# . .rl!F 

# •
. STATE OF MICHIGAN 

### DEPARTMENT OF ENVIRONMENTAL QUALITY LANSING 

# DEit -· 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 ofstandards by reference," and R 336.1972, "Emission Standards for Existing Sewage Sludge Incineration Units," ofthe administrative rules promulgated pursuant to Part 55, Air Pollution Control, ofthe 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, operatortraining 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 of40 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 ofalternatives 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 recordkeeping 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 WESTALLEGAN STREET• P.0. BOX 30473 • LANSING, MICHIGAN 48909-7973 www.michigan.gov/deq • (BOO) 662-9278

## Dr. Susan Hedman Page 2 September21, 2015
Therefore, the MDEQ requests approval ofthe enclosed State Plan, with the exception ofthe above-named exclusions. An opportunityfor 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 ofthe MDEQ Environmental Calendar excerpt is included as Attachment C. Attachment C also includes the Opening Statementforthe August 19, 2015, MDEQ public hearing, a copy ofthe one comment received concerning this State Plan, and the MDEQ's response to it. Ifyou should have any questions regarding this submittal, please contact Ms. Lynn Fiedler, Chief, AirQuality Division, at 517-284-6773; fiedlerl@michigan.gov; or MDEQ, P.O. Box 30260, Lansing, Michigan 48909-7760; oryou may contact me.

Enclosure 

# =;!;i0

Dan Wyant Director 517-284-6700
cc/enc: Ms. Margaret Sieffert, USEPA, 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

Preparedby: Michigan Department ofEnvironmental Quality Air QualityDivision



### P.O. Box30260 Lansing, Ml48909-7760 INTERNET: httpJ!www.michigan.gov/deqair

## TABLE OF CONTENTS


## Introduction Inventory ofSSI Units and Compliance Dates pg. 1 pg.2 pg.3 Emissions Inventories Enforceable State Mechanism and Requirements at Least as Protective as the Federal Emission Guidelines pg. 

## 3-6 pg.6 Provision for State Progress Reports to the USEPA

ATTACHMENTS: ATTACHMENTA 

## Part 9, Emission Limitations and Prohibitions- Miscellaneous, Final form ofadopted rules, effective May

## 20, 2015. Includes: R 

## 336.1902 Miscellaneous Provisions. R 

## 336.1972 Emission standards for existing sewage sludge incineration units. Secretary ofState's Notice of Filing ofAdministrative Rules, May 

## 20, 2015. Attorney General certification of MDEQ authorityto 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 Permitfor Detroit, Warren, and Ypsilanti. ATTACHMENT 

## C Notice of public hearing from MDEQ Environmental Calendar, 

## July 

## 13, 2015. Opening statementfrom August 

## 19, 2015, public hearing. Response to comments.

## Introduction States must submit to the United States Environmental Protection Agency (USEPA), a State Plan in accordance with the requirements of Sections 111(d) and 129 ofthe federal Clean AirAct (CAA) for implementation and enforcement ofthe "Emission Guidelines and Compliance Times for Existing Sewage Sludge Incineration Units," (Guidelines), Title 40, Code of Federal Regulations (CFR), Part 60, Subpart MMMM. The Guidelineswere promulgated by the USEPA on March 21, 2011. The State Plan must meet the requirements of40 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 ofthe 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 ofSSI 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 ofSSI Units and Compliance Dates, and included in Attachment B). 4. Emission limitations, emission standards, operatortraining 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, recordkeeping, 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 briefwritten summary of each presentation orwritten submission (included in Attachment C). 7. Provision for state progress reports to the USEPA on the implementation ofthe State Plan (included in the State Plan section on Provision forState Progress Reports to USEPA). 8. Identification ofenforceable 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 ofthe state's legal authority to carry out Section 111(d) and Section 129 ofthe 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 ofSSI 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 ofthis 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 afinal closure notification with date ofclosure on or before March 21, 2016; (2) Submittal ofa final plan by March 21, 2015, to come into full compliance by March 21, 2016; or (3) Submittal ofa notification to the MDEQ ofan 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 oroperators ofSSI 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) forthe 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 oroperators ofSSI 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 ofSewage 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 perdrystandard cubic meter; **ppmvd: partpermillion, dry volume; ***ng/dscm: nanogram perdrystandardcubic meter. 

## Enforceable State Mechanism and Requirements at Least as Protective as the Federal Emission Guidelines Underthe CAA Section 129(f)(3), it is unlawful for any source to operate in violation of any standard promulgated underthe Guidelines. In accordance with R 336.1972, sources must come into compliance with the Guidelines by March 21, 2016, the latest date available underfederal law. The consequences for non-compliance with R 336.1972, orany 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 ofstandards by reference," along with certification ofadoption ofthe rules by the Michigan Secretary of State. These rules satisfy the State Plan requirement forthe following: 1. Emission limits, emission standards, operatortraining 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 ofenforceable state mechanisms for ii'nplementing the Guidelines. Also included in Attachment A is a certification by the Michigan Department ofAttorney General that the MDEQ has the authorityto adopt by reference federal emission guidelines, such as those in 40 CFR, Part 60, Subpart MMMM. As part ofthe State Plan requirements, 40 CFR §60.26 requires a demonstration of authority by states. The MDEQ draws its authqrityto satisfythese requirements from Part 55, Air Pollution Control, ofthe 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 of40 CFR §60.26 are demonstrated as follows: 

## 1. Authorityto 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 shallpromulgate rules for the purposes ofdoing all ofthe following: (a) Controlling orprohibiting airpollution. (b) Complying with the clean airact

.... (g) Establishing suitable emission standards consistent with federal ambientairqualitystandards

.... 

## R 336.1972 Emission standards for existing sewage sludge incineration units. (3) ByMarch 21, 2016, each SSI unitshallcomply with the following provisions of"Emission Guidelines andCompliance Times for Existing Sewage Sludge Incineration Units,"40 C.F.R. Part 60, SubpartMMMM, adoptedbyreference in R 336. 1902

.. .. 

## 2. Authorityto 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 attorneygeneralmaycommence 

# a civilaction against

# a person forappropriate relief, including injunctive relief, and

## a civil fine as

## providedin subsection (2) foranyofthe following: (a) Violating thispartor

## a rule promulgatedunderthis part

.... (c) Failure to comply with the terms of

## a permitoran orderissued underthispart

....

4

## 3. Authority to obtain information necessaryto determine whether designated facilities are in compliance with applicable laws, regulations, standards, and compliance schedules, including authorityto require recordkeeping, and to make inspections and conduct tests ofdesignated 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 departmentmay
...enterandinspectanypropertyat reasonable times for the purpose ofinvestigating eitheran actualor suspectedsource ofairpollution orascertaining compliance or noncompliance with thispart, rules promulgated underthispart, the clean airact, 

## a permitissued underthispart, oranydetermination or orderissued underthispart

.... In implementing this subsection, the department orits authorizedrepresentative maydo anyofthe following: (a) Have access to andcopy
...anyrecords thatare required to be maintainedpursuant to thispart, rules promulgated underthispart, the clean airact, 

## a permitissued underthispart, oranydetermination or orderissued underthispart. (b) Inspectatreasonable times anyfacility, equipment, including monitoring andairpollution controlequipment, practices, oroperations regulated orrequired underthis part, rules promulgatedunderthispart, the clean airact, 

## a permitissued underthispart, oranydetermination ororderissued underthispart. (c) Sample ormonitoratreasonable times substances orparameters for the purpose ofdetermining compliance with thispart, rules promulgated underthispart, the clean airact, 

## a permitissued under thispart, orany determination ororderissued underthis part

.... 4. Authorityto require owners oroperators ofdesignated 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 authorityforthe 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 owneroroperatorof

## a SSI unit thathas notsubmitted

## a closure orexemption notification to the departmentshallsubmitan application for

## a renewable operatingpermitand, byMarch 21, 2015, shallsubmit

## a final controlplan meeting the requirements of40 C.F.R. §60.5110 thatis signedbythe owneroroperatorofthe unit.

5

## (3) ByMarch 21, 2016, each SSI unitshallcomply with the following provisions of"Emission Guidelines and Compliance Times forExisting Sewage Sludge Incineration Units,"40 C.F.R. Part 60, Subpart MMMM, adoptedbyreference 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 andReporting,"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 ofconfidential information. (2) A copyofeach permit, permitapplication, order, compliance plan andschedule ofcompliance, emissions orcompliance monitoring report, sample analysis, compliance certification, orotherreport or information required underthis part, rules promulgated underthispart, orpermits ororders issuedunderthispartshallbe available to the public to the extentprovidedby the freedom ofinformation act, ActNo. 442 ofthe PublicActs of 1976, being sections 15.231 to 15.246 ofthe Michigan CompliedLaws. (3)

....Data on the amountandnature ofaircontaminants emitted from a source shallbe available to the public. 

## Provision for State Progress Reports to the USEPA The provision of40 CFR §60.25(e) requires the state to submit progress reports on State 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 oftechnical 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 ofthese items.

6

### DEPARTMENT OFENVIRONMENTAL QUALITY AIRQUALITYDIVISION PART9. EMISSIONLIMITATIONSAND PROHIBITIONSMISCELLANEOUS (By authority confe!Ted on the director ofthe department ofenvironmental quality by sections 5503 and 5512 of1994 PA451, MCL 324.5503 and MCL324.5512)



### R 336.1901 Air contaminant orwatervapor; prohibition.

Rule 901. Notwithstandingtheprovisions ofany otherrule, aperson shallnot causeor permitthe emissionofan air contaminant orwatervaporin quantities that cause, alone orin reactionwith other aircontaminants, eitherofthefollowing: (a) Injurious effects to human health or safety, 

## animal life, plant life of significant economicvalue, orproperty. (b) Unreasonableinterferencewiththecomfortableenjoymentoflife andpropetiy. History: 1980AACS; 2002 AACS; 2015 MR 11,Eff. May 20, 2015.


### R 336.1902 Adoption ofstandards byreference.

Rule 902. (1) Thefollowing standards are adoptedbyreference 

### in these rules. Copies are available for inspection and purchase at the Air Quality Division, Depmiment of Environmental Quality, 525 WestAllegan Street, Lansing, Michigan 48909-7760, at a cost as ofthe time ofadoption ofthese 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 costas ofthe tinte ofadoptionoftheserules (GPOprice). The standards can also beviewed and/orprinted free ofcharge athttp://ecfr.gpoaccess.gov. (a) ''NationalPrimary and SecondaryAmbientAirQuality Standards," 40 C.F.R. Pati 50 (2013), AQDprice$61.00/$51.00 GPO priceforPati50tlu·ough Pati51. (b) Thefollowing sections of"Requirements for Preparation, Adoption, and Submittal ofhnplementation Plans," 40 C.P.R. Pati 51 (2013), AQD price $61.00/$51.00 GPO price for Pati50through Part 51: 

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

### (ii) "Legallyenforceableprocedures," 40 C.F.R. §51.160. 

### (iii) "Permitrequirements," 40 C.P.R. §51.165. (iv) "Preventionofsignificantdeterioration ofairquality," 40 C.P.R. §51.166. (v) ''Definitions," 40 C.F.R. §51.301. (vi) "Sources ThatWould Locate 

### in a Designated NonattainmentArea,"Appendix S. (vii) "ReconnnendedTestMethodsfor State hnplementation Plans," Appendix M. (viii) "Guideline on Air QualityModels,"AppendixW. 

### (ix.) "Guidelines forBARTDeterminations undertheRegional Haze Rule," Appendix Y.
Page I Courtesy of li'Hllv.michigan.gml/on· I 

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### (c) "Prevention ofSignificantDeterioration ofAir Quality," 40 C.F.R. §52,21 (2013); AQDpdce$74.00/$64.00 GPO pricefor Part52 (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 throughPmt59. (e) "Standards ofPerformancefor New Stationary Sources," 40 C.F.R. Patt 60, except 40 C.F.R. Part 60, Subpart AAA, "Standards ofPerformance for New Residential Wood Beaters" (2013);AQD price $74.00/$64.00 GPO pricefor 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 AirPollutants," 40 C.F.R. Patt 61 (2013); AQDprice$61.00/$51.00 GPO price

### for Pmt61 throughPart 62. (h) "National Emission Standardsfor HazardousAirPolluta11ts for Source Categories," 40 C.F.R. Patt63, SubpattA to Z (2014); AQDprice$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 GPOprice. (k) "National Emission Standards for Hazm·dous Air Pollutants for Source Categories (Continued),"40 C.F.R. Part63, Subpmt QQQ to 

## YYYY (2014); AQD price$47.00/$37.00 GPO price. (I) 

### "National Emission Standards for Hazardous AirPollutants for Source Categories (Continued)," 40 C.F.R. Part 63, Subpmt ZZZZ to MMMMM (2014); AQD price $50/$40 GPO price. (m) "NationalEmission Standards for Hazardous AirPolluta11ts for Source Categories (Continued)," 40 C.F.R. Patt63, SubpartNNNNNto end (2014); AQDprice $50,00/$40.00 GPOprice. (n) "Compliance Assurance Monitoring," 40 C.F.R. Part 64 (2013); AQD price $44.00/$34.00 GPOpriceforPatt64throughPart71. (o) The following sections of "State Operating Permit Programs," Patt 70 (2013); AQD ptice $44.00/$34.00 GPOpriceforPart 64 throughPart71: (i) "Applicability,"40 C.F.R. §70.3. (ii) "Re-openingsfor causebyEPA," 40 C.F.R. §70.7(g). (iii) "Transmission ofinformation to the Administrator," 40 C.P.R. §70.8(a)(1) and 

### (2). (iv) "EPA objection,"40 C.F.R. §70.8(c). (v) "Publicpetitions to theAdministrator,"40 C.P.R. §70.8(d). (p) 

### "Permit Regulations," 40 C.F.R. Pati 72 (2013); AQD price $78.00/$68.00 GPO pricefor Pmt72 through Pmt80. (q) "Sulfur Dioxide Opt-Ins," 40 C.F.R. Part 74 (2013); AQD price $78.00/$68.00 GPOpriceforPatt72 through Pat'! 80. (r) "Continuous Emission Monitoting," 40 C.P.R. Patt 75 (2013); AQD price $78.00/$68.00 GPOprice forPmt72 through Part 80. (s) "Acid Rain Nitrogen Oxides Emission Reduction Program," 40 C.F.R. Part 76 (2013); AQDprice $78.00/$68.00 GPO pricefor Pati72 throughPatt 80. Page2 Courtesyofwww.michigau.govlon·

### (t) "Federal NOx Budget Trading Program and CAIR NOx and S02 Trading Programs,"40 C.F.R. Part97 (2013); AQD price $76.00/$66.00 GPO pricefor Part96 through Pmt99. (u) "Global Warming Potentials," 40 C.F.R. Patt 98, Subpart A, Table A-1 (2013); AQDPrice$76.00/$66.00 GPOpricefor Pmt96 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 344through Section 856. (w) "Solid Waste Disposal Act, Section 3005," 42 U.S.C. §6925 (2012); AQD Price $68.50/$58.50 GPOpricefor Sections 6201 to end. (2) The following United States Environmental Protection Agency (U.S. EPA) documents are adopted byreference 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, MI48909-7760, at a cost as ofthe time ofadoption ofthese roles of $20.00 each. A copy may also be obtained from the U.S. Environmental Protection Agency, Office ofthe Science Advisor, 1200 PennsylvaniaAvenue, NW, Washington, DC 20460 or on the U.S. EPAwebsite, www.epa.gov, free ofcharge as ofthe time ofadoption oftheseroles. (a) "Advances in Inhalation Gas Dosimetry for Derivation of a Reference Concentration (RfC) andUseinRiskAssessment," EPA/600/R-12/044, September2012. (b) "Guidelines for Carcinogen Risk Assessment, and Supplemental Guidance for Assessing Susceptibilityfrom Em·ly-Life Exposureto 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) "BenchmarkDose 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 AirSources,"EPA-450/AP-425-ED, January 1995. (3) Thefollowing Federal Register documents are adoptedbyreference in theserules. A copy is available for inspection and purchase attheAir Quality Division, Depaltment of Enviro1llllental Quality, 525 West Allegan Street, Lansing, MI 48909-7760, at a cost as of the tllne ofadoption oftheserules of$10.00: (a) U.S. EPAEmissionsTradingPolicy statement, 51 F.R. 43814, December4, 1986. (b) U.S. EPA RecommendedPolicyonControl ofVolatile Organic Compounds, 42 FR35314, 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 ofthe time of adoption ofthese rules (AQD price). Copies may also be obtained from ASTM Intemational, P.O. Box C700, West Conshohocken, Pennsylvania 19428-2959 or onthe ASTM website, www.astm.org, at a cost as ofthe time ofadoption ofthese rules (ASTMprice): (a) Standard Test Method for Distillation of Petroleum Products at Atmospheric Pressure,ASTMmethodD86, 2012; AQD price $60.00/$50.00ASTMprice. Page3 CourtesyojJPww.michfgcm.gov/oiT

### (b) Standard Test Method for Pour Po:int ofPetroleum Products, ASTM D97, 2012; AQD price $52.00/$42.00ASTMprice. (c) Standard Test Method for Vapm· Pressure ofPetroleum Products, ASTM D323, 2008; AQDprice$52.00/$42.00ASTMprice. (d) Standard Specification for Fuel Oils, ASTM D396, 2013; AQD price $52.00/$42.00ASTMprice. (e) Standard TestMethodfor DistillationofCutbackAsphaltic (Bitum:inous) Products, ASTM D402, 2008; AQD price $52.00/$42.00ASTMprice. (f) 

### Standard Specification for Aviation Gasol:ines, ASTM D910, 2013; AQD price $52.00/$42.00ASTMprice. (g) Standard Specification for Diesel Fuel Oils, ASTM D975, 2014; AQD price $70.00/$60.00 ASTMprice. (h) Standard Specification for Aviation Turbine Fuels, ASTM Dl655, 2013; AQD price $58.00/$48.00ASTMprice. (i) Standard Specificationfor Gas Turb:ine Fuel Oils, ASTMD2880, 2013; AQDprice $49.00/$39.00ASTMprice. 

