeeping 

Page 6 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

16. Records of any periodic emission or parametric monitoring required In this ROP shall Include the following 

information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)): 

a. The date, location, time, and method of sampling or measurements. 

b. The dates the analyses of the samples were performed. 

c. The company or entity that performed the analyses of the samples. 

d. The analytical techniques or methods used. 

e. The results of the analyses. 

f. The related process operating conditions or parameters that existed at the time of sampling or 

measurement. 

17. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records, for continuous monitoring Instrumentation and copies of all reports required by the ROP. 

(R 336.1213(1)(e), R 336.1213(3)(b)(ii)) 

Certification & Reporting 

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(ili)(B), any document required to be 

submitted to the department as a term or condition of this ROP shall contain an original certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c)} 

19. A responsible official shall certify to the appropriate AQD District Office and to the USEPA that the stationary 

source is and has been In compliance with all terms and conditions contained in the ROP except for deviations 

that have been or are being reported to the appropriate AQD District Office pursuant to Rule 213(3)(c). This 

certification shall Include all the information specified in Rule 213(4)(c)(l) through (v) and shall state that, based 

on information and belief formed after reasonable inquiry, the statements and information In the certification are 

true, accurate, and complete. The USEPA address is: USEPA, Air Compliance Data - Michigan, Air and 

Radiation Division, 77 West Jackson Boulevard, Chicago, Illinois 60604. (R 336.1213(4)(c)) 

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed In the special 

conditions, or more frequently if specified In an applicable requirement or in this ROP. (R 336.1213(4)(c)) 

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt 

reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(li) as follows, unless otherwise 

described In this ROP. (R 336.1213(3)(c)) 

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All repo1is submitted pursuant to 

this paragraph shall be promptly certified as specified In Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to 

Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the 

semiannual reports required by Rule 213(3)(c)(l). The report shall describe reasons for each deviation and 

the actions taken to minimize or correct each deviation. 

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 

Page 7 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in 

Rule 213(3)(c)(lll) as either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible official with each report which stales that, based on information 

and belief formed after reasonable Inquiry, the statements and information In the report are true, accurate, 

and complete. 

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports 

of deviations from the emissions allowed under the ROP were submitted to the department pursuant to 

Rule 213(3)(c)(ii), a certification by a responsible official which states that, "based on Information and belief 

formed after reasonable inquiry, the statements and informatiori contained In each of the reports submitted 

during the previous month were true, accurate, and complete". The certification shall include a listing of the 

reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a 

monthly basis pursuant to this paragraph shall include a statement that certification of the report will be 

provided within 30 days following the end of the calendar month. 

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently If specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate AQD District Office. All 

instances of deviations from ROP requirements during the reporting period shall be clearly identified in the 

reports. (R 336.1213(3)(c)(i)) 

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine 

the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6)) 

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required in Rule 912, to the appropriate AQD District Office. The notice shall 

be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal conditions 

or malfunction. Notice shall be by any reasonable means, Including electronic, telephonic, or oral communication. 

Written reports, if required under Rule 912, must be submitted to the appropriate AQD District Supervisor within 10 

days afterthe start-up or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been 

corrected, or within 30 days of discovery of the abnormal conditions or malfunction, whichever is first. The written 

reports shall include all of the information required In Rule 912(5) and shall be certified by a responsible official In a 

manner consistent with the CM. (R 336.1912) 

Permit Shield 

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements 

as of the date of ROP Issuance, if either of the following provisions Is satisfied. (R 336.1213(6)(a)(l), 

R 336.1213(6)(a)(il)) 

a. The applicable requirements are Included and are specifically Identified In the ROP. 

b. The permit includes a determination or concise summary of the determination by the department that other 

specifically Identified requirements are not applicable to the stationary source. 

Any requirements Identified in Part E of this ROP have been idenf'lfied as non-applicable to this ROP and are 

included In the permit shield. 

27. Nothing In this ROP shall alter or affect any of the following: 

a. The provisions of Section 303 of the CAA, emergency orders, Including the authority of the USEPA under 

Section 303 of the CAA. (R 336.1213(6)(b)(i)) 

b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at 

the time of this ROP issuance. (R 336.1213(6)(b)(li)) 

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CM. 

(R 336.1213(6)(b)(iii)) 

Page 8 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

d. The ability of the USEPA to obtain information from a source pursuant to Section 114 of the CM. 

(R 336.1213(6)(b)(iv)) 

28. The permit shield shall not apply to provisions Incorporated Into this ROP through procedures for any of the 

following: 

a. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5)) 

b. Administrative Amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii)) 

c. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved 

by the department. (R 336.1216(1)(c)(lii)) 

d. Minor Permit Modifications made pursuant to Rule 216(2). (R 336.1216(2)(f)) 

e. State-Only Modifications made pursuant to Rule 216(4) until the changes have been approved by the 

department. (R 336.1216(4)(e)) 

29. Expiration of this ROP results In the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration 

date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP 

does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original 

ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a)) 

Revisions 

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the 

ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216) 

31. A change In ownership or operational control of a stationary source covered by this ROP shall be made pursuant to 

Rule 216(1). (R 336.1219(2)) 

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the timE) frames specified in Rule 216. (R 336.1210(9)) 

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the 

department takes final action, the permittee shall comply with both the applicable requirements governing the 

change and the ROP terms and conditions proposed in the application for the modification. During this time 

period, the permittee may choose to not comply with the existing ROP terms and conditions that the application 

seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the 

application during this time period, the terms and condHions In the ROP are enforceable. (R 336.1216(1)(c)(lll), 

R 336.1216(2)(d), R 336.1216(4)(d)) 

Reopenings 

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under 

any of the following circumst.ances: 

a. If additional requirements become applicable to this stationary source with three or more years remaining In 

the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 

expiration date. (R 336.1217(2)(a)(i)) 

b. If additional requirements pursuant to Tille IV of the CM become applicable to this stationary source. 

(R 336.1217(2)(a)(ll)) 

c. If the department determines that the ROP contains a material mistake, information required by any 

applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or 

the terms or conditions of the ROP. (R 336.1217(2)(a)(lll)) 

d. If the department determines that the ROP must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv)) 

Page 9 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Renewals 

ROP No: Ml-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

35. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by 

. the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. 

{R 336.1210{7)) 

Stratospheric Ozone Protection 

36. If the permittee is subject to Title 40 of the Code of Federal Regulations {CFR). Part 82 and services, 

maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of appliances 

containing refrigerant, Including MVAG and small appliances, or if the permittee Is a refrigerant reclalmer, 

appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall 

comply with all applicable standards for recycling and emissions reduction pursuant to 40 CFR, Part 82, 

Subpart F. 

37. If the permittee is subject to 40 CFR, Part 82, and performs a service on motor {fleet) vehicles when this 

service involves refrigerant In the MVAC, the permittee is subject to all the applicable requirements as specified 

in 40 CFR, Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as used 

in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used lor refrigerated cargo or an air conditioning system on passenger buses using 

Hydrochlorofluorocarbon-22 refrigerant. 

Risk Management Plan 

38. If subject to Section 112(r) of the GAA and 40 CFR, Part 68, the permittee shall register and submit to the 

USEPA the required data related to the risk management plan for reducing the probability of accidental 

releases of any regulated substances listed pursuant to Section 112(r)(3) of the GAA as amended in 40 CFR, 

Part 68.130. The Jist of substances, threshold quantities, and accident prevention regulations promulgated 

under40 GFR, Part 68, do not limit in any way the general duty provisions under Section 112.(r){1). 

39. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall comply with the requirements 

of 40 CFR, Part 68, no later than the latest of the following dates as provided In 40 CFR, Part 68. 1 O(a): 

a. June21,1999, 

b. Three years after the date on which a regulated substance Is first listed under 40 CFR, Part 68.130, or 

c. The date on which a regulated substance Is first present above a threshold quantity in a process. 

40. If subject to Section 112(r) of the GAA and 40 GFR, Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 

40 GFR, Part 68. 

41. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall annually certify compliance with 

all applicable requirements of Section 112{r) as detailed in Rule 213(4)(c)). {40 CFR, Part 68) 

Emission Trading 

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the USEPA as a part of 

Michigan's State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. 

{R 336.1213(12)) 

Page 10 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Permit To Install (PTI) 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

43. The process or process equipment Included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued b)' the department, except to the extent such action is exempt 

from the PTI requirements by any applicable rule. 2 (R 336.1201(1)) 

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence 

indicates the process or process equipment is not performing In accordance with the terms and conditions of 

the PTI or is violating the department's rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451) 

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or 

operates the process or process equipment at the location authorized by the PTI. If a new owner or operator 

submits a written request to the department pursuant to Rule 219 and the department approves the request, 

this PTI will be amended to reflect the change of ownership or operational control. The request must include all 

of the information required by Subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the 

appropriate AQD District Supervisor, MDEQMMDEQ. 2 (R 336.1219) 

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and 

conditions have been approved has not commenced wtthin 18 months, or has been interrupted for 18 months, 

the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the 

department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall 

notify the department via the Supervisor, Permit Section, MDEQ, AQD, P. 0. Box 30260, Lansing, Michigan 

48909, if It is decided not to pursue the ins!allation2 reconstruction, relocation, or modification of the equipment 

allowed by the terms and conditions from that PTI. (R 336.1201(4)) 

Footnotes: 

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201 (1)(a). 

Consent Orders 

The conditions contained in this ROP for which a Consent Order is the only identiffed underlying applicable 

requirement shall be considered null and void upon the effective date of termination of the Consent Order. The 

effective date of termination is defined for the purposes of this condition as the date upon which the 

Termination Order is signed by !he Chief of the AQD. 

Page 11 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

B. SOURCE-WIDE CONDITIONS 

Part 8 outlines the Source-Wide Terms and Conditions that apply to this stationary source. The permittee is 

subject to these special conditions for the stationary source in addition to the general conditions In Part A and any 

other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details In the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in 

the table. If there are no Source·Wide Conditions, this section will be left blank. 

Page 12 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-821 03-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

SOURCE-WIDE CONDITIONS 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(S) 

Pollutant Limit Time Period/ Operating 

Scenario 

1. Beryllium 10 grams 24-hour period 

~-Mercury 3,200 grams 24-hour period 

II. MATERIAL LIMIT(S) 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

NA 

V. TESTING/SAMPLING 

Equipment 

All process 

equipment at the 

facility, including 

equipment covered 

by other permits, 

grand-fathered 

equipment and 

exempt equipment. 

All process 

equipment at the 

facility, including 

equipment covered 

by other permits, 

grand-fathered 

equipment and 

exempt equipment. 

Equipment 

NA 

Monitoring/ 

Testing 

Method 

Appendix 4 

V.1, Appendix 4 

Monitoring/ 

Testing Method 

NA 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

Underlying 

Applicable 

Requirements 

40 CFR 61.32(a) 

40 CFR 61.52(b) 

Underlying 

Applicable 

Requirements 

NA 

1. The permittee shall test sewage sludge samples from the Incinerator feed system once per calendar month for 

mercury content using EPA Reference Method 105. If the measured mercury content from the incinerator feed 

system exceeds 1.43 mg/kg, then the permittee shall notify the District Supervisor. Test results shall be 

submitted to the District Supervisor. (40 CFR 61.52(b), 40 CFR 61.53(d)(2), 40 CFR 61.54(a), 40 CFR Part 

503.43, 40 CFR Part 503.46) 

See Appendix 5 

Vi. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

Page 13 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

1. The permittee shall keep records of the fugitive dust control measures taken at the facillty, utilizing the format In 

Appendix 4.1. (Act 451, Part 55 §324.5524), (Consent Order MDEQ SIP No. 11-1993) 

See Appendix 4 

Vll. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4J(c)) 

See Appendix 8 

VIII. STACKIVENT RESTRICTION(S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otheiWise noted: 

Stack & Vent ID Maximum Minimum Height Underlying Applicable 

Exhaust Above Ground Requirements 

Dimensions (feet) 

(inches) 

NA NA NA NA 

IX. OTHER REQUIREMENTISJ 

1. The permittee shall implement and maintain a Fugitive Dust Control Plan, including the following provisions: 

1. Paved Road 

a) Daily sweeping, washing, or vacuuming In the material handling area on days when material handling takes 

place 

b) Weekly sweeping, washing or vacuuming- All other paved roadways 

c) The frequency of the above treatment In a & b can be exempted when at least one of the following 

conditions occurs: 

I. Daily precipitation exceeds 0.1 in. 

II. Daily high temperature does not exceed 32° F. 

Iii. Road salt is applied and for 48 hours thereafter 

iv. Freezing conditions are anticipated 

v. No bulk material handling operations are conducted. 

(Consent Order MDEQ SIP No. 11-1993), (Act 451, Part 55 §324.5524) 

2. Gravel Parking- Add gravel cover as needed. {Consent Order MDEQ SIP No. 11·1993), (Act 451, Part 55 

§324.5524) 

3, Incineration Complexes I and II- Watering dally to the following area 

a) Five Ash Silos 

b) Gravity Discharge 

(Consent Order MDEQ SIP No.11-1993), (Act 451, Part 55 §324.5524) 

4. Unpaved roads, paved roads, storage piles, and material handling, and open areas and lots, created after the 

effective date of the consent order (dated May 19, 1993) shall meet the same requirements as similar area 

Page 14 of 106 

I . 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

sources specifically identified in Appendix 4.1. (Consent Order MDEQ SIP No. 11-1993), (Act 451, Part 55 

§324.5524) 

5. The permittee shall notify the Division within 30 calendar days following the quarter in which any new area 

sources were created and the notification shall Include a description of any new area source. (R336.1213(3)), 

(Consent Order MDEQ SIP No. 11-1993) 

6. The permittee shall not retain dewatered sludge on the plant site for more than 12 hours, except when landfill 

opportunities are limited, such as weekends and holidays. (R336.1901)', (Act 451, Part 55 §324.5524) 

7. The sludge from the exterior of the vehicles hauling sludge shall be washed at intervals at the plant. Such 

washings shall be routed to the treatment plant. (R336.1901 )

1

, (Act 451, Part 55 §324.5524) 

8. The permittee shall wash and clean all roadways on a daily basis or more frequent if odor occurs to prevent 

accumulations of sludge or the generation of odors. (R336.1901)1, (Act 451, Part 55 §324.5524) 

9. The conditions contained In this RO permit for which a Consent Order is the only Identified applicable 

requirement shall be considered null and void upon the effective date of the termination of the Consent Order. 

The effective date of termination Is defined for the purposes of this condition as the date upon which the 

Termination Order is signed by the Chief of Air Quality Division. (Consent Order MDEQ SIP No. 11-1993) 

10 The permittee shall comply with the fugitive dust control plan as described below: 

DETROIT WATER AND SEWERAGE DEPARTMENT -WASTEWATER TREATMENT PLANT 

FUGITIVE DUST CONTROL PLAN 

Wind Erosion and Traffic Emissions 

Roads, Parking Lots, and Open Areas 

Type of Surface PAVED GRAVEL PAVED GRAVEL CONSTRUCTION 

Usage ROAD ROAD PARKING PARKING AREA 

SURFACE AREA 713,361 4,531 145,307 20,575 445,254 

(Square Feet) 

Average Vehicle Speed (MPH) 10 10 

PASSENGER CARS 

& SMALL TRUCKS 

Average number per day 90 15 

Average feet traveled/vehicle 32,000 1,100 

MED. DUTY VEHICLES 

(3-15 TONS) 

Average number per day 10 10 

Average Feet traveled/vehicle 12,000 1,100 

HEAVY DUTY VEHICLES (>15 Tons) 

Average Number per day 20 1 0 

Average feet traveled/vehicle 6,000 1,100 

Sweep, wash, or vacuuming for material handling areas daily and for other roadways weekly. 

(Act 451, Part 55 §324.5524),(Consent Order MDEQ SIP No. 11-1993, Fugitive Control Plan, May, 1993) 

Footnotes: 

1

This condition Is state only enforceable and was established pursuant to Rule 201 (1 )(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 

Page 15 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

C. EMISSION UNIT CONDITIONS 

Part C outlines terms and conditions that are specific to Individual emission units listed in the Emission Unit 

Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General 

Conditions In Part A and any other terms and conditions contained In this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited, If a specific condition type does not apply, NA {not applicable) has been used in the table. If 

there are no conditions specific to individual emission units, this section will be left blank. 

EMISSION UNIT SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions. 

EUJNC03 

sewage sludge with the aid of natural gas 

burners to reduce its volume. Residual ash is 

sent to storage silos or lagoon before 

transport to landfilL Emissions are controlled 

by a venturi scrubber followed by an 

impingement type wet scrubber and mist 

Incinerator combusts 

sewage sludge with the aid of natural gas 

burners to reduce its volume. Residual ash Is 

sent to storage silos or lagoon before 

transport to landfilL Emissions are controlled 

by a venturi scrubber followed by an 

type wet scrubber and mist 

combusts municipal 

sewage sludge wiih the aid of natural gas 

burners to reduce its volume. Residual ash is 

sent to storage silos or lagoon before 

transport to landfill. Emissions are controlled 

by a venturi scrubber followed by an 

impingement type wet scrubber and mist 

i i 

sewage sludge with the aid of natural gas 

burners to reduce its volume. Residual ash Is 

sent to storage silos or lagoon before 

transport to landfilL Emissions are controlled 

by a venturi scrubber followed by an 

impingement type wet scrubber and mist 

Page 16 of 106 

FGCOMPLEX1 

.I 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Incinerator combusts dewatered municipal 

sewage sludge with the aid of natural gas 

burners to reduce its volume. Residual ash Is 

sent to storage silos or lagoon before 

transport to landfill. Emissions are controlled 

by a venturi scrubber followed by an 

type wet scrubber and mist 

It I 

combusts dewatered municipal sewage 11/01/2013 

sludge with the aid of natural gas burners to 

reduce its volume. Residual ash Is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCI), 

emissions will be controlled by an upgraded 

Impingement tray wet scrubber followed by a 

i i 

Multiple hearth sewage 

combusts dewatered munldn"l sewage 

sludge with the aid of natural gas burners to 

reduce its volume. Residual ash is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCI), 

emissions will be controlled by an upgraded 

Impingement wet scrubber followed by a 

i 

Page 17 of 106 

FGAQCI 

FG4M-INCIN 

FG2013Project 

FGAQCI 

FG4M-INCIN 

FG2013Project 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

EUINC11 

hearth sewage sludge incinerator 

dewatered municipal sewage 

sludge with the aid of natural gas burners to 

reduce its volume. Residual ash is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an Impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control Improvements (AQCI), 

emissions will be controlled by an upgraded 

impingement tray wet scrubber followed by a 

dewatered municipal sewage 

sludge with the aid of natural gas burners to 

reduce its volume. Residual ash Is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCI), 

emissions will be controlled by an upgraded 

impingement tray wet scrubber followed by a 

and a mist eliminator. 

Multiple hearth sewage sludge incinerator 

combusts dewatered municipal sewage 

sludge with the aid of natural gas burners to 

reduce its volume. Residual ash is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an Impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCJ), 

emissions will be controlled by an upgraded 

impingement tray wet scrubber followed by a 

venturi i I 

sewage 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

No.: 

970 I 

11/0112013 

I 

1110112013 

FGCOMPLEX2 

FGAQCI 

FG4M-INCIN 

FG2013Project 

FGAQCi 

FG4M-iNCIN 

FG2013Project 

FGCOMPLEX2 

FGAQCI 

FG4M-INCIN 

FG2013Project 

combusts dewatered municipal sewage 11/0112013 

sludge with the aid of natural .gas burners to 

FGAQCI 

FG4M-INCIN 

reduce its volume. Residual ash is sent to FG2013Project 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCI), 

emissions will be controlled by an upgraded 

impingement tray wet scrubber followed by a 

anda i 

Page 18 of 106 

I 

I 

l I 

I I 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

sewage 

dewatered municipal sewage 

sludge with the aid of natural gas burners to 

reduce Its volume. Residual ash Is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control Improvements (AQCi), 

emissions will be controlled by an upgraded 

impingement wet scrubber followed by a 

new venturi and a mist eliminator. 

sewage 

combusts dewatered municipal sewage 11/01/2013 

sludge with t11e aid of natural gas burners to 

reduce its volume. Residual ash Is sent to 

storage silos or lagoon before transport to 

landfill. Emissions are controlled by a venturi 

scrubber followed by an impingement tray wet 

scrubber and a mist eliminator. Following the 

air quality control improvements (AQCI), 

emissions will be controlled by an upgraded 

impingement tray wet scrubber followed by a 

a mist eliminator. 

System for conveying ash from Complex 2 11 

sludge incinerators and storing it prior to 

transport to sanitary landfill. Emissions are 

controlled a fabric filter. 

System for i 

sludge incinerators and 

transport to sanitary landfill. 

emergency 

emergency 

emergency 

emergency 

emergency 

Page 19 of 106 

11/01/1983 

05/12/2005 

03-2014a 

FGCOMPLEX2 

FGAQCi 

FG4M-INCIN 

FG2013Project 

FGAQCi 

FG4M-INCiN 

FG2013Project 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

EUGEN-G4 

Page 20 of 1 06 

ROP No: Mi-ROP-B2103-2014a 

EXjJiration Date: January 31, 2019 

FGNSPSBOILERS 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

mixing facility and 

ROP No: MI,RQP,B2103,2014a 

EXi>irallion Date: January 31, 2019 

I 

Lime Pad have been replaced with Indoor 05/12/2005 

Central Offloading Facility (COF) and a new 

EUDryerTralnA 

EUDryerTrainB 

EUDryerTrainC 

outdoor Lime Pad facility. Belt conveyors 

transfer sludge cake from Complex 1 and 

Complex 2 dewatering units to three holding 

tanks and the cake Is then transferred to three 

cake mixers where lime from three silos are 

added by gravity to mixers. All the cake 

mixers are connected to a scrubber, where 

any residual dust and gases are scrubbed. 

The mixture Is dropped directly into trucks for 

transport to a landfill. Occasionally, the 

mixture of cake and lime is dropped into the 

Lime Pad area, where scum or ash is added 

and mixed with front loaders. Lime Pad Is an 

outdoor three,slded concrete/steel mixing 

area used to prepare residuals for disposal in 

a sanitary landfill. The mixture is allowed to 

stabilize, then loaded into trucks for transport 

II 

i dryer train consisting of a triple,pass 

rotary natural gas, fired dryer equipped with a 

low,NOx burner and exhaust recirculation, a 

cyclone product collector, a vibrating 

screener, a recycle bin, and a crusher. 

Emissions from the dryer train's cyclone 

exhaust through a three,stage impingement 

tray scrubber followed by a regenerative 

thermal oxidizer. Emissions from the recycle 

rotary natural gas,fired dryer eqtJipf>ea 

low,NOx burner and exhaust recirculation, a 

cyclone product collector, a vibrating 

screener, · a recycle bin, and a crusher. 

Emissions from the dryer train's cyclone 

exhaust through a three,stage impingement 

tray scrubber followed by a regenerative 

thermal oxidizer. Emissions from the recycle 

bin are controlled with a fabric filter collector. 

i dryer I i 

rotary natural gas,fired dryer equipped with a 

low,NOx burner and exhaust recirculation, a 

cyclone product collector, a vibrating 

screener, a recycle bin, and a crusher. 

Emissions from the dryer train's cyclone 

exhaust through a three,stage impingement 

tray scrubber followed by a regenerative 

thermal oxidizer. Emissions from the recycle 

Page21 of106 

11/01/2013 

11/01/2013 

11/01/2013 

FGDryerFacility, 

FG2013Project 

i 

FGDryerFacility, 

FG2013Project 

FGDryerTrains, 

FGDryerFacility, 

FG2013Project 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

EUDryerTrainD 

EUSo/idsSi/o1 

EUSolidsSi/o2 

EUSo/idsSilo3 

EUSolidsSI/o4 

EUWaterHeater 

EUAirHandling 

EUMakeUpAir 

rotary natural gas-fired dryer equipped with a 

low-NOx burner and exhaust recirculation, a 

cyclone product co/lector, a vibrating 

screener, a recycle bin, and a crusher. 

Emissions from the dryer train's cyclone 

exhaust through a three-stage impingement 

tray scrubber followed by a regenerative 

thermal oxidizer. Emissions from the recycle 

i I I 

four rnai<~-L'fl 

heat for the process area of the biosollds 

drying facility. Heat Input duty approximately 

5.121 MMBTU/hr unit. 

Page 22 of 1 06 

ROP No: MI-ROP-B2103-2014a 

I Date: January 31, 2019 

11/01/2013 

11/01/2013 

11/01/2013 

11/01/2013 

11/01/2013 

11/01/2013 

11/01/2013 

11/01/2013 

I ' 

FGDryerFacility, 

FG2013Project 

FGDryerFacility, 

FG2013Project 

FG2013Project 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

DESCRIPTION 

EULIMEPAD 

EMISSION UNIT CONDITIONS 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

The old sludge/lime mixing facility and the Lime Pad have been replaced with indoor Central Offloading Facility 

(COF) and a new outdoor Lime Pad facility. Belt conveyors transfer sludge cake from Complex 1 and Complex 2 

dewatering units to three holding tanks and the cake is then transferred to three cake mixers where lime from three 

silos are added by gravity to mixers. Ail the cake mixers are connected to a scrubber, where any residual dust and 

gases are scrubbed. The mixture Is dropped directly into trucks for transport to a landfill. Occasionally, the mixture 

of cake and lime is dropped Into the Lime Pad area, where scum or ash is added and mixed with front loaders. 

Lime Pad is an outdoor three-sided concrete/steel mixing area used to prepare residuals for disposal in a sanitary 

landfill. The mixture is allowed to stabilize, then loaded into trucks for transport to a landfill. 