### (j) Standard Test Method for Detennination ofNitrogen 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; AQDprice $52.00/$42.00ASTMprice. (k) Standard Specification for Biodiesel FuelBlend Stock (B100) forMiddle Distillate Fuels, ASTMD6751,2012;AQDprice $52.00/$42.00ASTMprice. 

### (I) Standard Test Method for Elemental, Oxidized, Pruticle-Bound and TotalMercury in Flue Gas Generated from Coal-Fired Stationary Sources, ASTM D6784, 2008; AQD price$58.00/$48.00ASTMprice. (m) Standru·d Guide forPackaging and ShippingEnvironmental SampleforLaboratory Analysis, ASTMD6911, 2010;AQDprice $52.00/$42.00ASTMprice. (n) Standard TestMethod for Distillation ofEmulsifiedAsphalt, ASTM D6997, 2012; AQD price $47.00/$37.00ASTMprice. (o) Standard Specification for Diesel Fuel Oil, Biodiesel Blend (B6 to B20), ASTM D7467, 2013; AQDprice $58.00/$48.00ASTMprice. 

## (p) Standard Practices for General Techniques of Infi·ared Quantitative Analysis, ASTMEl68, 2006; AQD price$58.00/$48,00 ASTMprice. (q) 

### Standard Practices for General Techniques of Ultraviolet-Visible Quantitative Analysis, ASTME169, 2009; AQDprice $58.00/$48.00ASTMprice, (1) Standard Practice for Packed Column Gas Chromatography, ASTM E260, 2011; AQDprice$58.00/$48.00ASTMprice. (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 ofthe time ofadoption ofthese rules (AQD price). Copies may also be obtained Jl'om the American Association ofState Highway and Transportation Officials, AASHTO Publication OrderDeprutment, P.O. Box 933538, Atlanta, Georgia, 31193-3538, at a cost as ofthetime ofadoption oftheserules (AASHTOprice): (a) Standard Method ofTest for Testing Emulsified Asphalts, AASHTO T59, 2013; AQDprice$86.00/$76.00AASHTOprice. Page4 Courtesy oflPlllll',michigan.gov/Oir

### (b) 

### Standard Method of Test for Cutback Asphalt Products, AASHTO T78, 2014; AQDprice $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 byreference in these rules. A copyis available for inspection and pmchase at the Air QualityDivision, Department of Environmental Quality, 525 WestAllegan Street,Lansing, MI 48909-7760, at a cost as ofthe tin1e ofadoption ofthese mles of$69.95. A copymay also be obtained from the American Conference ofGovernmental 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 ofthe time ofadoption of thesetules of$49.95. (7) "NIOSH Pocket Guide to Chemical Hazards," 2010, is adopted by reference in thesetules. A copy onCD-ROM is available for inspection and purchase atthe Air Quality Division, Department of Environmental Quality, 525 West Allegan Street, Lansing, MI 48909-7760, for $20.00 as ofthe time ofadoption ofthese rules. A copyon CD-ROMmay also be obtained from the Centers for Disease Control website, www.cdc.gov/nioshlnpg/, for free as ofthe time ofadoption ofthese rules. (8) "AmericanPetroleum Institute Manual ofPetroleum Measurement Standards Cl9 S2," is adopted byreference in these rules. Acopy 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 ofthese 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 athttp://www.techsh·eet.com/api/products/2409, at a cost as ofthe time ofadoption oftheserules of$129.00. (9) "OTCModel 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, DepartmentofEnvironmental Quality, 525 WestAllegan Street, Lansing,MI 48909-7760, at a cost as ofthe time ofadoption ofthese mles of$10.00. A copy may also be obtained fi·om the Ozone Transport Commissionwebsite, www.otcair.org, for fi·ee as of thetime ofadoption ofthese tules. History: 2008 AACS; 2013 AACS; 2015MR 11,Eff. May 20,2015.



### R 336.1906 Diluting and concealing emissions.

Rule 906. Unless priorwritten approval is obtainedfi·om the department, aperson shall not build, erect, install, or use any ruticle, machine, equipment, or other conh·ivance ifthe solepurpose ofthe article, machine, equipment, or other conh·ivance is to dilute or conceal an emissionwithoutresulting in areduction in the totalrelease ofair contaminants into the ahnosphere. This mle does not applyto the control ofodors. Histmy: 1980 AACS; 2002 AACS; 2015 MR 11, Eff. May20, 2015.



### R 336.1910 Air-cleaning devices. PageS Courtesy o[ll'lV\l'.IJJichigaJJ.gov/orr

### Rule 910, 

## An air-cleaning device shall be installed, maintained, and operated 

## in a satisfactorymannerand in accordance with theserules and existinglaw. History: 1980 

### AACS,


### R 336.1911 Malfunction abatementplans.

Rule 911. (1) 

### Uponrequest ofthe department, apersonresponsible for the operation of a source of an air contaminant shall prepare a malfunction abatement plan to prevent, detect, and correctmalfunctions m· equipmentfailures resulting in emissions exceeding any applicable emissionlimitation. (2) 

### A malfunction abatement plan required by submle (1) 

### of this rule shall be in w1·iting and shall, at aminimum, specity all ofthe following: (a) 

### A complete preventative maintenance program, including identification of the supervisorypersom1ell'esponsiblefor overseeing the inspection, maintenance, and repair of air-cleaning devices, a desCJiption ofthe items or conditions that shall be inspected, the frequency ofthe inspections or 1·epairs, and an identification ofthe majol' replacementparts that shallbemaintained in inventoryfor quickreplacement. (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 ofthese vmiables, and adescription ofthemethod ofmonitoring or surveillanceprocedures, (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 subjecttoreview and approval bythe department. 

### If, in the opinion ofthe department, theplan does not adequately carry outthe objectives as set forth 

### :in subrules (1) and (2) ofthis rule, then the department may disapprove theplan, state its reasons for disapproval, and order the preparation ofan 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 ofamalfunction abatement plan shall implement the maltinlction abatementpla11requiredby subrule (1) ofthis 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 ofa somce, process, o1· process equipment shall, to the extent reasonably possible, operate a source, process, or process equipment 

## in a mmmerconsistentwith good airpollutioncontrol practicesforminimizing emissions during periods ofabn01mal conditions, stmt-up, shutdown, and malfimctions, 

### A source, process, Page6 Courtesy ojll'lFM1 .michigangovlon·

### 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 forminimizing 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 ofahazardous airpollutantwhich continueformore than l hour in excess ofany applicable standaJ"d or limitation established by the clean air act or the emissions ofa 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 specifiedin ape1mitissued Ol'

### Ol'der enteredunder the airpollution act. (3) The owner or operator of a source, process, or process equipment shall provide notice and a written repmt ofan abnmmal condition, start-up, shutdown, or a malfunction that results in emissions ofany air contaminant continuing for more than 2 hours in excess ofa standard or limitation establishedbyany applicablerequirement. ( 4) The notices requil'ed by this rule shall be provided to the department as soon as reasonablypossible, butnotlaterthan 2business days afterthe stmt-up or shutdownor after discovery ofthe abn01mal conditions or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, ororalcommunication. (5) Thewrittenrepmts requiredunder this mle shall be submittedwithin 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 ofdiscovery ofthe abnormal conditions or malfunction, whichever is first. The written reports shall include all ofthe following infmmation: (a) The time and date, the probable causes m· reasons for, and the duration of the abnormal conditions, stmt-up, shutdown, ormalfunction. (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 ofthetype and, whereknownorwhere 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 minimizeemissions. (d) For abnmmal conditions and malfunctions, the report shall also include a summary ofthe actions taken to correct and to prevent a reoccurrence ofthe abnmmal conditions or malfunction and the time taken to correctthemalfunction. (6)Actions takento conect and toprevent a reoccuJTence ofan abnormal condition or a malfunction shall become a pat'! of any preventative maintenance and malfunction abatementplanrequil'edbyR 

## 336.1911. (7) The tmth, accuracy, and completeness ofthe Wlitten reports required under this rule for a stationary source subjectto therequirements ofR

## 336.1210 shall be certifiedby a responsible official in amannerconsistentwiththecleanail' act. ffistory: 1980AACS; 1995 AACS; 2015 MR 11,Eff. May 20,2015.

Pago7 

### Courtesyof l!IWtl'.micfligml.

### govlon·

### R 336.1913 

### Rescinded. History: 

### 1995 AACS; 2001 AACS.



### R 336.1914 

### Rescinded. Histmy: 1995 AACS; 2001 AACS,



### R 336.1915 

### Enforcementdiscretion 

### ininstances ofexcess emissions resulting from malfunction, start-up, or sh11tdown. Rule 915. (1) In 

### determining whetherthe 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) ofthis 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 ofthefollowing, as applicable:

(a) The excess emissions were a result of a sudden and unavoidable breakdown of process orcontrol equipment,beyond thereasonablecontrol oftheperson.

(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 themaximum extentpracticable.

(c) The excess emissions caused by a bypass (an intentional diversion of control equipment) were unavoidable to prevent loss oflife, personal injury, or severe property damage.

(d) Repairs were made in an expeditious fashion when theperson knew or should have known that applicable emission limitations were being exceeded. To the extentpracticable, 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 themaximum extentpracticableduringperiods ofthe emissions.

(f) 

### All reasonably possible steps were taken to minimize the inlpact of the excess emissions on ambient airquality.

(g) The excess emissions resulting from the malfunction were not pmt ofa recumng pattern indicative ofinadequate design, operation, ormaintenance.

(h) Themalfunctionwas aninfrequent event andwas notreasonablypreventable. (i) All emissionmonitoring systems werekept in operationifat 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 withboth ofthe following provisions:
Page 8 

### Courtesy ofwli'W.michigan.gov/o,T

### (i) Any malfunction abatementplan developed in accordance with R 336.1911(2) shallbe maintained onsite and available for inspection, upon request, bythe depmiment for the life ofthe emission unit01' units. Thedepartmentmayrequirethat the personresponsiblefor the malfunction abatement plan make revisions to the plan. The person shall revise the malfunction abatement plan within 45 days after a requestby the department. The revised malfunction abatementplan shall be developedin accordancewithR 336.1911(2).

(ii) If

### the malfunction abatement planfails to address or inadequately addresses an event that meets the characteristics ofa malfunction at the time the plan is initially developed, then the person shall revise the malfunction abatementplan 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 humanhealth, 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. Ifrequested by the department, a person shall submit a full written report that includes the !mowncauses, the conective actions taken, and thepreventive measures to be takento minimizeoreliminatethechance ofrecurrence.

(I) 

### The actions during the petiod of excess emissions were documented by contempomneous operatinglogsorotherrelevant evidence as providedbyR 336.1912.

(m) Any information submitted to the depmiment under this subrule shall be properly certifiedinaccord811ce with theprovisions ofR336.1912.



## (4) Aperson 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) ofthis mle; subdivisions (a), (b), (c) ofthis subrule; andR336.1912, as applicable. (a) Theperiods ofexcess emissions that occurred during start-up or shutdown were sh01t 811d infrequent and couldnothavebeenprevented through carefulplanning and design.

(b) 

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

### recunlligpattern indicative ofinadequatedesign, operation, ormaintenance.

(c) Thepersonresponsiblefor operating the source ofair cont8111inants has a preventative maintenanceplan, consistentwiththerequirements setf01th inR 336.1911(2)(a). 

### (5) For an emission unit or units subject to standards and limitations promulgated pursuantto section 111 or 112 ofthe clean air act, the strut-up, shutdown, 01' malfunction provisions ofthe applicablerequirements within section 111 or 112 shall 

### apply. (6) Nothing in this mle shall be consttued to limit the authmity ofthe department to seekinjunctivereliefor to enforcetheprovisions ofthe act and theregulationspromulgated underthe act. History: 2002 AACS.



### R 336.1916 Affirmative defensefor excess emissions duringstart-uporshutdown. Rule 916. (1) The person operating a source with emissions inexcess ofan applicable emission limitation due to start-up or shutdown may claim an affrrmative defense to an enforcementpmceeding, excluding ajudicial action seeking injunctive relief, ifthe person has compliedwiththereportingrequirements ofR336.1912 and has demonstrated all ofthe following: Page9 

### Courtesy o[JI'WJV.mkltiga1t.govlorr

### (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 recurringpattemindicativeofinadequatedesign, operation, ormaintenance.

(c) The excess emissions caused by a bypass (an intentional diversion of conu·ol equipment) were unavoidable to prevent loss oflife, 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 themaximum extentpracticable.

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

### quality.

(g) All emissionmonitoring systems werekeptin operationifat allpossible. (h) The actions during the period of excess emissions were documented by contemporaneous operatinglogs orotherrelevant evidenceasprovidedbyR 336.1912.

(i) Excess emissions presenting an imminent threat to human health, safety, or the environmentwererepmted to thedepattmentas soon as possible.



### (j) Unless otherwise specified in the facility's petmit, other excess emissions were reported as provided inR 336.1912. Ifrequestedby the department, aperson shall submit a full written report that includes the known causes, the corrective actions taken, and the preventivemeasures to be taken to minimizeor eliminatethechanceofrecurrence.

(k) Any information submitted to the depattment unde1· this snbmle shall beproperly cettifiedin accOl'dance with theprovisions ofR336.1912. (2) This affirmative defense does not apply when a single emissionunit, m· multiple emission units at a stationmy source, causes an exceedance ofthe national ambient air qualitystandards m· any applicablepreventionofsignificantdeteriorationincrement. (3) Ifthe proximate cause ofthe excess emissions which occurred during routine start-up or shutdownperiods was due to a malfunction, then, absent anyintervening acts or superseding causes, the instances shall be treated as malfunctions in accordance with R 336.1915. (4) Nothing inthis mle shall be construed to limit the authority ofthe department to seekinjunctivereliefor to enforcetheprovisions ofthe act atld theregulationspromulgated underthe act History: 2002 AACS,



### R 336.1930 Emission ofcarbon monoxidefrom ferrous cupola operations.

Rule 930. (1) 

### Itis unlawful for apersonto operate a ferrous cupola that has a melting capacity of20 or more tons perhourlocated within any area listed inTable 91, unless the ferrous cupola is equipped with an afterbumer control system, orequivalent, whichreduces the carbonmonoxide emissions from thefen·ous cupolaby 90%. (2) The emission rate ofcarbon monoxide from a fen·ous cupola shall be determined byusing referencetest method 

### 1 0, unless otherwise specifiedbythe depmtment. Page 10 Courtesyo[wli'W.michigan.gov/on·

### TABLE91 Areas SubjecttoR336,1930 County Area Wayne TOlS, R09E to Rl2E T02S, R09Eto RilE T03S, R09Eto RIDE History: I995AACS; 2001 AACS; 2015 MR 11, Eff. May 20, 2015.



### R 336.1931 

### Rescinded. Hist01y: 1999AACS; 2002 AACS; 20I5MR II,Eff. May 20, 2015.



### R 336.1932 

### Rescinded. History: 1999 AACS; 2002 AACS; 2015 MR 11, Eff. May20, 2015.



### R 336.1933

### Rescinded. History: 2000 AACS; 2013 AACS.



### R 336.1940 

### Ethylene OxideEmissions Standardsfor SterilizationFacilities.

Rule 940. (1) Theprovisions of40 C.F.R. Part 63, Subpart 

### 0, are adoptedbyreference 

### inR 336.1902. A personresponsible for the operation ofa facility subject to the provisions of "Ethylene Oxide Emissions Standards for Sterilization Facilities," 40 C.F.R. Part 63, Subpart

### 0, shall complywith thoseprovisions. (2) For the purpose of this rule, the terms "administrator" and "EPA" as used in 40 C.F.R. Part63, Subpart0 

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



### R 336.1941 

### Emission standards for chromium emissions from ha1·d and decorative chromium electroplating andchromiumanodizing tanks. Rule 941. (1) Theprovisions of40 C.F.R. Part 63, subpartN, are adopted byreference 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 ChromiumElectroplating and ChromiumAnodizingTanks," 40 C.F.R. Part 63, SubpartN, shall complywith those provisions. (2) For the purpose of this rule, the terms "administrator" and "EPA" as used in 40C.F.R. Part 63, SubpartN mean the department. Page 11 Courtesy ojli'WlV.michigml.govlorr 

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### R 336.1942 Emission standardsfor 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 Standardsfor Asbestos," 40 C.P.R. Pmt

### 61, SubpartM, shall complywiththoseprovisions. (2) For the purpose of this mle, the terms "administrator" and "EPA" as used in 40 C.P.R. 

### Pa:tt 

### 61, SubpartM meanthe department. History: 2000 AACS; 2008 AACS; 2015MR 11, Eff. May 20,2015.


### R 336.1943 General provisionsfor emission standard.

Rule

### 943. (1) 

### Theprovisions of40 C.P.R. Pmt

### 63, SubpmtA, are adoptedbyreference in 

### R 

### 336.1902. The owner or operator ofa facility subject to the provisions of "General Provisions," 40 C.P.R. Pmt 63, Subpa1tA, shall comply with thoseprovisions. (2) Forpmposes ofthisrule, theterms "administrator" and "EPA" as used in40 C.P.R. 

### Part 

### 63, SubpartAmean the department. History: 2008 AACS;2015 MR 11,Eff.May20,2015.


### R 336.1944 Emission standardsforPortland cementmanufacturing.

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 ofa 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) Forpurposes ofthis rule, the tetms "administrator" and "EPA" as usedin 40 C.F.R. Pmt 

### 63, SubpmtLLLmeanthe department. History: 2008 AACS; 2015 MR 11,Eff. May 20, 2015.



### R 336.1945 Emission standardsforpublicly owned treatmentworks.

Rule 945. (1) 

### The provisions of40 C.P.R. Prut 63, Subpmt VVV, are adopted by reference in R 

### 336.1902. The owner or operator ofa facility subject to the provisions of "National Emission Standm·ds for Hazardous Air Pollutants: Publicly Owned Treatment Works," 40 C.P.R.Pmt

## 63, S11bpartVVV, shall complywith thoseprovisions. (2) Forpmposes ofthisrule, thetetms "administrator" and "EPA" as used in

### 40 C.P.R. Part 63, SubpartVVVmeanthe department. History: 2008 AACS; 2015 MR 11, Eff. May 20, 2015.



### R 

### 336.1946 Emission standardsfor secondaryaluminumproduction. Page 12 Com1esy of ll'll'lv,michigan,go-v/orr

### 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 ofa facility subject to the provisions of "National Emission Standards for Hazardous Air 

### Pollutants for Secondary Aluminum Production," 40 C.P.R. Pmt 63, SubpartRRR, shall complywith thoseprovisions. (2) Forpurposes ofthis rule, the terms "administrator" and "EPA" as used in40 C.F.R. Part 63, SubpattRRR meanthe depattment. Histoq: 2008AACS; 2015 MR 11, Eff. May 20,2015.



### R 336.1947 Emission standardsfor siteremediation.

Rule 947. (1) 

### The provisions of40 C.F.R. Pmt 63, Subpart GGGGG, are adoptedby reference 

### in R 336.1902. The owner or operator ofa facility subject to the provisions of "NationalEmission Standards fm· Hazardous 

### Ait· Pollutants: SiteRemediation," 40 C.P.R. Part 63, SubpartGGGGG, shall comply withthoseprovisions. (2)Forpurposes ofthis mle, the terms "administrator" and "EPA" as used 

### in40 C.F.R. Pmt 63, SubpartGGGGGmean 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 of40 C.F.R. Part 63, Subpmt YYYYY, are adopted by reference 

### in R 336.1902. The owner or operato'r ofa 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 thoseprovisions. (2) Forpurposes ofthisrule, the tetms "administrator" and "EPA" as usedin40 C.F.R. Pmt 63, SubpattYYYYYmeanthe depattment. History: 2013 AACS; 2015 MR 11, Eff. May 20, 2015.



### R 336.1949 Emissions standards for iron and steelfoundry area sources.

Rule 949. (1) The provisions of40 C.F.R. Part 63, Subpart ZZZZZ, are adopted by reference iu R 336.1902. The owner or operator ofa facility subject to theprovisions of "National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area Sources,"40 C.P.R. Part 63, SubpartZZZZZ, shall complywith those provisions. (2) Forpurposes ofthisrule,theterms "administrator" and "EPA" as used 

### in 40 C.F.R. Pmt 63, SubpmtZZZZZmeanthedepartment. Histoq: 2013 AACS; 2015 MR 11,Eff. May 20, 2015.



### R 336.1950 Emissions standards for aluminum, copper, and other nonferrous foundry area sources. Page 13 Courtesy oj'JI'lVlV.michigan. gov!otT 

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# I 

# I •

### Rule 950. (1) Theprovisions of40 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 complywith thoseprovisions.

·(2) Forpurposes ofthis rule, the terms "administrator" and "EPA" as usedin 40 C.F.R. Part 63, SubpartZZZZZZmeanthedeprutment. History: 2013 AACS; 2015 MR 11, Eff. May 20, 2015.


### R 336.1951 

### Emissions standardsfor 

### secondarylead smelting.

Rule 951. (1) Theprovisions of40 C.P.R. Pa1t63, SubpmtX, are adoptedbyreference in R 336.1902. The owner ot· operator of

### a facility subject to the provisions of''National Emissions Standru·ds forHazardous

### AirPollutantsfrom SecondaryLead Smelting," 40 C.P.R. Pmi 63, SubprutX,shall complywith thoseprovisions. (2) 

### Forpurposes ofthisrule, theterms "administrator" and "EPA" as usedin 40 C.F.R. Prut 63, Subpati

### X meanthe depatiment. Histol'y: 2015 MR11,Eff. May 20,2015.


### R 336.1952 

### Emissions standardsforhazardous 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. Patt63, SubpattEEE, shall complywith thoseprovisions. (2) 

### For purposes ofthis rule, thetetms "administrator" and "EPA" as used in40 C.F.R. Patt63, Subpati

## BEE meanthe depmtment. History: 2015 MR 11,Eff.May20,2015.


### R 336.1953 Emissions standardsfor

### mercury cell chlor-alkaliplants.

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 MercmyCell Chlor-Alkali Plants," 40 C.P.R. Part 63, SubpartHill, shall complywitbthose provisions. (2) Forpurposes ofthis rule, thetetms "administrator" and "EPA" asusedin40 C.P.R. Pmt63, Subpati

### ill!Imeanthe depatiment. History: 2015 MR 11,Eff. May 20,2015.


### R 

### 336.1954 Emissions standardsfor primary copper smelting area sources.

Rule 954. (1) Theprovisions of40 C.P.R. Pmt 63, Subpatt EEEEEE, m·e adopted by reference ia R 336.1902. The owner m· operator ofa facility subject to the provisions of Page14 Courtesy ofHil!IW.mfchigan.r;;ov/orr

### "National Emissions Standards for Hazardous Air Pollutants for Primary Copper Smelting Area Sources," 40 C.F.R. Pmt 63, SubpartEEEEEE, shall complywiththoseprovisions. (2) Forpurposes ofthis mle, the terms "administrator" and "EPA" as used in40 C.P.R. Pmt 63, SubpartEEEEEEmean thedepartment. History: 2015 MR 11, Eff. May 20,2015.



### R 336.1955 Emissions standardsfor secondary coppersmelting area sources.

Rule 955. (I) 

### The provisions of40 C.F.R. Part 63, Subpmt FFFFPF, are adopted by reference in R 336.1902. The owner or operator ofa 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)Forpurposesofthis mle, the terms "administrator" and "EPA" as used 

### in 40 C.P.R. Part 63, SubpmtPPFFFP 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) 

### Theprovisions of40 C.P.R. Part 63, SubpmtGGGGGG, are adopted by reference 

### in R 336.1902. The owner or operator ofa facility subject to the provisions of "NationalEmissions Standards for HazardousAirPollutants for PrimaryNonferrous Metals Area Sources- Zinc, Cadmium, andBeryllium," 40 C.P.R. Part63, Subpmt GGGGGG, shall complywith thoseprovisions. (2) Forpurposes ofthis rule, the tenus "administrator" and "EPA" as used 

### in 40 C.P.R. Patt 63, SubpartGGGGGG meanthe depmiment. History: 2015 MR ll,Eff.May20, 2015.



### R 336.1957 Emissions standardsforcarbon blackproduction area sources.

Rule 957. (1) The provisions of40 C.F.R. Pmt 63, Subpmt MMMMMM, are adopted byreference 

### inR 336.1902. The owneroroperator ofa facility subject to theprovisions 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) Forpurposes ofthis mle, the terms "administrator" and "EPA" as usedin 40 C.F.R. Part 63, SubpartMMMMMMmean the depattment. History: 2015 MR 11,Elf. May 20, 2015.



### R 336.1958 Emissions standards for chemical manufacturing area sources for chromium compounds. Page 15 

### Courtesy of\JIWIV.michigan.gov/orr

### Rule 958. (1) Theprovisions of40 C.P.R. Part 63, SubpartNNNNNN, are adoptedby 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 complywiththoseprovisions. (2) Forpurposes ofthis rule, thetetms "administrator" and "EPA" 

### as used in 40 C.F.R Part 63, SubpartNNNNNNmean the department. History: 2015 MR 11,Eff. May20,2015.



### R 336.1959 Emissions standards for glass manufacturingarea sources.

Rule 959. (!)The provisions of40 C.P.R. Pmt 63, Subpart SSSSSS, are adopted by reference in R 336.1902. The owner or operator ofa facility subject to the pmvisions of "National Emissions Standards for Hazardous AirPollutants for Glass ManufacturingArea Sources,"40 C.P.R. Pmt 63, Subpart SSSSSS, sha11 complywiththoseprovisions. (2) Forpmposes ofthis mle, the tetms "administrator" and "EPA" asusedin 40 C.P.R. Pmt63, Subpa1t SSSSSS mean the department. History: 2015 MR 11,Eff. May20,2015.



### R 336.1960 Emissions standardsfor chemicalmanufactoring area sources.

Rule960, (I)The provisions of40 C.P.R. Pmt 63, SubpmtVVVVVV, 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, SubpatiVVVVVV, shall complywiththoseprovisions. (2) Forpurposes ofthis rule, thetetms "administrator" and "EPA" as usedin 40C.P.R. Patt 63, SubpartVVVVVVmeanthe department. History: 2015 MR 11,Eff.May20,2015.



### R 336.1970 Rescinded. HistOJ'y: 2008 AACS; 2015MR 11,Eff. May 20,2015.



### R 336.1971 

### Bestavailable retrofittechnology orBARTprogram.

Rule 

### 971. (!) The department shall detetmine applicability ofbest available retrofit technologybasedontheprovisions of40 C.P.R. Pmt51, Subpa1tP, adopted byreferencein 

### R 336.1902

.. (2) The owner or operator of a unit subject to BART shall perform an engineering analysis as described intheprovisions of40 C.P.R. Patt51, SubpmtP and shall providethe results ofthe analysis to the depmtmentwithin 60 days oftheeffectivedate ofthis mle. (3) If an electric generating unit (EGU) subject to BART is subject to the trading programs ofthe Clean AirInterstateRuleunder40 C.P.R. Part

### 97, the owner oroperatorof Page 16 Courtesy ofwtFW.miclrigaH.govlorr

### the EGU is not required to conduct a BART analysis for sulfur dioxide and oxides of nitrogen emissionsunder this rule. (4) An engineeting analysis required by submle (2) ofthis 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 owneror operator additionalinformationrequests andcomments in writing. Theowner or operator shall provide the requested inf01mation within 60 days from receipt ofwtitten requests and comments from the department. The department may delelmine that more than 60 days will beallowed. (5) The department shall detetmine the BART level ofcontrol for each unit subject to BART based on the engineeting analysis referenced in subrule (2) of this rule, the provisions of40 C.F.R. Part 51, Subpart P and other infmmation which the department determines to berelevant. (6) The owner oroperator ofa unit subjectto BARTshall enter into apetmitto 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 bein place and operatingnotlaterthan 1 year from an approved engineeting analysis. (7) An owner or operator subject to this rule shall measure oxides ofnitrogen and sulfurdioxide emissionswith 1ormoreofthefollowing: (a) A continuous emissionmonitoring system. (b) 

### An altematemethod as described in 40 C.F.R. Part 60 or 75, adoptedbyreference inR 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, includingmethods containedinexistingpermitconditions. (8) Anowneroroperatorofan emissionunitthatmeasures oxides ofnitrogen 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 acceptableto the department. (b) Use procedures set forth in40 C.P.R. Patt75, and associated appendices, adopted byreference inR 336.1902, as applicable and acceptableto thedepmiment. (9) An owner or operator of an emission unit who uses a continuous emission monitoting system to demonsh·ate compliance withthis rule and who has alreadyinstalled a continuous emissionmonitming systemfor oxides ofnitrogen or sulfur dioxidepursuant to other applicable federal, state, or local rules shall meet the installation, testing, operation, quality assurance, and repotting requirements specifiedbythedepartment. (10) 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) ofthis 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 ofeach calendar year. The reports shall include all ofthe following intbtmation: (a) Thedate, time, magnihlde ofemissions, and emissionrates where applicable, ofthe specifiedemissionunitorutilitysystem. Page 17 

### Courtesy oj\l'lVJI'.micltigan.gov/orr

### (b) 

### Ifemissions or emission rates exceed the emissions or emission rates allowed by the applicable emission limit,the cause, 

### ifknown, and anyconectiveactiontaken. (c) The total operating time ofthe emissionunitdudngthetimeperiod. (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 ofthe system repairs or adjustu1ents. When the continuous monitoring system has not been inoperative, repaired, oradjusted, theinfmmation shall bestatedinthe repmt. (11) Quarterlysummaryrepmts, 

### ifrequired bythe depa1tment pursuanttoR 336.1213, shall be submitted within 30 days following the end ofthe calendar qumter and may be used inplaceofthe semi-ammalreports requiredpursuantto subrule

### (10) ofthis 1ule. History: 2008 AACS; 2015MR 11, Eff. May 20,2015.


### R 336.1972 Emissions standardsfor existing sewage sludgeincinerationunits.

Rule 972. (1) Exceptasprovidedinsubdivisions (c) to (e) ofthis subrule, by March 21,2016, each sewage sludge incineration (SSI) unitfor whichconstruction 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 compliancewith the requirements ofthis rule. Final compliance means all process changes and control devices, as specified 

### inthe fmal controlplan, arecompleted and operating as designed andthe departmentreceivesnotification ofcompliance, including a signature oftheowner oroperator oftheunit. (a) The SSIunitremains subjectto the requirements and deadlines ofthisrule 

### ifany of the following apply: (i) The owneror operator ofa SSIunitmakes physical oroperation changes to theunit primarily to comply with this mle and the unit commenced constmction on or before September21, 2011. (ii) TheSSIunit closes and restartspriorto March 21, 2016. (b) Ifthe SSI unit closes andrestarts after March 21, 2016, then the owner or operator ofthe unit shall meet the emission limits, emission standards, and operating limits in this mleon the datetheunitrestarts operations. (c) A combustionunitthatincinerates sewage sludge and is notlocated at a wastewater treallnent facility designed to u·eat domestic sewage sludge is exempt from this rule upon notification to thedcpm1ment. (d) Ifthe 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 ofPerformance for New Sewage SludgeIncineration Units," 40 C.F.R. Part 60, SubpartLLLL. Suchunitis exemptfi·om this ruleuponnotification to the depmtment. (e) If an owner or operator chooses to cease operation of the SSI unit rather than complywith this rule, a closurenotification shall be submitted to the deparllnentbyMarch 21,2015. (2) The owner or operator ofa SSIunit that has not submitted a closure or exemption notification to the department shall submit an application for a renewable operating pe1mit and, byMarch 21, 2015, shall submit a final conu·ol plan meeting the requirements of40 C.F.R. §60.5110 thatis signed bytheowneror operatoroftheunit. Page 18 Courtesyof 1i'li1W.micltigau.govlo1r

### (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. Pali60, SubpaliMMMM, adopted byreference in R 

### 336.1902: (a) "Increments ofProgress," 40 C.P.R. §60.5110. (b) "OperatorTraining and Qualifications," 40 C.P.R. §§60.5130to 60.5160. (c) "Emission Limits, Emission Standards, and Operating Limits arid Requirements," 40 C.P.R. §§60.5165 to 60.5180. (d) "Initial ComplianceRequirements,"40 C.P.R. §§60.5185 to 60.5200. (e) "Continuous ComplianceRequirements," 40 C.P.R. §§60.5205 to 60.5215. (f) "Performance Testing, Monitoring, and Calibration Requirements," 40 C.F.R. §§60.5220to 60.5225. (g) "RecordkeepingandReporting,"40 C.P.R. §§60.5230to 60.5235. (h) "TitleV OperatingPermits," 40 C.P.R. §§60.5240to 60.5245. (i) 

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

### Tables 2 to 6.

(4) For purposes ofthis mle the term "administrator" as used in 40 C.P.R. Prut 60, SubpaliMMMMmeansthe depattment. History: 2015MRll,Eff.May 20,2015.

Page 19. 