Flexible Group JD: NA 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(S) 

Pollutant Limit Time Period/ Operating 

Scenario 

NA NA NA 

II. MATERIAL LIMIT!Sl 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(Sl 

NA 

V. TESTING/SAMPLING 

Equipment Monitoring/ 

Testing Method 

NA NA 

Equipment Monitoring/ 

Testing Method 

NA NA 

Records shall be maintained on flte for a period of five years. (R 336.1213(3)(b)(ii)) 

NA 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

NA 

Page 23 of 106 

Underlying 

Applicable 

Requirements 

NA 

Underlying 

Applicable 

Requirements 

NA 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

VII. REPORTING 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. {R 336.1213{3)(c){ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. {R 336.1213{3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

{R 336.1213(4)(c)) 

See Appendix 8 

VIII. STACK/VENT RESTRICTIONIS) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Minimum Height Underlying Applicable 

Exhaust Above Ground Requirements 

Dimensions (feet) 

(inches) 

NA NA NA NA 

IX. OTHER REQUIREMENT(S) 

1. All trucks hauling away sludge or blended sludge off site from facility shall have their wheels cleaned after the 

trucks are loaded, so as to prevent sludge trackout off of plant property. (R336.1213{3)) 

2. All unstabilized and blended sludge conveyors and conveyor transfer points shall be inspected once per 

operating shift for spillage, and any spill shall be cleaned up during that operating shift. Such inspections shall 

be logged including date of Inspection, time of inspection, name of person performing such inspections, 

conditions observed with respect to spillage, and actions taken. Such logs shall be made available to the 

Division upon request. (R336.1213{3)) 

Footnotes: 

1

Thls condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

'This condition is federally enforceable and was established pursuant to Rule 201 {1)(a). 

Page 24 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-621 03-2014a 

D. FLEXIBLE GROUP CONDITIONS 

Part D outlines the terms and conditions that apply to more than one emission unit. The permittee is subject to the 

special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and 

conditions contained in this ROP. · 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no special conditions that apply to more than one emission unit, this section will be left blank. 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions. 

group covers i 

before the air quality control improvements. It consists EUINC09, EUINC10, 

of eight (8) multiple hearth sewage sludge EUINC11, EUINC12, 

incinerators, each with an Impingement tray wet EUINC13, EUINC14 

scrubber followed by a venturi scrubber and a mist 

group for 

used to stabilize residuals hauled to 

emergency generators. 

EUGEN-D2, EUGEN-04, 

EUGEN-05, EUGEN-06, 

EUGEN-G1, EUGEN-G2, 

EUGEN-G3, EUGEN-G4, 

EUGEN-G5, EUGEN-G6, 

EUGEN-GS, EUGEN-G9, 

EUGEN-G10, EUGEN-P1, 

I are , 

ilrAJm~e•nl in NSPS Subpart De to track fuel usage EUBOILER9, EUBOILER10 

Page 25 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Exrlimtion Date: January 31, 2019 

I I 

201 pursuant to 278 and Rule (h) or 

Rule 285(r)(lv). Existing cold cleaners were placed 

into operation prior to July 1, 1979. New cold 

cleaners were placed into operation on or after July 1, 

i flexible group covers the Complex 2 

for which the air quality control improvements {AQCI) 

have been completed. When the AQCI have been 

completed, It will consist of eight (8) multiple hearth 

sewage sludge incinerators, each with a venturi 

scrubber followed an impingement tray wet 

i 

facility. In addition to the dryer trains, the storage 

silos, and the biosolids drying facility roadways, it 

Includes the following equipment inside the building to 

prepare feed to the dryer trains: eight sludge grinders 

(two for each dryer train), eight electrically-powered 

dewatering centrifuges (two for each dryer train), a 

cake bin and enclosed pug mill for each dryer train, 

and conveyors to transfer materials. The facility also 

has a hot water heater, an air handling unit, and 

make-up air units for the building, all natural gas-fired. 

All process area building ventilation exhaust is routed 

I 

i group covers 

incinerators and the blosollds drying facility. It 

addresses the emissions of the overall project, which 

consists of the incinerator upgrades and the blosollds 

drying facility. 

Page 26 of 1 06 

' EUINC09, EUINC10, 

EUINC11, EUINC12, 

EUINC13, EUINC14 

EUINC09, EUINC10, 

EUINC11, EUINC12, 

EUINC13, EUINC14 

I 

EUDryerTrainB, 

EUDryerTrainC, 

EUDryerTrainD, 

EUSolldsSilo1, 

EUSolidsSilo2, 

EUSolidsSIIo3, 

EUSolldsSIIo4, 

EUWaterHeater, 

EUAirHandling, 

EUMakeUpAir 

I , EUINC08, 

EUINC09, EUINC10, 

EUINC11, EUINC12, 

EUINC13, EUINC14, 

EUDryerTrainA, 

EUDryerTralnB, 

EUDryerTrainC, 

EUDryerTralnD, 

EUSolidsSIIo1, 

EUSolidsSilo2, 

EUSolidsSIIo3, 

EUSolldsSilo4, 

EUWaterHeater, 

EUAirHandling, 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

DESCRIPTION 

FGC1ASH 

FLEXIBLE GROUP CONDITIONS 

Three ash conveying and storage systems for conveying ash from the Complex 1 sludge Incinerators and storing it 

prior to transport to sanitary landfill. 

Emission Units: EUC1ASH01, EUC1ASH02, EUC1ASH03 

POLLUTION CONTROL EQUIPMENT 

Fabric filters 

I. EMISSION LIMIT($) 

Pollutant Limit Tlme Period/ Operating 

Scenario 

1. Particulate Matter 0.2 pounds As determined by the 

per 1,000 average of three one 

pounds hour test runs. 

exhaust air 

. Visible emissions Presence of Three one hour 

visible observation periods 

emissions 

for no more 

than 5 

percent of 

the hourly 

observation 

period 3 

If. MATERIAL LIMIT($) 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION($) 

Equipment Monitoring/ 

Testing Method 

FGC1ASH V.1, V1.1 

FGC1ASH Vl.1 

Equipment Monitoring/ 

Testing Method 

NA NA 

1. The pressure drop across each baghouse shall not exceed 10 Inches of water. (R336.1213(3)) 

IV. DESIGN/EQUIPMENT PARAMETER($) 

NA 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ll)) 

Underlying 

Applicable 

Requirements 

R336.1331{3) 

40 CFR Part 60, 

Subpart MMMM 

Underlying 

Applicable 

Requirements 

NA 

1. The permittee shall conduct emission tests to demonstrate initial compliance with the emission limits and 

standards for fugitive emissions from ash handling operations. The emission test must be conducted using the 

test methods, averaging methods and minimum sampling volumes or durations specified In Table 2 or 3 of 40 

CFR Part 60, Subpart MMMM, and according to the testing, monitoring and calibration requirements specified 

in 40 CFR 60.5220(a). The permittee may use results from a performance test conducted within the two 

previous years that was conducted under the same conditions and demonstrated compliance with the emission 

Page 27 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-82103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

limits and standards specified in the Emission Limits section of this Flexible Group, provided that no process 

changes have been made since the performance test was conducted. If the results of a past performance test 

are used, the permittee must continue to meet the operating limits established during that performance test that 

demonstrated compliance with the applicable emission limits. The past performance test must have used the 

same test methods specified in Table 2 or 3 of 40 CFR Part 60 Subpart MMMM. Not less than 30 days prior to 

the anticipated test date, a complete stack testing plan shall be submitted to the AQD District Supervisor for 

approval. (40 CFR 60.5185(a)) 

2. The permittee shall have the option of demonstrating continuous compliance with the emission limits and 

standards for fugitive emissions from ash handling operations using a performance test. If the permittee elects 

to choose the option of performance testing to demonstrate Initial and continuous compliance with the emission 

limits for the pollutants previously listed, performance tests shall be conducted on an annual basis for each 

pollutant (between 11 and 13 calendar months following the previous performance test), except as provided in 

40 CFR 60.5205(a)(3) and (e). The performance tests must be conducted using the test methods, averaging 

methods and minimum sampling volumes or durations specified in Table 2 or 3 of 40 CFR Part 60, Subpart 

MMMM, and according to the testing, monitoring and calibration requirements specified in 40 CFR 60.5220(a). 

Not less than 30 days prior to the anticipated test date, a complete stack testing plan shall be submitted to the 

AQD District Supervisor for approval. The permittee may elect to choose, In lieu of performance testing, to 

demonstrate continuous compliance with the emission limit using a continuous emissions monitoring system as 

described in 40 CFR 60.5205(b).' (40 CFR 60.5205{a) and (b)) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall comply with the following conditions while operating any ash silo in FGC1 ASH: 

a. The permittee shall monitor and record, on a daily basis, the pressure drop across the baghouse serving the 

ash silo operation. 

b. The permittee shall perform and record, on a daily basis, a visible emissions observation to determine the 

presence or absence of visible emissions. This may be performed by either a certified or non-certified 

reader. 

c. If visible emissions are observed, it should be recorded along with the corrective action. 

d. The permittee shall perform and record a visible emission observations utilizing Method 22 to determine the 

presence or absence of visible emissions. The visible emissions observations shall consist of three one hour 

observation periods. This Method 22 visible emissions observation shall be performed as part of the initial 

compliance testing for FGCOMPLEX1.' 

(R336.1213{3), 40 CFR Part 60, Subpart MMMM) . 

2. The permittee shall develop and submit a site-specific monitoring plan for the ash handling system.' (40 CFR 

60.5200) 

See Appendices 3 and 4 

VII. REPORTING 

1: Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(il)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. {R 336.1213(3)(c)(i)) 

Page 28 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VJIJ. STACKNENT RESTRICTION(S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Minimum Height Underlying Applicable 

1. SV1ASH01 

2. SV1ASH02 

3. SV1ASH03 

IX. OTHER REQUIREMENT(S) 

NA 

Footnotes: 

Exhaust 

Dimensions 

(inches) 

12 L 

12 < 

12' 

Above Ground Requirements 

(feet) 

122,5 L R336.1201 1 

122.5 R336.1201 1 

122.5' R336.1201 1 

1

This condition Is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 3

Thls condition is future applicable. The date of future applicability is based upon the date of approval of the State 

Plan, and will be the earlier of (1) March 15, 2016, or (2) three years after the effective date of State Plan approval. 

Page 29 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: Mi-ROP-82103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

DESCRIPTION 

FGC2ASH 

FLEXIBLE GROUP CONDITIONS 

Two ash conveying and storage systems for conveying ash from the Complex 2 sludge incinerators and storing It 

prior to transport to sanitary landfill. 

Emission Units: EUC2ASH01, EUC2ASH02 

POLLUTION CONTROL EQUIPMENT 

Fabric filters 

emissions 

for no more 

than 5 

percent of 

the hourly 

observation 

3 

II. MATERIAL LIMIT(Sl 

Material Limit 

NA NA 

Time Period/ Operating 

Scenario 

NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

Equipment Monitoring/ 

Testing Method 

NA NA 

1. The pressure drop across each baghouse shall not exceed 10 Inches of water. (R336.1213(2)) 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

1. NA 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(li)) 

Underlying 

Applicable 

Requirements 

NA 

1. The permittee shall conduct emission tests to demonstrate initial compliance with the emission limits and 

standards for fugitive emissions from ash handling operations. The emission test must be conducted using the 

test methods, averaging methods and minimum sampling volumes or durations specified In Table 2 or 3 of 40 

CFR Part 60, Subpart MMMM, and according to the testing, monitoring and calibration requirements specified 

In 40 CFR 60.5220(a). The permittee may use results from a performance test conducted within the two 

Page 30 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

previous years that was conducted under the same conditions and demonstrated compliance with the emission 

limits and standards specified In the Emission Limits section of this Flexible Group, provided that no process 

changes have been made since the performance test was conducted. If the results of a past performance test 

are used, the permittee must continue to meet the operating limits established during that performance test that 

demonstrated compliance with the applicable emission limits. The past performance test must have used the 

same test methods specified in Table 2 or 3 of 40 CFR Part 60 Subpart MMMM. Not less than 30 days prior to 

the anticipated test date, a complete stack testing plan shall be submitted to the AQD District Supervisor for 

approval. (40 CFR 60.5185(a)) 

2. The permittee shall have the option of demonstrating continuous compliance with the emission limits and 

standards for fugitive emissions from ash handling operations using a performance test. If the permittee elects 

to choose the option of performance testing to demonstrate initial and continuous compliance with the emission 

limits for the pollutants previously listed, performance tests shall be conducted on an annual basis for each 

pollutant (between 11 and 13 calendar months following the previous performance test), except as provided in 

40 CFR 60.5205(a)(3) and (e). The performance tests must be conducted using the test methods, averaging 

methods and minimum sampling volumes or durations specified in Table 2 or 3 of 40 CFR Part 60, Subpart 

MMMM, and according to the testing, monitoring and calibration requirements specified in 40 CFR 60.5220(a). 

Not less than 30 days prior to the anticipated test date, a complete stack testing plan shall be submitted to the 

AQD District Supervisor for approval. The permittee may elect to choose, in lieu of performance testing, to 

demonstrate continuous compliance with the emission limit using a continuous emissions monitoring system as 

described in 40 CFR 60.5205(b).3 (40 CFR 60.5205(a) and (b)) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(il)) 

1. The permittee shall comply with the following conditions while operating any ash silo in FGC2ASH: 

a. The permittee shall monitor and record, on a daily basis, the pressure drop across the baghouse serving the 

ash silo operation. 

b. The permittee shall perform and record, on a daily basis, a visible emissions observation to determine the 

presence or absence of visible emissions. This may be performed by either a certified or non-certified 

reader. 

c. If visible emissions are observed, it should be recorded along with the corrective aclion. 

d. The permittee shall perform and record a visible emission observations utilizing Method 22 to determine the 

presence or absence of visible emissions. The visible emissions observations shall consist of three one 

hour observation periods. This Method 22 visible emissions observation shall be performed as part of the 

initial compliance testing for FGCOMPLEX2.3 

(R336.1213(3), 40 CFR Part 60, Subpart MMMM) 

2. The permittee shall develop and submit a site-specific monitoring plan for the ash handling system.' (40 CFR 

60.5200) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

Page31 of106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTJ-B2103-2014a 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VII!. STACKNENT RESTRICTION{S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Minimum Height Underlying Applicable 

1. SVC2ASH1 

2. SVC2ASH2 

IX. OTHER REQUIREMENT($) 

NA 

Footnotes: 

Exhaust 

Dimensions 

(inches) 

20" 

20. 

Above Ground Requirements 

(feet) 

119.5" R336.1201 (1) 

119.5. R336.1201(1) 

1

This condition Is state only enforceable and was established pursuant to Rule 201(1)(b). 2

Thls condition Is federally enforceable and was established pursuant to Rule 201 (1)(a). 

'This condition is future applicable. The date of future applicability is based upon the date of approval of the State 

Plan, and will be the earlier of (1) March 15,2016, or (2) three years after the effective date of State Plan approval. 

Page 32 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

FGCOMPLEX1 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

Five (5) sewage sludge incinerators, each with a venturi scrubber followed by an impingement type wet scrubber 

and mist eliminator. 

Emission Units: EUINC01, EUINC02, EUINC03, EUINC04, EUINC05, EUINC06 

POLLUTION CONTROL EQUIPMENT 

Emissions from the Incinerators are controlled by a venturi scrubber followed by an impingement type wet scrubber 

and mist eliminator. 

I. EMISSION LIMIT!Sl 

Pollutant limit Time Period/ Operating Equipment Monitoring/ Underlying 

Scenario Testing Method Applicable 

Reauirements 

1. Particulate 80 milligrams Average of three test runs FGCOMPLEX1 V.1, 40 CFR Part 60, 

Matter per dry standard (a minimum of 0.75 dry Vl.7- Vl.13 Subpart MMMM 

cubic meter3 standard cubic meters (§60.5165) 

collected per test run). 

. Hydrogen 1.2 part per Average of three test runs FGCOMPLEX1 V.1, 40 CFR Part 60, 

hloride million, dry (for Method 26, collect a V1.7- Vl.13 Subpart MMMM 

volume3 minimum volume of 200 (§60.5165) 

liters per run. For Method 

26A, collect a minimum 

volume of 1 dry standard 

cubic meters per test run). 

3. Carbon 3,800 parts per Average of three test runs FGCOMPLEX1 V.1,VI.3, 40 CFR Part 60, 

monoxide million, dry (collect sample for a Vl.4 Subpart MMMM 

volume3 minimum duration of one (§60.5165) 

hour per run). 

4. Dloxins/furans 5.0 nanograms fA.verage of three test runs FGCOMPLEX1 V.1 40 CFR Part 60, 

(total mass basis) per dry standard (a minimum of 1 dry Subpart MMMM 

cubic meter3 standard cubic meters (§60.5165) 

collected per test run). 

5. Dioxlns/furans 0.32 nanograms f"verage of three test runs FGCOMPLEX1 V.1 40 CFR Part 60, 

(toxic equivalency per dry standard (a minimum of 1 dry Subpart MMMM 

basis)' cubic meter3 standard cubic meters (§60.5165) 

collected per test run). 

3. Mercury ).28 milligrams Average of three test runs FGCOMPLEX1 V.1 40 CFR Part 60, 

oer dry standard (for Method 29 and ASTM Subpart MMMM 

~ublc meter3 D6784-02, collect a (§60.5165) 

minimum volume of 1 dry 

standard cubic meters per 

run. For Method 308, 

collect a minimum sample 

as specified In method 

308 at 40 CFR Part 60, 

appendix A-8). 

Page 33 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Pollutant Limit Time Period/ Operating 

Scenario 

7. Oxides of 220 parts per Average of three test runs 

nitrogen million, dry (collect sam pie for a 

volume3 minimum duration of one 

hour E_er run). 

8. Sulfur Dioxide ~6 part per fAverage of three test runs 

million, dry (for Method 6, collect a 

volume3 minimum volume of 200 

liters per run. For Method 

~c. collect sample for a 

minimum duration of one 

hour per run). 

f-1. Cadmium 0.095 milligrams fAverage of three test runs 

per dry standard (a minimum of 1 dry 

cubic meter3 fstandard cubic meters 

collected per test run). 

10. Lead ~.30 milligrams :Average of three test runs 

per dry standard (a minimum of 1 dry 

cubic meter3 standard cubic meters 

collected per test run). 

Equipment 

FGCOMPLEX1 

FGCOMPLEX1 

FGCOMPLEX1 

FGCOMPLEX1 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No· MI-PTI-B2103-2014a " 

Monitoring/ Underlying 

Testing Method Applicable 

Requirements 

V.1, Vl.3, 40 CFR Part 60, 

Vl.4 Subpart MMMM 

(§60.5165) 

V.1, 40 CFR Part 60, 

VI.7-V1.13 Subpart MMMM 

(§60.5165) 

V.1, 40 CFR Part 60, 

VI.7-VI.13 Subpart MMMM 

(§60.5165) 

V.1, 40 CFR Part 60, 

VI.?- Vl.13 Subpart MMMM 

(§60.5165) 

'All emlss1on llm1ts are measured at 7 percent oxygen, dry basis at standard conditions. 

The emission limits and standards apply at all times any of the emission units addressed by FGCOMPLEX1 are 

operating and during periods of malfunction. The emission limits and standards apply to emissions from a bypass 

stack or vent while sewage sludge is in the combustion chamber (i.e. until the sewage sludge feed to the combustor 

has been cut off for a period of time not less than the sewage sludge incineration residence time). 

' The permittee has the option to comply with ellher the dioxin/furan limit on a total mass basis or the dioxin/furan 

emission limit on a toxic equivalency basis. 

II. MATERIAL LIMIT($) 

Material Limit Time Period/ Operating Equipment Monitoring/ Underlying 

Scenario Testing Method Applicable 

Req_uirements 

NA NA NA NA NA NA 

IlL PROCESS/OPERATIONAL RESTRICTION($) 

1. The permittee shall not operate the incinerators In FGCOMPLEX1 unless the venturi/impingement tray wet 

scrubbers and mist eliminators are installed and operating properly. Such control equipment shall be 

maintained in good repair and operated in such a manner as to ensure compliance with emission requirements 

and visible emission requirement! (R336.1201(3)), (R336.1910) 

2. The permittee shall operate the incinerators in FGCOMPLEX1 such that hearth #1 burners will maintain a 

combustion temperature between 1100"F and 1500"F, based on a 24-hour block average, unless It can be 

demonstrated that an alternative operating range can be used to achieve compliance with particulate matter 

and opacity limits. (R336.1213(3)) 

3. The pressure drop across the venturi-impingement tray scrubber shall not be less than 18 Inches of water 

column, based on an 8-hour block average. (R336.1910), (R336.1213(3)) 

Page 34 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

4. Use of the bypass stack associated wllh an incinerator in FGCOMPLEX1 at any time that sewage sludge is 

being charged to that incinerator is an emissions standards deviation for all of the pollutants listed In Special 

·Conditions 1.1 through 1.10.3 (40 CFR 60.5220(d)) 

IV. DESIGN/EQUIPMENT PARAMETER(Sl 

1. The permittee shall conduct an air pollution control device inspection, in accordance with 40 CFR 60.5220(c), 

by the compliance date of 40 CFR Part 60, Subpart MMMM. The inspection shall include, at a minimum3

: 

a. Inspect air pollution control device(s) for proper operation; 

b. Generally observe that the equipment Is maintained in good operating condition; 

c. Develop a site-specific monitoring plan according to the requirements of 40 CFR 60.5200. 

(40 CFR 60.5195, 40 CFR 60.5220) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall have the option of conducting emission tests to demonstrate initial compliance with the 

emission limits and standards for particulate matter, hydrogen chloride, carbon monoxide, dioxlns/furans (total 

mass or toxic equivalency basis), mercury, nitrogen oxides, sulfur dioxide, cadmium, and lead. If the permittee 

chooses the option of performing emission tests, then the emission tests must be conducted using the test 

methods, averaging methods and minimum sampling volumes or durations specified in Table 2 or 3 of 40 CFR 

Part 60, Subpart MMMM, and according to the testing, monitoring and calibration requirements specified in 40 

CFR 60.5220(a). The permittee may use results from a performance test conducted within the two previous 

years that was conducted under the same conditions and demonstrated compliance with the emission limits 

and standards specified in the Emission Limits section of this Flexible Group, provided that no process changes 

have been made since the performance test was conducted. If the results of a past performance test are used, 

the permittee must continue to meet the operating limits established during that performance test that 

demonstrated compliance with the applicable emission limits. The past performance test must have used the 

same test methods specified in Table 2 or 3 of 40 CFR Part 60 Subpart MMMM. Not less than 30 days prior to 

the anticipated test date, a complete stack testing plan shall be submitted to the AQD District Supervisor for 

approval. (40 CFR 60.5185(a)) 

2. In lieu of conducting the emissions test specified In Special Condition V.1, the permittee may elect to 

demonstrate initial compliance with the emission limits for particulate matter, hydrogen chloride, carbon 

monoxide, dloxins/furans, mercury, nitrogen oxides, sulfur dioxide, cadmium and lead by substituting the use of 

a continuous emission monitoring system for any or all of these pollutants In accordance with the requirements 

of 40 CFR 60.5185(b)-' (40 CFR 60.5185(b)) 

3. The permittee shall have the option of demonstrating continuous compliance with the emission limits and 

standards for particulate matter, hydrogen chloride, carbon monoxide, dioxins/furans (total mass or toxic 

equivalency basis), mercury, nitrogen oxides, sulfur dioxide, cadmium and lead using a performance test. If the 

permittee elects to choose the option of performance testing to demonstrate initial and continuous compliance 

with the emission limits for the pollutants previously listed, performance tests shall be conducted on an annual 

basis for each pollutant {between 11 and 13 calendar months following the previous performance test), except 

as provide in 40 CFR 60.5205{a)(3) and (e). The performance tests must be conducted using the test 

methods, averaging methods and minimum sampling volumes or durations specified in Table 2 or 3 of 40 CFR 

Part 60, Subpart MMMM, and according to the testing, monitoring and calibration requirements specified in 40 

CFR 60.5220(a). Not less than 30 days prior to the anticipated test date, a complete stack testing plan shall be 

submitted to the AQD District Supervisor for approval. 3 (40 CFR 60.5205(a)) 

4. In lieu of conducting the performance tests specified in Special Condition V.3, the permittee may elect to 

demonstrate continuous compliance with the emission limits for particulate matter, hydrogen chloride, carbon 

monoxide, dioxins/furans, mercury, nitrogen oxides, sulfur dioxide, cadmium and lead by substituting the use of 

a continuous emissions monitoring system for any or all of these pollutants in accordance with the requiro;>ments 

of 40 CFR 60.5205(b). A continuous automated sampling system can be used in !leu of performance tests to 

demonstrate continuous compliance with the mercury or dioxin/furans emission limits.' (40 CFR 60.5205(b)) 

Page 35 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

5. The use of a bypass stack during a performance test Invalidates the results of the performance test.3 (40 CFR 

60.5220{d)) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period offive years. (R 336.1213(3){b)(ii)) 

1. The permittee shall monitor and record the sewage sludge feed rate to the incinerators in FGCOMPLEXi on a 

continuous basis, and calculate the dally average sewage sludge feed to each Incinerator in FGCOMPLEX1 for 

all hours of operation during each 24-hour period. 3 {40 CFR 60.5170(1)(1)) 

2. The permittee shall monitor and record the moisture content (as a weight percent) of the sewage sludge by 

taking a grab sample of the sewage sludge, on a daily basis, for the purpose of recording the range of moisture 

content. If the permittee takes more than one grab sample in a day, then the daily average moisture content for 

the number of grab samples taken shall be calculated. 3 (40 CFR Part 60.5170{1)(2)) 

3. The permittee shall monitor and record the combustion chamber temperature for each incinerator in 

FGCOMPLEX1 on a continuous basis. Measurements of the combustion chamber temperature shall be 

recorded every 15 minutes. 3 (40 CFR 60.5170(a)) 

4. The permittee shall establish a minimum combustion chamber operating temperature (or minimum afterburner 

temperature), equal to the lowest 4-hour average combustion chamber temperature (or afterburner 

temperature) measured during the most recent performance test demonstrating compliance with all applicable 

emission limits. 3 (40 CFR 60.5190) 

5. The permittee shall develop and submit a site-specific monitoring plan for each continuous monitoring system 

required by 40 CFR Part 60 Subpart MMMM. 3 (40 CFR 60.5200) 

6. Permittee shall monitor and record the opacity from FGCOMPLEX1, on a continuous basis in a manner and 

with instrumentation acceptable to the Air Quality Division and according to the monitoring requirements in 40 

CFR Part 75. 2 (R336.1213{3)), Consent Order MDEQ SIP No. 11·1993) 

7. Except during periods when an Incinerator is out of service (in cold standby mode), the permittee shall conduct 

monthly inspections for the purpose of determining the operating condition of the scrubber, and, if necessary, 

the reasons for malfunction or failure, using monitoring and recordkeeping procedures outlined in Appendix 3 

and 4. (R336.1213(3)) 

8. The permittee shall monitor and record, on a continuous basis, the pressure drop across the Inlet and outlet of 

the scrubber serving any incinerator in operation. Measurements of the pressure drop shall be recorded every 

15 minutes. 3 {40 CFR 60.5190) 

9. The permittee shall establish a minimum pressure drop across each wet scrubber that Is used to meet the 

particulate matter, lead and cadmium emission limits, equal to the lowest 4-hour average pressure drop across 

each scrubber measured during the most recent performance test demonstrating compliance with the 

particulate matter, lead and cadmium emission limits. The permittee is not required to establish the minimum 

~ressure drop If a continuous monitoring system Is used to demonstrate compliance with these emission limits. 