### Courtesyof lt'Wlv.michigan.govlorr

## To: Secretary ofthe Senate Sl:A.'IE oF MJ:cmoAN 

### Ru·mJoHNSoN, SECRE'l'ARYOF

### S·rATE DEPARTMENT OF STATE LANSING 

## May 20,2015


# NOTICE OFFILING ADMINISTRATIVERULES

ClerkoftheHouseofRepresentatives JointCommittee onAdministrative Rules State Office ofRegulatoryReinvention (AdministrativeRule#2013-109-EQ) Legislative ServiceBureau (SecretaryofStateFiling#15·05·10) DepartmentofEnvironmental Quality · In

## accordancewiththeprovisions ofSection46(1) ofAct306, 

## PublicActs of1969, as amended, andExecutive Order 1995·6, this is to adviseyou thatthe MichiganDepartmentofLicensing andRegulatoryMfairs andthe State Office ofRegulatory Reinventionfiled Admi11istrative Rule #2013-109-EQ (SecretaryofStateFiling #15-05-10) 

## onthis date at4:09 P.M. forthe Department ofEnvironmental Quality, entitled "Pact9, EmissionLinlltations andl'rohibitionsMiscellaneous", Theserules**becom~**

## effectiveimmediatelyuponfiling withthe Secretary of

## Stateunless adopted under sections 33, 44 or45a(6) of1969 PA 306. Rules adoptedunderthese sections become effective 7**~ays** 

## afterfiling withthe Secretary ofState. Sincerely, RuthJohnson Secretary ofState

# f{~v**~**

# -/zY?/4-tJ Robin 

## 1. Houston, Departmental Supervisor Office ofthe GreatSeal 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,MlohJgan.gov/Go.s

### niLLSCHUE'r'l'E AT'rORNEY GENEEAL


## Certification ofAuthority for the P.O. Box 30766 LANSING, MICHIGAN 48909



## MichiganDepartment ofEnvironmental Quality to Adopt byReference the Emission Guidelines and Compliance 'l'imes for ExistingSewage Sludge Incinerators,40 C.F.R. Part 60, SubpartMMMM I hereby ce1•tizy thattheMichiganDe}lartment ofEnvironmental Quality (MDEQ) has adoptedbyreference theEmission Guidelines and Compliance Times for Existing Sewage Sludge Iucineratm·Units, 40 C.F.R. Part 60, SubpartMMMM, §§ 

## 60.5000 et seq., 

## inRule 902 oftheMichiganAil' Pollution Control Rules, 2015 A.A.C.S., R 336.1902,pmsuant to its authority under Michigan law. I further certifythat the adoption by reference isvalid andenforceable. Michigan'sAdminiatt·ative ProceduresAct, M.C.L. §§ 

## 24.201 et seq., 

## authorizes the MDEQ to adoptby reference initsrules all or anypart ofa regulation adopted by an agency ofthe United States. Section 32(4) ofthe Administrative ProceduresAct, M.C.L. § 

## 24.232(4), statesinrelevantpart: (4) An agencymay adopt, by 1•eferenceinitsrules ancl without pt1blisl1ing the adoptedmatter infull, allor anypa1·tofa code, standardor regulation which hasbeen adoptedby an agency oftJ1e United Statesorby a nationally recognized organization or association. The reference shallfully identify the adopted matte1• bydate and otherwise. OnMay 20, 2015, the MDEQ adopted by reference all of40 C.F.R. Part 60 (2013), includingthe emission guidelines for existing sewage sludge incinerator units, inRule 902(1)(e) oftheMichiganAi1• Pollution ControlRules. 2015 A.A.C.S., R 836.1902(1)(e). Also onMay 20, 2015, theMDEQpromulgatedRule 972 ofthe Aix Pollution ControlRules, 2015 A.A.C.S., R 336.1972. Rule 972 establishes emission standards for existingsewage sludge incineration units aml requires that such units comply with the modelt·ule provisions intheemissionguidelines. Rule 9?2 also statesthatfor purposes oftherule thete1·m "administrator" as used in 40 C.F.R. Part 60, SubpartMMMM means the MDEQ.

## 'flle MDEQ's adoption by reference ofEPA's Emission Gtiidelines and ComplianceTimesfor Existing Sewage Sludge IncineratorUnits i11 

## R11le 902(1)(e) of the MichiganAil' Pollution Control Rules islawft1l and enforceable.

Date: May27, 2015 Nei! 

## D, Gordon AssistantAttm:ney General Environment, Natural Resources andAgriculture Division (517) 373-7540

Lf•': ENRA Gordon, Neil (Ah·lssnes)AG/12007·3000lJ8-MCertit:ication**~** ofAnUJOl'i!.y2015·05·27



### 2NATURALRESOURCESAND ENVIRONMENTALPROTECTIONACT (EXCERPT) Act451 of1994 

### 324.5512 Rules. Sec. 5512. (1) Subject to section 5514, the depatiment shall promulgate rules for purposes ofdoing all of the following: (a) Controlling orprohibiting airpollution. (b) Complying with the clean air act. (c) ControlHng anymode oftransportation that is capable ofcausingorconhibutingto airpollution. (d)Reviewing proposed locations ofstationary emission sources, (e) Reviewing modifications ofexisting emissionsources. (f) Prohibiting locations ormodifications ofemission sources that impair the state1S ability to meet federal ambientairquality standards. (g) Establishing suitable emission standards consistent with federal ambient air quality standards and factors including1 but not limitedto, conditions ofthe terrain, windvelocities and directions, land usage ofthe region, and the anticipated characteristics and quantities ofpotential airpollution sources. 

### This part does not prohibitthe <iepartment from denying or revoking a pem1it to operate a source,process, orprocess equipment thatwould adversely affecthuman health orotherconditionsimportant to thelife ofthe community. (h) Implementing sections 5505 and 5506. (2) Unless otherwiseprovided in this part, each rule, pennit, or administrative orderpromulgated or issued under this part prior to November 13 1 1993 shall remain in effect according to its tenns unless the rule or orderis inconsistentwithtills 

### pa1t oris revised, amended, orrepealed. (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 Admlntstrativerules: R 336.1101 et seq,; R336.1122; and R 336.1201 etseq. ofthe MichiganAdministrativeCode.

RenderedTuesday, June2, 2015 © Legislative Councll, State ofMichigan Page 1 Michigan CompliedLaws CompleteThrough PA 39 of2015 Courtesyofwww./egis/ature.migovNATURALRESOURCESAND ENVIRONMENTALPROTECTION ACT (EXCERPT) Act451 of1994 

### 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 ofinformation act, ActNo. 442 of the Public Acts ofl976, beingsections 15.231 to 15.246 ofthe MichiganCompiledLaws. (3) A 

### person whose activities areregulatedunder this 

### pmt may designate a record or other infonnation, or a portion ofa record, pennitapplication, orotherinformation fi.ll'nished to or obtained 

### by the department orits agents, as being only for the confidential use of the department. The department shall notifY the person asserting confidentiality ofa requestfor public recordsunder section 5 ofthe freedom ofinfOnnation act, Act No. 442 ofthe Public Acts of 1976, being section 15.235 oftheMichigan Compiled Laws, the scope ofwhich includes infonnation that has been designated by the regulated person as being confidential. The person asserting confidentiality has 25 days after the receipt ofthe 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 infonnationunless the person regulated under this part demonstrates to the satisfaction ofthe department that the information should notbe disclosed, Ifthere is a dispute between the person asserting confidentiality and the person requesting infonnation under Act No. 442 ofthe 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 informationrequested shall notbe released unti18 business days after the regulated person1s receipt ofnotice ofthe departments decision. This does notprevent the use ofthe infonnation by the department in compiling or publishing analyses or summaries relating to ambient air quality if the analyses or summaries do not identifY theperson orreveal infmmation which is othenvise confidentialunder this section. This sectiondoes not render data on the quantity, composition, or quality ofemissions from any source confidential. Data on the amount andnature ofair contaminants emittedfrom a source shallbe available to the public. History: 1994, Act 451,Etf. Mar. 30, 199S, Popular name:**Ac~**45I Popular name: NREPA

RenderedTuesday,June 2, 2015 © Legislative Council, State of Michigan Page 1 Michigan Compiled laws Complete Through PA39 of2015 Courtesyofwww.leglslalure.mi.govNATURAL RESOURCES AND ENVIRONMENTAL PROTECTIONACT (EXCERPT) 

### Act451 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 ofcredentials 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 ofaircontaminants are taken for analysis, a duplicate ofthe analytical report shall be furnished promptly to theperson who is suspected ofcausing the airpollution. In implementing this subsection, the department orits authorizedrepresentativemay do any ofthe following: (a) Have access to and copy, atreasonable times, any records that arerequired to bemaintained pursuant to this part, rules promulgated under this part, the clean air act, a permit issued under this part, or any detennination or orderissued underthis part. (b) Inspect at reasonable times any facility, equipment, including monitoring and air pollution control equipment, practices, or operations regulatedorrequiredunder this part, mlespromulgatedunder this part, the cle(ln airact, 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 promulgatedunder this part, the clean air act, apermit issued under this part, or any detetmination or order issued under this part. The department may enterinto a contract with a person to sample and monitoras authorizedunder this subdivision. (2) Ifthe department, or an authorized representative of the**department~** 

### is refused entry or access to records and samples under subsection (1) for the purposes ofutilizing .this section, the attorney general, on behalfofthe state, may do either ofthe following: (a) Petition the court ofappropriatejurisdiction for a wan·ant authorizing entty or access to records and samplesp11rsuant 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, andto enjoin interferencewith theutilization ofthis section. (3)ABused in this section, "authorizedrepresentative" means anyofthefollowing: (u) A full- or part-time employee of the department ofnatural resources or other state department or agency to which the department delegates certain duties underthis section. (b) Acounty to which authority is delegatedundersection 5523. (c) For the pmpose ofutilizing the powers confened in subsection (l)(c), a conh·actot·retained by the state or acounty to which authorityis delegatedunder section 5523, History: 1994, Act451, Eff. Mar. 30, 1995. Popular name: Act451 Popularname:NREPA

Rendered Tuesday, June 2, 2015 Page 1 © 

### Legislative Council, StateofMichigan Michigan Complied Laws CompleteThrough PA 39 of2015 Courtesyofwww.leglslature.mi.gov 

# I INATURALRESOURCES AND ENVIRONMENTALPROTECTIONACT (EXCERPT) 

### Act451 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 injunctiverelief, and a civil fine as provided in subsection (2) for any ofthe following: (a) Violating this partorarulepromulgatedunderthis part. (b)Failure to obtain apermitnnder thispart. 

### (c)Failureto complywith the terms ofapennit oran orderissuedunder this part. (d) Failure to pay an airquality fee or complywith afiling requirementunder this part. (e)Failure to complywiththe**inspection~** entry, and monitoringrequirements ofthis part. (f)A violation described in section 5518(2). (2) In addition to any other reliefauthorized under this section, the court may impose a civil fine ofnot more than $10,000,00 for each instance ofviolation and, 

### ifthe violation continues, for each day ofcontinued violation. (3) In addition to otherreliefauthorized under this section, the attorney general may, at the request ofthe department, file an action 

### in a court ofcompetentjurisdiction to recover the full value ofthe injuries done to the nahualresources ofthe 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 substantiallyprevailingparty

### ifthe courtdetermines 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 oflngham, 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 broughtunder this section as determined to be appropriate by a court ofcompetentjurisdiction. 

### (7) Fines 

### imposed under 

### this section shall be 

### assessed for each 

### instance ofviolation and1 

### ifthe 

### violation is continuous, shallbeassessableup to the maximum amount for each day ofviolation. History: 1994,Act 451, Eff. Mar. 30, 1995. Popularname: Act451 PopularDl\me: NREPA

Rendered Tuesday, June 2, 2015 © Legislative Council, State 

### of Michigan Page 1 Michigan Complied Laws Complete Through PA 39 of2015 

### Courtesyofwww.legislature.mi.gov

# CITY OF BATTLE CREEK DEPARTMENT OF PUBLIC WORKS • WASTEWATER DIVISION



### Mr. Rex Lane Senior Environmental QualityAnalyst Air Quality Division Kalamazoo District Office

Dear Mr. Lane: Subject: Closure Date forSSJ Units Jn Battle creek

Pursuant to the request 

## bythe Departmentof Environmental Qualityto notifyofBattle creek WastewaterTreatment Plant's Intenton future lnclneratlon, we herebysubmit 

### formal notification of Closure. The City ofBattle Creek Michigan will no longerincinerate waste municipal solids, and will decommission thetwo Sewage Sludge Incinerators by March 21, 2016, Ifyou have anyfurther questions orconcerns regarding our Intentions please feel free to contact 

## me at anytime.

WastewaterSuperintendent 

# RECEI:VED

# E2~'l City ofBattle 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 1of2

E;ast Lansing Waste WaterTreatment 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, oracombination ofthese that process wastewatertreatment plant sludge, shall not exceed 3.2 kg 

### (7.1 lb) of mercury per24-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 ofthis subpart shall not exceed 10 grams (0.022lb) Qf beryllium overa24-hour period. 40 CFR 60 Subpart MMMM--Emission Guidelines and Compliance Timesfor 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 ofthis year and compliance In anotherthree years. Citation 60.5125 states that Ifasource plans to close its SSI unit ratherthan comply with the state plan, they need to submit a closure notification, Including the date of closure, to theAdministrator 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 WaterTreatment is not apermitted hazardous waste storage ordisposal facility, so Is notsubject to this subpart. 40 CFR 63 subpart FF, MACT NESHAP for Publicly Owned Waste WaterTreatment plants. East Lansing Waste WaterTreatment Is not aMajor Source of HAP, so is not subject to this subpart. The Incinerators were last used on October 17, 2002. 

### ' Iarrived at 2:30. Imetwith JeffJohnston; Superintendent ofthe source. We discussed !he advantages ofvoiding the permits. Istated that Itwas 

### myopinion thatthey 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 102-72were issued to East Lansing Waste Waterfor the installation oftwo Multiple Hearth Inc. Incinerators. The Incinerators were permitted with scrubbers and lowvelocity mist eliminators. It Is my understanding thatthe Incinerators are 6 hearth units. Two hearths dry, two Incinerated, and two cool. Ash disposal for the original Incineratordesign included ash quenching and pumping the slurry to two lagoons situated east ofthe plant. During my Inspection I identified the two incinerators. They were not operating and appeared to 

### be



## v 

## ''"St3/2011 

# I**~**

# I 

# I I 

# I 

# I I 

# I

## Page 2of2
decommissioned. Analyzer components for the CEM/COMs were missing aswere the computer components for DataAcquisition and Storage (DAS). Instrumentation in the control room was out

## ofrepair. Wayne slated lhat the gas supply to the units had been disconnected. Ialso noticed from aphotograph that the east ash lagoon had been filled ln. The west lagoon still exists butwas reduced in size. · At presentthe sludge Is being dewatered, loaded on trucks, and sent to Granger landfill. The remaining waste watertreatment 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 hotwater. Rule 282 (b) exempts these u\1\s from the need for an air use permit.

# "~**[ft--t~,** MS+col/

# ~-•oo"**~···**

--**-:--"·----~~** . i 

### I 

### 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 

# I

I
I 

# I 

# I ( 'i

# I I I

# CITY OFFLINT DEPARTMENTOF

### PUBLICWORKS 

# WATERPOLLUTION CONTROL DIVISION
DayneWalling Mayor DARNELLEARLEY 

### Robert

## J. Case

## EMERGENcYMANAG~~Q·AQD 

## LANSING o.(YPC Supervisor

Mr. G. VinsonHellwig Chief, Air Quality Division

. MichiganDepartment ofEnvironmental 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: TitleVRenewable OperatingPermit, City ofFlintWaterPollution Control

DearMr. Culham: 

## As we discussed last week, a submission date is approaching this weekwhich mayrequire tbat tbe City ofFlint 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 recentyears, 

## 40 CFR Part

## 60, SubpartMMM,M, hasbeenpwmulgated to 

### regulate all existing SSis. The compliance datefor SubpartMMMM is March 21,2016. The City ofFlinfhasevaluated 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 neededto draft and negotiate an ROP when the City intends to shut downtbese SSls in thenear fi.rture, and cettainlywell before theMarch21, 

## 2016compliance 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. · · · Italso plans to more cost-effectivelymanage its sludge by Iandfilling it,rather than incinerating it. Currently, design for a new loadout building and conveyance system to enable the landfilling

WaterPollutionControlDlvlslon • G-4652 Beecher.Rond • Fllnf 1Michigan 48532 ' (810} 766-7210 (phone) • (810}230-3154(fax)
TnolnShutdownPianDEiQhq.DOC 

# I I I

## is undetway. The Cityhas engaged the engineeringfitm ofHubbell, Roth, and Clarkto perform the work. Theprojected scheduleis to :finish the design, prepare bid specifications, procure DEQ approval, bid and award the contract, and begin constructionthis summer. Construction should be completeby earlynextyear. Oncethe initial operations and adjustments have beenmade, 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 unlikelypossibility). Anotice will be sentto bothDEQ andUSEPA whenthe shutdown dateisknown. The City ofFlinttherefore will notsubmit an ROP application. Inthe unlikely eventthatthe City ever considers resuming incinerator operation, you will be notified. The incinerators would not resume·operationuntilthe appropriateretrofits, improvements, andairuse permits wereinplace. I thank you for your attention in this matter. Should you need any further information, youmay contactme byphone at (810) 577-6703 oremail atrcase@cityoffiint.com.

cc: M. Robinson, WNJ. J. 

## Thaler, FTCH 

## BrianCuiham, MDEQ

laoinShutdowuPliUlOBQhq.DOC 

# I I i**~** 

# I

! 

# I ! 

# I I I

# WRC

March 6, 2015



## Mr. ChristopherEthridge SoutheastMichigan DistrictSupervisor Air QualityDivision SoutheastMichigan District 27700 

## DonaldCourt Warren, Michigan48092-2793 

## Re: DeconunissioningExistingSewage SludgeIncinerationUnits located at Pontiac WastewaterTreatmentPlant 155 

## N. Opdyke Road, Pontiac MI DearMr. Ethridge: The PontiacWastewater TreatmentFacility Chapter20 

## Drainage District (COPWWTFDD) is inreceipt ofyourletterdated February 10,2015.

## The operation ofthe existing sewage sludge incineration (SSI) ceased onJune 16, 2011 whenthe City ofPontiac entered into an agreementwithUnited Waterfor ope1·ation and maintenance ofthe wastewatertreatment facility. This letter is

## to serve as an official closmenotification to the MichiganDepartmentof Environmental Quality for the deconnnissioning ol'theexistingPontiac Wastewater TreatmentFacility Sewage SludgeIncinerationUnit. The COPWWTFDD plans to isolate and discom1ectthe natural gas feed line and the sludge feed conveyorto the sewage sludge incineratorbyno laterthanMay 1, 2015. Please do nothesitate to contactme ifyou have any questions or concems.