(40 CFR 60.5190) 

10. The permittee shall monitor and record, on a continuous basis, the liquid flow rate through the scrubber serving 

any incinerator in operation. Measurements of the scrubber liquid flow rate shall be recorded every 15 minutes. 

' {40 CFR 60.5190) 

11. The permittee shall establish a minimum scrubber liquid flow rate (measured at the inlet to each wet scrubber), 

equal to the lowest 4-hour average liquid ftow rate measured during the most recent performance test 

demonstrating compliance with all applicable emission limits. 3 {40 CFR 60.5190) 

Page 36 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: Ml-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: Ml-PTI-B2103-2014a 

12. The permittee shall monitor and record, on a continuous basis, the scrubber liquid pH. Measurements of the 

scrubber liquid pH shall be recorded every 15 minutes. 3 (40 CFR 60.5190) 

13. The permittee shall establish a minimum scrubber liquid pH for each wet scrubber used to meet the sulfur 

dioxide or hydrogen chloride emission limits equal to the lowest 1-hour average scrubber liquid pH measured 

during the most recent performance test demonstrating compliance with these emission limits. 3 (40 CFR 

60.5190) 

14. The permittee shall monitor oxygen concentration for each operating incinerator. (R336.1213(3)) 

15. Except for periods when an incinerator is out of service (cold standby mode), the permittee shall conduct the 

preventative maintenance for the devices and with the frequency as Indicated in Appendix 9. (R336.1213(3)) 

16. The permittee shall maintain hourly records of incinerator status, i.e. whether an Incinerator is in service, on 

stand-by, pre-start up, start up, malfunctioning or out of service. (R336.1213(3)) 

See Appendices 3, 4 and 9 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

Vfff. STACKNENT RESTRICTION(S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Underlying Applicable 

Dimensions Above Ground Requirements 

(Inches) (feet) 

1. SVBYPASS01/2 NA NA NA 

2. SVSTUB01 NA NA NA 

3. SVSTACK01 32 2 254 2 R336.1201(1) 

4. SVSTUB02 NA NA NA 

5. SVSTACK02 32' 254' R336.1201(1) 

6. SVBYPASS03/4 NA NA NA 

7. SVSTUB03 NA NA NA 

8. SVSTACK03 32' 254 < R336.1201(1) 

9. SVSTUB04 NA NA NA 

10. SVSTACK04 32 2 254 < R336.1201(1) 

11. SVBYPASS05/6 NA NA NA 

12. SVSTUB05 NA NA NA 

13. SVSTACK05 32 254' R336.1201(1) 

14. SVSTUB06 NA NA NA 

15. SVSTACK06 32 < 254 < R336.1201(1) 

Page 37 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

IX. OTHER REQUIREMENT($) 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

1. The permittee shall maintain the stack gas oxygen concentration monitoring systems and opacity monitoring 

systems. (R336.1213(3)) 

2. The permittee shall Implement and comply with the Operator Training and Qualification provisions as specified 

in 40 CFR 60.5130 through 60.5160. 3 (40 CFR 60.5130, 40 CFR 60.5135, 40 CFR 60.5140, 40 CFR 60.5145, 

40 CFR 60.5150, 40 CFR 60.5155, 40 CFR 60.5160) 

3. The permittee must conduct an air pollution control device Inspection according to 40 CFR 60.5220(c) by the 

final compliance date for 40 CFR Part 60 Subpart MMMM. For air pollution devices installed after the final 

compliance date, the permittee must conduct the air pollution control device inspection within 60 days after 

installation of the control devlce.3 (40 CFR 60.5195, 40 CFR 60.5220(c)) 

4. Except during periods when an Incinerator is out of service (in cold standby mode), the permittee shall 

implement a Malfunction Abatement Plan (MAP) and record incidents of high opacity and inappropriate hearth 

temperatures as well as corrective actions and updates to the MAP. The MAP dated March 22, 2007, or its 

most recent revision, shall be Implemented. All maintenance activities regarding the MAP shall be recorded 

and made available to AQD upon request.' 

(R336.1911, Consent Order No. 17 -2006) 

5. The permittee shall comply with all applicable provisions of the Standards of Performance for New Stationary 

Sources, as specified in 40 CFR Part 60, Subpart A and Subpart MMMM for Existing Sewage Sludge 

Incineration Units by the compliance date' (40 CFR Part 60, Subparts A and MMMM) 

Footnotes: 

1

This condition Is state only enforceable and was established pursuant to Rule 201(1)(b). 

'This condition Is federally enforceable and was established pursuant to Rule 201(1)(a). 

3

This condition is future applicable. The date of future applicability is based upon the date of approval of the State 

Plan, and will be the earlier of (1) March 15, 2016, or (2) three years after the effective date of State Plan approval. 

Page 38 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-82103-2014a 

FGCOMPLEX2 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers the Complex 2 incinerators before the air quality control improvements. It consists of 

eight (8) multiple hearth sewage sludge Incinerators, each wlth an impingement tray wet scrubber followed by a 

venturi scrubber and a mist eliminator. 

Emission Units: EUJNC07, EUINC08, EUINC09, EUINC10, EUINC11, EUINC12, EUINC13, EUINC14 

POLLUTION CONTROL EQUIPMENT 

For each incinerator: an Impingement type wet scrubber followed by a venturi scrubber and a mist eliminator. 

I. EMISSION LIMIT(S) 

Time Period/ 

Pollutant Limit Operating 

Scenario 

0.151b per 1,000 

1. PM pounds of exhaust Test protocol* 

gases' 

• Test protocol shall specifY averagmg time. 

II. MATERIAL LIMIT(S) 

NA 

Ill. PROCESS/OPERATIONAL RESTRICTIONISl 

Testing I Underlying 

Equipment Monitoring Applicable 

Method Requirements 

Each incinerator in 

FGCOMPLEX2 GC 13 R 336.1331(1)(c) 

1. The permittee shall not operate the incinerators in FGCOMPLEX2 unless the venturi/Impingement tray wet 

scrubbers and mist eliminators are installed and operating properly. Such control equipment shall be 

maintained In good repair and operated in such a manner as to ensure compliance with emission requirements 

and visible emission requirements? (R 336.1910) 

2. The permittee shall operate each incinerator in FGCOMPLEX2 such that hearth #1 burners will maintain a 

combustion temperature between 1100"F to 1500"F, based on a 24-hour block average, unless It can be 

demonstrated that an alternative operating range can be used to achieve compliance with particulate matter 

and opacity limits' (R 336.1910) 

3. The differential pressure drop across the scrubber train shall not be less than 18 inches of water column, based 

on an 8-hour block average. (R 336.191 0) 

4. The permittee shall Implement a Malfunction Abatement Plan (MAP) for each incinerator in FGCOMPLEX2, 

and shall record all updates to the MAP. The MAP dated March 22, 2007, or its most recent revision, shall be 

implemented.' (R 336.1911, Consent Order No. 17-2006) 

IV. DESIGN/EQUIPMENT PARAMETERISl 

1. The permittee shall maintain the stack gas oxygen concentration monitoring systems and opacity monitoring 

systems.' (R 336.1911) 

V. TESTING/SAMPLING 

Page 39 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PT/-821 03-2014a 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

NA 

See Appendix 5 

Vf. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period offive years. (R 336.1213(3)(b)(il)) 

1. The permittee shall monitor and record the opacity of emissions from each incinerator in FGCOMPLEX2, on a 

continuous basis In a manner and with instrumentation acceptable to the Air Quality Division 

and according to the monitoring requirements In 40 CFR Part 75. The permittee shall keep all records on 

file at the facility and make them available to the Department upon request.' (Consent Order MDNRE SIP 

No. 11·1993) 

2. The permittee shall conduct monthly inspections of each incinerator in FGCOMPLEX2, except during periods 

when the incinerator is out of service (In cold standby mode), for the purpose of determining the operating 

condition of the scrubber, and, If necessary, the reasons for malfunction or failure, using monitoring and 

recordkeeping procedures outlined in Appendices 3 and 4. 2 (R 336.1910) 

3. The permittee shall monitor and record daily all of the following for each incinerator In FGCOMPLEX2, except 

during periods when the incinerator is out of service (in cold standby mode). The permittee shall keep all 

records on file at the facility and make them available to the Department upon request.' 

a. Water flow rate through the associated scrubber train. 

b. Differential pressure across the Inlet and outlet of each scrubber in the associated scrubber train. 

c. Hearth #1 combustion temperature 

(R 336.1910) 

4. For each incinerator in FGCOMPLEX2, the permittee shall monitor and record the daily sludge feed rate, as 

wet tons per day, except during periods when there is no sludge in the incinerator. The permittee shall keep all 

records on file at the facility and make them available to the Department upon request? (40 CFR 61 ,52) 

5. The permittee shall monitor oxygen concentration for each operating incinerator. The permittee shall keep all 

records on file at the facility and make them available to the Department upon request2 (R 336.1911) 

6. Except for periods when an incinerator is out of service (cold standby mode), the permittee shall conduct the 

preventative maintenance for the devices and with the frequency as indicated in Appendix 9.2 (R 336.1910, 

R 336.1911) 

7. The permittee shall maintain hourly records of incinerator status, i.e. whether an incinerator is in service, on 

stand-by, pre-start up, start up, malfunctioning, or out of service. The permittee shall keep all rec.ords on file at 

the facility and make them available to the Department upon request.' (R 336.1910, R 336.1911) 

8. For each incinerator in FGCOMPLEX2, .the permittee shall keep a record of incidents of high opacity and 

inappropriate hearth temperature as well as corrective actions taken and shall make the record available to the 

AQD upon request.' (R 336.1911, Consent Order No. 17-2006) 

9. For each incinerator in FGCOMPLEX2, the permittee shall keep a record of all maintenance 

activities regarding the MAP and shall make the record available to the AQD upon request? (R 336.1911, 

Consent Order No. 17-2006) 

See Appendices 3, 4 and 9 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

Page 40 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MJ-ROP-82103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VIJJ. ST ACKNENT RESTRICTION(S) 

The exhaust gases from the stacks listed In the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Slack & Vent ID Diameter/Dimensions Above Ground 

(inches) (feet) Requirements 

1. SVSTACK07 39< 254< R 336.12011 

2. SVSTACKOB 39' 254 R 336.1201 1 

3. SVSTACK09 39' 254' R 336.12011 

4. SVSTACK10 39< 254' R 336.1201 1 

5, SVSTACK11 39 254< R 336.1201 1 

6. SVSTACK12 39' 254 R 336,1201 1 

7. SVSTACK13 39' 254' R 336.1201 1 

8. SVSTACK14 39 254< R 336.1201 1 

IX. OTHER REQUIREMENT($) 

1. Both of the following apply to each incinerator in FGCOMPLEX2, and to its scrubber train, when the incinerator 

commences trial operation after the air quality control improvements authorized by this Permit to Install have 

been completed for that incinerator: 

a. The Special Conditions in FGAQCJ become applicable requirements for that incinerator and its scrubber 

train. 

b. The Special Conditions In FGCOMPLEX2 cease to be applicable requirements for that incinerator and Its 

scrubber train. 

(R 336.1201(3)) 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201 (1)(a). 

Page 41 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

DESCRIPTION 

FGLIMESTORAGE 

FLEXIBLE GROUP CONDITIONS 

This flexible group includes the storage devices for lime that is used to stabilize residuals hauled to landfill. 

Emission Units: EULIMESTOR1, EULIMESTOR2, EULIMESTOR3 

POLLUTION CONTROL EQUIPMENT 

Pulse jet fabric filter bag house. 

I. EMISSION LIMIT{S) 

Pollutant Limit Time Period/ Operating 

Scenario 

1. Particulate Matter 0.1 pounds As determined by the 

per 1,000 average of three one 

pounds of hour test runs. 

exhaust air 

12. Visible Emissions 5% opacity 6 minute average 

II. MATERIAL L!MIT(S) 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION{S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER!Sl 

NA 

V. TESTING/SAMPLING 

Equipment 

FGLIMESTORAGE 

FGLIMESTORAGE 

Equipment 

NA 

Monitoring/ 

Testing Method 

Vl.1- V1.3 

Vl.3 

Monitoring/ 

Testing Method 

NA 

Records shall be maintained on file for a period of five years. {R 336.1213(3}{b)(ii)) 

NA 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3){b}(ll)} 

Underlying 

Applicable 

Requirements 

R336.1331(1}(c) 

R336.1301(1J(c 

Underlying 

Applicable 

Reauirements 

NA 

1. At least once a month, the permittee shall conduct regular inspections for the purpose of determining the 

operating condition of the baghouse, and, If necessary, the reasons for malfunction or failure, using monitoring 

and recordkeeping procedures outlined in Appendix 3 and 4. (R336.1213(3)) 

2. The permittee shall monitor and record the pressure drop across the baghouse during the lime loading. 

(R336.1213(3)) 

Page 42 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

3. The permittee shall perform and record visible emission observations during daylight hours when lime Is loaded 

into the silo to determine the presence or absence of visible emissions. If visible emission exceeds 5%, the 

permittee shall also record the corrective actions along with the visible emission reading. (R336.1213(3)) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VIII. STACK/VENT RESTRICTION!Sl 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent 10 Maximum Minimum Height Underlying Applicable 

Exhaust Above Ground Requirements 

Dimensions (feet) 

(inches) 

1. SVLIMESTOR1 10' 85' R336.12011 

2. SVLJMESTOR2 10' 85 1 R336.1201 1 

3. SVLJMESTOR3 10' 85' R336.1201 1 

IX. OTHER REQUIREMENT(S) 

1. The permittee shall repair or replace any defective parts discovered during the monthly preventive maintenance 

inspection or place unit out of service. (R336.1213(3)) 

Footnotes: 

1

Thls condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 

Page 43 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

DESCRIPTION 

FGENGINES 

FLEXIBLE GROUP CONDITIONS 

Seventeen emergency generators 

Emission Unit: EUGEN-D1A, EUGEN-D1B, EUGEN-D2, EUGEN-D4, EUGEN-05, EUGEN-D6, EUGEN-G1, 

EUGEN-G2, EUGEN-G3, EUGEN-G4, EUGEN-G5, EUGEN-G6, EUGEN-GS, EUGEN-G9, EUGEN-G10, EUGENP1, EUGEN-P2 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LJMIT/S) 

Pollutant Limit Time Period/ Operating 

Scenario 

1. NOx 36 tons ,per 12 month rolling time 

year period as determined at 

the end of each calendar 

mo'nth. 

Equipment Monitoring/ Underlying 

Testing Method Applicable 

Requirements 

FGENGINES 111.2, V1.1, Vl.3, R336.1205 

VJ.5 

.. . . The NOx hm1t IS based on the engme-spec1f1c em1ss1on factors listed 1n Appendix 7, or determined from em1sslons 

testing, whichever is greater. 

II. MATERIAL LIMIT(S) 

Material Limit Time Period/ Operating Equipment Monitoring/ Underlying 

Scenario Testing Method Applicable 

Requirements 

NA NA NA NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(Sl 

1. The sulfur content of the diesel fuel used in any of the generators In FGENGINES shall not exceed 15 ppm 

(0.0015) percent by weight. (R336.1205, R336.1402(1), 40 CFR 60.4207, 40 CFR 80.510(b)) 

2. The permittee shall not operate FGENGINES for more than 500 hours each per 12-month rolling time period as 

determined at the end of each calendar month? (R336.1205, R336.1225, R336.1702(a)) 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

NA 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

NA 

VI. MONJTORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(li)) 

1. The permittee shall monitor in a satisfactory manner the hours of operation for FGENGINES on a monthly 

basis? (R336.1205, R336.1225, R336.1702(a)) 

Page 44 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

2. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by 

the last day of the calendar month, for the previous calendar month, unless otheiWise specified in any 

recordkeeping, reporting or notification special condition. 2 (R336,1205) 

3. The permittee shall keep, in a satisfactory manner, monthly and previous 12-month NO, emission calculation 

records for FGENGINES, as required by Special Condition 1.1. The permittee shall keep all records on file for a 

period of at least five years and make them available to the Department upon request. 2 (R336.1205) 

4. The permittee shall keep records of the fuel oil sulfur content, In percent by weight, for each shipment of fuel oil 

received. The permittee shall keep all records on file for a period of at least five years and make them available 

to the Department upon request. 2 (R336.1205) 

5. The permittee shall keep, In a satisfactory manner, a written log of the monthly hours of operation of 

FGENGINES. The permittee shall keep all records on file for a period of at least five years and make them 

available to the Department upon request. 2 (R336.1205, R336.1225, R336.1702(a)) 

See Appendix 7 

VII. REPORTING 

1. Prompt reporting of deviations pursuant lo General Conditions 21 and 22 of Part A (R 336.1213{3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Condlllons 19 and 20 of Part A The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VIII. STACK/VENT RESTRICTION($) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otheiWise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Underlying Applicable 

Dimensions Above Ground Requirements 

(inches) Jfeet)_ 

1. SV-D1A 8 13.2 R336.1225 

2. SV-D1B 8' 13.2 R336.1225 

3. SV-D2 8' 13.2 R336.1225 

4. SV-04 8 13.5 R336.1225 

5. SV-D5 9 8.4 R336.1225 

6. SV-D6 3' 6' R336.1225 

7. SV-P1 4' 9' R336.1225 

8. SV-P2 4 9 R336.1225 

9. SV-G1 5' 12 R336.1225 

10. SV-G2 5' 12 R336.1225 

11. SV-G3 3.4 5.2 R336.1225 

12. SV-G4 2.5 4.83' R336.1225 

13. SV-G5 3.4 5.2' R336.1225 

14. SV-G6 2.5 4.83' R336.1225 

15. SV-G8 3.4 5.2 R336.1225 

16. SV-G9 2.5 4.83 R336.1225 

17. SV-G10 7.1 ' 13.2' R336.1225 

Page 45 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

IX. OTHER REQUIREMENT(S) 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

1. The permittee shall comply wilh the provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subpart A, Subpart 1111 and Subpart JJJJ, as they apply to the engines 

in FGENGINES. (40 CFR Part 60 Subparts A, 1111 & JJJJ) 

2. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, as !hey apply to the engines in 

FGENGINES. (40 CFR Part 63 Subparts A and ZZZZ, 40 CFR 63.6595) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2 This condition is federally enforceable and was established pursuant to Rule 201 (1)(a). 

Page 46 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-82103-2014a 

FGCIENGINES 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

Five (5) compression ignition, diesel-fired engines that are subject to specific provisions of the New Source 

Performance Standards for Stationary Compression Ignition Internal Combustion Engines (40 CFR Part 60, 

Subpart 1111). 

Emission Unit: EUGEN-D1A, EUGEN-D1 8, EUGEN-D2, EUGEN-D5, EUGEN..06 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(S) 

Scenario 

Page 47 of 106 

Equipment 

' EUGEN-018 60.4205(a), 

40 CFR 

94.8(a)(1) 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

II. MATERIAL LIMIT($) 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

Equipment 

NA 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Monitoring/ Underlying 

Testing Method Applicable 

Reauirements 

NA NA 

1. The sulfur content of the diesel fuel used In any of the engines in FGtCENGINES shall not exceed 15 ppm 

(0.0015) percent by weight. (R336.1205, R336.1402(1), 40 CFR 60.4207,40 CFR 80.510(b)l 

2. The permittee shall not operate FGCIENGINES for more than 500 hours each per 12-month rolling time period 

as determined at the end of each calendar month. The 500 hours Includes the 100 hours for the purpose of 

necessary maintenance checks and readiness testing as described in SC 111.3. {R 336.1205(1){a) & (3), 

R 336.1225, R 336.1702(a), R 336.2803, R 336.2804, 40 CFR 52.21 {c) & (d)) 

3. The permittee may operate the engines In FGICENGINES for no more than 100 hours per 12-month rolling 

time period as determined at the end of each calendar month for the purpose of necessary maintenance 

checks and readiness testing, provided that the tests are recommended by Federal, State, or local government, 

the manufacturer, the vendor, or the insurance company associated with the engine. Permittee may petition 

the Department for approval of additional hours to be used for maintenance checks and readiness testing. A 

petition is not required if the owner or operator maintains records Indicating that Federal, State, or local 

standards require maintenance and testing of emergency internal combustion engines beyond 100 hours per 

year. The engines in FGICENGINES may operate up to 50 hours per year in non-emergency situations, but 

those 50 hours are counted towards the 100 hours per year provided for maintenance and testing. The 50 

hours per year for non-emergency situations cannot be used for peak shaving or to generate Income for a 

facility to supply non-emergency power as part of a financial arrangement with another entity. (40 CFR 

60.4211(f)). 

4. The permittee shall install, maintain, and operate each of the engines in FGICENGINES according to the 

manufacturer written instructions, or procedures developed by the owner/operator and approved by the engine 

manufacturer, over the entire life of the engine. (R 336.1205(1)(a) & (3), R 336.1225, R 336.1911, R 336.2803, 

R 336.2804,40 CFR 52.21(c) & (d), 40 CFR 60.4206, 40 CFR 60.4211) 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

1. The permittee shall equip and maintain each engine in FGCIENGINES with non-resettable hours meters to 

track the operating hours. (R 336.1205(1)(a) & (3), R 336.1225, 40 CFR 60.4209) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213{3)(b)(il)) 

1. The permittee shall conduct an initial performance test for the engines in FGCIENGINES within one year after 

startup of the engines to demonstrate compliance with the emission limits in 40 CFR 60.4205 unless the 

engines have been certified by the manufacturer and the permittee maintains the engine as required by 40 CFR 

Part 60 Subpart 1111. If a performance test Is required, the performance tests shall be conducted according to 40 

CFR 60.4212 (less than 30 liters) or 40 CFR 60.4213 (greater than 30 liters). No less than 30 days prior to 

testing, a complete test plan shall be submitted to the AQD. The final plan must be approved by the AQD prior 

to testing. Verification of emission rates includes the submittal of a complete report of the test results to the 

AQD within 60 days following the last date of the test. (40 CFR 60.4211, 40 CFR 60.4212, 40 CFR Part 60 

Subpart 1111) 

Page 48 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

VI. MONITORING/RECOROKEEPING 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

Records shall be maintained on file for a period of five years. (R 336.1213{3){b)(li)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by 

the last day of the calendar month, for the previous calendar month, unless otherwise specified In any 

recordkeeping, reporting or notification special condition. (R 336.1205(1)(a) & (3), R 336.2803, R 336.2804, 40 

CFR 52.21 (c) & {d)) 

2. The permittee shall keep, In a satisfactory manner, a record of testing required in SC V.1 or manufacturer 

certification documentation indicating that the engines in FGCIENGINES meet the applicable emission 

limitations contained in the federal Standards of Performance for New Stationary Sources 40 CFR Part 60 

Subpart 1111. The permittee shall keep all records on file and make them available to the Department upon 

request. (40 CFR 60.4211) 

3. The permittee shall monitor and record the total hours of operation and the hours of operation during nonemergencies for the engines in FGCIENGINES, on a monthly and 12-month rolling time period basis, .in a 

manner acceptable to the District Supervisor, Air Quality Division. The permittee shall document how many 

hours are spent for emergency operation of the engines in FGCIENGINES, including what classified the 

operation as emergency and how many hours are spent for non-emergency operation. (R 336.1205(1)(a) & 

(3), 40 CFR 60.4211,40 CFR 60.4214) 

4. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, 

for each delivery of diesel fuel oil used in the engines in FGCIENGINES, demonstrating that the fuel sulfur 

content meets the requirement of 40 CFR 80.51 O(b ). The certification or test data shall include the name of the 

oil supplier or laboratory, and the sulfur content of the fuel oil. (R 336.1205(1)(a) & (3), R 336.1402(1), 

40 CFR 80.510(b)) 

5. The permittee shall monitor and record In a satisfactory manner the diesel fuel usage rate for the engines in 

FGCIENGINES on a monthly and 12-month rolling time period basis. The permittee shall keep all records on 

file and make them available to the Department upon request. (R 336.1205(1)(a) & (3), R 336.1225, 

R 336.1702(a), R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d)) 

See Appendix 7 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3){c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A The report shall 

be postmarl1ed or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VIII. STACK/VENT RESTRICTION(S) 

The exhaust gases from the stacks listed In the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Page 49 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

IX. OTHER REQUIREMENT($) 

Exhaust 

Dimensions 

Above Ground 

(feet) 

ROP No: MI-ROP-B2103-2014a 

Exr>iration Date: January 31, 2019 

Requirements 

1. The permittee shall comply with the provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subpart A and Subpart 1111, as they apply to the engines in 

FGCJENGINES. (40 CFR Part 60 Subparts A & 1111) 

2. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, as they apply to the engines in 

FGCIENGINES. (40 CFR Part 63 Subparts A and ZZZZ, 40 CFR 63.6595) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201 (1 )(b). 2 This condition Is federally enforceable and was established pursuant to Rule 201(1)(a). 

Page 50 of 1 06 

.I 

I ! 

11 

I 

II 

I 

! 

I 

II 

! 

! 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

DESCRIPTION 

FGNSPSBOILERS 

FLEXIBLE GROUP CONDITIONS 

Four {4) small natural gas-fired boilers that are subject to the requirement in NSPS Subpart De to track fuel usage 

rates. 

Emission Unit: EUBOILER7, EUBOILER8, EUBOILER9,EUBOILER1 0 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(S) 

Pollutant Limit Time Period/ Operating 

Scenario 

NA NA NA 

II. MATERIAL LIMIT(S) 

Material Limit Time Period/ Operating 

Scenario 

NA NA NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

Equipment 

NA 

Equipment 

NA 

Monitoring/ Underlying 

Testing Method Applicable 

Requirements 

NA NA 

Monitoring/ Underlying 

Testing Method Applicable 

R"quirements 

NA NA 

1. The permittee shall only fire natural gas in the boilers that make up FGNSPSBOILERS. (R336.1213(3)) 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

NA 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213{3)(b)(ii)) 

NA 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period offlve years. (R 336.1213(3)(b)(il)) 

1. The permittee shall record and maintain records of natural gas usage in each boiler on a calendar month basis. 

in lieu of recording the actual fuel usage rates, the permittee may record potential fuel usage based on the 

maximum design capacity of a boiler. (40 CFR 60.48c(g)) 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336,1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213{3)(c)(i)) 

Page 51 of 106 

I

i 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

Vlll. STACK/VENT RESTRICTION($) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Minimum Height Underlying Applicable 

NA 

IX. OTHER REQUIREMENT($) 

NA 

Footnotes: 

Exhaust 

Dimensions 

(inches) 

NA 

Above Ground 

{feet) 

NA 

1 This condition is state only enforceable and was established pursuant to Rule 201(1){b). 2 This condition is federally enforceable and was established pursuant to Rule 201 (1){a). 

Page 52 of 106 

Requirements 

NA 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: Ml-ROP·B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

FGCOLDCLEANERS J 

FLEXIBLE GROUP CONDITIONS c.____----'---~--'--------------

DESCRIPTION 

Any cold cleaner that Is grandfathered or exempt from Rule 201 pursuant to Rule 278 and Rule 281 (h) or Rule 

285(r)(iv). Existing cold cleaners were placed into operation prior to July 1, 1979. New cold cleaners were placed 

into operation on or after July 1, 1979. 

Emission Unit: NA 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(Sl 

NA 

II. MATERIAL LIMIT(Sl 

1. The permittee shall not use cleaning solvents containing more than five percent by weight of the following 

halogenated compounds: methylene chloride, perchloroethylene, trichloroethylene, 1, 1,1-trlchloroethane, 

carbon tetrachloride, chloroform, or any combination !hereof. (R 336.1213(2)) 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

1. Cleaned parts shall be drained for no less than 15 seconds or until dripping ceases. (R 336.1611(2)(b), 

R 336.1707(3){b)) 

2. The permittee shall perform routine maintenance on each cold cleaner as recommended by the manufacturer. 

(R 336.1213(3)) 

IV. DESIGN/EQUIPMENT PARAMETER($) 

1. The cold cleaner must meet one of the following design requirements: 

a. The air/vapor interface of the cold cleaner is no more than ten square feet. (R 336.1281(h)) 

b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general In-plant 

environment. (R 336.1285(r)(iv)) 

2. The cold cleaner shall be equipped with a device for draining cleaned parts. (R 336.1611(2)(b), 

R 336.1707(3)(b)) 

3. All new and existing cold cleaners shall be equipped with a cover and the cover shall be closed whenever parts 

are not being handled in the cold cleaner. (R 336.1611(2)(a), R 336.1707(3)(a)) 

4. The cover of a new cold cleaner shall be mechanically assisted if the Reid vapor pressure of the solvent Is 

more than 0.3 psia or if the solvent is agitated or heated. (R 336.1707(3){a)) 

5. If the Reid vapor pressure of any solvent used in a new cold cleaner Is greater than 0.6 ps/a; or, if any solvent 

used in a new cold cleaner Is heated above 120 degrees fahrenheit, then the cold cleaner must comply with at 

least one of the following provisions: 

a. The cold cleaner must be designed such that the ratio of the freeboard height to the width of the cleaner is 

equal to or greater than 0.7. (R 336.1707(2)(a)) 

Page 53 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

b. The solvent bath must be covered with water if the solvent is insoluble and has a specific gravity of more 

than 1.0. (R 336.1707(2)(b)) 

c. The cold cleaner must be controlled by a carbon adsorption system, condensation system, or other method 

of equivalent control approved by the AQD. (R 336.1707(2)(c)) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(li)) 

NA 

VI. MONJTORING/RECORDKEEPING 

Records shall be maintained on file for a period offive years. (R 336.1213(3)(b)(li)) 

1. For each new cold cleaner in which the solvent is heated, the solvent temperature shall be monitored and 

recorded at least once each calendar week during routine operating conditions. (R 336.1213(3)) 

2. The permittee shall maintain the following information on file for each cold cleaner: (R 336.1213(3)) 

a. A serial number, model number, or other unique identifier for each cold cleaner. 

b. The date the unit was installed, manufactured or that It commenced operation. 

c. The air/vapor interface area for any unit claimed to be exempt under Rule 281(h). 

d. The applicable Rule 201 exemption. 

e. The Reid vapor pressure of each solvent used. 

f. If applicable, the option chosen to comply with Rule 707(2). 

3. The permittee shall maintain written operating procedures for each cold cleaner. These written procedures 

shall be posted in an accessible, conspicuous location near each cold cleaner. (R 336.1611(3), R 336.1707(4)) 

4. As noted in Rule 611 (2)(c) and Rule 707(3)(c), if applicable, an initial demonstration that the waste solvent is a 

safety hazard shall be made prior to storage in non-closed containers. If the waste solvent Is a safety hazard 

and Is stored in non-closed containers, verification that the waste solvent is disposed of so that not more than 

20 percent, by weight, is allowed to evaporate into the atmosphere shall be made on a monthly basis. 

(R 336.1213(3), R 336.1611(2)(c), R 336.1707(3)(c)) 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 8 

VIII. STACK/VENT RESTRICTION($) 

NA 

IX. OTHER REQUIREMENT($) 

NA 

Page 54 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

FGAQCI 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers the Complex 2 incinerators for which the air quality control improvements (AQCI) have 

been completed. When the AQCI have been completed, it will consist of eight (8) multiple hearth sewage sludge 

Incinerators, each with a venturi scrubber followed by an impingement tray wet scrubber and a mist eliminator. 

Emission Unit: EUINC07, EUINC08, EUINC09, EUINC10, EUINC11, EUINC12, EUINC13, EUINC14 

POLLUTION CONTROL EQUIPMENT 

For each incinerator: a venturi scrubber followed by an Impingement type wet scrubber and a mist eliminator. 

I. EMISSION LIMIT(S) 

Time Period/ Testing I Underlying 

Pollutant Limit Operating Equipment Monitoring Applicable 

Scenario Method Requirements 

1. Particulate 80 milligrams per Each Incinerator In GC 13, R 336.1331, 

Malter dry standard cubic Test protocol' FGAQCI SC V.1 R 336.2801(ee) meter 82 

~· PM2.5 1.20 lb/hr2 Test protocol' Each incinerator in GC 13, R 336.2801(ee), 

FGAQCI SC V.1 40 CFR 52.21(c) i. (d 

e. PM10 1.20 lb/hr2 Test protocol' Each incinerator In GC 13, R 336.2801(ee), 

FGAQCI SC V.1 40 CFR 52.21{c) & (d 

~·Hydrogen 1.2 ppmv dry' 1 Test protocol' Each incinerator in GC 13, R 336.1224 chloride FGAQCI SC V.1 

5. Carbon 3,800 ppmv dry ' Test protocol' Each incinerator in GC 13, R 336.2801(ee), 

monoxide FGAQCI SC V.1 40 CFR 52.21 (d) 

6. voc 3.20 lb/hr2 Test protocol' Each Incinerator in GC 13, R 336.2801(ee), 

FGAQCI SCV.1 R 336.170:2/a) 

7. Dioxins/furans 5.0 nanograms per Each incinerator In GC 13, (total mass dry standard cubic Test protocol' R 336.1224 

basis) b,o meter a, 1 FGAQCI SCV.1 

8. Dloxins/furans 0.32 nanograms per Each incinerator In GC 13, toxic equivalency dry standard cubic Test protocol' FGAQCI SC V.1 R 336.1224 

basi~h,c meter a, 1 

0.28 milligrams per Each incinerator In GC 13, 9. Mercury dry standard cubic Test protocol' R 336.1224 

meter a, 1 FGAQCI sc V.1 

10. Nitrogen 220 ppmv dry" Test protocol' Each incinerator in GC 13, R 336.2801(ee), 

xides FGAQCI SC V.1 40 CFR 52.21(c) & (d 

11. Sulfur Dioxide 26 ppmv dry ' 2 Test protocol' Each incinerator in GC 13, R 336.2801(ee) FGAQCI SC V.1 

Each Incinerator in GC 13, R 336.1224, 

12. H2So4 1.3 lb/hr2 Test protocol' R 336.2801(ee) FGAQCI SC V.1 40 CFR 52.21(b)(3)(i) 

0.095 milligrams per Each incinerator in GC 13, R 336.1224, 13. Cadmium dry standard cubic Test protocol' 

meter a. 1 FGAQCI SC V.1 R 336.1225(2) 

0.30 milligrams per Each incinerator in GC 13, R 336.2801(ee), 14. Lead dry standard cubic Test protocol' 

meter a 2 FGAQCI SC V.1 40 CFR 52.21(d) 

15. Fluorides 1.73 lb/hr2 Test protocol' Each Incinerator in GC 13, R 336.2801(ee) FGAQCI SCV.1 

Page 55 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Time Period/ 

Pollutant Limit Operating 

Scenario 

12-month rolling 

16. PM 46.6 tpy2 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

17. PM10 59.6 tp/ 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

18. PM2.5 58.3 tpy' 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

19. co 1 ,522.4 tpy2 determined at the 

end of each 

calendar month 

12-month rolling 

?0. NOx 663.4 tp/ 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

~1. so, 37.6 tpy2 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

~2. voc 64.8 tpy2 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

~3.Lead 0.54 tp/ 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

~4. co,e 237,275 tpy' 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

~5. H,SO, 25.9 tpy2 

time period as 

determined at the 

end of each 

calendar month 

Equipment 

FGAQCI 

FGAQCI 

FGAQCI 

FGAQCI 

FGAQCI 

FGAQCI 

· FGAQCI 

FGAQCI 

FGAQCI 

FGAQCI 

Page 56 of 1 06 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No· .. Ml -PTI -82103 " 2014a 

Testing I Underlying 

Monitoring Applicable 

Method Requirements 

R 336.1205(1), SCV1.7 R 336.2801(ee) 

R 336.1205(1), SC Vl.7 R 336.2801(ee) 

R 336.1205(1), 

SCVI.7 R 336.2801(ee), 

40 CFR 52.21(b)(3)(i) 

R 336.1205(1), SCVI.7 R 336.2801(ee) 

R 336.1205(1), SC Vl.7 R 336.2801(ee) 

R 336.1205(1), SCVI.7 R 336.2801(ee) 

R 336.1205(1), SCVI.7 R 336.2801(ee) 

R 336.1205(1), SCVI.7 R 336.2801(ee) 

R 336.1205(1), SCVI.7 40 CFR 52.21(b)(3)(i) 

R 336.1205(1), SCVI.7 R 336.2801(ee) 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Pollutant Limit 

Time Period/ 

Operating 

Scenario 

12-month rolling 

time period as 

126. Fluorides 35.0 tpy' determined at the 

end of each 

calendar month 

Equipment 

FGAQCI 

ROP No: MJ-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTi No· .. MJ-PTI-B2103-2014a 

Testing I Underlying 

Monitoring Applicable 

Method Requirements 

R 336.1205(1), SC VI.? R 336.2801(ee) 

All emission limits are measured at 7 percent oxygen, dry basis, at standard conditions. For the emission limits In 

this table, standard conditions means a temperature of 68 oF (20 °C) and a pressure of 1 atmosphere (101.3 

kilo pascals). 

Dioxlnslfurans means tetra- through acta-chlorinated dibenzo-p-dloxins and dibenzofurans. 

The permittee has the option to comply with either the dioxin/furan limit on a total mass basis OJ' the dioxinl/furan 

emission limit on a toxic equivalency basis. 

Test protocol shall specify avera!)in!l time. 

II. MATERIAL LIMIT(S) 

Time Period I Testing/ Underlying 

Material Limit Operating Equipment Monitoring Applicable 

Scenario Method Requirements 

12-month rolling R 336.1205(1), 

1. Total 129,564 dry time period as R 336.1225(1), 

Judge feed tons per year" determined at the FGAQCI SCV/.6 R 336.1225(2), 

end of each R 336.2801 (ee), 

calendar month 40 CFR 52.21(b)(J)(JI 

EUJNCJN01, EUJNCJN03, 

12-month rolling EUINCIN04, EUINCIN05, 

~·Total 157,000 dry time period as EUJNCIN06, EUJNCIN07, R 336.1205(1), 

tons per year" determined at the EUINCIN08, EUJNCJN09, SCV/.8 R 336.2801(ee), Judge feed 2 end of each EUJNCIN10, EUJNCJN11, 40 CFR 52.21 (b)(3)(1) 

calendar month EUJNCJN12, EUJNCJN13, 

EUJNCJN14 

This requirement is terminated on and after March 21, 2016, or whenever EUINCIN01, EUJNCIN02, EUJNCJN03, 

EUINCIN04, EUJNCIN05, and EUJNCJN06 have all been permanently shut down, whichever comes first. 

Ill. PROCESS/OPERATIONAL RESTRICTION IS) 

1. The permittee shall not operate any incinerator in FGAQCI unless the associated venturi scrubber, impingement 

tray wet scrubber, and mist eliminator are installed, maintained, and operating in a satisfactory manner! 

(R 336.1224, R336.1910) 

2. The permittee shall not feed sludge to any incinerator in FGAQCI unless the parameters listed below are within 

the ranges specified In the approved malfunction abatement plan (MAP), except for limited periods while 

attempting to restore a parameter to its specified range, as provided for In the approved MAP.' 

a. Water flow rate for each scrubber In the associated scrubber train. 

b. Differential pressure across the Inlet and outlet of each scrubber in the associated scrubber train. 

c. Hearth #1 combustion temperature 

(R 336.1224, R 336.1702(a), R 336.1910) 

Page 57 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

3. The permittee shall not operate any incinerator in FGAQCI unless an update to the malfunction abatement plan 

(MAP) for the incineration process has been submitted within 180 days of commencing trial operation of the 

first incinerator in FGAQCI, and the updated MAP is implemented and maintained. If at any time the MAP falls 

to address or inadequately addresses an event that meets the characteristics of a malfunction, the permittee 

shall amend the MAP within 45 days after such an event occurs. The permittee shall also amend the MAP 

within 45 days if new equipment is Installed or upon request from the District Supervisor. The permittee shall 

submit the MAP and any amendments to the MAP to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the MAP or amended MAF shall be 

considered approved. Until an amended plan Is approved, the permittee shall implement corrective procedures 

or operational changes to achieve compliance with all applicable emission limits.' (R 336.1911) 

IV. DESIGN/EQUIPMENT PARAMETER(S\ 

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a device to monitor and 

record the parameters specified below for each Incinerator In FGAQCI and Its associated scrubber train.' 

a. Water flow rate for each scrubber In the associated scrubber train. 

b. Differential pressure across the inlet and outlet of each scrubber in the associated scrubber train. 

c. Hearth #1 combustion temperature 

(R 336.1224, R 336.1702(a), R 336.1910) 

2. The permittee shalllnstall, callbrate, malntain and operate In a satisfactory manner, a device to monitor and 

record the oxygen emissions for each incinerator in FGAQCI on a continuous basis2 (R 336.1224, 

R 336.2801(ee), 40 CFR 52.21(b){3)(i)) 

3. The permittee shall install, calibrate, maintain and operate in a satlsfactory manner, a device to monitor and 

record the visible emissions from each incinerator In FGAQCJ on a continuous basis.2 (R 336.1301) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336_1213{3){b)(ii)) 

1. This condition applies to each pair of Incinerators In FGAQCI for which this permit authorizes air quality control 

Improvements. After the air quality control improvements have been completed for each pair of incinerators in 

FGAQCI, and within 180 days after commencement of trial operation of either Incinerator In that pair of 

incinerators, the permittee shall verify PM, PM10, PM2.5, HCI, CO, VOC, dloxlns/furans, mercury, NOx, S02, 

H2S04, cadmium, lead, and fluorides emission rates from one of the incinerators in the pair by testing at 

owner's expense, in accordance with Department requirements. No less than 30 days prior to testing, the 

permittee shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The AQD 

must approve the final plan prior to testing. Verification of emission rates Includes the submittal of a complete 

report of the test results to the AQD Technical Programs Unit and District Office within 60 days following the 

last date of the test.2 (R 336.1224, R 336.1225, R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, 

R 336.2801(ee), 40 CFR 52.21(b){3){i), 40 CFR 52.21(c) & (d)) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall continuously monitor and record, in a satisfactory manner, the oxygen emissions from each 

incinerator In FGAQCI. The permittee shall operate each Continuous Emission Monitoring System (GEMS) to 

meet the timelines, requirements and reporting detailed in Appendix 8.2 (R 336.1224, R 336.2801(ee), 

40 CFR 52.21 {b )(3)(i)) 

Page 58 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: Mt-PTI-B2103-2014a 

2. The permittee shall continuously monitor and record, in a satisfactory manner, the visible 

emissions from each incinerator in FGAQCJ. The permittee shall operate each COM system 

to meet the tlmelines, requirements and reporting detailed In Appendix 3.3.C.2 (R 336.1301, Consent Order 

MDNRE SIP No. 11-1993) 

3. The permittee shall conduct periodic inspections of each incinerator in FGAQCI as provided in the approved 

MAP, except during periods when the incinerator Is out of service (in cold standby mode). The permittee shall 

keep records of all inspections and actions taken in response to the Inspections on file at the facility and make 

them available to the Department upon request.' (R 336.1910, R 336.1911) 

4. The permittee shall monitor and record, in a satisfactory manner, all of the fallowing for each incinerator in 

FGAQCI on a daily basis, except during periods when the incinerator is out of service (in cold standby mode). 

The permittee shall keep all records on file at the facility and make them available to the Department upon 

request.' 

a. Water flow rate through the associated scrubber train. 

b. Differential pressure across the inlet and outlet of each scrubber In the associated scrubber train. 

c. Hearth #1 combustion temperature 

(R 336.191 0) 

5. The permittee shall monitor and record, In a satisfactory manne1·, all other parameters identified in the approved 

malfunction abatement plan for FGAQCI, at the frequency identified in the plan, except during periods when 

there is no sludge In the incinerator. The permittee shall keep all records on file at the facility and make them 

available to the Department upon request. (R 336.1911) 

6. For each incinerator in FGAQCI, the permittee shall monitor and record the dally sludge feed rate, as wet tons 

per day, except during periods when there is no sludge In the incinerator. The permittee shall keep all records 

on file at the facility and make them available to the Department upon request. 2 (40 CFR 61.52) 

7. The permittee shall calculate the emission rates of the pollutants listed below from FGAQCI monthly, both for 

the calendar month and for the 12-month rolling time period ending that month, using a method acceptable to 

the AQD District Supervisor. The permittee shall keep all records on file at the facility 

and make them available to the Department upon request.' (R 336.1205(1), R 336.2B01(ee), 

40 CFR 52.21 (b)(3)(i)) 

a. PM 

b. PM10 

c. PM2.5 

d. co 

e. NOx 

f. so, 

g. voc 

h. Lead 

1. co,e 

j. H,so, 

k. Fluorides 

B. For each incinerator in FGAQCI and for FGCOMPLEX2, EUINCJN01, EUINCJN03, EUINCIN04, EUINCIN05, 

and EUINCIN06, the permittee shall monitor and record the sludge feed rate for each calendar month and for 

the 12-month rolling time period ending that month, as dry tons per month, except during periods when there is 

no sludge in the incinerator. The permittee shall keep all records on file at the facility and make them available 

to the Department upon request.' (R 336.1205(1), R 336.2801(ee), 40 CFR 52.21(b)(3)(i)) 

See Appendices 3 and 4 

Vll. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(II)J 

Page 59 of 1 06 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

4. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install for each Incinerator In FGAQCI, the permittee or the authorized agent 

pursuant to Rule 204, shall notify the AQD District Supervisor, In writing, of the completion of the activity. 

Completion of the installation, construction, reconstruction, relocation, or modification Is considered to occur not 

later than commencement of trial operation of the Incinerator as part of FGAQCI. 2 (R 336.1201 (7)(a)) 

5. No later than the date that the permittee permanently ceases operating EUINCIN02, the permittee or the 

authorized agent pursuant to Rule 204 shall submit a closure notification, Including the date of closure, to the 

AQD District Supervisor. For this condition, "permanently ceases operating" means that the unit has ceased 

operating and that the permittee has decided to not restart 1!.2 (40 CFR 60.5125) 

See Appendix 8 

VIII. STACKNENT RESTRICTION(S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID 

IX. OTHER REQUIREMENT!S) 

1. Both of the following apply to each Incinerator in FGAQCJ, and to Its scrubber train, when the incinerator 

commences trial operation after the air quality control improvements authorized by this Permit to Install have 

been completed for that incinerator': 

a. The Special Conditions in FGAQCI become applicable requirements for that incinerator and its scrubber 

train. 

b. The Special Conditions In FGCOMPLEX2 cease to be applicable requirements for that Incinerator and its 

scrubber train. 

(R 336.1201(3)) 

2. Except during periods when an incinerator is out of service (cold standby mode), the permittee shall Implement 

a MAP and record Incidents of high opacity and inappropriate hearth temperatures as well as corrective actions 

and updates to the MAP. The MAP dated March 22, 2007, or Its most recent revision, shall be Implemented. 

All maintenance activities regarding the MAP shall be recorded and made available to AQD upon request.2 

(R 336.1911, Consent Order No.17-2006) 

Footnotes: 

Page 60 of 1 06 
Detroit Department of Water & Sewerage ROP No: MI-ROP-821 03-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 1 This condition Is state only enforceable and was established pursuant to Rule 201 (1 )(b). 2 This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a). 

Page 61 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

FG4M-INCIN 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers all sewage sludge incinerators subject to 40 CFR Part 60, Subpart MMMM. The 

conditions for this flexible group take effect on and after the effective date of Subpart MMMM: March 21, 2016. 

Emission Unit: EUINC07, EUINC08, EUINC09, EUINC10, EUINC11, EUINC12, EUINC13, EUINC14 

POLLUTION CONTROL EQUIPMENT 

For each incinerator: a venturi scrubber followed by an impingement tray wet scrubber and a mist eliminator. 

I. EMISSION LIMIT(S) 

Time Period/ Testing I Underlying 

Pollutant Limit Operating Equipment Monitoring Applicable 

Scenario Method Requirements 

1. Particulate 80 milligrams per Each incinerator in SC V.1-5, dry standard cubic Test protocol' 40 CFR 60.5165 Matter meter 32 FG4M-INCIN Vl.5, Vl.6, Vl.9 

2. Hydrogen 1.2 ppmvdry' 2 Test protocol' Each Incinerator in SC V.1-5, 40 CFR 60.5165 Qhloride FG4M-INCIN Vl.5-7, V1.9 

G. Carbon 3,800 ppmv dry '2 Test protocol' Each incinerator in SC V.1-5, 40 CFR 60.5165 monoxide FG4M-INCIN Vl.3, Vl.9 

. Dioxins/furans 5.0 nanograms per Each Incinerator In SC V.1-5, (total mass basis) dry standard cubic Test protocol' 40 CFR 60.5165 '0 meter a 2 FG4M-INCJN Vl.3, Vl.9 

5. Dioxlns/furans 0.32 nanograms Each incinerator in SC V.1-5, 40 CFR 60.5165 (toxic equivalency per dry standard Test protocol' 

basi:ll b,c cubic meter a2: FG4M-INCIN Vl.3, Vl.9 40 CFR 60.5185(c) 

~·Mercury 

0.28 milligrams per Each incinerator in SC V.1-5, dry standard cubic Test pro loco I' 40 CFR 60.5165 

meter a:i: FG4M-JNCIN Vl.9 

7. Oxides of 220 ppmv dry a 2 Test protocol* Each incinerator in SC V.1-5, 40 CFR 60.5165 nitrogen FG4M-INCIN Vl.3, V1.9 

~· Sulfur Dioxide 26 ppmv dry' 2 Test protocol' Each incinerator in SC V.1-5, 40 CFR 60.5165 FG4M-INCIN Vl.5-7, Vl.9 

~.Cadmium 

0.095 milligrams Each incinerator in SC V.1-5, per dry standard Test protocol* 40 CFR 60.5165 

cubic meter a 2 FG4M-INCIN Vl.5, Vl.6, Vl.9 

0.30 milligrams per Each incinerator in SC V.1-5, 10. Lead dry standard cubic Test protocol' FG4M-INCIN Vl.5, Vl.6, VL9 40 CFR 60.5165 

meter a 2 

All emission limits are measured at 7 percent oxygen, dry basis, at standard conditions. For the emission limits in 

this table, standard conditions are defined in 40 CFR 60.5250. 

Dloxins/furans are defined in 40 CFR 60.5250. 

The permittee has the option to comply with either the dioxin/luran limit on a total mass basis or the dioxin//furan 

emission limit on a toxic equivalency basis. 

Test protocol shall specify averaQinQ time. 