NavidMeln·am, P.E. OperationEngineer

cc: MichaelDaniels, United Water LauraVerona, MDEQ**~-** 

## - - -**~** ' ' 

## . ' '

- ' \ 

### -**~** '**~** 

### - -
- - - 

### -
- ' : 

### - - 

## ',
- ' 

### . 

# "**t_~\** 

# " One PublicWorl<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** "',_.=;

- -- - '

- - '

### NavidMehram, PE Oakland CountyWRC 1Public Works Dr. Waterford, MI 48328
April 30, 2015 Dear

## Mr. Mehram, As yourequestedwepermanentlydecommissioned the sludgeincinerator at thePontiac (Aubum) WastewaterTreatmentPlant. Weperfmmed the decommissioningbyshutting offthe gas supply, removing a section ofthe gas piping andinstallingblindflanges to bothends ofthepipe. To assurethatno sludge will befed to theincineratorbothfeed hatches were cappedwithsteel and welded shut. Therewas anorthfeed hatch and a southfeedhatch. Ihave attached pictures ofthemodifications that weremade to verifYthe decommissioning. The pictures are labeledfor yourconvenience. If

### youhave questions, pleasecontact me at yom· convenience. Sincerely,

JeanetteM. Best ProjectManager United Water

### Michigan Department of Environmental Quality Air Quality Division EFFECTIVE DATE: January 31,2014 REVISION DATE: June 13, 2014 ISSUED TO Detroit Waterand Sewerage Department DetroitWastewater 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 

## Ipursuant to Act451 and the federal Clean AirAct.



## SOURCE-WIDE PERMIT TO INSTALL
Permit Number: MI-PTI-B2103-2014a 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 airapplicable 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 ofWater &

### Sewerage Detroit WastewaterTreatment 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

............................................................................................................................................... 10 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 SUMMARYTABLE

..................................................................................................... 16 EULIMEPAD

..........................................................................................................................................23 

### D. FLEXIBLE GROUP CONDITIONS
...................................................................................................25 FLEXIBLE GROUP SUMMARYTABLE

.................................................................................................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 ofCompliance

.................................................................................................... 80 Appendix 3. Monitoring Requirements

..................................................................................................80 Appendix 4. Recordkeeping

..................................................................................................................82 Appendix 4.1: Recordkeeping (continued)

...................................................................................... 83 Page 2 of 106

### Detroit Department ofWater & 

### 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 ofWater &

### Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a 

## AUTHORITYAND 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 forwhich this permit has been issued. The department 

### is defined in Rule 104(d) as the Director ofthe 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 orsubsumed, 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 ofthis 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
IIDetroit Department ofWater & Sewerage Detroit WastewaterTreatment 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 ofthis 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 allowthe department, or an authorized representative ofthe department, upon presentation of credentials and other documents as may be required by law and upon stating the authority for and purpose ofthe investigation, to perform any ofthe 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 ofthe 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 ofthe 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 underthe ROP. d. As authorized 

### by Section 5526 of Act 451, sample or monitor at reasonable times substances or parameters for the purpose ofassuring compliance with the ROP or applicable requirements. 5. The permittee shall furnish to the department, within a reasonable time, any information the departmentmay 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 ofthis 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 106Delran Department ofWater & Sewerage ROP No: MI-ROP-B2103-2014a DetroitWastewater 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 ofthis 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 336.1910)


### 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 otheraircontaminants, either ofthe 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 ofthe 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 ofthe test. (R 336.2001(4)) 

### Monitoring/Recordkeeping
Page 6 of 106

### Detroit Department ofWater & 

### Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment 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 ofthe samples were performed. c. The company orentity that performed the analyses ofthe samples. d. The analytical techniques or methods used. e. The results ofthe 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 orcorrect each deviation.

Page 7 of 106Detroit Department ofWater 

### & 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 ofthe following (R 336.1213(3)(c)): a. Submitting a certification by 

### a responsible official with each report which stales that, based on information and beliefformed after reasonable Inquiry, the statements and information In the report are true, accurate, and complete. b. Submitting, within 30 days following the end ofa 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 bya responsible official which states that, "based on Information and belief formed after reasonable inquiry, the statements and informatiori contained In each ofthe reports submitted during the previous month were true, accurate, and complete". The certification shall include a listing ofthe 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 ofthe 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 inventoryforms provided bythe 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 ofany 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 ofthe abnormal conditions or malfunction. Notice shall be by any reasonable means, Including electronic, telephonic, or oral communication. Written reports, ifrequired under Rule 912, must be submitted to the appropriate AQD District Supervisor within 10 days afterthe start-up or shutdown occurred, within 10 days afterthe abnormal conditions or malfunction has been corrected, or within 30 days ofdiscovery of the abnormal conditions or malfunction, whichever is first. The written reports shall include all ofthe information required In Rule 912(5) and shall be certified by a responsible official In a mannerconsistentwith 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 ofthe determination by the department that other specifically Identified requirements are not applicable to the stationary source. Any requirements Identified in Part E ofthis 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 oraffect any ofthe following: a. The provisions of Section 303 of the CAA, emergency orders, Including the authority of the USEPA under Section 303 ofthe CAA. (R 336.1213(6)(b)(i)) b. The liability ofthe owner or operator ofthis source for any violation ofapplicable requirements prior to or at the time ofthis 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 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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, butthe 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 departmenttakes 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 ofa 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 notcomply with the existing ROP terms and conditions that the application seeks to change. However, ifthe 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 ofthe following circumst.ances: a. Ifadditional requirements become applicable to this stationary source with three or more years remaining In the term of the ROP, but not ifthe 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 106Detroit Department ofWater 

### & 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 ofthis 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 ofthe 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 under40 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 necessaryto ensure compliance with the requirements of 40 GFR, Part 68. 41. Ifsubject to Section 112(r) ofthe 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 bythe Administrator ofthe USEPA as a part of Michigan's State Implementation Plan. Such activities must complywith Rule 215 and Rule 216. 

### {R 336.1213(12))

Page 10 of 106

### Detroit Department ofWater 

### & 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 ofAct 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 ofownership oroperational control. The request must include all ofthe 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!allation

### 2reconstruction, 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 oftermination ofthe 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 Chiefof the AQD.

Page 11 of 106Detroit Department ofWater& 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 otherterms 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. Ifthere are no Source·Wide Conditions, this section will be left blank.

Page 

### 12 of 

### 106

### Detroit Department ofWater & 

### Sewerage ROP No: MI-ROP-82103-2014a 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 offive 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 Incineratorfeed system once per calendar month for mercury content using EPA Reference Method 105. Ifthe 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 offive years. (R 336.1213(3)(b)(ii)) Page 13of 106Detroit Department ofWater 

### &Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January 31,2019 PTI No.: MI-PTI-B2103-2014a 1. The permittee shall keep records ofthe fugitive dust control measurestaken 

## 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 1to 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, orvacuuming In the material handling area on days when material handling takes place b) Weekly sweeping, washing orvacuuming- 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), (Act451, Part 55 §324.5524) 3, Incineration Complexes Iand 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 ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 ofany 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

, (Act451, 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 ofthe termination of the Consent Order. The effective date oftermination Is defined for the purposes ofthis condition as the date upon which the Termination Order is signed bythe Chief ofAir Quality Division. (Consent Order MDEQ SIP No. 11-1993) 10The permittee shall comply with the fugitive dust control plan as described below: DETROITWATER AND SEWERAGE DEPARTMENT -WASTEWATERTREATMENT PLANT FUGITIVE DUST CONTROL PLAN Wind Erosion and Traffic Emissions Roads, Parking Lots, and Open Areas Type ofSurface 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. DUTYVEHICLES (3-15 TONS) Average number per day 10 10 Average Feet traveled/vehicle 12,000 1,100 HEAVY DUTYVEHICLES (>15 Tons) Average Numberperday 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, Part55 §324.5524),(Consent Order MDEQ SIP No. 11-1993, Fugitive Control Plan, May, 1993) Footnotes: 1This 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 15of 106

### Detroit Department ofWater & 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 SUMMARYTABLE 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 ofWater & 

### 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 ofWater 

### & Sewerage Detroit WastewaterTreatment 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 

### byan 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 Impingementtray 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 FG2013Project 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 anda i

Page 18 of 106 

# I I 

# l I 

# I I

### Detroit Department ofWater & 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 FG2013ProjectDetroit Department ofWater 

### & Sewerage Detroit WastewaterTreatment Plant

EUGEN-G4

Page 20 of 106 ROP No: Mi-ROP-B2103-2014a EXjJiration Date: January 31, 2019

FGNSPSBOILERS

### Detroit Department ofWater & 

### 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 afabric 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 ofWater & 

### 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 106 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 FG2013ProjectDetroit Department ofWater & 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 NADetroit Department ofWater & Sewerage Detroit Wastewater Treatment Plant 

### VII. REPORTING ROP No: MI-ROP-B2103-2014a Expiration Date: January 31, 2019 PTI No.: MI-PTI-82103-2014a

1. Prompt reporting ofdeviations 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 1to 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 afterthe trucks are loaded, so as to prevent sludge trackout offof 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 pursuantto Rule 201 {1)(a).

Page 24 of 106

### Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January 31,2019 PTI No.: MI-PTI-62103-2014a 

## 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 SUMMARYTABLE 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 106

### Detroit Department ofWater 

### & 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 106 ' 

### 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 ofWater 

### & 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 priorto 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 bythe per 1,000 average ofthree 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 ofwater. (R336.1213(3)) 

### IV. DESIGN/EQUIPMENT PARAMETER($) NA 

### V. TESTING/SAMPLING Records shall be maintained on file for a period offive 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 of40 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 underthe same conditions and demonstrated compliance with the emission Page 27 of 106Detroit Department ofWater 

### & 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. Ifthe 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 of40 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. Ifthe 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 offive years. (R 336.1213(3)(b)(ii)) 1. The permittee shall comply with the following conditions while operating any ash silo in FGC1ASH:
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. Ifvisible 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 orabsence ofvisible 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 ofdeviations 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 ofPart 

### A. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to December31 and September 15 for reporting period January 1to June 30. {R 336.1213(3)(c)(i))
Page 28 of 106

### Detroit Department ofWater 

### & 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

1This condition Is state only enforceable and was established pursuant to Rule 201(1)(b). 2

### This condition is federally enforceable and was established pursuantto Rule 201(1)(a). 3

### Thls condition is future applicable. The date of future applicability is based upon the date ofapproval of the State Plan, and will be the earlier of (1) March 15, 2016, or (2) three years after the effective date ofState Plan approval.

Page 29 of 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: Mi-ROP-82103-2014a Expiration Date: January31, 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 ofwater. (R336.1213(2)) 

### IV. DESIGN/EQUIPMENT PARAMETER(S) 

### 1. NA 

### V. TESTING/SAMPLING Records shall be maintained on file for a period offive 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 106Detroit Department ofWater & 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. Ifthe 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 of40 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 ofperformance 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 offive 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. Ifvisible 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 ofdeviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 2. Semiannual reporting ofmonitoring and deviations pursuantto 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 ofWater 

### &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 ofState Plan approval.

Page 32 of 106Detroit Department ofWater 

### & Sewerage DetroitWastewaterTreatment Plant ROP No: MI-ROP-82103-2014a Expiration Date: January 31, 2019 PTI No.: MI-PTI-82103-2014a 

## 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 ofthree test runs FGCOMPLEX1 V.1, 40 CFR Part 60, Matter perdrystandard (a minimum of 0.75 dry Vl.7- Vl.13 Subpart MMMM cubic meter 3 standard cubic meters (§60.5165) collected pertest run).

. Hydrogen 1.2 part per Average ofthree 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 of200 (§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 ofthree 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 ofone (§60.5165) hour per run). 4. Dloxins/furans 5.0 nanograms fA.verage ofthree test runs FGCOMPLEX1 V.1 40 CFR Part 60, (total mass basis) per drystandard (a minimum of 1 dry Subpart MMMM cubic meter 3 standard cubic meters (§60.5165) collected per test run). 5. Dioxlns/furans 0.32 nanograms f"verage ofthree test runs FGCOMPLEX1 V.1 40 CFR Part 60, (toxic equivalencyper dry standard (a minimum of 1 dry Subpart MMMM basis)' cubic meter3 standard cubic meters (§60.5165) collected pertest run). 3. Mercury ).28 milligrams Average ofthree 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 106Detroit Department ofWater & Sewerage Detroit Wastewater Treatment Plant Pollutant Limit Time Period/Operating Scenario 7. Oxides of 220 parts per Average ofthree test runs nitrogen million, dry (collect sampie for a volume3 minimum duration of one hourE_errun). 8. Sulfur Dioxide**~6** part per fAverage ofthree test runs million, dry (for Method 6, collect a volume3 minimum volume of200 liters per run. For Method

### ~c. collect sample for a minimum duration ofone hour per run). 

### f-1. Cadmium 0.095 milligrams fAverage ofthree test runs per dry standard (a minimum of 1dry cubic meter3 fstandard cubic meters collected pertest run). 10. Lead**~.30** milligrams :Average ofthree test runs per dry standard (a minimum of 1dry cubic meter3 standard cubic meters collected pertest run). Equipment
FGCOMPLEX1

FGCOMPLEX1

FGCOMPLEX1

FGCOMPLEX1 ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 offfor a period oftime 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 106Detroit Department ofWater & Sewerage Detroit WastewaterTreatment 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 of40 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 of40 CFR 60.5200. (40 CFR 60.5195, 40 CFR 60.5220) 

### V. TESTING/SAMPLING Records shall be maintained on file for a periodoffive 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 ortoxic 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 ofthis Flexible Group, provided that no process changes have been made since the performancetest was conducted. Ifthe 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 of40 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 of40 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 of40 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 Supervisorfor 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 orall ofthese 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 mercuryor dioxin/furans emission limits.' (40 CFR 60.5205(b))
Page 35 of 106Detroit Department ofWater 

### &Sewerage Detroit WastewaterTreatment 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 offiveyears. (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 ofthe sewage sludge, on a daily basis, for the purpose of recording the range of moisture content. Ifthe 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 ofservice (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 ofthe 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 106Detroit Department ofWater & Sewerage Detroit WastewaterTreatment 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 ofservice. (R336.1213(3))
See Appendices 3, 4 and 9 

### VII. REPORTING 1. Prompt reporting ofdeviations 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 unlessotherwise 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 106Detroit Department ofWater 

### &Sewerage Detroit WastewaterTreatment 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 ofthe 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: 1This 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). 3This condition is future applicable. The date offuture 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 ofState Plan approval.

Page 38 of 106

### Detroit Department ofWater 

### & 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 Impingementtype wet scrubber followed by a venturi scrubber and a misteliminator. 

### I. EMISSION LIMIT(S) Time Period/ Pollutant Limit Operating Scenario 0.151b per 1,000 1. PM pounds ofexhaust 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 336.1910) 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 ofWater 

### &Sewerage ROP No: MI-ROP-B2103-2014a Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PT/-82103-2014a 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 offiveyears. (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. Waterflow rate through the associated scrubbertrain. b. Differential pressure across the Inlet and outlet ofeach 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 atthe 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 atthe 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 ofdeviations pursuant to General Conditions 21 and 22 of Part

### A. (R 336.1213(3)(c)(ii)) Page 40 of 106Detroit Department ofWater 

### & Sewerage Detroit WastewaterTreatment Plant ROP No: MJ-ROP-82103-2014a Expiration Date: January31, 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. 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: 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 forthat 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: 1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuantto Rule 201 (1)(a).

Page 41 of 106Detroit Department ofWater 

### &Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 Pulsejet fabric filter baghouse. 

### 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 hourtest 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 offive years. {R 336.1213(3}{b)(ii)) NA See Appendix 5 

### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period offive 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 106Detroit Department ofWater 

### & 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 orplace unit out of service. (R336.1213(3))

Footnotes: 1Thls condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 43 of 106Detroit Department ofWater 

### & 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 ofeach 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 offive years. (R 336.1213(3)(b)(ii)) NA 

### VI. MONJTORING/RECORDKEEPING Records shall be maintained on file for a period offive 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 106Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment 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 ofthe fuel oil sulfur content, In percent by weight, for each shipment offuel oil received. The permittee shall keep all records on file for a period ofat 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 PartA. 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 1to 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 Appendix8 

### 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 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant


### IX. OTHER REQUIREMENT(S) ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 

### andZZZZ, 40 CFR 

### 63.6595)

Footnotes: 1This 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 ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-82103-2014a 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-D18, 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 ofWater 

### & Sewerage DetroitWastewaterTreatment 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, R336.2804, 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 ofthe 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 offive 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 bythe manufacturer and the permittee maintains the engine as required by 40 CFR Part 60 Subpart 1111. Ifa 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 106Detroit Department ofWater & Sewerage Detroit Wastewater Treatment Plant 

### VI. MONITORING/RECOROKEEPING ROP No: MI-ROP-82103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-82103-2014a Records shall be maintained on file for a period offive 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 ofoperation 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 ofthe engines in FGCIENGINES, including what classified the operation as emergency and how many hours are spentfor 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 of40 CFR 80.51O(b). The certification ortest data shall include the name ofthe 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 ofdeviations pursuantto General Conditions 21 and 22 of Part A. (R 336.1213(3){c)(ii)) 2. Semiannual reporting of monitoring and deviations pursuantto 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 106Detroit Department ofWater 

### &Sewerage Detroit WastewaterTreatment 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: 1This condition is state only enforceable and was established pursuant to Rule 201 (1)(b). 2This condition Is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 50 of 106 

# .I



# I !

11

# I

II

# I ! 

# I
II ! 

### !Detroit Department ofWater 

### & 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,EUBOILER10 

### 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 offive years. (R 336.1213{3)(b)(ii)) NA 

### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period offlveyears. (R336.1213(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 ofmonitoring 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. 