II. MATERIAL LIMIT(S) 

NA 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

Page 62 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-82103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

1. Use of the bypass stack associated with an incinerator in FG4M-INCIN at any time that sewage sludge is being 

charged to that incinerator is an emissions standards deviation for all of the pollutants listed In Special 

Conditions 1.1 through 1.10.2 (40 CFR 60.5220(d)) 

IV, DESIGN/EQUIPMENT PARAMETER(Sl 

1. For each pollutant and incinerator for which the permittee has chosen the compliance demonstration option 

specified in SC V.2 or V.4, the permittee shall install, calibrate, maintain and operate in a satisfactory manner, a 

device to monitor and record the pollutant emissions from the incinerator on a continuous basis.2 (40 CFR 

60.13, 40 CFR 60.5220(b)(3))) 

2. The permittee shall Install, calibrate, maintain and operate in a satisfactory manner, a device to monitor 

and record the sewage sludge feed rate for each Incinerator In FG4M-INCIN on a continuous basis.' (40 CFR 

60.5170(f)(1)) 

3. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a device to monitor and 

record the combustion chamber temperature for each incinerator In FG4M-INCIN on a continuous basls.2 

(R 336.1910,40 CFR 60.5200,40 CFR 60.5170(a)) 

4. The permittee shall Install, calibrate, maintain and operate in a satisfactory manner, a device to monitor and 

record the pressure drop across the inlet and outlet of each scrubber in each scrubber train for FG4M-INCIN on 

a continuous basis.2 (R 336.1910, 40 CFR 60.5200,40 CFR 60.5170(b)) 

5. The permittee shall Install, calibrate, maintain and operate In a satisfactory manner, a device to monitor and 

record the liquid flow rate through each scrubber in each scrubber train for FG4M-INCIN on a continuous 

basis.' (R 336.1910,40 CFR 60.5200,40 CFR 60.5170(b)) 

6. The permittee shall install, calibrate, maintain and operate In a satisfactory manner, a device to monitor and 

record the liquid pH for each scrubber in each scrubber train for FG4M-INCIN on a continuous basis.2 

(R 336.1910, 40 CFR 60.5200, 40 CFR 60.5170(b)) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ll)) 

1. The permittee shall have the option of conducting emission tests to demonstrate Initial compliance with the 

emission limits and standards for particulate matter, hydrogen chloride, carbon monoxide, dloxins/furans (total 

mass or toxic equivalency basis), mercury, nitrogen oxides, sulfur dioxide, cadmium, and lead. If the permittee 

chooses the option of performing emission tests, then the emission tests shall be conducted using the test 

methods, averaging methods and minimum sampling volumes or durations speCified In Table 3 of 40 CFR 

Part 60, Subpart MMMM, and according to the testing, monitoring and calibration requirements specified In 

40 CFR 60.5220(a). Stack testing procedures and the location of stack testing ports shall be in accordance 

with the applicable federal Reference Methods, 40 CFR Part 60 Appendix A. The permittee may use results 

from a performance test conducted within the two previous years that was conducted under the same 

conditions and demonstrated compliance with the emission limits and standards specified in the Emission 

Limits section of this Flexible Group, provided that no process changes have been made since the performance 

test was conducted. If the results of a past performance test are used, the permittee shall continue to meet the 

operating limits established during that performance test that demonstrated compliance with the applicable 

emission limits. The past performance test must have used the same test methods specified in Table 3 of 

40 CFR Part 60 Subpart MMMM. Not less than 30 days prior to the anticipated test date, a complete stack 

testing plan shall be submitted to the AQD Technical Programs Unit and District Office for approval. The AQD 

must approve the final plan prior to testlng.2 (40 CFR 60.5185(a)) 

2. In lieu of conducting the emissions test specified in Special Condition V. 1, the permittee may demonstrate initial 

compliance with the emission limits for particulate matter, hydrogen chloride, carbon monoxide, dioxlns/furans, 

mercury, nitrogen oxides, sulfur dioxide, cadmium and lead by substituting the use of a continuous emission 

monitoring system for any or all of these pollutants In accordance with the requirements of 40 CFR 60.5185(b). 2 

(40 CFR 60.5185(b)) 

Page 63 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTJ-B2103-2014a 

3. The permittee shall have the option of demonstrating continuous compliance with the emission limits and 

standards for particulate matter, hydrogen chloride, carbon monoxide, dioxins/furans (total mass or toxic 

equivalency basis), mercury, nitrogen oxides, sulfur dioxide, cadmium and lead using a performance test. If the 

permittee elects to choose the option of performance testing to demonstrate continuous compliance with the 

emission limits for the pollutants previously listed, performance tests shall be conducted on an annual basis for 

each pollutant (between 11 and 13 calendar months following the previous performance test), except as 

provide in 40 GFR 60.5205(a)(3) and (e). The performance tests shall be conducted using the test methods, 

averaging methods and minimum sampling volumes or durations specified in Table 3 of 40 GFR Part 60, 

Subpart MMMM, and according to the testing, monitoring and calibration requirements specified In 40 GFR 

60.5220(a). Stack testing procedures and the location of stack testing ports shall be in accordance with the 

applicable federal Reference Methods, 40 CFR Part 60 Appendix A. Not less than 30 days prior to the 

anticipated test date, a complete stack testing plan shall be submitted to the AQD Technical Programs Unit and 

District Office for approval. The AQD must approve the final plan prior to testing.' (40 CFR 60.5205(a)) 

4. In lieu of conducting the performance tests specified In Special Condition V.3, the permittee may elect to 

demonstrate continuous compliance with the emission limits for particulate matter, hydrogen chloride, carbon 

monoxide, dioxins/furans, mercury, nitrogen oxides, sulfur dioxide, cadmium and lead by substituting the use of 

a continuous emissions monitoring system (GEMS) for any or all of these pollutants in accordance with the 

requirements of 40 GFR 60.5205(b). A continuous automated sampling system can be used tn lieu of 

performance tests to demonstrate continuous compliance with the mercury or dioxinlfurans emission limits. 

Should the permittee discontinue use of the GEMS to demonstrate continuous compliance with an emission 

limit for an incinerator, then a performance test, as specified in SC V.3, shall be performed before discontinuing 

use of the GEMS.2 (40 CFR 60.5205(b)) 

5. As specified in 40 GFR 60.5190, the permittee shall establish the following parameters from the performance 

tests specified In SG V.1 and V.3: 

a. A minimum combustion chamber operating temperature (or minimum afterburner temperature) for each 

Incinerator. 

b. A minimum pressure drop across each wet scrubber In each scrubber train. 

c. A minimum scrubber liquid flow rate (measured at the inlet to each wet scrubber in each scrubber train). 

d. A minimum scrubber liquid pH for each wet scrubber In each scrubber train 

Each established parameter shall be equal to the lowest 4-hour avera.ge of the parameter measured during the 

most recent performance test demonstrating compliance with all applicable emission limits. The permittee shall 

keep records on file at the facility for a period of five years.' (40 CFR 60.5190) 

6. The use of a bypass stack during a performance test invalidates the results of the performance test.2 (40 CFR 

60.5220(d)) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall monitor and record the sewage sludge feed rate to the incinerators In FG4M-INCIN on a 

continuous basis, and calculate the dally average sewage sludge feed to each Incinerator in FG4M-INGIN for 

all hours of operation during each 24-hour period. The permittee shall keep all records on file at the facility and 

make them available to the Department upon request.' (40 CFR 60.5170(!)(1)) 

Page 64 of 106 
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Detroit Wastewater Treatment Plant 

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PT/ No.: MI-PTI-B2103-2014a 

2. The permittee shall monitor and record the moisture content (as a weight percent) of the sewage sludge by 

taking a grab sample of the sewage sludge, on a daily basts, for the purpose of recording the range of moisture 

content. If the permittee takes more than one grab sample in a day, then the dally average moisture content for 

the number of grab samples taken shall be calculated. The permittee shall }<eep all records an file at the facility 

and make them available to the Department upon request' (40 CFR 60.5170(1)(2)) 

3. The permittee shall monitor and record the combustion chamber temperature for each Incinerator in 

FG4M-INC/N on a continuous basis. Measurements of the combustion chamber temperature shall be recorded 

every 15 minutes. The permittee shall keep all records on file at the facility and make them available to the 

Department upon request.' (40 CFR 60.5170(a)) 

4. The permittee shall develop and submit to the AQD District Supervisor a site-specific monitoring plan for each 

continuous monitoring system required by 40 CFR Part 60 Subpart MMMM.' (40 CFR 60.5200) 

5. The permittee shall monitor and record, on a continuous basis, the pressure drop across the inlet and outlet of 

each scrubber In each scrubber train serving any incinerator in operation. Measurements of the pressure drop 

shall be recorded every 15 minutes. The fermittee shall keep all records on file at the facility and make them 

available to the Department upon request. (40 CFR 60.5170(b)) 

6. The permittee shall monitor and record, on a continuous basis, the liquid flow rate through each scrubber in the 

scrubber train serving any incinerator in operation. Measurements of the scrubber liquid flow rate for each 

scrubber in the scrubber train shall be recorded every 15 minutes. The permittee shall keep all 

records on file at the facility and make them available to the Department upon request' (40 CFR 60.5170(b), 

40 CFR 60.5230) 

7. The permittee shall monitor and record, on a continuous basis, the scrubber liquid pH for each scrubber in the 

scrubber train serving any incinerator in operation. Measurements of the scrubber liquid pH for each scrubber 

in the scrubber train shall be recorded every 15 minutes. The permittee shall kee~ all records on file at the 

facility and make them available to the Department upon request.' (40 CFR 60.5170(b), 

40 CFR 60.5230) 

B. The permittee shall keep records of any notifications to the AQD District Supervisor required by SC V/1.1 and 

V/1.2. The permittee shall keep all records on file at the facility and make them available to the Department 

upon request.2 (40 CFR 60.5230(g)(1)) 

9. For each pollutant and Incinerator for which the permittee has chosen the compliance demonstration option 

specified In SC V.2 or V.4, the permittee shall continuously monitor and record, in a satisfactory manner, the 

pollutant emissions from the incinerator. The permittee shall operate each Continuous Emission Monitoring 

System (CEMS) to meet the timelines, requirements and reporting detailed in Appendix A and shall use the 

CEMS data to demonstrate compliance with the applicable emission limit in SC /.1-10.2 (40 CFR 60.13, 

40 CFR 60,5165,40 CFR 60.51B5(c), 40 CFR 60,5220(b)(3)) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3){c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

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Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

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4. The permittee shall notify the AQD District Supervisor, in writing, one month before starting use of a continuous 

emissions monitoring system to demonstrate continuous compliance with an emission limit in 

SC 1.1-102 (40 CFR 60.5220(b)(1)) 

5. The permittee shall notify the AQD District Supervisor, in writing, one month before stopping use of a 

continuous emissions monitoring system to demonstrate compliance with an emission limit in SC 1.1-10.2 

(40 CFR 60.5220(b)(1)) 

See Appendix 8 

Vlll. STACKNENT RESTRICTION($) 

NA 

IX. OTHER REQUIREMENT/$) 

1. The requirements of this flexible group become effective on March 21, 2016. Before that date, they are not 

applicable requirements.2 (40 CFR Part 60, Subparts A and MMMM) 

2. The permittee shall implement and comply with the Operator Training and Qualification provisions as specified 

in 40 CFR 60.5130 through 60.5160.2 (40 CFR 60.5130, 40 CFR 60.5135, 40 CFR 60.5140, 40 CFR 60.5145, 

40 CFR 60.5150, 40 CFR 60.5155, 40 CFR 60.5160) 

3. For each air pollution control device In FG4M-INCIN, the permittee shall conduct an air pollution control device 

inspection according to 40 CFR 60.5220(c) by March 21,2016. For air pollution devices Installed after the final 

compliance date, the permittee must conduct the air pollution control device inspection within 60 days after 

installation of the control device. The Inspection shall include, at a minimum, all of the followlng2

: 

a. Inspect air pollution control device(s) for proper operation; 

b. Generally observe that the equipment Is maintained in good operating condition; 

c. Develop a site-specific monitoring plan according to the requirements of 40 CFR 60.5200. 

(40 CFR 60.5195(a), 40 CFR 60.5220(c)) 

4. The permittee shall comply with all applicable provisions of the Standards of Performance for New Stationary 

Sources for Existing Sewage Sludge Incineration Units, as specified in 40 CFR Part 60, Subparts A and 

MMMM.2 (40 CFR Part 60, Subparts A and MMMM) 

5. The emission limits and standards of 40 CFR Part 60, Subparts A and MMMM, apply to each emission unit In 

FG4M-INCIN at all times the emission unit Is operating and during periods of malfunction. The emission limits 

and standards apply to emissions from a bypass stack or vent while sewage sludge is in the combustion 

chamber (i.e. until the sewage sludge feed to the combustor has been cut off for a period of time not less than 

the sewage sludge Incineration residence time).2 (40 CFR 60.5165) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1 )(b). 

2 This condition Is federally enforceable and was established pursuant to Rule 201 (1 )(a). 

Page 66 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

FGDryerTrains 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers all four dryer trains in the biosolids drying facility. 

Emission Unit: EUDryerTralnA, EUDryerTrainB, EUDryerTrainC, EUDryerTrainD 

POLLUTION CONTROL EQUIPMENT 

Each dryer train has its own emission controls: 

Three-stage impingement scrubber 

Regenerative thermal oxidizer (RTO) 

Each recycle bin has its own emission control device: 

Fabric filter collector 

I. !;MISSION LIMITIS) 

Time Period/ 

Pollutant Limit Operating 

Scenario 

1. PM 0.005 gr/dscf2 Test protocol' 

~- PM10 0.005 gr/dscf Test protocol' 

3. PM2.5 0.005 grldscf Test protocol' 

. NOx 3.95 lb/hr2 Test protocol' 

5, co 3.67 lblhr2 Test protocol' 

6. PM 1.22 lb/hr2 Test protocol' 

17. PM10 1.63 lblhr' Test protocol* 

~· PM2.5 1.14 lb/hr2 Test protocol' 

[9. so, 0.82 iblhr' Test protocol' 

10. voc 1.68 lb/hr2 Test protocol' 

11. Lead 2.5 x 1 o"" lb/hr2 Test protocol* 

12. H,S 0.38 lb/hr1 Test protocol' 

Test protocol shall specify averaQinalime. 

II. MATERIAL LIMIT(S) 

NA 

Ill. PROCESS/OPERATIONAL RESTRICTIONISl 

Testing I 

Equipment Monitoring 

Method 

Each recycle bin in GC 13, 

FGDryerTralns Vl.3-4 

Each recycle bin In GC 13, 

FGDrverTrains V1.3-4 

Each recycle bin in GC 13, 

FGDr}ierTrains Vl.3-4 

Each dryer train in SC V.1-V.2 FGDr)'erTrains 

Each dryer train in SC V.1-V.2, 

FGDryerTrains Vl.2 

Each dryer train in SC V.1-V.2, 

FGDryerTrains V1.2 

Each dryer train In SC V.1-V.2, 

FGDryerTrains V1.2 

Each dryer train In SC V.1-V.2, 

FGDryerTrains Vl.2 

Each dryer train in SCV.1 FGDryerTrains 

Each dryer train in SC V.1, Vl.2 FGDrverTrains 

Each dryer train in SC V.1 FGDrverTralns 

Each dryer train in SC V.1, Vl.2 FGDrverTrains 

Underlying 

Applicable 

Requirements 

R 336.1331 

40 CFR 52.21(c) & (d) 

40 CFR 52.21(c) & (d) 

40 CFR 52.21(c) & (d) 

40 CFR 52.21(d) 

R 336.1331(c) 

40 CFR 52.21(c) & (d) 

40 CFR 52.21 (c) & (d) 

R 336.1407(a) 

R 336.1702(a) 

40 CFR 52.21 (d) 

R 336.1224 

1. The total operating time for all dryer trains in FGDryerTralns shall not exceed 31,536 hours per 12-month rolling 

time period as determined at the end or each calendar month. For this condition, a dryer train shall be 

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PTI No.: MI-PTI-B2103-2014a 

considered to be operating whenever the dryer is processing sludge cake.' (R 336.1205(1), R 336.1225(2), 

R 336.2801 (ee), 40 CFR 52.21(b)(3)(i), 40 CFR 52.21 (c) & (d)) 

IV. DESIGN/EQUIPMENT PARAMETER($) 

1. The permittee shall not operate any dryer train in FGDryerTrains unless the associated impingement tray 

scrubber and regenerative thermal oxidizer (RTO) are installed, maintained, and operated in a satisfactory 

manner.' (R 336.1224, R 336.1702(a), R 336.1910) 

2. The permittee shall not transfer material to any recycle bin in FGDryerTralns unless the associated fabric filter 

collector is Installed, maintained, and operated in a satisfactory manner.' (R 336.1910) 

3. The permittee shall install, calibrate, maintain and operate in a salisfactory manner, devices for each drying 

train in FGDryerTrains to monitor and record the parameters listed below, on a continuous basis, during 

operation of the dryer !rain. 2 

a. Temperature In the RTO combustion chamber 

b. Liquid flow rate to the impingement tray scrubber 

c. Pressure drop across the impingement tray scrubber 

d. Pressure drop across the recycle bin fabric filter collector 

(R 336.1224, R 336.1702(a), R 336.1910) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. For each dryer train in FGDryerTrains, within 180 days after commencement of trial operation of the dryer train, 

the permittee shall verify NOx, CO, PM, PM1 0, PM2.5, so,, VOC, lead, and H2S emission rates from the dryer 

train by testing at owner's expense, In accordance with Department requirements. No less than 

30 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The AQD must approve the final plan prior to testing. Verification of emission rates 

Includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and District 

Office within 60 days following the last date of the test.' (R 336.1224, R 336.1331(c), R 336.1407(a), 

R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, R 336.2801(ee), 40 CFR 52.21(b)(3)(1), 40 CFR 52.21(c) 

& (d)) 

2. The permittee shall periodically verify NOx, CO, PM, PM10, and PM2.5, emission rates from all dryer trains in 

FGDryerTrains by testing at owner's expense, In accordance with Department requirements. No less than 30 

days prior to each test, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The AQD must approve each final plan prior to testing. Verification of emission rates 

Includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and District 

Office within 60 days following the last date of the test. Periodic verification of emission rates shall comply with 

the following': 

a. The permittee shall conduct the first tests required by this condition no later than 30 months after 

commencement of trial operation of the first dryer train In FGDryerTralns, 

b. Every two years, the permittee shall conduct testing for two dryer trains. The test plan submitted for 

approval for each test shall identify the dryer trains to be tested. 

c. The permittee shall rotate the dryer trains tested so that each dryer train is tested at least once every six 

years. If extenuating circumstances preclude meeting this requirement for a particular test, the submitted 

test plan shall describe the extenuating circumstances and request that this requirement be waived for that 

test. 

(R 336.1331(c), R 336.2001, R 336.2003, R 336.2004) 

See Appendix 5 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(il)) 

1. The permittee shall keep, in a satisfactory manner, a log of the monthly and 12-month rolling time period hours 

of operation for the dryer trains in FGDryerTrains. The permittee shall keep all records on file at the facility and 

Page 68 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

make them available to the Department upon request.' (R 336.1205(1}. R 336.2801(ee), 40 CFR 52.21(b)(3)(i), 

40 CFR 52.21 (c) & (d)) 

2. The permittee shall monitor and record, In a satisfactory manner, the parameters listed below for each drying 

train in FGDryerTrains on the specified basis. The permittee shall keep all records on file at the facility and 

make them available to the Department upon request.' 

a. Temperature in the RTO combustion chamber, whenever a dryer train Is exhausting to the RTO, on a 

continuous basis 

b. Liquid flow rate to the Impingement tray scrubber, once each day that the dryer train operates 

c. Pressure drop across the Impingement tray scrubber, once each day that the dryer train operates 

R 336.1224, R 336.1702(a), R 336.1910) 

3. The permittee shall monitor and record, in a satisfactory manner, the pressure drop across each recycle bin 

fabric filter collector on a weekly basis, during operation of the associated dryer train. The permittee shall keep 

all records on file at the facility and make them available to the Department upon request.' (R 336.191 0) 

4. The permittee shall conduct a daily visible emissions check of each recycle bin's stack during routine operating 

conditions. For this condition, such checks do not have to be in accordance with Method 9. If a check reveals 

any visible emissions from a stack other than uncombined water vapor, the permittee shall inspect the fabric 

filter collector associated with the stack and perform any maintenance required to eliminate visible emissions. 

The permittee shall keep records of the results of the daily visible emissions check and of any maintenance 

performed after visible emissions are observed. The permittee shall keep these records on file and make them 

available to the AQD upon request.' (R 336.1910) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ll)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(l)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

4. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify the 

AQD District Supervisor, in writing, of the completion of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification Is considered to occur not later than commencement of trial operation 

of any dryer train In FGDryerTrains.' (R 336.1201(7)(a)) 

See Appendix 8 

VIII. STACK/VENT RESTR!CT!ON(Sl 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID 

Page 69 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Maximum Exhaust 

Stack & Vent ID Diameter/Dimensions 

4. SVDryerTrainD 

5. SVRecycleBinA 

6. SVRecycleBinB 

7. SVRecvcleBinC 

8. SVRecycleBinD 

IX. OTHER REQUIREMENT(S) 

NA 

Footnotes: 

(inches) 

30' 

8' 

8 

8' 

8' 

Minimum Height 

Above ~;)ound (feet 

130' 

130' 

130' 

130' 

130' 

ROP No: MI,ROP,B2103,2014a 

Expiration Date: January 31, 2019 

PTI No· .. Ml " " PTI 82103 " 2014a 

Underlying Applicable 

Requirements 

R 336.1225, 40 CFR 52.21(c) & (d) 

40 CFR 52.21 c) & d 

40 CFR 52.21 c) & d 

40 CFR 52.21 c) & d 

40 CFR 52.21 c) & d 

1 This condition is state only enforceable and was established pursuant to Rule 201 (i)(b). 

2 This condition Is federally enforceable and was established pursuant to Rule 201 (1)(a). 

Page 70 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

FGDryerFacility 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers the entire biosolids drying facility. In addition to the dryer trains, the storage silos, and the 

biosollds drying facility roadways, it includes the following equipment inside the building to prepare feed to the dryer 

trains: eight sludge grinders (two for each dryer train), eight electrically-powered dewatering centrifuges (two for 

each dryer train), a cake bin and enclosed pug mill for each dryer train, and conveyors to transfer materials. The 

facility also has a hot water heater, an air handling unit, and make-up air units for the building, all natural gas-fired. 

All process area building ventilation exhaust is routed through four alkaline hypochlorite scrubbers. 

Emission Unit: EUDryerTrainA, EUDryerTrainB, EUDryerTrainC, EUDryerTralnD, EUSolldsSilo1, EUSolidsSilo2, 

EUSolidsSilo3, EUSolldsSIIo4, EUWaterHeater, EUAirHandling, EUMakeUpAir 

POLLUTION CONTROL EQUIPMENT 

All building ventilation exhaust Is routed through four alkaline hypochlorite scrubbers. 

I. EMISSION LIMIT(S) 

Time Period/ Testing I Underlying 

Pollutant Limit Operating Equipment Monitoring Applicable 

Scenario Method Requirements 

12-month rolling 

71.5 tpl 

time period as R 336.1205(1), 1. NOx determined at the FGDryerFacility SCVI.2 R 336.2801(ee) end of each 

calendar month 

12-month rolling 

e. co 65.7 tpy" 

time period as R 336.1205(1), determined at the FGDryerFacility SC Vl.2 R 336.2801(ee) end of each 

calendar month 

12-month rolling 

20.0 tpy" 

time period as R 336.1205(1), 3. PM determined at the FGDryerFacillty SCVI.2 R 336.2801 ( ee) end of each 

calendar month 

12-month rolling 

26.9 tpy" 

time period as R 336.1205(1), . PM10 determined at the FGDryerFacility SC Vi.2 R 336.2801(ee) end of each 

calendar month 

12-month rolling 

~- PM2.5 19.2 tpy" 

time period as R 336.1205(1), 

detenmined at the FGDryerFacility SC Vl.2 R 336.2801(ee), 

end of each 40 CFR 52.21(b){3){i) 

calendar month 

12-month rolling 

~- co,e 90,361 tpy" 

time period as R 336.1205{1), determined at the FGDryerFacility SC Vl.2 40 CFR 52.21 {b){3){1) end of each 

calendar month 

Visible emissions from all truck traffic at the biosolids drying facility shall not exceed five {5) percent 

opacity. Compliance shall be demonstrated using Test Method 9D as defined In Section 324.55250) of Part 55, Air 

Page 71 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 

451). 2 {R 336.1301) 

II. MATERIAL LIMIT(S) 

NA 

Ill. PROCESS/OPERATIONAL RESTRICTION($) 

1. The permittee shall keep each pug mill's C?Ver closed when the pug mill is in operation, except as necessary 

for operation, inspection, and maintenance.' {R 336.1910) 

2. The permittee shall not feed biosollds to any dryer train in FGDryerFacillty unless a malfunction abatement plan 

(MAP) as described in Rule 911(2), for all FGDryerFacility operations has been submitted, and Is Implemented 

and maintained. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. 

The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon request from the 

AQD District Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD 

District Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of 

submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is approved, the 

permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. 2 (R 336.1911) 

3. Whenever trucks are loaded with material from the silos in FGDryerFacility, the permittee shall apply nonvolatile oil to the material being transferred, to minimize the generation of fugitive dust.' (R 336.1371, 

R 336.1372, Act 451 324.5524) 

4. The permittee shall only transfer material to silos In FGDryerFacillty through enclosed conveyors. 2 

(R 336.1910) 

5. The total natural gas-burning time for all equipment In EUMakeUpAir shall not exceed 16,000 hours 

per 12-month rolling time period as determined at the end of each calendar month. For this condition, "natural 

gas burning time" means time when natural gas burners are consuming fuel. 2 (R 336.1205(1), 

40 CFR 52.21(c) & (d)) 

IV. DESIGN/EQUIPMENT PARAMETER(S) 

1. The permittee shall pave all roadways at FGDryerFacility and maintain them In good condition, to minimize the 

generation of fugitive dust.' (R 336.1205{1), R 336.1371, R 336.1372, R 336.2801(ee)) 

2. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, devices to monitor and 

record the parameters specified below for equipment in FGDryerFacility2

: 

a. The pH of the scrubber liquid In each alkaline hypochlorite scrubber. 

b. The oxidation-reduction potential (ORP) of the scrubber liquid in each alkaline hypochlorite scrubber. 

c. All other parameters identified in the approved malfunction abatement plan for FGDryerFacility, at the 

frequency identified in the plan 

(R336.1910, R 336.1911) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ll)) 

NA 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

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Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by 

the last day of the calendar month, for the previous calendar month, unless otherwise specified In any 

monitoring/recordkeeping special condition.2 (R 336.1205(1)) 

2. The permittee shall calculate the emission rates of the pollutants listed below from FGDryerFaclllty monthly, 

both for the calendar month and for the 12-month rolling time period ending that month, using a method 

acceptable to the AQD District Supervisor. The permittee shall keep all records on file at the facility and make 

them available to the Department upon request.' 

a: NOx 

b. co 

c. PM 

d. PM10 

e. PM2.5 

f. co,e 

(R 336.1205(1), R 336.2801(ee), 40 CFR 52.21(b){3)(i)) 

3. The permittee shall monitor and record, In a satisfactory manner, the parameters listed below for 

FGDryerFacillty, on the specified basis. The permittee shall keep all records on file at the facility and make 

them available to the Department upon request.' 

a. The pH of the scrubber liquid In each alkaline hypochlorite scrubber, once each shift that the scrubber 

operates. 

b. The oxidation-reduction potential (ORP) of the scrubber liquid in each alkaline hypochlorite scrubber, once 

each shift that the scrubber operates. 

c. All other parameters identified in the approved malfunction abatement plan for FGDryerFacillty, on the 

basis identified in the plan. 

(R 336.1910, R 336.1911) 

4. The permittee shall keep, in a satisfactory manner, a Jog of all actions taken to comply with SC IV.1. The 

permittee shall keep all records on file at the facility and make them available to the Department upon request.' 

(R 336.1205(1), R 336,1371, R 336.1372, R 336.2801(ee)) 

5. The permittee shall keep, In a satisfactory manner, a log of the monthly and 12-month rolling time period hours 

of operation of EUMakeUpAir. The permittee shall keep all records on file at the facility and make them 

available to the Department upon request.2 (R 336.1205{1), 40 CFR 52.21(c) & {d)) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A (R 336.1213{3){c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213{3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

4. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install for FGDryerFacillty, the permittee or the authorized agent pursuant to Rule 

204, shall notify the AQD District Supervisor, In writing, of the completion of the activity. Completion of the 

installation, construction, reconstruction, relocation, or modification is considered to occur not later than 

commencement of trial operation of any dr~er in FGDryerFacility, which is considered to occur when the 

permittee first feeds sludge cake to any dryer. (R 336.1201 (7)(a)) 

5. For each incinerator listed below, no later than the date that the permittee permanently ceases operating the 

incinerator, the permittee or the authorized agent pursuant to Rule 204 shall submit a closure notification, 

Page 73 of 1 06 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

including the date of closure, to the AQD District Supervisor. For this condition, "permanently ceases operating" 

means that the unit has ceased operating and that the permittee has decided to not restart it. 2 

a. EUiNCIN01 

b. EUINCiN03 

c. EUINCIN04 

d. EUINCIN05 

e. EUINCIN06 

(40 CFR 60.5125) 

See Appendix 8 

VIII. STACK/VENT RESTRICTION(S) 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID 

IX. OTHER REQUIREMENT(Sl 

Minimum Height 

Above Ground (feet) 

Underlying Applicable 

Requirements 

1. The start-up of each dryer In FGDryerFacillty requires the permanent shutdown of one or more of EUINCIN01 

(incinerator No.1), EUINCIN03 (incinerator No.3), EUINCIN04 (incinerator No.4), EUINCIN05 (Incinerator No. 

5), and EUINCIN06 (incinerator No. 6), as listed below. For this condition, "start-up" of a dryer means the 

Introduction of blosolids into the dryer.' (R 336.1205(1), R 336.2801(ee), 40 CFR 52.21 (b)(3)(i)) 

a. No later than start-up of the first dryer in FGDryerFacllity, the permittee shall permanently cease operating 

incinerators according to the requirements listed In row (i) of the table below. 

b. No later than start-up of the second dryer in FGDryerFacility, the permittee shall permanently cease 

operating Incinerators according to the requirements listed In row (ii) of the table below. 

c. No later than start-up of the third dryer In FGDryerFacility, the permittee shall permanently cease operating 

incinerators according to the requirements listed in row (Ill) of the table below. 

d. No later than start-up of the fourth dryer in FGDryerFacility, the permittee shall permanently cease 

operating Incinerators according to the requirements listed In row (lv) of the table below. 

Number of Dryers that have Incinerators that Must Permanently Cease 

Started Operation Operating {Permanently Shut Down) 

{I Only one dryer" Any single incinerator of Nos. 1, 3, 5, and 6 

Jii Any two dryers Any two incinerators of Nos. 1, 3, 4, 5, and 6 

(Iii Any three dryers " Any three Incinerators of Nos. 1, 3, 5, and 6 

{lv) All four dry_ers All five of Incinerator Nos. 1, 3 4, 5, and 6 

! "·" If Incinerator No. 4 has permanently ceased operating when this occurs, it does not 

affect the number of other Incinerators that must permanently cease operation. 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201 (1 ){b). 2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 

Page 74 of 106 

l 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

FG2013Project 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION 

This flexible group covers all the upgraded incinerators and the biosolids drying facility. 

Emission Unit: EUINC07, EUING08, EUINC09, EUINC10, EUINC11, EUINC12, EUINC13, EUINC14, 

EUDryerTrainA, EUDryerTrainB, EUDryerTralnC, EUDryerTralnD, EUSolidsSilo1, EUSolidsSilo2, EUSolidsSIIo3, 

EUSolidsSilo4, EUWaterHeater, EUAirHandling, EUMakeUpAir 

POLLUTION CONTROL EQUIPMENT 

NA 

I. EMISSION LIMIT(S) 

Pollutant Limit 

1. NOx 735.0 tpy2 

2.CO 1,588.1 tpy2 

3. PM 66.6 tpy' 

~· PM10 86.5 tpy2 

5. PM2.5 77.5ipy' 

p. co,e 327,636 tpy' 

II. MATERIAL LIMIT(S) 

NA 

Time Period/ 

Operating 

Scenario 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

Ill. PROCESS/OPERATIONAL RESTRICTION(S) 

Equipment 

FG2013Project 

FG2013Project 

FG2013Project 

FG2013Project 

FG2013Project 

FG20.13Project 

Page 75 of 1 06 

Testing I Underlying 

Monitoring Applicable 

Method Requirements 

R 336.1205(1), SCVI.1 R 336.2801(ee) 

R 336.1205(1), SC Vl.1 R 336.2801(ee) 

R 336.1205(1), SCVI.1 R 336.2801(ee) 

R 336.1205(1), SCVI.1 R 336.2801(ee) 

R 336.1205(1), 

SC Vl.1 R 336.2801(ee), 

40 CFR 52.21(b)(3)(i) 

R 336.1205(1), SC Vl.1 40 CFR 52.21 (b )(3)(1) 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(Sl 

NA 

V. TESTING/SAMPLING 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Records shall be maintained on file for a period offive years. (R 336.1213(3)(b)(ll)) 

NA 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall calculate the emission rates of the pollutants listed below from FG2013Project monthly, 

both for the calendar month and for the 12-month rolling time period ending that month, using a method 

acceptable to the AQD District Supervisor. The permittee shall keep all records on file at the facility and make 

them available to the Department upon request.' (R 336.1205(1), R 336.2801(ee), 40 CFR 52.21(b)(3)(i)) 

a. NOx 

b. co 

c. PM 

d. PM10 

e. PM2.5 

f. co,e 

2. The permittee shall conduct an ambient air monitoring program for N02 in a manner and with instrumentation 

approved by the AQD Air Monitoring Unit. Monitoring shall consist of at least two air monitoring locations and 

shall begin no later than the earlier of the dates listed below. The permittee shall conduct monitoring in 

accordance with the plan for three years or until one year of acceptable data collection shows that the ambient 

air concentrations of N02 are no higher than 50% of the applicable 1-hour and annual N02 National Ambient Air 

Quality standards, whichever comes first. "Acceptable data collection" means fully quality assured and no Jess 

than 75% complete.' 

a. By startup of the last dryer train in FG2013Project. 

b. March 21,2016 

(40 CFR 52.21(d)) 

See Appendices 3 and 4 

VII. REPORTING 

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(il)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 .to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

4. No later than 90 days after Issuance of this permit, the permittee shall submit to the AQD Air Monitoring Unit an 

acceptable plan for the ambient air monitoring program for NO, required by sc Vl.2.2 (40 CFR 52.21(d)) 

5. The permittee shall submit all ambient air monitoring data records to the AQD Air Monitoring Unit in an 

acceptable format within 30 days following the end of the month in which the data were collected. 2 

(40 CFR 52.21(d)) 

Page 76 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

See Appendix 8 

VIII. STACKNENT RESTRICTION(S) 

NA 

IX. OTHER REQUIREMENT(S) 

NA 

Footnotes: 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

1 This condition Is state only enforceable and was established pursuant to Rule 201 (1 )(b). 2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 

Page 77 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

E. NON-APPLICABLE REQUIREMENTS 

At the time of the ROP Issuance, the AQD has determined that no non-applicable requirements have been 

identified for incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to 

Rule 213(6)(a)(ii). 

Page 78 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

APPENDICES 

Appendix 1: Abbreviations and Acronyms 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

The following is an alphabetical listing of abbreviations/acronyms that may be used In this permit. 

AHSPO Assistant Head Sewage Plant Operator MW Megawatts 

AQD Air Quality Division NA Not Applicable 

Acfm Actual cublc feel per minute NAAQS National Ambient Air Qua lily Standards 

BACT Best Available Control Technology NESHAP National Emission Standard for Hazardous Air 

Pollutants 

BTU British Thermal Unit NHMC Non-methane Hydrocarbons 

·c Degrees Celsius NMOC Non-methane Organic Compounds 

CAA Federal Clean Air Act NOx Oxides of Nitrogen 

CAM Compliance Assurance Monitoring NSPS New Source Performance Standards 

CEM Continuous Emission Monitoring NSR New Source Review 

CFR Code of Federal Regulations PM Particulate Matter 

co Carbon Monoxide PM-10 Particulate Matter less than 10 microns In diameter 

COM Continuous Opacity Monitoring POTW Publlcally Owned Treatment Works 

department Michigan Department of Environmental Quality pph Pound per hour 

dscf Dry standard cubic foot ppm Parts per million 

dscm Dry standard cubic meter ppmv Parts per million by volume 

EPA United States Environmental Protection Agency ppmw Parts per million by weight 

EU Emission Unit PS Performance Specification 

OF Degrees Fahrenheit PSD Prevention of Significant Deterioration 

FG Flexible Group psi a Pounds par square inch absolute 

GACS Gallon of Applied Coaling Solids psig Pounds per square inch gauge 

gr Grains PeTE Permanent Total Enclosure 

HAP Hazardous Air Pollutant PTI Permit to Install 

HC Hydrocarbon RACT Reasonable Available Control Technology 

HCFC Hydrochlorof/uorocarbon RMP Risk Management Plan 

Hg Mercury ROP Renewable Operating Permit 

hr Hour sc Special Condlllon 

HP Horsepower scf Standard cubic feet 

H,S Hydrogen Sulfide sec Seconds 

HVLP High Volume Low Pressure "' SCR Selective Catalytic Reduction 

ID Identification (Number) so, Sulfur Dioxide 

IRSL Initial Risk Screening Level SPA Sewage Plant Attendant 

ITSL Initial Threshold Screening Level SPO Sewage Plant Operator 

LAER Lowest Achievable Emission Rate SRN State Registration Number 

lb Pound Sr. SPO Senior Sewage Plant Operator 

m Meter TAC Toxic Air Contaminant 

MACT Maximum Achievable Control Technology Temp Temperature 

MAERS Michigan Air Emissions Reporting System THC Total Hydrocarbons 

MAP Malfunction Abatement Plan lpy Tons per year 

MDEQ Michigan Department of Environmental Quality ~g Microgram 

mg Milligram VE VIsible Emissions 

mm Millimeter voc Volatile Organic Compounds 

MM Million wtph Wet Tons per Hour 

MSDS Material Safety Data Sheet WWTP Waste Water Treatment Plant 

MVAC Motor vehicle air conditioner yr Year 

'For HVLP applicators, the pressure measured at the gun air cap shall not exceed 10 pounds per square Inch gauge (psig). 

Page 79 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Appendix 2. Schedule of Compliance 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: Mi-PTI-B2103-2014a 

The permittee certified in the ROP application that this stationary source is in compliance with all applicable 

requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of 

Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii)) 

Appendix 3. Monitoring Requirements 

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements 

identified and referenced in fiexible groups FGCOMPLEX1, FGCOMPLEX2, and FGLIMESTORAGE. 

3.1 BAGHOUSE INSPECTIONS 

1. Inspections shall be conducted during scheduled outages or downtimes, and Immediately after obseiVing 

visible emissions or pressure drops outside the normal range, but not less frequently than every six months. 

(R336.1213(3)} 

2. The operational condition, and if necessary, reasons for failure or malfunction of the bags, metal housings, 

fans, blowers, hopper bottom discharge valve, reverse air dampers or pulse jets, access doors and gaskets 

(whichever is applicable) shall be determined during the inspection. (R336.1213(3)) 

3. Any repairs and corrective actions needed to address the causes of malfunction or falllrre shall be performed 

promptly to maintain compliance. (R336.1213(3)) 

4. Permittee shall perform weekly maintenance inspections of the baghouses which shall include visual inspection 

of the fabric filter bags for security of attachment, holes or tears in the fabric filter bags for security of 

attachment, holes or tears in the fabric and evidence of dust leakage. R336.1213(3)) 

3.2 SCRUBBER INSPECTIONS 

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements 

identified and referenced In FGCOMPLEX2. 

1. Inspections shall be conducted during scheduled outages or downtimes, and immediately after observing 

visible emissions or differential pressures outside the normal range, but not less frequently than every six 

months. (R336.1910) 

2. The operational condition, and If necessary, reasons for failure or malfunction of the pumps, spray nozzles, 

venturi throats, plates, baffles, packing, orifices, tangential openings, mechanically driven rotors, entrainment 

separators (mist eliminators), fans, blowers, (whichever is applicable), shall be determined during the 

inspection. (R336.191 0) 

3. Any repairs and corrective actions needed to address the causes of malfunction or failure shall be performed 

promptly to maintain compliance. (R336.191 0) 

3.3.A. POLLUTANT MONITORING FOR 40 SUBPART 60 SUBPART MMMM, Continuous Emission 

Monitoring System (CEMS) Requirements 

1. Within 30 calendar days of submitting the written notification required by FG4M-INCIN SC VJL 1, the permittee 

shall submit two copies of a Monitoring Plan to the AQD, for review and approval. The Monitoring Plan shall 

include drawings or specifications showing proposed locations and descriptions of the required CEMS. 

2. Within 150 calendar days of submitting the written notification required by FG4M-INCIN SC Vll.1, the 

permittee shall submit two copies of a complete test plan for the CEMS to the AQD for approval. 

Page 80 of 1 06 

I I 
Detroit Department of Water & Sewerage ROP No: MI-ROP-82103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

3. Within 180 calendar days of submitting the written notification required by FG4M-INGIN SG Vll.1, the 

permittee shall complete the installation and testing of the GEMS. 

4. 

• 

5. 

6. 

7. 

8. 

Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final report 

demonstrating the GEMS complies with the requirements of the corresponding Performance Specifications 

(PS) In the following table. 

Pollutants with a Applicable 

Promulgated PS PS 

PM 11 

HCI 13 

co 4 

Mercury 12A or 128 

Nitrogen oxides 2 

so, 2 

Oxygen 3 

Pollutants without Applicable 

a promulgated PS PS 

Cadmium NA* 

Lead NA* 

Dioxins/furans NA* 

Upon promulgation of a PS for this pollutant, the promulgated PS becomes an "applicable PS" for this 

appendix. 

The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

Each GEMS shall be installed, calibrated, maintained, and operated in accordance with the procedures set 

forth in 40 CFR 60.13 and the above-listed PS of Appendix 8 to 40 CFR Part 60. 

Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the GEMS set forth 

In Appendix F of 40 CFR Part 60. Within 30 days following the end of each calendar quarter, the permittee 

shall submit the results to the AQD in the format of the data assessment report (Figure 1, Appendix F). 

In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report In an acceptable format to the AQD, within 30 days following the end of 

each calendar quarter. The Summary Report shall ~allow the format of Figure 1 in 40 CFR 60.7(d). The EER 

shall include the following Information: 

a) A report of each exceedance above the limits specified in the conditions of this permit. This includes the 

date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b) A report of all periods of GEMS downtime and corrective action. 

c) A report of the total operating time of the incinerator served by the GEMS during the reporting period. 

d) A report of any periods that the GEMS exceeds the instrument range. 

e) If no exceedances or GEMS downtime occurred during the reporting period, the permittee shall report 

that fact. 

The permittee shall keep all monitoring data on file for a period of at least five years and make them available to the 

AQD upon request. 

3.3.8. OXYGEN MONITORING FOR FGAQCI, Continuous Emission Monitoring System (GEMS) 

Requirements 

Page81 of106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

1, The span value shall be 2.0 times the lowest emission standard or as specified In the federal regulations. 

2. The CEMS shall be Installed, calibrated, maintained, and operated in accordance with the procedures set 

forth in 40 CFR 60.13 and PS 3 of Appendix B to 40 CFR Part 60. 

3. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the CEMS set forth 

in Appendix F of 40 CFR Part 60. Within 30 days following the end of each calendar quarter, the permittee 

shall submit the results to the AQD in the format of the data assessment report (Figure 1, Appendix F). 

4. In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report in an acceptable format to the AQD, within 30 days following the end of 

each calendar quarter. The Summary Report shall follow the format of Figure 1 in 40 CFR 60. 7(d). The EER 

shall include the following information: 

a) A report of all periods of CEMS downtime and corrective action. 

b) A report of the total operating time of the incinerator during the reporting period. 

c) A report of any periods that the CEMS exceeds the instrument range. 

d) If no exceedances or CEMS downtime occurred during the reporting period, the permittee shall report 

that fact. 

The permittee shall keep all monitoring data on file for a period of at least five years and make them available to the 

AQD upon request. 

3.3.C. VISIBLE EMISSIONS MONOTIRING FOR FGAQCI, Continuous Opacity Monitoring System 

(COMS) Requirements 

1. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

2. The COMS shall be installed, calibrated, maintained, and operated In accordance with the procedures set 

forth In 40 CFR 60.13 and PS 1 of Appendix B, 40 CFR Part 60. 

3. The permittee shall perform an annual audit of the COMS using the procedures set forth in USEPA 

Publication 450/4-92-010, "Performance Audtts Procedures for Opacity Monitors'', or a procedure acceptable 

to AQD. Within 30 days after the completion of the audit, the results of the annual audit shall be submitted to 

theAQD. 

4. In accordance with 40 CFR 60. 7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report in an acceptable format to Air Quality Division, within 30 days following the 

end of each calendar quarter. The Summary Report shall follow the format of Figure 1 In 40 CFR 60.7(d). 

The EER shall Include the following information: 

a) A report of all periods of COMS downtime and corrective action. 

b) A report of the total operating time of the incinerator during the reporting period. 

c) If no exceedances or COMS downtime occurred during the reporting period, the permittee shall report 

that fact. 

The permittee shall keep all monitoring data on file tor a period of at least five years and make them available to the 

AQD upon request. 

Appendix 4. Recordkeeping 

The permittee shall use the following approved formats and procedures for the recordkeeping requirements 

referenced in the Source Wide Requirements and flexible groups FGCOMPLEX1, FGCOMPLEX2, and 

FGLIMESTORAGE. Alternative formats must be approved by the AQD District Supervisor. 

For Requirements in FGLIMESTORAGE 

BAGHOUSE INSPECTIONS 

Page 82 of 106 

II 

I 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

A. A log of the inspections, cause(s) of malfunctions or failures, repairs made and corrective actions taken 

shall be maintained on file for a period of at least five years. (R336.1213(3)) 

B. The permittee shall keep records of the preventive maintenance inspections. These records shall include 

the date and time of inspection, name of person making the inspection, Identification of the unit inspected, 

conditions of the unit and descriptions of any corrective action taken. These records shall be maintained 

for a minimum of five years and made available to the Division upon request. (R336.1213(3)) 

For Requirements in FGCOMPLEX1. FGCOMPLEX2 

SCRUBBER INSPECTIONS 

A Jog of the inspections, cause(s) of malfunctions or failures, repairs made and corrective actions taken shall 

be maintained on file (hardcopy or electronic) for a period of at least five years. (R336, 191 0) 

For Requirements under Source Wide Requirements 

Mercury and Beryllium 

1. The permittee shall retain records of emission test results and other data needed to determine total emissions 

of beryllium at the facility for a minimum of five years and made available, upon request, for inspection, by the 

Division. (40CFR 61.33(e)) 

2. The permittee shall retain records of emission test results and other data needed to determine total emissions 

of mercury at the facility for a minimum of five years and made available, upon request, for inspection, by the 

Division. (40CFR 61.53(d)(6)) 

Appendix 4.1: Recordkeeping (continued) 

The permittee shall use the following approved formats and the procedures for the recordkeeping requirements 

referenced In Source Wide Requirements. 

1. The permittee shall keep records of implementation of requirements specified in the fugitive dust control 

program described below and for all requirements of the Consent Orders, Civil Actions and Consent Judgments 

described In Table B. These records shall be kept on file at the facility for the most recent five-year period and 

shall be made available to the Division upon request. 

(R336.1213(3)), (Consent Order MDEQ SIP No. 11·1993) 

ADDENDUM 

(Act 451, Part 55 324.5524), (Consent Order MDEQ SIP No. 11-1993, Fugitive Control Plan, May, 1993) 

RECORDKEEPING FOR FUGITIVE DUST SOURCES 

REQUIRED RECORDS 

UNPAVED ROADS/LOTS 

1. DATE OF TREATMENT 

2. CONTROL MEASURE USED 

3. RESPONSIBLE PERSON'S INITIALS 

4. NAME OF PRODUCT APPLIED 

5. AMOUNT OF SOLUTION/WATER APPLIED 

6. DILUTION RATIO 

7. ROAD SEGMENT/LOT IDENTIFICATION 

PAVED ROADS/LOTS 

1. DATEOFTREATMENT 

Page 83 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

2. CONTROL MEASURE USED 

3. RESPONSIBLE PERSON'S INITIALS 

4. ROAD SEGMENT/LOT IDENTIFICATION 

STORAGE PILES/MATERIAL HANDLING 

1. DATE OF TREATMENT 

2. CONTROL MEASURE USED 

3. RESPONSIBLE PERSON'S INITIALS 

4. DILUTION RATIO {IF APPLICABLE) 

5. AMOUNT DUST SUPPRESSANT/WATER APPLIED 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

6. IDENTIFICATION OF PILE/MATERIAL HANDLING OPERATION TREATED 

7. EQUIPMENT USED 

OPTIONAL RECORDS 

WEATHER CONDITIONS 

1. PRECIPITATION 

2. TEMPERATURE 

3. WIND DIRECTION AND VELOCITY 

Appendix 5. Testing Procedures 

The following table lists the test methods that are to be used, in accordance with 40 CFR Part 60, Subpart MMMM, 

to satisfy the testing requirements for FGC1ASH, FGC2ASH, FGCOMPLEX1 and FGCOMPLEX2. 

Pollutant Test Method Minimum sampling volumes or 

durations 

Particulate matter EPA Reference Test Method 5 at 40 3-run average (collect a minimum 

CFR part 60, appendix A-3; Method volume of 0. 75 dry standard cubic 

26A or Method 29 at 40 CFR part 60, meters per run) 

appendix A-8. 

Hydrogen chloride EPA Reference Test Method 26 or 26A 3-run average {For Method 26, 

at 40 CFR part 60, appendix A-8. collect a minimum volume of 200 

liters per run. For Method 26A, 

collect a minimum volume of 1 dry 

standard cubic meters per run) 

Carbon Monoxide EPA Reference Test Method 10, 10A, 3-run average (collect sample for a 

or 10B at 40 CFR part 60, appendix A- minimum duration of one hour per 

4. run) 

Dioxins/furans (total mass basis) EPA Reference Test Method 23 at 40 3-run average (collect a minimum 

CFR part 60, appendix A-7. volume of 1 dry standard cubic 

meters per run) 

Mercury EPA Reference Test Method 29 at 40 3-run average (For Method 29 and 

CFR part 60, appendix A-8; Method ASTM D6784-02 (Reapproved 

308 at 40 CFR part 60, appendix A-8; 2008), collect a minimum volume of 

or ASTM 06784-02 (Reapproved 1 dry standard cubic meters per run. 

2008) For Method 30B, collect a minimum 

sample as specified in Method 30B 

at 40 CFR part 60, appendix A-8) 

Oxides of nitrogen EPA Reference Test Method 7 or 7E at 3-run average (Collect sample for a 

40 CFR part 60, appendix A-4 minimum duration of one hour per 

run) 

Page 84 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-62103-2014a 

Expiration Date: January 31, 2019 

PTI No· .. Ml -PTI -62103 -2014a 

Pollutant Test Method Minimum sampling volumes or 

durations 

Sulfur dioxide EPA Reference Test Method 6 or 6C at 3-run average (For Method 6, collect 

40 CFR part 40, appendix A-4; or a minimum volume of 200 liters per 

ANSI/ASME PTC 19.10-1981. run. For Method 6C, collect sample 

for a minimum duration qf one hour 

per run) 

Cadmium EPA Reference Test Method 29 at 40 3-run average (collect a minimum 

CFR part 60, appendix A-8. volume of 1 dry standard cubic 

meters per rw)) 

Lead EPA Reference Test Method 29 at 40 3-run average (collect a minimum 

CFR part 60, appendix A-8. volume of 1 dry standard cubic 

meters per run) 

Fugitive emissions from ash Visible emission test (Method 22 of Three 1-hour observation periods. 

handling appendix A-7 of this part). 

Appendix 6. Permits to Install 

The following table lists any PTis issued since the effective date of previously issued ROP No. 199600412. Those 

ROP revision applications that are being issued concurrently with this ROP renewal are identified by an asterisk(*). 

Those revision applications not listed with an asterisk were processed prior to this renewal. 

NA A component plan was 

to reflect operations at the facility; a 

emission monitoring requirement was updated to 

clarify that visible emissions observation are not 

expected to occur at night; special conditions 

addressing an incinerator operating temperature 

requirement and the scrubber pressure drop were 

i 

Conditions, 

FGCOMPLEX1, 

FGCOMPLEX2, 

FGLIMESTORAGE 

The following ROP amendments or modifications were issued after the effective date of ROP No. MI·ROP-62103-

2014. 

Page 85 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Appendix 7. Emission Calculations 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: 31, 2019 

I 

The permittee shall use the following emission factors In conjunction with monitoring, testing or recordkeeping data 

to determine compliance with the applicable requirements referenced in FGENGINES. 