# i I
IIDetroit Department ofWater 

### &Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment Plant Expiration Date: January31, 2019 PTI No.: MI-PTI-82103-2014a 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

1This condition is state only enforceable and was established pursuant to Rule 201(1){b). 2This condition is federally enforceable and was established pursuant to Rule 201 (1){a).

Page 52 of 106 Requirements

NADetroit Department ofWater & 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 ofthe following design requirements:
a. The air/vapor interface ofthe 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 

### coverand the 

### covershall 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 ifthe 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 greaterthan 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 ofthe following provisions:
a. The cold cleaner must be designed such that the ratio ofthe freeboard height to the width of the cleaner is equal to or greater than 0.7. (R 336.1707(2)(a)) Page 53 of 106Detroit Department ofWater 

### & 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 ifthe 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 offive 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 ofeach 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. Ifthe 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), 

### R336.1707(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 106Detroit Department ofWater 

### & Sewerage Detroit WastewaterTreatment 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 scrubberfollowed byan 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 scrubberfollowed 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 ppmvdry ' 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 drystandard 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 drystandard 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 drystandard 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 ppmvdry' 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 drystandard 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 drystandard cubic Test protocol' 

### meter a2 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 106Detroit Department ofWater 

### & 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 ofeach calendar month 12-month rolling 17. PM10 59.6 tp/ time period as determined at the end ofeach 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 atthe end of each calendar month 12-month rolling 

### ?0. NOx 663.4 tp/ time period as determined at the end ofeach calendar month 12-month rolling

### ~1. so, 37.6 tpy2 time period as determined at the end ofeach calendar month 12-month rolling

### ~2. voc 64.8 tpy2 time period as determined at the end ofeach 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 ofeach calendar month 12-month rolling

### ~5. H,SO, 25.9 tpy2 time period as determined at the end ofeach 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: January31, 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 

### R336.2801(ee)Detroit Department ofWater 

### & Sewerage DetroitWastewater Treatment Plant
Pollutant Limit Time Period/ Operating 

### Scenario 12-month rolling time period as 126. Fluorides 35.0 tpy' determined at the end ofeach calendar month Equipment

FGAQCI ROP No: MJ-ROP-B2103-2014a Expiration Date: January31, 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. Forthe emission limits In this table, standard conditions means a temperature of 68 oF (20 °C) and a pressure of 1 atmosphere (101.3 kilopascals). 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 ofeach 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 atthe 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 permanentlyshut down, whichever comes first.


### Ill. PROCESS/OPERATIONAL RESTRICTIONIS) 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 parameterto its specified range, as provided for In the approved MAP.' a. Waterflow rate for each scrubber In the associated scrubber train. b. Differential pressure across the Inlet and outlet ofeach scrubber in the associated scrubber train. c. Hearth #1 combustion temperature (R336.1224, R 336.1702(a), R 336.1910)

Page 57 of 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January 31, 2019 PTI No.: MI-PTI-82103-2014a 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. Ifat 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 scrubbertrain.' a. Waterflow 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 offive 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, H2

### S04, 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 offive 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 106Detroit Department ofWater& Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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. Waterflow 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 monitorand 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 drytons 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 ofdeviations pursuant to General Conditions 21 and 22 of Part

### A. (R 336.1213(3)(c)(II)J
Page 59 of 106Detroit Department ofWater 

### &Sewerage ROP No: MI-ROP-B2103-2014a DetroitWastewaterTreatment Plant Expiration Date: January31, 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 1to 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 ofthe installation, construction, reconstruction, relocation, or modification Is considered to occur not laterthan commencement oftrial operation ofthe 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 scrubbertrain. (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 106

### Detroit Department 

### ofWater 

### & Sewerage ROP No: MI-ROP-82103-2014a 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 106Detroit Department ofWater & Sewerage Detroit WastewaterTreatment 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 forthis 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) drystandard 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 TestprolocoI' 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 a2 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 eitherthe 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 ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-82103-2014a Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a 1. Use ofthe 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 ofeach 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, sulfurdioxide, 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. Ifthe 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 ofconducting 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 ofthese pollutants In accordance with the requirements of40 CFR 60.5185(b). 2 

### (40 CFR 60.5185(b)) Page 63 of 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-82103-2014a 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. TheAQD must approve the final plan priorto 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 ofthe 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 wetscrubber 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 offive 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 offive 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

### Detroit Department ofWater 

### &Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 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 ofthe sewage sludge, on a daily basts, for the purpose ofrecording the range of moisture content. Ifthe 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 ofthe 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 by40 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 ofthe 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 1to 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))
Page 65 

### of 106Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a 4. The permittee shall notifythe AQD District Supervisor, in writing, one month before starting use ofa 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 ofthe control device. The Inspection shall include, at a minimum, all ofthe 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 Part60, 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 oftime 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). 2This condition Is federally enforceable and was established pursuant to Rule 201 (1)(a).

Page 66 of 106

### Detroit Department ofWater &

### 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 dryertrains 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/hr 2 

### Test protocol' 

## 17. PM10 1.63 lblhr' Test protocol*

### ~· PM2.5 1.14 lb/hr 2 

### 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 dryertrain in SC V.1-V.2



### FGDr)'erTrains Each dryer train in SC V.1-V.2,



### FGDryerTrains Vl.2 

### Each dryertrain in SC V.1-V.2,



### FGDryerTrains V1.2 

### Each dryertrain In SC V.1-V.2,



### FGDryerTrains V1.2 

### Each dryer train In SC V.1-V.2,



### FGDryerTrains Vl.2 

### Each dryertrain in SCV.1

FGDryerTrains Each dryertrain in SC V.1, Vl.2



### FGDrverTrains Each dryertrain in SC V.1

FGDrverTralns Each dryertrain in SC V.1, Vl.2



### FGDrverTrains Underlying Applicable Requirements

R336.1331 40 CFR 52.21(c) & 

### (d) 40 CFR 52.21(c) & (d) 

### 40 CFR 52.21(c) & (d) 40 CFR 52.21(d)

R336.1331(c) 40 CFR 52.21(c) & (d) 

### 40 CFR 52.21 (c) & 

### (d) R336.1407(a) R336.1702(a) 40 CFR 52.21 (d) 

### R336.1224

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 Page 67of 106 

# I 

# I

• 

# I

### Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-B2103·2014a Detroit WastewaterTreatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a considered to be operating whenever the dryer is processing sludge cake.' (R336.1205(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, R336.1702(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 ofthe 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 dryertrain in FGDryerTrains, within 180 days after commencement oftrial operation of the dryer train, the permittee shall verify NOx, CO, PM, PM1 0, PM2.5, 

## so,, VOC, lead, and H2

### S 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 ofthe 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 oftrial operation ofthe first dryertrain 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 identifythe dryertrains 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 dryertrains in FGDryerTrains. The permittee shall keep all records on file at the facility and Page 68 of 106Detroit Department ofWater & Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-82103-2014a Expiration Date: January31, 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 Impingementtray scrubber, once each day thatthe dryer train operates c. Pressure drop across the Impingementtray scrubber, once each daythatthe dryertrain 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 aftervisible 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 pursuantto General Conditions 21 and 22 of Part

### A. (R 336.1213(3)(c)(ll)) 2. Semiannual reporting of monitoring and deviations pursuantto 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 1to 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, ofthe completion ofthe activity. Completion ofthe installation, construction, reconstruction, relocation, or modification Is considered to occur not later than commencement oftrial operation ofany 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 106Detroit Department ofWater 

### &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: January31, 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). 2This condition Is federally enforceable and was established pursuant to Rule 201 (1)(a).

Page 70 of 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 dryertrains, 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 atthe FGDryerFacility SC Vi.2 R 336.2801(ee) end ofeach calendar month 12-month rolling

### ~- PM2.5 19.2 tpy" time period as R 336.1205(1), detenmined atthe FGDryerFacility SC Vl.2 R 336.2801(ee), end ofeach 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 106Detroit Department ofWater 

### &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 ofa 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, 

### R336.1372, 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 forequipment in FGDryerFacility2: a. The pH ofthe 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, 

### R336.1911) 

### V. TESTING/SAMPLING 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)) Page 72 of 106Detroit Department ofWater 

### & 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) ofthe 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 ofthe 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 ofmonitoring 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 1to 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 106Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a including the date ofclosure, 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 ofblosolids into the dryer.' (R 336.1205(1), R 336.2801(ee), 40 CFR 52.21 (b)(3)(i)) a. No later than start-up ofthe first dryer in FGDryerFacllity, the permittee shall permanently cease operating incinerators according to the requirements listed In row (i) ofthe 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) ofthe table below. c. No laterthan start-up ofthe third dryer In FGDryerFacility, the permittee shall permanently cease operating incinerators according to the requirements listed in row (Ill) ofthe 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) ofthe table below. Number of Dryers that have Incinerators that Must Permanently Cease Started Operation Operating {PermanentlyShut 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 affectthe number ofother Incinerators that must permanently cease operation.

Footnotes: 1This 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 

# lDetroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 ofeach calendar month 12-month rolling time period as determined atthe end of each calendar month 12-month rolling time period as determined at the end ofeach calendar month 12-month rolling time period as determined at the end ofeach calendar month 12-month rolling time period as determined atthe end ofeach calendar month



### Ill. PROCESS/OPERATIONAL RESTRICTION(S) Equipment

FG2013Project

FG2013Project

FG2013Project

FG2013Project

FG2013Project

FG20.13Project

Page 75 of 106 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 ofWater 

### & 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 offive 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% ofthe applicable 1-hourand annual N02 National AmbientAir Quality standards, whichever comes first. "Acceptable data collection" means fully quality assured and no Jess than 75% complete.' a. Bystartup ofthe last dryertrain in FG2013Project. b. March 21,2016 (40 CFR 52.21(d)) See Appendices 3 and 4 

### VII. REPORTING 1. Prompt reporting ofdeviations pursuant to General Conditions 21 and 22 of PartA. (R 336.1213(3)(c)(il)) 2. Semiannual reporting ofmonitoring 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 ofthis 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 CFR52.21(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 106Detroit Department ofWater 

### & 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: January31, 2019 PTI No.: MI-PTI-B2103-2014a

1This 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 106Detroit Department ofWater 

### & Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-82103-2014a 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 106Detroit Department ofWater & Sewerage DetroitWastewaterTreatment 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 NotApplicable Acfm Actual cublc feel per minute NAAQS National Ambient Air Qualily 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 byweight EU Emission Unit PS Performance Specification OF Degrees Fahrenheit PSD Prevention ofSignificant Deterioration FG Flexible Group psia 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 cubicfeet 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 PlantAttendant 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 ControlTechnology Temp Temperature MAERS Michigan Air Emissions Reporting System THC Total Hydrocarbons MAP Malfunction Abatement Plan lpy Tons per year MDEQ Michigan Department ofEnvironmental 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 WaterTreatment Plant MVAC Motorvehicle air conditioner yr Year 'For HVLP applicators, the pressure measured at the gun aircap shall not exceed 10 pounds persquare Inch gauge (psig). Page 79 of 106 

# I

i 

### I ' 

# I "Detroit Department ofWater & Sewerage Detroit Wastewater Treatment Plant 

### Appendix 2. Schedule ofCompliance 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 ofthe 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 duringthe inspection. (R336.1213(3)) 3. Any repairs and corrective actions needed to address the causes of malfunction orfalllrre shall be performed promptly to maintain compliance. (R336.1213(3)) 4. Permittee shall perform weekly maintenance inspections ofthe baghouses which shall include visual inspection ofthe fabric filter bags for security ofattachment, holes ortears in the fabric filter bags for security of attachment, holes or tears in the fabric and evidence ofdust 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. (R336.1910) 3. Any repairs and corrective actions needed to address the causes of malfunction or failure shall be performed promptly to maintain compliance. (R336.1910) 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 ofthe 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 106 

# I 

# I

### Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-82103-2014a Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-82103-2014a 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 ofAppendix 8 to 40 CFR Part 60. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures ofthe 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 ofthe 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 ofthis permit. This includes the date, time, magnitude, cause and corrective actions ofall 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 ofthe incinerator served by the GEMS during the reporting period. d) A report ofany 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 ofat 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 ofWater 

### &Sewerage ROP No: MI-ROP-B2103-2014a Detroit Wastewater Treatment Plant Expiration Date: January 31, 2019 PTI No.: MI-PTI-82103-2014a 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 ofAppendix Bto 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 ofthe 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 ofthe total operating time ofthe incinerator during the reporting period. c) A report ofany 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 ofat 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 ofAppendix 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 ofthe audit, the results ofthe 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 ofall periods of COMS downtime and corrective action. b) A report 

### ofthe total operating time ofthe 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 

### tora 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 ofat 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 ofthe unit inspected, conditions of the unit and descriptions of any corrective action taken. These records shall be maintained for a minimum offive 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 leastfive years. (R336,1910)
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 ofthe 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 106Detroit Department ofWater & Sewerage Detroit WastewaterTreatment 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, at40 CFR part 60, appendix A-8. collect a minimum volume of200 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 at40 CFR part 60, appendix A- minimum duration ofone 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 1dry standard cubic meters per run) Mercury EPA Reference Test Method 29 at 40 3-run average (For Method 29 and CFR part 60, appendixA-8; Method ASTM D6784-02 (Reapproved 308 at 40 CFR part 60, appendix A-8; 2008), collect a minimum volume of orASTM 06784-02 (Reapproved 1drystandard 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 ofone hour per run)

Page 84 of 106Detroit Department ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-62103-2014a Expiration Date: January31, 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 of200 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 at40 3-run average (collect a minimum CFR part 60, appendix A-8. volume of 1dry 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 1dry standard cubic meters per run) Fugitive emissions from ash Visible emission test (Method 22 of Three 1-hourobservation periods. handling appendix A-7 ofthis 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 06Detroit Department ofWater & 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 

### @ 100% 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 C15 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 gasfired 30 kW generator 0.78 EU-G4 Ford G20F3 natural gasfired 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 ofoperation for each engine by Its respective engine-specific emission factor listed above, or as determined from testinQ, whichever isJ1reater. 

### 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 bythe AQD District Supervisor. B. Other Reporting

Page 86 of 106Detroit Department ofWater 

### & Sewerage ROP No: MI-ROP-B2103-2014a Detroit WastewaterTreatment 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 ofthe calendar quarter in which data were collected. (R336.1213(3}}, (Consent Order MDEQ SIP No. 11-1993)


### Appendix 9. Preventative Maintenance Summary For details aboutthe 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 ofWater& Sewerage Detroit WastewaterTreatment Plant ROP No; 

### MI-ROP-B2103-2014a Expiration Date: January 31, 2019 PTI No.: MI-PTI-B2103-2014a



# Malfunction Abatement Plan

The City ofDetroit WastewaterTreatmentPlant 9300 WestJeffersonAvenue Detroit, MI 48209

Revision C March 2007

Page 88 of 106 1.Detroit Department ofWater 

### & Sewerage Detroit WastewaterTreatment Plant



### Section 

## Table ofContents ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a



### Page
Plan 

### Description

........................................................................................................ J 

### Table I-KeyMonitored ProcessParameters

.......................................................... 4 Tobie2 - 

### MnlfunctionAbatement

### Stunmnry

............................................................ 5 Table 3- Preventative

### Maln1enanceSummary......................................................... 8 

### Tnble 4- Spare Paris ldentiflcntion

.......................................................................... 14

Page 89 of 106

### Detroit Department ofWater & 

### Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January 

### 31, 2019 PTI No.: MI-PTI-B2103-2014a



## lncinerationProcess Malfunction Abatement Plan The CityofDetroitWnsfowaterTrca!mentPlan!



### This document contains the Incinemtlon Process Malfunctio11 AbatementPlan tobe tJSed 

### at the City ot'Dclt'oit's WastewaterTreatmentPlant, 9300 WestJefferson Avenue, Deh·oit, Michigan48209. The plan's p\Jrpose is to assure compliancewith theemission limit on opacity in the eventofo malfuuction or failure ofanypart ofthe process that affects opncity. Rule 9l1 

### ofthe Stole ofMichigan Air Pollution Control R11les requires theDWWTP to haven MalfunctionAbatementPlan in place) 4

### 'to prevent,**deteol~** 

### and correct lllfllfunctions orequipment £1i1ures resultingin emissions exceeding any upplicable emission limitation."The emission limitation !Ills plan is concerned with is the 

### O})acity limitation of20 percent. The rulerequires that the plan specify, at aminimum: n) Acomplete-prcve.ntutive maintemmce program, inoh1ding lden!ificRtiou ofUte supervisory personnel responsible for overseeing !heInspection, maitttcnanceandrepairofair-cleaning devices, adescription ofthe items orconditions that shall be-Juspeoted, the J}cqucucy ofthese inspeotious orrepnir11, and an identification of!he mnjorreplacemenl paris that shnll bo maintained iniuventory forquickreplacement. b) An idenlificntlon ofthe sotlrceand nlr-cleaning davicc operating \'arlahles !lmtshall bo U\Oilltored to detectamalfimction orf."tilllre, the normal**OJ>er<~ling** rnnse ofthesevariables, rntd adcscrlptio!l oflhe method ofmonitoring orsurveillance procedures. c) Adescription oflite con:ecliYe }>rocedmes oroperational c:lJ!Jnges lhnt shall be taken in !he event of<1ntalfunction orf!lilure to nchle\'ecompliancewith the applic!lbleemission Ilmlls. 