Engine-Specific Emission Factors 

Emission Unit ID Emission Unit Description NOx emissions @ 1 00% 

load (lb/hr) 

EU-D1A Caterpillar 3512 diesel fired 1500 kW generator 28.98 

EU-D1B Caterpillar 3512 diesel fired 1500 kW generator 28.98 

EU-D2 Caterpillar 3508 diesel fired 1000 kW generator 29.67 

EU-D4 Caterpillar C32 diesel fired 1000 kW generator 18.83 

EU-05 Caterpillar C 15 diesel fired 400 kW generator 5.93 

EU-06 Caterpillar 1103C-33G1 diesel fired 20 kW generator 0.28 

EU-P1 Portable diesel fired 70 kW generator 0.98 

EU-P2 Portable diesel fired 70 kW generator 0.98 

EU-G1 Caterpillar G3406 NA natural gas fired 150 kW generator 5.75 

EU-G2 Caterpillar G3406 NA natural gas fired 150 kW generator 5.75 

EU-G3 Ford G30F3 natural gas fired 30 kW generator 0.78 

EU-G4 Ford G20F3 natural gas fired 20 kW generator 0.49 

EU-G5 Ford G30F3S natural gas fired 30 kW generator 0.78 

EU-G6 Ford G20F3 natural gas fired 20 kW generator 0.49 

EU-GB Ford G40F3 natural gas fired 30 kW generator 0.78 

EU-G9 Ford G20F3 natural gas fired 20 kW generator 0.49 

EU-G10 Caterpillar G3516 LE natural gas fired 1040 kW generator 6.45 

The permittee shall calculate NOx emissions for each engine by multiplying the hours of operation for each engine 

by Its respective engine-specific emission factor listed above, or as determined from testinQ, whichever is J1reater. 

Appendix 8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting Section of 

the Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Page 86 of 106 
Detroit Department of Water & Sewerage ROP No: MI-ROP-B2103-2014a 

Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

The permittee shall use the following approved formats and procedures for the reporting requirements referenced in 

Source Wide Requirements, FGCOMPLEX1, FGCOMPLEX2. Alternative formats must be approved by the AOD 

District Supervisor. 

For Source Wide Requirements 

1. Beginning with the calendar quarter starting on October 1, 1993, and quarterly thereafter, the Permittee shall 

submit to the Division a report identifying each day in which any emission limit, operational requirement, or 

recordkeeping requirement, was not met. 

(R336.1213(3)), (Consent Order MDEQ SIP No.11·1993) 

2. The report specified In Condition 1 (above) shall, for each instance, explain the reason that the emission limit, 

operational requirement, or recordkeeping requirement was not met, the duration of the event, the remedial 

action taken, and a description of the steps which were taken to prevent recurrence. 

(R336.1213(3)), (Consent Order MDEQ SIP No. 11·1993) 

3. The report specified in Condition 1 (above) shall be submitted within 30 days following the end of the calendar 

quarter in which data were collected. 

(R336.1213(3}}, (Consent Order MDEQ SIP No. 11-1993) 

Appendix 9. Preventative Maintenance Summary 

For details about the Preventative Maintenance Summary, please refer to the updated Malfunction Abatement Plan, 

which was last revised in March 2007, and which is attached in the pages that follow. 

Page 87 of 106 
Detroit Department of Water& Sewerage 

Detroit Wastewater Treatment Plant 

ROP No; MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Malfunction Abatement Plan 

The City of Detroit 

Wastewater Treatment Plant 

9300 West Jefferson Avenue 

Detroit, MI 48209 

Revision C 

March 2007 

Page 88 of 106 

1. 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Section 

Table of Contents 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Page 

Plan Description ........................................................................................................ J 

Table I -Key Monitored Process Parameters .......................................................... 4 

Tobie 2 - Mnlfunction Abatement Stunmnry ............................................................ 5 

Table 3- Preventative Maln1enance Summary ......................................................... 8 

Tnble 4- Spare Paris ldentiflcntion .......................................................................... 14 

Page 89 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

lncineration Process Malfunction Abatement Plan 

The City ofDetroitWnsfowaterTrca!ment Plan! 

This document contains the Incinemtlon Process Malfunctio11 Abatement Plan to be tJSed 

at the City ot'Dclt'oit's Wastewater Treatment Plant, 9300 West Jefferson Avenue, 

Deh·oit, Michigan 48209. The plan's p\Jrpose is to assure compliance with the emission 

limit on opacity in the event ofo malfuuction or failure of any part of the process that 

affects opncity. 

Rule 9l1 of the Stole of Michigan Air Pollution Control R11les requires theDWWTP to 

haven Malfunction Abatement Plan in place) 4'to prevent, deteol~ and correct 

lllfllfunctions or equipment £1i1ures resulting in emissions exceeding any upplicable 

emission limitation." The emission limitation !Ills plan is concerned with is the O})acity 

limitation of20 percent. The rule requires that the plan specify, at a minimum: 

n) A complete- prcve.ntutive maintemmce program, inoh1ding lden!ificRtiou of Ute supervisory 

personnel responsible for overseeing !he Inspection, maitttcnance and repair of air-cleaning 

devices, a description of the items or conditions that shall be- Juspeoted, the J}cqucucy of these 

inspeotious or repnir11, and an identification of!he mnjor replacemenl paris that shnll bo maintained 

in iuventory for quick replacement. 

b) An idenlificntlon of the sotlrce and nlr-cleaning davicc operating \'arlahles !lmt shall bo U\Oilltored 

to detect a malfimction or f."tilllre, the normal OJ>er<~ling rnnse of these variables, rntd a dcscrlptio!l 

oflhe method of monitoring or surveillance procedures. 

c) A description of lite con:ecliYe }>rocedmes or operational c:lJ!Jnges lhnt shall be taken in !he event 

of <1 ntal function or f!lilure to nchle\'e compliance with the applic!lble emission Ilmlls. 

The plrm is divided into fmu· sections in tabular fommt: 

1. Represented by Tnble 1, Key Monflored Process Fm·ameters, tills section 

relntos toR 336.1911 (2)(b) und dellneales, "the source and air-cleaning 

device operating variables that shall bo monitored to detect a mall\mclion ot' 

failure, the nomwl ope~·atingmuge ofthcso val'iables, and a description of tho 

method of monitoring or surveillance procedures. h 

Tho first cohmm of Table 1 shows the t'eferenco number which is used to link 

the ma1funolion range (condition) ofTablo 2 items and maintenance activities 

in Table 3 with one Ol' more process parameters given in Table l. Tl1e 

Operations personnel af the DWWTP have determined, through experience, 

the incineration process lHH'ameters whos0 vnrlrmce has a direct effect on the 

opacity of incineration emissions. These parameters are -shown in column 2 of 

Table 1. 

Columns 3 to 7 contain information 1'egarding the device or method used to 

monitor fl given proccs$ pal'lmleter in colunm 2} Ute location of such device, 

the fi·eq~Jency of monitoring, the nonnal range ofthe process parameter and 

the mal1\u1Ction range for a given pnt·ftmeter. 

The value of a given parf!meter Is indicative of either notmal operallon or 

Pngc 1 of 18 

Page 90 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

malftmction or failure ofthe process. Table 1 contains fields for both the 

normal operating range and the malfunction range for each monitored process 

parameter. If any of these pat·ameter's vnlues fall within the partloulnr 

pm·ameter's malfunction rnngej remedial actiott must be taken to prevent a 

deviation from the emission limitation 

2. Represented by Table 2, Ma!fimcllon Abatement SIII/11/IGI/', this section relates 

to R 336,191 I (2)(c) and is an, "identification of the somce and air-cleaning 

device operating variables that slmll be monitored to detect a malfunction or 

fnillll'c, the normal operating range of Jhese variables, and a description of the 

method of monitoring Ol' surveillance procedures." This table details the 

action(s) to be taken in the event that one or more of the monitored Process 

Parmlletel'S value(s) in Table#I enters its malftmction range. 

As nn example, assume lhe oxygen level has fallen below 4 percent. Using 

Table 1, It is determined that <4% oxygen is indicative of a malfunction. 

Oxygen Level%, in !he firsl row of'l'ahle 1, has a Process Parameter 

Reference Numbel' oful, 11 Using !his reference number al'ld Table 2) it is 

detennined that thet'e are three possible causes for this condition (low 

oxygen). The opemtor need only determine wltich of the tlu·ee is tho actual 

en use and take the actlonrecommended 1n the Remedial AcUon column 

corresponding Ia the cause, 

All opacity exceedances and the corrective action(s) taken will be recorded. 

Records of each operata!' adj11stment (o prevent an opacity excecdance need 

not be recol'dcd. 

3. Tobie 3, Prevenfative Maiulenauce Summm:}', is a summary of the 

preventative maintenance to be perfonned on devices whose failure may 

conhibute to opacity devjatlon8. The maintenance program relates to 

requirement (2)(a) ofR 336.1911. 

As an example, refer to tlte first row of Table 3. The induced draft fan affects 

process parameters associoted with Process Parameter Reference N11mbers 1-

6, 9 and t 1. These reference numbers are used to reference Table l's first 

column whloh indicntes that Oxygen Level (%), Tempm·ature, Draft Pressure. 

Feed Rntc, Hoppel' Depth, Auxiliary Combustion Ail' Damper, Manna] 

Opacity Monitm• Calibrations and Slag Buildup are all affected if tho induced 

draft fan malfunctioJlS, The fi·eqnency of PM activity applies to units that are 

operating. Records ofPM activity will be maintained. 

4, Tnblc 4, Spare Parts List, lists pf!tts that are in inventory for use in the 

maintenance of devices listed In Table 3. This table, along with Table 3, 

relates to requirement (2)(a) ofR 336.1911. For convenience, the attached 

Page 2 of l& 

Page 91 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31,2019 

PTI No.: MI-PTI-B2103-2014a 

spare parts list may detail supplier·name and Sllpplier part numbeL', Howevel', 

the De!rolt Wastewater Treatment Plant reserves the right to purchase spare 

purls fi·otn any company offudng an acceptable subslihHe. The quantity of 

parts included in tWs section is A suggested number of spares, The Detroif 

Wastewater Trenhnent Plant reserves the righl to lwve suppliers expedile 

de1ivel'y ofpat1s fi·om their factory Ol' warehouse in Heu ofstodng onsite, 

The intended function of the mulfunotlou abatement pian (MAP) is) 0 to prevent, detect, 

and con·ecl malfunclions or equipment failures n.:sulting in emissions exceeding any 

applicable emission limitation/' The emission limitation is 20% opacity, 

DefJuition of Acronyms 

PLC- Progmmmnble Logic Conlroller 

OCS- Ovation Control System 

SFE- Screened Final Effluent (process water ·used where wate1· Js needed) 

DWWTP- Detroit Wastewatet' Treatment Platlt 

J.D. FQn- Induced Draft Fan 

MAP- Malfunction Abatement Plan 

COMS- Continuous Opacity Monitoring System 

P.M.- Preventative Maintenance 

ID -l11side diameter 

OD- Outside diameter 

C 1 - Incineration Complex One 

CII- Incineration Complex Two 

IS- In~Service 

1/0- b>put/Outpul 

Pnte 3 of 18 

Page 92 of 1 06 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

>=.m- ·~ Process P.ararneter -~~ Number 

l Oxygen Level("/..) 

2 Hearth #l Te:nper.a:ture 

3 Combustion Zone 

Temper:a'l:txre 

• DT3ft Pressure 

5 Feed R:a.te 

• Totll Serobbe!:' System Inlet-. 

Outlet Diff(:rentl21 E"reSSore 

7 Scrubber Water Ilow 

8 Sludge Combustion Air 

Supply 

9 S12g:Buildup 

,. Ash :&uildu.p on .Bottom 

B:oartb 

ll Opacity 

ROP No: MI-ROP-82103-2014 

Expiration Date: January31, 2019 

PTI No.: MI-PTI-82103-2014 

Incineration Process Malfunction Abatement Plan 

The City of Detroit Wastewater Treatment Plant 

Table 1 - Key Monitored Process Parameters 

Monito-ring Device or Location ofMonitor Frequency .of Normal Operating M::alfnnction R:mge: Method MonitOring Range 

Oxygen Anal;,-ze,; Bre:ach/Heanh #3 Comi:nuous 1-12% <1% 

Thermocouple Hearth#! Continuous llOO -1500 °F. <900 .. F. 

Thermocouple Coro.bn.stion zone Cottlhmous 1200-J.9SO °F. <1200 "F. ot>l9:50 "'F. beattbs 

Ptessw:e g2uge Bteeeh/Hearth #5 Continuous 0.0 to-1.5 in..of!fzO > +0.0 inches of:S::P 

Weiglllometers Co:o:veyor beli$ Continuous ComplexJ:0-16~tonslllr.: Ccmptexi>16wett~ 

Complexl!: 0-20W>::ttonslbr Complex. U>20 wct.tonslhr 

Pxessu:re ,gal.lges Venruri section inlet Continuous >18 inches ofRzO <18 inches ofH;P 

2:1ld tray section olltlet <:olu.:mn eo-ltrr.c:rJ. 

Flow meters CoJ:rtrolRoom. Conti:tluoas. 3-4 SFE pumps in- < 3 SFE ptu:trps inservice se:rvice 

Shaft re:t:u:rn air and <Antrolltoom. Co:c.ti:c.nous 0 to 100% open Umesponsive a:r.ccili2cy air dampex:s 

Combustion zone All holes open a:od ~ ZSOA boles blocked. 

Visual hea:rtbs and center Shaft As needed cen.tet shaft c1~ Cen~ shaft: d~ 

okay notokav. 

V=al Complex I-basement As needed Empty (co buildup) Plugged drop hole Complex n-:fi:cst floor 

Opacity mo:Utor Roof Comi=ous Below20% No reading or oonstant 

low or high readings 

Table 1: Page4of1S 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

P:.:r2.mctc:r ·~ Condition Rclb'<~nc;c 

Number 

1 Low oxygen. 

1 Low oxygen 

1 Lowoxy.gen 

2 Low hearth #1 

temperature 

3 Low combustion 

t_..-atures 

3 Low com.bustion 

temperatw:es 

3 High combustion 

4 Low or high diaft 

5 No feed 

5 Too much. feed 

5 Hopper bridging 

6 Low scrubber sy:stern 

di:fferential presswe 

7 Low scro.bber w.1ter flow 

rate 

8 Low or no sludge 

combustion air supply 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

The City of Detroit Wastewater Treatment Plant 

Table 2-Malfunction Abatement Summary 

Possible C:ause(s) MeaiJs of Detection Corrective Prooedures 

Too many burnet'S I.S. PLC'OCS Reduce bUl'llCr :firill,g r.ates or number ofbumers in use 

Low di2ft pressure PLC!OCS Increase draft p:ressore setpoio.t 

Process control problems PLC'OCS Increase oxygen set p<Jint, or manually increase air dmlper 

openings 

Feed tate increase or lower PLC'OCS hla:ease upper hearth burner :tiring r.ates and! or reduce feed 

ca.~e solids rate ff necessary 

Low- bum.ernseprofiles PLC'OCS Increase D.UJ:nber ofbum.ers ill use :and! or firing tates as needed. 

Feed r.ate increase or lower PLC'OCS Increase number ofburners in use and/or firing :rates as needed. 

cake solids Or,. if necesSary,. reduce feed rate. 

Lost feed, burner use profile, PLC'OCS Restore feed or redoce number ofbume:rs ariD! or :5:ring: rates or change in cake solids 

V arlous ptocess cllanges PLC'OCS Increase or decrease d:taft pressure set point as needed 

Conveyor(s) stopped or PLC'OCS & visual Restart conveyors 2JJ.d/or clear hopper bridging.. Check screw 

b,opper bridging fuspections speed settings 

Not c::o.onghincineratoiS VlSUal Inspection Put more incinerators hl-service I decrease feed 

Cake corrtaiWJ:lg a:n excessive Visual hlspection R:u.u the hopper until it;,; empty (this eliminams the brid.,.;,g) amou.nt of polymer 

Various process changes PLC'OCS Inctease draft a:ad ventu..'i differential presst~te set points 

!ncorroct settmgs ot loss in PLC'OCS Increase flow setti:ngs and/or restore water supply pressure water supply pressure 

Oxygen COIJ.trol sysrem or air PLC'OCS Open air dampers in manual mode and visu:ally check damper 

damper problems action, open lower hearth~ holes if necessary 

Tabie2: PageS ofiS 
Detrott Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

,.~~ "'~- I Ro<~ 

N~""" 

9 

10 

11 

Any 

Condl"'tion 

Slag buildup 

A:sb buildup on bottom 

hemb. 

Opacity monitor 

malfunction 

Prev=t:ative~ 

-------L____ 

I 

ROP No: MI-ROP-821 03-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

Incineration Process Malfunction Abatement Plan 

The City ofDetroit Wastewater Treatment Plant 

Table 2-Malfunction Ab"tement Snmmary 

POS>ible Cause(•) I Meons ofl>et<otion I C<»:rrective Procedures 

High corobustion zone PLO'OCS/Vlsual De-slag affected heart.bs :mdlor center shaft secriODS If needed I temperatures 

OJ.ec.'l( ash .system.. J:fnot worlcing, stop feed, stop shaft and _I 

Ash system not re.J::IlOvi:ng .ash PLC/OCSNisu:al corrt:rol bumout, and place incinetator our:-o$-service before 

co:rective maimenance b~ __ 

Electrical or dirt;y l=ses PLCIOCS Place incineratOr om-of-service for instrument corrective 

mainterumce • 

Other components slro.t off as PLC'OCS Control bttmou:t and place iiJcinerator in stalldby =ode prior to 1 

a r=J.t ofP .M. PM ____ ~_ _ 

Table 2: Page 6 of 18 

Page 95 of 106 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: Mi-PTI-B2103-2014a 

-. 

Incineration Pl"ocess Malfunction Abatement Plan 

City ofDetroit Wastewater Treatment Plant 

Table 3-Preventative Maintenance Summary- Tasks Common to both Complex I and Complex II 

P~= P.=t.r.u•~<:ter 

R.c:fo:ren<:e M::o.>oe:.i1;0ed E:quipm<:t~t P.-.:vcne:.tive M:l.it~tCn<U'I<>e T::t$k R.<l:l'pon:s:<bfo: 

(Titte) 

s .. ~ 

Num~ 

Electrical i:ospection. Amrually EWG S'llb-Foremm. 

4,5, 6 fuduced draft fun on lubrication & sensory check Amrually Plam M.ai:ateaance SubFor= 

Oil change - bearings Amm2lly PlamMaintenance SubForeman 

1.~3 fucinerator _g3S btll"Xlelt Mechznic:al inspection ofbumers Quarterly Piam:Maiotenmcc SubPo= 

2.,3,4, 5 Main stack damper Electric:al & pneuma:O.e systeDl cheeks Quarterly OpC'lations 

4 Scrobber damper Check Q=ly Plant Maintenance SubFor= 

I. 2, 3* 5. 9, 11 C..'"D.te:r shaft system Lube and m.ecb:an:ical check Montbly Plant :M:afu.tena:Dce SnbForeman 

Oil level and mechanical inspection Quarterly Plant MaioteJ;latlce SubForeman 1,2,3,4,9, 11 Bumer·air fan Pla:nt~ee Sub- Mec:h.acieal check-drive belt Q=ly Fot= 

11 AJ1 opacity monitors Opacity monttor? M. Monthly WSCIT Sttb--Fo:reman 

Table 3: Page 7 of 18 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

City ofDetroit W astewarer Treannent Plant 

Table 3 -Preventative Maintenance Summary- Tasks Common to both Complex l and Complex IT 

Proc:c:ss-f'::lr.:>:md:CT ResponsibleS~~:~~r l;kren:nc:e M::Untlin«< Equipment l"l"~~trv~ M:lir..tcn:knce T:;~;sl-:: 

Naml>et- (TrtJc) 

Electrical inspection Anllually EWG Sub-Foreman 

Mecha:aical I:cspection Bi Plant Maintenance SubAnllually Foreman 

Oper.ator inspection - Butter.fly valve l.eahge Quacte<Iy Opex:ations- HSPO 

Gear drive- Bearing oil ch2nge, anchor bolt check Amlually Plan:tMaintemmce SubForeman 6, 7,11 SFEpmnp:s Plan.tMain:renance Sub- Bearing housi.ng i:nspectlon o:o. sti::ainern: Annually Foreman 

Electrical inspection AJmually EWG Sub--F orema::a 

Flexible couplillg L'cbe1 <>per:ation & alignment Bi Plant Maintenance SUb- ' 

check Amlually Fore=m I 

Bearing housill.g Utspection Bi Plant Maintenance Sub- AJmuaJJv Foreman 

Wc:i,ghtometerforbeit# 15-1 

I Weigbtometerforbelt# 15-2 

Weightomet:erforbelt# 15-3 

' 

Weightometer for belt# 15-4 / 

2,. 3, 5~ 9~ 11 Cali'brationf.fuspection Mon:t:hly WSCIT Sub-Fo..-eman 

Wei,ghtometerforbelt# 15-5 

w eightometer for belt # 15-.6 

W eighrometer for belt# X-9 

Wcightometer for helt # P 7 & S - -·- ----- --

T::able3: Page 8 ofl8 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

City ofDetroit Wastewater Treatment Plant 

Table 3 -Preventative Maintenance Summary-Tasks Common to both Complex I and Comple:di I 

l"t'OCCSS l":l.l":l.rnct"er &t:!:ponsib1<: Super>isor Refo:n:-nce M:ti,.b.in~ EquipM¢tlt PJ"~at:ltiVe M:Um:~::.;aa: T::.sk Freqa<:n<y {rrtl<) Numl:>t:l:' 

Weigb:tometerforbelt#P 9 & 10 

W eig.b.to~ter for belt # P 11 & 12 

Weightometerforbelt#P 13& 14 

Weigb.tometet for belt# K-1 & 2 

Weightometer for belt# Irl & 2 

I 2,3,5,9, 11 Weig:btotl:lete! for belt# Q-7 & 8 Molllhly 

Weightomcter for belt# Q-9 & I 0 

Wcigb!xlmeterforbelt# Q-11 & 12 Calibrationllnspection WSCIT Sub-Foreman 

Weighrometer fer belt# Q-13 & 14 

' 

We:ightomererforbe:It#M-1 &2 

W eigb.tometer for belt# N-1 & 2 

I:acinetator #I Oxygen ADalyzers 

Incinerator #2 Oxygen Aml yzeJ"S 

I, 11 Monthly 

Incinerator #3 0'-)'gen Analyzexs 

Incinerator #4 Oxygen Analyzers 

T:a.ble3:Page9ofl8 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Incineration Process Malfunction Abatement Plan 

City ofDen-oit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Table 3 -Preventative Maintenance Summary- Tasks Common to both Complex I and Complex II 

~P:I;r.o.m~:tel" RC$pCll1~bleSnj)t:t"'oisor R-cr.eren~ M:tlnt::lincd. Eqoipmc>~t ~t:::l.tive M::rlntc:rr.an«' T:~sk 

Numb« (Title) 

Incinerator #5 Oxygen Analyzexs 

Incina:ator ~ Oxygen A:oalyzers 

Incinerator #7 A Oxygen Analyzer 

Incinerator #7B O>..")'gen. Analyzer 

Incinerator '#SA Oxygen Atlalyze:r 

Incinerator #8B Oxygen Analyzer 

Incinerator#9A Oxygen Analyzer 

1.11 Incineruor#9B Oxygen An:al}Zer Calibrntioollnspection Monthly WSCIT Sub-Foreman 

.Incinenttor#lOA Oxygen .Analyzer 

In.cio.erator #1 OB Oxygen Analyzer 

Incinerator#llA Oxygen .Analyzer 

Jnc:inera.tor #! l:S Oxygen Analyzer 

Incinerator #12..<\ Oxygen Aoalyzer 

Tncinerator#l2B Oxygen Analyzer 

Incinerator #l3A OXygen Analyzer 

T:able3: Page 10 ofl8 
--~----------------------------------------·--------------------------------------------

Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: Mi-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MJ-PTJ-B21 03-2014a 

Incineration Process Malfunction Abatement Plan 

CityofDetroit Wastewater Treatment Plant 

Table 3- Preventative Maintenance Su=ry-Tasks Common to both Complex I and Complex II 

l'rocess P;~.r.UJ~ct~:r Responsible Supe>:'Viscr Rcf~ee M:ti-=incd Eqa~pment Pn!-venttti"'c M::tintcn::u'<<:e T::~sk 

NumQ.c.- (fitlc) 

lllcinemor #13-B Oxygen Analyzer 

1, 11 Iucine:r:ator #14A Oxygen Analyzer Ca!fbtatio:o!Inspection Moothiy WSCIT Sub--Foreman 

Incinera-tor #14B Oxygen Allalyzer 

Ta:ble 3: Page 11 ofiS 
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: Ml-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

City of Detroit WastewaterTre21ment Plaru 

Table 3-Preventative Maintenance Snmmary- Tasks Pecttliar to Incineration Complex II. Equiptr~cnt 

ComPQI'Itnt M:~iln:::itncd EquipmeJtt P«!YeE~t:ati"ve M:i.utcna:.c:e T2Sk Frequency RcspoMiblc SapCM'isar ""'.,..,., (Tltle) 

N~..,. 

Noz:de inspection Semi- Pl:aDt Mai:ol:e;oance Sub- 4, 6, 7, 11 Venturi nozzle =mally For= 

Electrical inspection A=lly E'WG Sub-F'oren:J2ll 

1,2,3,4,8 Au:xi.liazy combustion air fan Semi- Plant !V.faintenance Sub- Mec'blmical check- belt drive ammally Fo= 

Table 3: Page 12 of 18 

·-·-------------
Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

.M:aintaiDed Equipment 

Complex 2 Induced Dxaft Fm 

Inciner.a:tor Gas Bnmers 

C2 Ce:nt:rai Slta.fr: Cooling Air Fan 

Jncmer:aror Drive Reducers 

A.1JxilWy Combusti()n Air Fan 

Incineration Process Malfunction Abatement Plan 

City of Detroit Wastewater Treatment Pl:ant 

Table 4- Spare Parts Identification 

Description of Part EM:P AC or Mfg~ Part Number 

Adapter.,. Be:aJ:i!lg: 2-5116"' bore 000000000004203 

Bearing, l'illow Block: SKF FSAF 000000000007966 517 

Bea:cillg. Roller: tapered with race 000000000003456 

Cotrp~ Flexible: Type crowned 

tooth 000000000000240 

Ring,. Stabilizing: S'KF SR17 000000000013075 

Seal. Ring: (grease) ID 2.938" OD 000000000008361 3.565"' 

Actttator, Valve #EA5300000-000013 000000000005499 

.Belr, V-drive: Dayeo PIN' SVX950 000000000002134 

Belt,. V -drive: Dayco PIN 5VX950 000000000002134 

limiter, Incinerator: Torque409/3 000000000508320 

Belt, V-drive: Goodyear 000000000008796 

Damper. Fan: Btcn:l.ei' air f'a:r:t #73-NH 000000000002496 

Adapter, lncineta:cor ooooooooOoo2731 

Coupl.i:tlg, Hose: l ~"'typeD female 000000000009922 

Complex 1 Incinerator Piping/Hoses Hose,. Incinerator 000000000003045' 

Nozzle, Inciner.ator 000000000003964 

Nozzle,. Spray 000000000007157 

Tab!e4: Page 13 of IS 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Quantity 

2 

2 

1 

1 

1 

4 

15 

2 

2 

1 

2 

1 

s 

8 

8 

2 

s 

---·----·-------·-· 
.