### The plrm 

### is divided into fmu· sections in tabularfommt: 1. Represented by

### Tnble 

### 1, KeyMonfloredProcessFm·ameters, tills section relntos toR 336.1911 

### (2)(b) und dellneales, "thesource and air-cleaning device operatingvariables that shall bo monitored to detect amall\mclion ot' failure, the nomwl**ope~·atingmuge** 

### ofthcsoval'iables, and adescription oftho method 

### ofmonitoring orsurveillanceprocedures. h 

### Thofirst cohmm ofTable 1

### shows thet'eferenconumberwhich is used to link thema1funolion range (condition) ofTablo 2items andmaintenance activities inTable 3with one Ol'

### moreprocess parameters given in Table l.Tl1e Operations personnel af 

### theDWWTP have determined, through experience, the incineration process lHH'ameters whos0vnrlrmce has adirect effect on the opacityofincineration emissions. These parameters are-shown in column 2of Table 1. 

### Columns 3to 7contain information 1'egardingthe device ormethod used to monitor fl 

### given proccs$pal'lmleter

### in colunm 2} Ute

### locationofsuch device, the**fi·eq~Jency** 

### ofmonitoring, thenonnal range oftheprocess parameter and the mal1\u1Ction range for agiven pnt·ftmeter. The value ofagiven parf!meterIs indicative ofeithernotmal operallon or
Pngc 1of18



### Page 90 of 106Detroit Department 

### ofWater 

### & Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a



### malftmction orfailure oftheprocess. Table 1

### contains fields forboth the normal operating rangeand themalfunction range for each monitored process 

### parameter. Ifany ofthesepat·ameter's vnlues fall within thepartloulnr 

### pm·ameter's malfunction rnngej remedial actiott

### must be taken to 

### prevent a deviation from theemission limitation 

### 2. Represented byTable 2,

### Ma!fimcllon Abatement SIII/11/IGI/', 

### this section relates to R336,191 

### I (2)(c) and is an, "identification ofthe somce and air-cleaning deviceoperatingvariables 

### that slmll be monitored to 

### detect amalfunction 

### or fnillll'c, the normal operatingrange ofJhese variables, and adescription ofthe method 

### ofmonitoring Ol'

### surveillance 

### procedures." This 

### table details the action(s) to be taken in the event that oneormore ofthemonitoredProcess Parmlletel'S value(s) 

### in Table#I enters 

### its malftmction range. As nn example, assume lhe oxygen level has fallen below 4percent. Using 

### Table 1, It 

### is determined that <4% oxygen is indicativeofamalfunction. Oxygen Level%, 

### in !he firsl row of'l'ahle 1, has aProcessParameter Reference Numbel' 

### oful,11

### Using !his reference number

### al'ld Table

### 2) it is 

### detennined thatthet'e are threepossiblecauses for this condition (low oxygen). Theopemtorneed onlydeterminewltich ofthe tlu·eeis tho actual 

### enuse

### and take 

### the actlonrecommended 

### 1ntheRemedialAcUon 

### column corresponding Ia 

### the cause, 

### All opacity exceedances and the corrective action(s) taken will be recorded. Records ofeach operata!' 

### adj11stment (o 

### prevent an opacity 

### excecdanceneed not be recol'dcd. 

### 3. Tobie 3,

### PrevenfativeMaiulenauceSummm:}', is asummary ofthe preventative maintenance to be perfonned on 

### devices whose 

### failuremay conhibute to opacity devjatlon8. The maintenanceprogram relates to 

### requirement (2)(a) ofR 336.1911. As an example, referto tlte first row ofTable3. The induced draftfan affects process 

### parameters associoted with 

### Process Parameter

### ReferenceN11mbers 

## 1- 6, 9and 

### t1. These reference numbers areused toreferenceTable l'sfirst 

### column 

### whloh indicntes that Oxygen Level 

### (%), Tempm·ature,DraftPressure. FeedRntc, Hoppel' Depth, Auxiliary Combustion Ail'Damper,Manna] 

### OpacityMonitm• Calibrations and SlagBuildup are all affected ifthoinduced draft fan malfunctioJlS, The fi·eqnency ofPM activity applies to units that are operating. Records ofPMactivitywill bemaintained. 4, Tnblc 4, 

### SparePartsList, lists pf!tts that are

### in inventoryforusein the 

### maintenanceofdevices listed In Table 3. This table, along with Table3, relates to requirement(2)(a) ofR336.1911. Forconvenience, the attached

Page2ofl&

Page 91 of 106

### Detroit Department ofWater &

### Sewerage Detroit Wastewater Treatment Plant ROP No: MI-ROP-82103-2014a Expiration Date: January 31,2019 PTI No.: MI-PTI-B2103-2014a

spare parts listmaydetail supplier·name and Sllpplier

### part numbeL', Howevel', the De!rolt WastewaterTreatment Plantreserves the right to purchase spare purls fi·otn any companyoffudng an acceptable subslihHe. Thequantityof parts included in tWs section is A

### suggested number ofspares, TheDetroif WastewaterTrenhnent Plantreserves therighl to lwvesuppliers expedile de1ivel'y ofpat1s fi·om their factory Ol' 

### warehouse in Heu ofstodngonsite, The intended function ofthemulfunotlou abatementpian (MAP) is) 0 

### to prevent, detect, and con·ecl malfunclions orequipmentfailures n.:sulting in emissions exceeding any applicable emission limitation/'The emission limitation is 20% opacity,
DefJuition ofAcronyms
PLC-Progmmmnble LogicConlroller OCS- Ovation Control System SFE- Screened Final Effluent (process water·used where 

### wate1·Js needed) DWWTP- Detroit Wastewatet'TreatmentPlatlt J.D. FQn- Induced Draft Fan 

### MAP- Malfunction Abatement 

### Plan COMS- Continuous OpacityMonitoring System P.M.- PreventativeMaintenance ID -l11side diameter OD- Outsidediameter C 1 - Incineration Complex One CII- Incineration Complex Two IS-**In~Service** 

### 1/0- b>put/Outpul

Pnte 3of18



### Page 92 of 106Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant

### ·~ >=.m- ProcessP.ararneter**-~~** Number

l OxygenLevel("/..) 2 Hearth#lTe:nper.a:ture 3 CombustionZone Temper:a'l:txre 

# • DT3ftPressure 5 FeedR:a.te 

# • TotllSerobbe!:'SystemInlet-. OutletDiff(:rentl21 E"reSSore 7 ScrubberWaterIlow 8 SludgeCombustionAir 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 ProcessMalfunctionAbatementPlan TheCityof DetroitWastewaterTreatmentPlant 

### Table 1 - KeyMonitoredProcess Parameters Monito-ring Deviceor LocationofMonitor Frequency.of Normal Operating M::alfnnctionR:mge: Method MonitOring Range

OxygenAnal;,-ze,; Bre:ach/Heanh#3 Comi:nuous 1-12% <1%

Thermocouple Hearth#! Continuous llOO-1500 °F. <900

..F. Thermocouple Coro.bn.stionzone Cottlhmous 1200-J.9SO°F. <1200 "F. ot>l9:50"'F. beattbs Ptessw:e g2uge Bteeeh/Hearth#5 Continuous 0.0to-1.5in..of!fzO > +0.0inchesof:S::P Weiglllometers Co:o:veyorbeli$ Continuous**ComplexJ:0-16~tonslllr.: Ccmptexi>16wett~**  Complexl!:0-20W>::ttonslbr Complex.U>20 wct.tonslhr Pxessu:re ,gal.lges Venrurisectioninlet Continuous >18inchesofRzO <18inchesofH;P 2:1ldtraysectionolltlet <:olu.:mn eo-ltrr.c:rJ. Flowmeters CoJ:rtrolRoom. Conti:tluoas. 3-4SFEpumps in- <3SFEptu:trps inservice se:rvice Shaftre:t:u:rnairand <Antrolltoom. Co:c.ti:c.nous 0 to 100%open Umesponsive a:r.ccili2cy airdampex:s Combustionzone Allholesopena:od**~**ZSOAbolesblocked. Visual hea:rtbs andcenterShaft As needed cen.tet shaft**c1~ Cen~**  shaft:**d~** okay notokav. V=al Complex I-basement Asneeded Empty(cobuildup) Pluggeddrophole Complexn- :fi:cstfloor Opacitymo:Utor Roof Comi=ous Below20% Noreadingoroonstant loworhighreadings

Table 1:Page4of1SDetroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant

### ·~ P:.:r2.mctc:r Condition**Rclb'<~nc;c** Number

1 Lowoxygen. 1 Lowoxygen 1 Lowoxy.gen 2 Lowhearth#1 temperature 3 Lowcombustion t_..-atures 3 Lowcom.bustion temperatw:es 3 Highcombustion
4 Loworhighdiaft 5 No feed 5 Toomuch.feed 5 Hopperbridging 6 Lowscrubbersy:stern di:fferentialpresswe 7 Lowscro.bberw.1terflow rate 8 Loworno sludge combustionairsupply ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a


## Incineration Process Malfunction AbatementPlan TheCity

### ofDetroitWastewaterTreatmentPlant 

### Table2-MalfunctionAbatementSummary
PossibleC:ause(s) MeaiJs ofDetection CorrectiveProoedures

Toomanyburnet'SI.S. PLC'OCS ReducebUl'llCr :firill,g r.ates ornumberofbumersinuse

Lowdi2ftpressure PLC!OCS Increase draftp:ressore setpoio.t Process controlproblems PLC'OCS Increaseoxygen setp<Jint, ormanuallyincreaseairdmlper openings Feedtateincreaseorlower PLC'OCS hla:easeupperhearthburner:tiringr.ates and! orreducefeed**ca.~e**solids rateffnecessary Low-bum.ernseprofiles PLC'OCS IncreaseD.UJ:nberofbum.ers illuse :and! orfiringtatesasneeded. Feedr.ate increaseorlower PLC'OCS Increasenumberofburnersinuseand/orfiring :rates as needed. cakesolids Or,. if necesSary,. reduce feedrate. Lostfeed, burneruseprofile, PLC'OCS Restorefeed orredocenumberofbume:rsariD! or:5:ring:rates orchangeincakesolids Varlousptocesscllanges PLC'OCS Increaseordecrease d:taftpressuresetpointasneeded Conveyor(s) stoppedor PLC'OCS& visual Restartconveyors2JJ.d/orclearhopperbridging.. Checkscrew b,opperbridging fuspections speedsettings Notc::o.onghincineratoiS VlSUalInspection Putmoreincineratorshl-service I decreasefeed CakecorrtaiWJ:lga:nexcessive Visualhlspection R:u.uthehopperuntilit;,; empty(thiseliminams thebrid.,.;,g) amou.ntof polymer Variousprocesschanges PLC'OCS Inctease drafta:adventu..'i differential**presst~te** setpoints !ncorroctsettmgs otloss in PLC'OCS Increaseflowsetti:ngs and/orrestorewatersupplypressure

watersupplypressure Oxygen COIJ.trol sysremorair PLC'OCS Openairdampers inmanualmodeandvisu:ally checkdamper damperproblems action, openlower**hearth~**holesif necessary

Tabie2:PageSofiSDetrott Department ofWater & Sewerage DetroitWastewaterTreatment Plant

## "'~- 

# I**,.~~ Ro<~** **N~"""**

9 10
11 Any Condl"'tion

Slagbuildup A:sb buildup onbottom hemb. Opacitymonitor

malfunction**Prev=t:ative~**

------- L____ 

# I ROP No: MI-ROP-82103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-82103-2014a



## IncinerationProcessMalfunctionAbatementPlan TheCityofDetroitWastewaterTreatmentPlant 

### Table2-MalfunctionAb"tementSnmmary
POS>ible Cause(•) 

# I Meonsofl>et<otion 

# I C<»:rrective Procedures

Highcorobustion zone PLO'OCS/Vlsual De-slagaffectedheart.bs :mdlorcentershaftsecriODS Ifneeded 

# I temperatures OJ.ec.'l( ash .system.. J:fnotworlcing, stop feed, stopshaftand _I Ashsystemnotre.J::IlOvi:ng.ash PLC/OCSNisu:al corrt:rol bumout,andplaceincinetatorour:-o$-servicebefore co:rectivemaimenance**b~**_ _ Electricalordirt;yl=ses PLCIOCS Place incineratOrom-of-serviceforinstrumentcorrective

• mainterumce Othercomponentsslro.t off as PLC'OCS Controlbttmou:tandplaceiiJcineratorinstalldby=odepriorto 1 a r=J.tofP.M. PM

____**~_** _

Table2:Page6 of18

Page 95 of106Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: Mi-PTI-B2103-2014a



# -. IncinerationPl"ocess MalfunctionAbatementPlan CityofDetroitWastewaterTreatmentPlant 

### Table3-PreventativeMaintenanceSummary- TasksCommonto bothComplexI and ComplexII**P~= P.=t.r.u•~<:ter**  R.<l:l'pon:s:<bfo:s..**~** 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 (Titte)**Num~**

Electricali:ospection. Amrually EWGS'llb-Foremm. 4,5, 6 fuduced draftfun onlubrication& sensorycheck Amrually PlamM.ai:ateaance SubFor= Oil change - bearings Amm2lly PlamMaintenance SubForeman**1.~3** fucinerator_g3S btll"Xlelt Mechznic:alinspectionofbumers Quarterly Piam:MaiotenmccSubPo= 2.,3,4, 5 Mainstackdamper Electric:al & pneuma:O.e systeDlcheeks Quarterly OpC'lations
4 Scrobberdamper Check Q=ly PlantMaintenanceSubFor= I.2,3* 5.9, 11 C..'"D.te:rshaftsystem Lubeandm.ecb:an:ical check Montbly Plant:M:afu.tena:DceSnbForeman Oillevelandmechanicalinspection Quarterly PlantMaioteJ;latlceSubForeman 1,2,3,4,9, 11 Bumer·airfan**Pla:nt~ee** Sub- Mec:h.aciealcheck-drivebelt Q=ly Fot= 11 AJ1 opacitymonitors Opacitymonttor?M. Monthly WSCIT Sttb--Fo:reman

Table3:Page7 of18Detroit Department ofWater & Sewerage Detroit WastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date:January31, 2019 PTI No.: MI-PTI-B2103-2014a



## Incineration Process Malfunction AbatementPlan CityofDetroitW astewarerTreannentPlant 

### Table3-PreventativeMaintenanceSummary- TasksCommontoboth Complexl andComplexIT
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)

Electricalinspection Anllually EWGSub-Foreman Mecha:aical I:cspection Bi PlantMaintenanceSubAnllually Foreman Oper.atorinspection

- Butter.fly valvel.eahge Quacte<Iy Opex:ations-HSPO Geardrive- Bearingoilch2nge, anchorbolt check Amlually Plan:tMaintemmceSubForeman 6, 7,11 SFEpmnp:s Plan.tMain:renanceSub- Bearinghousi.ngi:nspectlon o:o.sti::ainern: Annually Foreman Electricalinspection AJmually EWGSub--Forema::a Flexible couplillg L'cbe1<>per:ation & alignment Bi PlantMaintenance SUb- ' check Amlually Fore=m I Bearinghousill.g Utspection Bi Plant MaintenanceSub- 

## AJmuaJJv Foreman Wc:i,ghtometerforbeit# 15-1
I Weigbtometerforbelt# 15-2 Weightomet:erforbelt# 15-3
' Weightometerforbelt# 15-4 / 2,. 3,**5~ 9~** 11 Cali'brationf.fuspection Mon:t:hly WSCIT Sub-Fo..-eman Wei,ghtometerforbelt# 15-5 

### weightometerforbelt# 15-.6 Weighrometerforbelt#X-9 Wcightometerforhelt#P 7 & S

- -·- ----- -- T::able3:Page8 ofl8Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a


## Incineration Process MalfunctionAbatementPlan CityofDetroitWastewaterTreatmentPlant 

### Table3-PreventativeMaintenanceSummary-TasksCommontobothComplexIandComple:di I

l"t'OCCSSl":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**forbelt# P 11 & 12 Weightometerforbelt#P 13& 14 Weigb.tometet forbelt#K-1 & 2 Weightometerforbelt#Irl & 2 

# I 2,3,5,9, 11 Weig:btotl:lete!forbelt#Q-7 & 8 Molllhly Weightomcterforbelt#Q-9& I 0 Wcigb!xlmeterforbelt#Q-11 & 12 Calibrationllnspection WSCITSub-Foreman Weighrometerferbelt#Q-13 & 14 ' We:ightomererforbe:It#M-1 &2 Weigb.tometerfor belt#N-1 & 2 I:acinetator#I OxygenADalyzers Incinerator#2 OxygenAml yzeJ"S I, 11 Monthly Incinerator#3 0'-)'genAnalyzexs Incinerator#4 OxygenAnalyzers
T:a.ble3:Page9ofl8Detroit Department ofWater

### & Sewerage DetroitWastewaterTreatment Plant



## Incineration ProcessMalfunction AbatementPlan CityofDen-oitWastewaterTreatmentPlant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a



### Table3-PreventativeMaintenanceSummary-Tasks Commonto both ComplexI andComplexII**~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#5OxygenAnalyzexs Incina:ator**~** OxygenA:oalyzers Incinerator#7A OxygenAnalyzer Incinerator#7B O>..")'gen.Analyzer Incinerator'#SA OxygenAtlalyze:r Incinerator#8B OxygenAnalyzer Incinerator#9A OxygenAnalyzer 1.11 Incineruor#9B OxygenAn:al}Zer Calibrntioollnspection Monthly WSCITSub-Foreman
.Incinenttor#lOA Oxygen.Analyzer In.cio.erator#1OB OxygenAnalyzer Incinerator#llAOxygen.Analyzer Jnc:inera.tor#!l:S OxygenAnalyzer Incinerator#12..<\ OxygenAoalyzer Tncinerator#l2B OxygenAnalyzer Incinerator#l3AOXygenAnalyzer