 ..   

-------

Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

Maintained Eqnipment 

Complex 1 Shaft Coolmg A.5r Fan 

Complex 1 Burner Air Fan 

Complex 1 Induced Dxaft Fan 

Opacity Monitor 

-

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-821 03-2014a 

Incineration Process Malfunction Abatement Plan 

City of Detroit Wastewater Treatment Plant 

T~ble 4- Spare Parts Identification 

Description ofP:art EMPAC or Mfg.l'artNumber Quantity 

·--· 

Belt, V --drive: Goodyear PIN C-90 000000000006584 3 

Sheave. Std V-belc 03 Grooves 000000000004562 1 TypeB-.2 

Sheave, Std V-belc:: C Groove 3 Type 000000000005484 I B2 

Bearing, Pillow Block: w/col ball 000000000010269 2 

Belt, V --drive: Wedge cog type 000000000009397 6 

Sheave. Std V-belt 5V -belt grooves 6 000000000008123 1 

Sheave, Std V-beh: 6 groove OD 9"' 000000000013117 1 

Adapter. .Bearing: 3-15/16" bore 000000000003642 2 

Bearing, P.Jiow Block: Linkbelt 000000000007546 2 

Bearing, Pillow Block:: 3-15!16" bore 000000000012520 2 

Bearing. Ro-Uer: Spherical tapered 000000000004311 1 

Couplin,g:,. Flexible Fa:o: End bore 3- 000000000000524 1 15116" 

Connector Kit,. Multi I/0 000000000508334 I 

Purge Filters 000000000508289 I 

Lens Oe2lling Fluid 00000000050S336 1 

Table4: Page 14 oflS 
--~-------------------------- ·~·------------·-------·----------

Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

M:aintai:oed Equipment 

Opacity Moni.ror 

SFE)'ump 

Oxyg001 Anal):Zer 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: Mi-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

City ofDetroitWastewaterTreatmeot Plant 

Table 4- Spare Parts Identification 

Description of P.art EMPAC or Mfg. Part Number Quantity 

Dessicator (Head) 000000000508537 1 

Dessk:ator (R.etro) 000000000508636 1 

AJ.igmnoot Tool 000000000508295 I 

0-lang, 0.139 X-«ori 3.359 ID 26!1895 116 1 

o.:Rmg, 0.139 X-s""'-1.6.500 ID 2612202116 1 

Bearing. sleeve 3-11!1 6 4-3fl6 2523773 186 1 

Bearing, sleeve 3-ll/I 6 4-3/16 2623774186 2 

Bea:r:itlg, sleeve 3-1VI6 4-3/16 2623775 IS~ 3 

Ring, lateral boWl wear{co:re#262 26243271!8 1 32l!XB) 

Co:re, late:r:al bowl wearring32HXB 2628537 222 1 

Bearing, sleeve 3-15/16 4-7/16 27271!2186 4 

Be:arlng,. shaft 3-15!16 5-718 4778535 118 I 

Assembly, Filter: oxygen :analyzer 000000000013438 1 

Board, printed circu:it power so.pply 000000000005146 I 

Board,. printed circuit: indicator 000000000005443 1 

Board. prln.ted circuit: processing. 0000000000!2594 ! 

Hexagon bolt M5 x I 6 mi!Iitneter 0000000000!2086 12 

T:a:ble 4: Page 15 of 18 

I 

I 

I 
------------------------------------------~------~------------

Detroit Department of Water & Sewerage 

Detroit Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PTI-B2103-2014a 

Incineration Process Malfunction Abatement Plan 

City of Detroit Wastewater Treatment Plant -

Table 4- Spare Parts Identification 

Maintained Equipment Descripti()D of P.art EMP AC or Mfg. Part Number Quantity 

Box, probe mounting 000000000004942 l 

Box, tetminal:: for detector 000000000005226 1 

N"rpple. Teflon.: for .25 OD 'lllbe 000000000007095 I 3 

0-riog. oxygen amt1yzer: for filter 000000000005678 6 

0-r.ing. seal: C-65 0000000000073!! 6 

O....nen.Analyzez Probe, sampl"' ZTA 30" 000000000010036 l 

Pun,p, air. l!SV AC 000000000012838 1 

Sensor, oxygen: forzicromatie 

oxv= 000000000001073 1 

Terminal block, ceramic 000000000012390 1 

Valve, a:oalyzer viton for oxygen 000000000013128 1 

V3lve. 3-way knob control st::riDJ.ess 000000000005679 1 ! 

Cable,. conttol: progr:amrrringfOIC 000000000007946 1 I 

cable 

Chassis, monitor: 10 slot 000000000001788 2 

Digital Control Systt:m Backlight lamp for LCD 000000000006782 1 

Module, control: modular card slot 000000000000328 4 

Module, COll.trol: analog output OQ0000000001616 2 modnic 

T2bie 4: Page 16 of IS: 
Detroit Department of Water & Sewerage 

Detro"l! Wastewater Treatment Plant 

ROP No: MI-ROP-B2103-2014a 

Expiration Date: January 31, 2019 

PTI No.: MI-PT!-B21 03-2014a 

Incineration Process Malfunction Ah~tE>:m.ent.Pt""'-·· 

City of Dcuoit \Vastewater Treatrne.nl Plant 

Table 4- Spare Parts Identification 

Mairrtained Equipment Descripti:on of Part EIVIP' AC Qr Mig. P2:rt Number Quantity 

-----· -- ---·-··- -- ------- --···-- ---- ---------~------ ------- --- ·- - -

Weig:b.tometer-T ecbnetics. model TratJSd:o:cer~ L VDT 0000000000!5373 I 

Board, computer: PIN EC0074 000000000000409 I 

Boord, display. sup~ PIN 000000000006492 I EC0725 

Board, power supply 000000000007842 I 

Welghtoroeter-Auroweigb Integ:tator Encoder~ weightometer beir:speed 000000000000731 1 model Micro V1 roodcl 

Integrator, weigh-scale: with 000000000006924 1 enclosure 

Integrator~ weigb-sca.le 000000000013662 1 

T:r:ansdncer, load cell 0000000000I3S4I 1 

Comrolle.r, history: trallsfer card 000000000013057 2 

Controller, memory: card 000000000004303 4 

Digital Co:ntroi System Controller, program: progr:ammable 000000000006406 2 

Supply, processor: power 000000000004440 2 

Switcb,trnmfor 000000000008247 1 

!'e:m:pe:Iml.lre Element Sensor,. tempe~: and thetmowell 00000000051)7867 20 

Table4'Page 18~fl8 
. ' 

March 18,2015. 

Mr. Christopher Ethridge 

Southeast Michigan District Supervisor 

Michigan Department of Environmental Quality 

Air Quality Division 

27700 Donald Coutt 

Warren, MI 48092-2793 

Re: Warren Waste Water Treatment P.iant 

Final Control Plan for Complianoe with 

~ ... 

40 CFR, Part. 60,-Subpatt MMMM and R336.1972 

Dear Mr. Ethl'idge: 

,James A. Fouls- Mayor 

WASTE WATHi THEATIVIENT PlANT 

32860 Warlwp 

Warren, Mlnlllgau4B093 

(536) 2llil-25:l0 

D,avltiiVI. IVIonotto 

· Dlvisiuu He~ (I 

The Warren WWTI' intends to add control devices to the Multiple Hearth Sewage Sludge 

Incinerator to achieve compliance with 40CFR, Patt 60, Subpmt· MMMM requirements on OJ' 

before the March 21, 2016 compliance date. · 

The t1ve final control plan elements required to indicate Wanen's intent to continue operation of 

our SSl unit, in accordance with 40 CFR, Section 60.5110 are herein listed, 

1. Description of control devices and process changes to comply.witlt the emission limits 

and otlter Subpart MMMM requirements. 

- Preliminary testing indicated that improvements to the SSI are necessary to meet the new 

HCI limits and, while results showed compliance with particulate, lead, and cadmium 

limits, technology should be added to assure consistent removal of these parameters as 

well. 

- Warren plans on designing aud htstalling additional equipment to control HCl, 

particulates, and solid metals and to allow provisions for adding mercury removal in the. 

future, if required. Tho teclmology selected is a venturi style wet scrubber technology 

called a Venturi Pak. 

2. Types of waste burned at the SSI nnlts, 

- Only sewage sluqge will be bumed. 
3, Maximum design capacity of your SS1 units. 

Based on 43 years of operating experience treating WWTP sludge with an average solids content 

of 17.5%, ma.'<inHlm design capacity is 14,000 wet Jbs/hour. Normal daily treatment capacity 

ranges t1·om 8,500 to 12,000 wet Jbs/hour, with the average at just over 9,000 wet Jbs/hour. 

4. Site specific operating limits under 40 C.F .R. §60.5175. 

- This is not applicable fo1' Warren's proposed technology. 

5, Signature oftlte owner m· operator oftlte SSI units, 

DM/mvc 

Certified No. 7013 3020 0000 5396 2254 

Adm.inServ/State/F1aniControlPhm 3 .18.15 

I 

" 
DedkHit•d to Provitliuu Top Qualh~, Co:-.:l Efl\.'l'f1H', and 

Em ii'IHIUll'l\tHily S.aft• \.V at1~1" uud \\ ll:ifl'\\ ;ltn Strvit:~~'i to Onl' Cn:-~foUh.'!':o; 

,_, .. ,,,, .. 

\'PSJIANTT C();\li\lliNITV FJ'IL!TlES Al'TJIOJHI'Y 2777 STATE ROAD 

\'l'SlLM•\'rJ, i\llCI![G.\1'\ ~SI98-'JJ !Z 

TELY PI! 0:\ 1(: 73.J··48.J-~6011 

wr-:usrn·:: www.ynw.org 

VIA FIRST CLASS MAIL 

Mr. Scott Miller 

Jackson District Supervisor 

Air Quality Division 

March 19,2015 

MICHIGAN DEPARTMENT OF ENVTRONMENTAL QUALITY 

301 E. Louis B. Glick Highway 

Jackson, Ml 49201-1556 

Re: Ypsihmti Community Utilities Authority- SRN B6237 

40 CFR Part 60 Subpa1t MMMM Final Control Plan 

Dear Mr. Miller: 

The following Final Control Plan is being stJbmitted in response to your letter dated 

January 30, 20 I 5 regarding the development of a Michigan State Plan for Existing Sewage Sludge 

Incineration Units under 40 CFR Pa1t 60, Subpart MMMM (4M). The Ypsilanti Community 

Utilities Authority (YCUA) cutTently operates a fluidized bed sewage sludge incinerator (EUFBSSI) under Pennit to Install 68-02B issued by the Michigan Department of Environmental 

Quality (MDEQ). As required by the 4M standard, YCUA submitted a Title V Renewable 

Operating Penn:it (ROP) application to the MDEQ on February 20, 2015. YCUA's ROP 

application was under mandatory review by the U.S. Enviromnental Protection Agency until 

March 16, 2015, YCUA is required to demonstrate compliance with the 4M standard prior to 

March 21, 2016. YCUA's Final Control Plan as required by the 4M standard is as follows: 

1, Description of control devices and process changes to comply with the emission limits 

and other Subpart Mlv!MM requirements: 

EU-FBSSI is currently controlled with a venturi scmbber, a multi-stage impingement 

tray scrubber, a wet electrostatic precipitator, and a granular activated carbon adsorber 

bed. YCUA notified MDEQ's Air Quality Division of planned enhancements for 

installing a caustic feed system in a letter dated July 17, 2014. YCUA plans to add a 

caustic feed system as an enhancement of the existing ventm1 scmbber to ensure 

compliance with upcoming sulfur dioxide limits in the 4M standard. The emission 

guidance promulgated under the 4M standard will limit sulfur dioxide emissions to 15 
Mr. Scott Miller 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

March 19,2015 

Page 2 

ppm V fi·om existing fluidized bed incinerators. Presently, EU-FBSSI is not currently 

regulated for sulfur dioxide emissions. but historical studies have shown emissions are 

above 15ppmV, A permit exemption analysis under Michigan Administrative Rule 

336.1285 has been provided to the MDEQ for installation of the caustic feed system. 

YCUA received notification from MDEQ in a letter dated July 29, 2014 that it is in 

suppoti of our analysis. YCUA anticipates construction of the caustic feed system will 

begin in the next 30-60 days. 

At this time, YCUA does not plan to install any further control devices or make process 

changes to comply with the emission limits established by the 4M standard. Results of 

previous stack testing indicates YCUA will be in compliance with the 4M emission 

limits for exiting fluidized bed incinerators without any fut1her modifications. 

2. Types of waste burned at the SSI units (solely sewage or other): EU-FBSSI only 

incinerates dewatered sewage sludge generated at the YCUA Wastewater Treatment 

Plant. 

3. Maximum design capacity ofyolll' SSI Units: Tile design capacity ofEU-FBSSl is 48 

million Btu per hour, which is the thermal equivalent of 6,300 dry pounds per hour 

assuming 75.6 %volatile solids, 25.5% total solids and a high heating value of 10,000 

Btu/lb. of volatile solids. 

4. Site specific operating limits 1.mder 40 CFR Part 60.5175: YCUA intends to establish 

site specific operating limits using the perfonnance test required by 40 CFR Part 60.8. 

Operating limits will be established for following parameters: combustion chamber 

operating temperature; pressure drop acl'Oss each sctubber; sctubber liquid flow rate; 

scmbber liquid pH; secondary voltage and amperage of electrostatic precipitator 

collection plates;· and effluent water flow rate at the outlet of the electrostatic 

precipitator. 

YCUA plans to petition the U.S. Environmental Protection Agency as required by 40 

CFR Part 60.5175 to establish specific operating parameters, operating limits, and 

averaging periods for the carbon adsorption system. 
Mr. Scott Miller 

MICHJGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

March 19,2015 

Puge3 

5. Signature of the wner or operator of the SSI units: 

Jef 

1rector 

March 19,2015 

If you have any questions or concerns regarding this information, please contact me by 

phone at (734) 484-4600 ext. 121 or by email at lblackburn(filycua.org. 

LUTHER BLACKBURN, Director of Wastewater Operations/Compliance 

Ypsilanti Community Utilities Authority 

Cc: Mr. Glen E1ickson, MDEQ 

Ms. Valerie 01.1enther, TetraTech 

Mr. Peter Daukss, Tetra Tech 

Mr. JetfCastro, YCUA 

Mr. Kevin Dupuis, YCUA 

Mr. Scott Westover, YCUA 

Mr. Alan Schock, YCUA 

YCUA File 

I 

I 

I 

I 

II 
ENVIRONMENTAL CALENDAR. · July 131.2015 

AUGUST 19, 2015 

10:00 a.m. 

AUGUST 19, 2015 

1:30 p.m. 

consent to resolve the liability of several arranger parties under Part 201 of Public Act 451 of 1994 

for contamination at the "Shiawassee Sanitary Landfill" site in Owosso, Shiawassee County. 

Copies of the proposed settlement can be obtained from: Richard Kuhl, Asst. Attorney General, G. 

Mennen Williams Building, 6~ Floor, 525 West Ottawa St, Lansing, Ml 48913. Public comment will 

be received through August 12, 2015 at the above address. Information Contact: Richard Kuhl, 

Department of Attorney General, 517-373-7540. 

DEADLINE FOR PUBLIC COMMENTS AND NOTICE OF PUBLIC HEARING ON PROPOSED 

STATE PLAN FOR IMPLEMENTATION AND ENFORCEMENT OF EMISSION GUIDELINES FOR 

EXISTING SEWAGE SLUDGE INCINERATION UNITS. A public hearing will be held on the 

Proposed State Plan on August 19, 2015, at 10:00 a.m. in Constitution Hall, 2'' Floor South, Ford 

Room, 525 West Allegan Street, Lansing, Michigan 48909. The Proposed State Plan documents 

can be viewed on the Web at www.michigan.gov/deg/O 4561,7-135-3310 70310 70940-346472--

00.html. Written comments, questions or copies of the proposed rules may be obtained by 

contacting Erica Wolf, Michigan Department of Environmental Quality, Air Quality Division, 

P.O. Box 30260, Lansing, Michigan 48909-7760 or via email to wolfe1@michigan.gov. Written 

comments will be accepted until5:00 p.m. on August 19, 2015. Information Contact: Erica Wolf, 

Air Quality Division, wolfe1@michigan.gov or 517-284-6766. 

PUBLIC HEARING REGARDING THE DRAFT FISCAL YEAR 2016 PROJECT PRIORITY LIST 

(PPL) AND DRAFT INTENDED USE PLAN (!UP) FOR THE DRINKING WATER REVOLVING 

FUND (DWRF). The Michigan Department of Environmental Quality (DEQ) will hold a public 

hearing on the draft Fiscal Year 2016 PPL for the DWRF, that lists projects for which complete, 

final Project Plans were submitted to the DEQ by May 1, 2015, and the draft Fiscal Year 2016 I UP. 

These documents can be found on the Department's Web site, www.michigan.gov/deq, or you may 

call517-284-5433 to have the packet mailed to you. The Public Hearing will be held at 1:30 p.m. 

on the Atrium Level of Constitution Hall, in the Edward Hutchinson Conference Room. The address 

is 525 West Allegan Street, Lansing, Michigan. The hearing record will remain open to receive 

written comments until 5 p.m. on August 26, 2015. Comments should be sent to: Ms. Sonya Butler, 

Chief, Revolving Loan Section, Office of Drinking Water and Municipal Assistance, DEQ, P. 0. Box 

30241, Lansing, Ml 48909-77 41. Information Contact: Sonya Butler, Office of Drinking Water and 

Municipal Assistance, 517-284-5433; or butlers2@michigan.gov. 

DJvis(oit Permit Contacts 

For additional information on permits, contact: 

Air Quality Division 

Air Quality Permits on Public Notice 

New Source Review (NRS) on Public Notice 517-284-6793 

Renewable Operating Permit fROPl on Public Notice 616-356-0243 

Office of Oil, Gas, and Minerals 

Oil and Gas Permits 

• Mineral Well and Sand Dune Mining Permits 

Water Resources Division 

Aquatic Nuisance Permits 

Dams 

Wetland and Land/Water Interface Permits 

Wastewater Discharge Permits 

• NPDES Permits on Public Notice 

• Certificates of Coverage on Public Notice 

• Groundwater Permits on Public Notice 

8 

517-284-6826 

517-284-5593 

517-284-6821 

517-284-5568 

517-284-5557 

Arnie Hartman 

Heidi Hollenbach 

Pam Studebaker 

Byron Lane 

Contact District Office 

Staff 

Susan Ashcraft 

Sherry Thelen 
Introduction 

Lynn Fiedler, Chief 

Air Quality Division 

Department of Environmental Quality 

Opening Statement 

By: Mike Jackson, Hearing Officer 

August 19, 2015 

Good morning. My name is Mike Jackson, and I am the Supervisor of the Air Quality Division's 

(AQD) Administration Section at the Michigan Department of Environmental Quality. I will be 

serving as the Hearing Officer for this public hearing on the proposed state plan for sewage 

sludge incinerators. 

With me are Lynn Fiedler, Chief of the AQD, who is representing the Director of the Department, 

Dan Wyant, as the decision-maker, and Cari DeBruler, AQD Rule Coordinator. I would also like 

to introduce Erica Wolf, who has been instrumental in developing this state plan. 

If no one is present at the hearing 

At the current time, no one is present at the hearing. We will take a break for an hour, and 

reconvene at {enter one hour from now}. 

Hearing Agenda 

First, we will begin with some background information about why we are here. Then, we will 

describe the purpose of the hearing and how your comments will be considered. Following that, 

we will outline the procedures under which we will take your comments and describe what will 

happen after today's hearing. Then it will be time to hear your comments. We will spend the 

majority of today's times listening to those comments. At the end of the hearing, we will provide 

a short summary and closing. 

Background Information 

The AQD is responsible for protecting Michigan's air resources. The law governing those 

responsibilities are Sections 5503 and 5512 of Part 55, Air Pollution Control, of the Natural 

Resources and Environmental Protection Act, 1994 PA 451, as amended. We are here for a 

public hearing on the proposed state plan for sewage sludge incinerators. Erica Wolf will now 

briefly summarize the proposed state plan. 

Purpose of Public Hearing 

Thank you, Erica. Now Cari DeBruler will explain the purpose of today's hearing and how your 

comments will be used. 

Cari: In order for rule promulgation to occur, the Department must follow the procedures set 

forth in the Administrative Procedures Act of 1969 and the Office of Regulatory Reinvention 
procedures. The purpose of today's hearing is to give anyone interested in the proposed state 

plan an opportunity to provide information that the Department can use in making its decision. 

The Notice of Public Hearing was published on the department calendar. Copies of the Notice of 

Public Hearing, Regulatory Impact Statement, proposed rules, and summary of the proposed 

rules were made available to those interested and are available today. 

As you came in, you were given an opportunity to fill out an attendance card. We request that 

everybody fill out a card and indicate if you wish to make a comment. We will use these cards to 

maintain a record of people who are interested in the proposed rules and to call upon those who 

want to make a statement today. When all of the names have been called, we will ask if anyone 

else would like to make a statement. 

When your name is called, please approach the table and give your statement. If you have 

written comments or materials that you would like to present, please hand them to Mr. Jackson 

as you come to the table. Before you begin your comments, please state your name and any 

group or association you may represent. 

This hearing is being recorded and your comments will become a part of the information that the 

Department will consider when making its decision on the proposed rules. The public comment 

period for the proposed rules ends today at 5:00p.m. Any and all comments received by 5:00 

p.m. today will be considered when the Department makes its decision. 

Following the public hearing, the AQD staff will review all of the comments and prepare an 

Agency Report, which includes the response to comments. The Agency Report will be available 

on the Department's website or by contacting the AQD office. The proposed state plan will then 

be submitted to the US EPA for approval. 

Thank you, Cari. I will now begin calling the names of those who have indicated that they would 

like to make a statement. 

Closing Statement 

Thank you for your comments and cooperation. We appreciate that you have shown an interest 

in this proposed rule revisions by taking the time to be here today. 

As previously mentioned, the public comment period ends today at 5:00 p.m. 

If you have any questions regarding the proposed state plan, AQD staff will be available 

immediately following this hearing to answer them. 

The hearing is now closed. Thank you again. 

***************************************************** 

If after one hour, no one has arrived for the hearing 

It is now {enter current time}, and no one has attended this hearing today. The hearing is now 

closed. 
Public Comments and Responses 

The MDEQ received one public comment on the Proposed State Plan for 

Implementation and Enforcement of Emission Guidelines for Existing Sewage Sludge 

Incinerators during the public comment period of July 13, 2015 to August 19, 2015.The 

public hearing was held on August 19, 2015, at 1 O:OOam with no attendees. The sole 

comment and response follows. 

Comment: 

From Margaret Sieffert, USEPA Region V, July 16, 2015, 3:47pm via email: 

Regarding the annual report- 40 C.F.R. §60.25 (a), (b), (e) and (f) provides: 

(a) Each plan shall include an inventory of all designated facilities, including emission 

data for the designated pollutants and information related to emissions as specified in 

appendix D to this part. Such data shall be summarized in the plan, and emission rates 

of designated pollutants from designated facilities shall be correlated with applicable · 

emission standards. As used in this Subpart, "correlated" means presented in such a 

manner as to show the relationship between measured or estimated amounts of 

emissions and the amounts of such emissions allowable under applicable emission 

standards. 

(b) Each plan shall provide for monitoring the status of compliance with applicable 

emission standards. Ea.ch plan shall, as a minimum, provide for: .... 

(e) The State shall submit reports on progress in plan enforcement to the Administrator 

on an annual (calendar year) basis, commencing with the first full report period after 

approval of a plan, or after promulgation of a plan by the Administrator. Information 

required under this paragraph must be included in the annual report required by 

§51.321 of this chapter. 

(f) Each progress report shall include: .... 

That language appears to require that the state submit in an annual report 

(per 40 C.F.R. § 51.321 ), an update on the status of all subject facilities, including the 

existence of subject facilities (the inventory), and compliance of each with emissions 

standards. The MDEQ's new provision seems contrary to that requirement if it only 

requires reporting of this information in discussions. 

If you would like to discuss this further, please let me know. 

Thanks, Margaret Sieffert 
MDEQ Response: 

The MDEQ agrees that the proposed plan section "Provision for State Progress Reports 

to US EPA" stated below, was inadequate to meet the requirements under 

40 C.F.R.§60.25. 

"The MDEQ agrees to inform the US EPA of the status of affected SSI 

sources with the March 21, 2016, compliance deadline by April30, 2016. 

Any compliance delay or follow up to non-compliance, will be identified in 

routine scheduled discussions between MDEQ and USEPA Region 5 

enforcement personnel." 

Therefore, the MDEQ has changed this section of the State Plan to the following: 

"The provision of 40 C.F.R. §60.25(e) requires the state to submit 

progress reports on plan enforcement to the USEPA. The annual report 

from the MDEQ will include updates to the inventory, removing sources 

that have shut down, adding new sources, and identifying any sources 

that have met increments of progress. The annual report will also include 

any enforcement activities initiated against designated facilities, and 

submission of technical reports on all performance testing on designated 

facilities, including updated emission inventories. The MDEQ will work with 

the USEPA Region V office regarding the format required for submission 

of these items. "