T:able3:Page 10 ofl8

### --~----------------------------------------·--------------------------------------------

Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant ROP No: Mi-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MJ-PTJ-B2103-2014a



## Incineration Process MalfunctionAbatementPlan CityofDetroitWastewaterTreatmentPlant 

### Table3- PreventativeMaintenance Su=ry-Tasks Commontoboth ComplexI andComplexII
l'rocess**P;~.r.UJ~ct~:r** Responsible Supe>:'Viscr**Rcf~ee** M:ti-=incd**Eqa~pment** Pn!-venttti"'cM::tintcn::u'<<:e**T::~sk** NumQ.c.- (fitlc)

lllcinemor#13-B OxygenAnalyzer 1, 11 Iucine:r:ator #14AOxygenAnalyzer Ca!fbtatio:o!Inspection Moothiy WSCIT Sub--Foreman Incinera-tor#14B OxygenAllalyzer

Ta:ble3: Page 11 ofiSDetroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant ROP No: Ml-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a



## Incineration Process MalfunctionAbatementPlan CityofDetroitWastewaterTre21mentPlaru 

### Table3-PreventativeMaintenanceSnmmary-TasksPecttliartoIncineration ComplexII.**Equiptr~cnt** ComPQI'Itnt**M:~iln:::itncd** EquipmeJtt**P«!YeE~t:ati"ve**M:i.utcna:.c:eT2Sk Frequency RcspoMiblcSapCM'isar 

# ""'.,..,., (Tltle)**N~..,.**

Noz:deinspection Semi- Pl:aDt Mai:ol:e;oance Sub- 4,6,7, 11 Venturinozzle =mally For= Electricalinspection A=lly E'WG Sub-F'oren:J2ll 1,2,3,4,8 Au:xi.liazycombustion airfan Semi- Plant!V.faintenanceSub- Mec'blmical check- belt drive ammally Fo=

Table3: Page 12of18



# ·-·-------------Detroit Department ofWater& Sewerage DetroitWastewaterTreatment Plant

.M:aintaiDed Equipment

Complex2 InducedDxaftFm

Inciner.a:torGasBnmers C2 Ce:nt:rai Slta.fr:CoolingAirFan

Jncmer:arorDriveReducers

A.1JxilWyCombusti()nAirFan 

## Incineration Process MalfunctionAbatementPlan City ofDetroitWastewaterTreatmentPl:ant



### Table4- 

### SparePartsIdentification DescriptionofPart EM:PACor**Mfg~**PartNumber

Adapter.,.Be:aJ:i!lg: 2-5116"'bore 000000000004203 Bearing,l'illowBlock: SKFFSAF 000000000007966 517 Bea:cillg.Roller: tapered with race 000000000003456**Cotrp~** Flexible: Typecrowned tooth 000000000000240 Ring,. Stabilizing: S'KFSR17 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 PIN5VX950 000000000002134 limiter,Incinerator: Torque409/3 000000000508320 Belt, V-drive: Goodyear 000000000008796 Damper. Fan: Btcn:l.ei'airf'a:r:t#73-NH 000000000002496 Adapter, lncineta:cor 

### ooooooooOoo2731 Coupl.i:tlg,Hose: l**~"'typeD** female 000000000009922 Complex 1IncineratorPiping/Hoses Hose,. Incinerator 000000000003045' Nozzle, Inciner.ator 000000000003964

Nozzle,. Spray 000000000007157 Tab!e4:Page 13 ofIS ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 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 ofWater & Sewerage DetroitWastewaterTreatment Plant

MaintainedEqnipment

Complex 1ShaftCoolmgA.5rFan

Complex 1BurnerAirFan

Complex 1Induced DxaftFan

OpacityMonitor

- ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-82103-2014a



## Incineration Process MalfunctionAbatementPlan CityofDetroitWastewaterTreatmentPlant**T~ble**

## 4- SparePartsIdentification Description ofP:art EMPAC orMfg.l'artNumber Quantity

·--·
Belt,V--drive: GoodyearPIN C-90 000000000006584 3 Sheave.StdV-belc 03 Grooves 000000000004562 1 TypeB-.2 Sheave,StdV-belc:: CGroove3Type 000000000005484 I B2 Bearing, PillowBlock: w/colball 000000000010269 2

Belt,V--drive: Wedge cogtype 000000000009397 6 Sheave.Std V-belt5V -beltgrooves6 000000000008123 1 Sheave, StdV-beh: 6grooveOD 9"' 000000000013117 1

Adapter. .Bearing:3-15/16"bore 000000000003642 2 Bearing, P.JiowBlock: Linkbelt 000000000007546 2 Bearing,PillowBlock::3-15!16"bore 000000000012520 2

Bearing. Ro-Uer: Sphericaltapered 000000000004311 1 Couplin,g:,.FlexibleFa:o: Endbore3- 000000000000524 1 15116" ConnectorKit,. MultiI/0 000000000508334 I PurgeFilters 000000000508289 I Lens Oe2llingFluid 00000000050S336 1

Table4:Page 14 oflS

### --~--------------------------**·~·------------·-------·----------**

Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant

M:aintai:oed Equipment

OpacityMoni.ror

SFE)'ump

Oxyg001 Anal):Zer ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: Mi-PTI-B2103-2014a



## Incineration ProcessMalfunctionAbatementPlan CityofDetroitWastewaterTreatmeotPlant



### Table4- SparePartsIdentification Description ofP.art EMPACorMfg.PartNumber Quantity

Dessicator(Head) 000000000508537 1 Dessk:ator (R.etro) 000000000508636 1 AJ.igmnootTool 000000000508295 I 0-lang,0.139X-«ori3.359ID 26!1895 116 1 o.:Rmg, 0.139 X-s""'-1.6.500 ID 2612202116 1 Bearing.sleeve3-11!164-3fl6 2523773 186 1 Bearing, sleeve3-ll/I64-3/16 2623774186 2 Bea:r:itlg, sleeve 3-1VI64-3/16 2623775**IS~** 3 Ring,lateralboWlwear{co:re#262 26243271!8 1 32l!XB) Co:re,late:r:albowlwearring32HXB 2628537222 1

Bearing,sleeve3-15/164-7/16 27271!2186 4

Be:arlng,. shaft3-15!165-718 4778535 118 I Assembly, Filter:oxygen :analyzer 000000000013438 1 Board,printed circu:itpowerso.pply 000000000005146 I

Board,.printedcircuit:indicator 000000000005443 1 Board.prln.ted circuit: processing. 0000000000!2594 ! HexagonboltM5x I 6mi!Iitneter 0000000000!2086 12 T:a:ble4:Page 15 of18 I I

I

## ------------------------------------------~------~------------

Detroit Department ofWater & Sewerage DetroitWastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PTI-B2103-2014a



## IncinerationProcess Malfunction Abatement

## Plan City ofDetroitWastewaterTreatmentPlant

-



### Table4- SparePartsIdentification
MaintainedEquipment Descripti()D ofP.art EMPAC orMfg. Part Number Quantity

Box, probemounting 000000000004942 l Box,tetminal:: for detector 000000000005226 1 N"rpple. Teflon.: for .25OD 'lllbe 000000000007095 

# I 3 0-riog.oxygenamt1yzer: forfilter 000000000005678 6 0-r.ing. seal: C-65 0000000000073!! 6 O....nen.Analyzez Probe,sampl"'ZTA30" 000000000010036 l Pun,p,air. l!SV AC 000000000012838 1 Sensor, oxygen: forzicromatie 

# oxv= 000000000001073 1 Terminalblock, ceramic 000000000012390 1 Valve, a:oalyzervitonforoxygen 000000000013128 1 V3lve. 3-wayknob controlst::riDJ.ess 000000000005679 1 ! Cable,.conttol:progr:amrrringfOIC 000000000007946 1 I cable Chassis,monitor: 10slot 000000000001788 2 Digital ControlSystt:m BacklightlampforLCD 000000000006782 1 Module, control: modularcardslot 000000000000328 4

Module, COll.trol:analogoutput OQ0000000001616 2 modnic

T2bie4:Page 16ofIS:Detroit Department ofWater & Sewerage Detro"l! WastewaterTreatment Plant ROP No: MI-ROP-B2103-2014a Expiration Date: January31, 2019 PTI No.: MI-PT!-B2103-2014a



## IncinerationProcessMalfunction**Ah~tE>:m.ent.Pt""'-··** City ofDcuoit \VastewaterTreatrne.nl Plant



### Table4- SparePartsIdentification
Mairrtained Equipment Descripti:on ofPart EIVIP'AC QrMig.P2:rt Number Quantity

-----· -- ---·-··- 

### -- ------- --···-- ----**---------~------** ------- --- ·- 

### - -
Weig:b.tometer-Tecbnetics.model**TratJSd:o:cer~** L VDT 0000000000!5373 I Board, computer: PINEC0074 000000000000409 I Boord, display.**sup~**PIN 000000000006492 I EC0725 Board, powersupply 000000000007842 I Welghtoroeter-AuroweigbInteg:tator**Encoder~**weightometerbeir:speed 000000000000731 1 modelMicroV1 roodcl Integrator, weigh-scale: with 000000000006924 1 enclosure**Integrator~**weigb-sca.le 000000000013662 1 T:r:ansdncer, loadcell 0000000000I3S4I 1 Comrolle.r, history: trallsfercard 000000000013057 2 Controller, memory: card 000000000004303 4 Digital Co:ntroiSystem Controller,program: progr:ammable 000000000006406 2 Supply,processor:power 000000000004440 2 Switcb,trnmfor 000000000008247 1 !'e:m:pe:Iml.lre Element Sensor,.**tempe~:**andthetmowell 00000000051)7867 20

Table4'Page**18~fl8**

### .

## '

March 18,2015.

Mr. ChristopherEthridge SoutheastMichiganDistrictSupervisor MichiganDepartmentofEnvironmental Quality Air QualityDivision 27700 Donald Coutt Warren, 

### MI 48092-2793 Re: Warren WasteWaterTreatmentP.iant FinalControlPlanfor Complianoe with**~** 

### ...



### 40 CFR, Part.60,-Subpatt

### MMMMandR336.1972


## DearMr.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' 

### beforetheMarch21, 2016 compliancedate. · The t1ve final control plan elements required to indicate Wanen's intentto continue operation of our SSl unit, inaccordance with 40 CFR, Section 60.5110 are hereinlisted, 1. Description ofcontroldevices and process changes to comply.witlttheemission limits and 

### otlter Subpart

### MMMMrequirements.



### - Preliminarytesting indicated thatimprovementsto the SSI

### are necessaryto meet the new HCI limits and, 

### while results showed compliance with particulate, lead, and cadmium limits, technology should be added to assure consistent removal ofthese parameters as well.

- Warren plans on designing aud htstalling additional equipment to control HCl, particulates, and solid metals and to allow provisions for adding mercuryremoval in

### the. future, ifrequired. Tho teclmology selected is a venturi style wet scrubber technology called aVenturi Pak. 2. Types ofwasteburnedattheSSInnlts,



### - Only sewage sluqgewillbe bumed.

### 3, 

### Maximum design 

### capacity of

### yourSS1 

### units. Based on 43 

### years ofoperating experience treatingWWTP 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 wetJbs/hour,

## withthe average atjustover9,000wetJbs/hour. 

## 4. Sitespecific operatinglimits under

### 40 C.F.R. 

### §60.5175.

- This 

### is notapplicable fo1'

### Warren'sproposed technology. 5, Signatureoftlte ownerm· operatoroftlte

### SSIunits,

DM/mvc
CertifiedNo. 7013 3020 0000 

### 5396 2254

Adm.inServ/State/F1aniControlPhm3.18.15 

# 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 TELYPI!0:\1(:**73.J··48.J-~6011** 

# wr-:usrn·:: www.ynw.org

VIAFIRST 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 CommunityUtilities

### Authority- SRN

### B6237 40 CFR Part60 Subpa1t

### MMMM Final ControlPlan

Dear Mr. Miller: The following Final Control Plan is being stJbmitted in response to your letter dated January 30, 20I 5 regarding the development ofa Michigan State Plan for ExistingSewageSludge 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 the4Mstandard is as follows: 1, Description ofcontrol devices and process changes to comply with the emission limits and other SubpartMlv!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 guidancepromulgated underthe 4M standard will limit sulfurdioxide emissions to 15

## Mr. ScottMiller MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY March 19,2015 Page 2

ppmV fi·om existing fluidized bed incinerators. Presently, EU-FBSSI is not currently regulated for sulfur dioxide emissions. buthistorical 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 ofthe caustic feed system. YCUA received notification from MDEQ in a letter dated July 29, 2014 that it is in suppoti ofour analysis. YCUA anticipates construction ofthe caustic feed system will begin in thenext 30-60 days. At this time, YCUA does notplanto install any further control devices ormakeprocess changes to complywith theemissionlimits established by the 4M standard. Results of previous stack testing indicates YCUA will be in compliance with the 4M emission limits for exitingfluidizedbed incinerators without any fut1hermodifications. 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 of6,300 dry pounds per hour assuming 75.6 %volatile solids, 25.5% total solids and ahigh heating value of 10,000 Btu/lb. ofvolatile 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 CFRPart 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 forthe carbon adsorption system.

### Mr. Scott Miller MICHJGAN DEPARTMENT OF ENVIRONMENTAL QUALITY March 19,2015 

### Puge3

5. Signature ofthe wner or operator of

### the SSI units:
Jef

1rector March 19,2015



## Ifyou 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 

## ofWastewater Operations/Compliance Ypsilanti CommunityUtilities Authority

Cc: Mr. Glen E1ickson, MDEQ Ms. Valerie 01.1enther, TetraTech Mr. PeterDaukss, 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 ofseveral 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: RichardKuhl, Department ofAttorney 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 atwww.michigan.gov/deg/O 4561,7-135-3310 70310 70940-346472-- 00.html. Written comments, questions or copies ofthe 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 IUP. 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 sentto: Ms. Sonya Butler, Chief, Revolving Loan Section, Office of Drinking Water and Municipal Assistance, DEQ, P.0. Box 30241, Lansing, Ml 48909-7741. Information Contact: Sonya Butler, Office of Drinking Water and Municipal Assistance, 517-284-5433; or butlers2@michigan.gov. 

# DJvis(oitPermit 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 SherryThelen

### 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 ofthe Air Quality Division's (AQD) Administration Section atthe Michigan Department of Environmental Quality. Iwill be serving as the Hearing Officerforthis public hearing on the proposed state plan for sewage sludge incinerators. With me are Lynn Fiedler, Chief ofthe AQD, who is representing the Director ofthe 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 hourfrom now}. Hearing Agenda First, we will begin with some background information aboutwhy we are here. Then, we will describe the purpose ofthe hearing and how your comments will be considered. Following that, we will outline the procedures underwhich we will take your comments and describe what will happen aftertoday's hearing. Then itwill be time to hearyour comments. We will spend the majority oftoday's times listening to those comments. At the end ofthe 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, ofthe 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 Wolfwill now briefly summarize the proposed state plan. Purpose of Public Hearing Thank you, Erica. Now Cari DeBrulerwill explain the purpose oftoday's hearing and how your comments will be used. Cari: In orderfor rule promulgation to occur, the Department mustfollow the procedures set forth in the Administrative Procedures Act of 1969 and the Office of Regulatory Reinvention

### procedures. The purpose oftoday'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 ofthe Notice of Public Hearing, Regulatory Impact Statement, proposed rules, and summary ofthe 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 everybodyfill out a card and indicate if you wish to make a comment. Wewill 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 ofthe names have been called, we will ask ifanyone else would like to make a statement. When your name is called, please approach the table and give your statement. Ifyou 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 ofthe information that the Department will consider when making its decision on the proposed rules. The public comment period forthe 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 staffwill review all ofthe comments and prepare an Agency Report, which includes the response to comments. The Agency Reportwill be available on the Department's website or by contacting the AQD office. The proposed state plan will then be submitted to the USEPA for approval. Thank you, Cari. I will now begin calling the names ofthose who have indicated that they would like to make a statement. Closing Statement Thank you foryour 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. Ifyou have any questions regarding the proposed state plan, AQD staffwill be available immediatelyfollowing this hearing to answer them. The hearing is now closed. Thank you again. ***************************************************** 

### Ifafter one hour, no one has arrived for the hearing It is now {enter currenttime}, 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 ofJuly 13, 2015 to August 19, 2015.The public hearing was held on August 19, 2015, at 1O: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 ofall designated facilities, including emission data forthe 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 manneras to show the relationship between measured or estimated amounts of emissions and the amounts of such emissions allowable underapplicable emission standards. (b) Each plan shall provide for monitoring the status ofcompliance 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 (calendaryear) basis, commencing with the first full report period after approval of a plan, orafter promulgation of a plan by the Administrator. Information required underthis paragraph must be included in the annual report required by §51.321 ofthis chapter. 

## (f) Each progress report shall include:

.... That language appears to require thatthe state submit in an annual report (per40 C.F.R. § 51.321 ), an update on the status ofall subject facilities, including the existence ofsubject facilities (the inventory), and compliance ofeach with emissions standards. The MDEQ's new provision seems contrary to that requirement if it only requires reporting ofthis information in discussions. Ifyou 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 USEPA" stated below, was inadequate to meet the requirements under 40 C.F.R.§60.25. "The MDEQ agrees to inform the USEPA ofthe status ofaffected 

## SSI sources with the March 21, 2016, compliance deadline by April30, 2016. Any compliance delayorfollow 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 ofthe State Plan to the following: "The provision of40 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 oftechnical 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 ofthese items. "