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HomeMy WebLinkAbout05.a.4) Title V Annual Report Report on Environmental Protection Agency final sewage sludge incinerator regulations (Section 129)5.a.� Centr Co Cost Sanitar District ........................ .... .......... ......... ........ .............. ....... .. : . ......... February 17, 2011 TO: HONORABLE BOARD OF DIRECTORS a VIA: JAMES M. KELLY, P.E., GENERAL MANAGER . - F M ARGAR ET P . ORR, P.E., DIRECTOR OF PLANT O SUBJECT: TITLE V ANNUAL REPORT OVERVIEW Central Contra Costa Sanitary District (CCCSD) is regulated by the Bay Area Air Quality Management District (BAAQMD) under a Major Facility Review Permit (Plant # A0907). An annual report is due to the United States Environmental Protection Agency (USEPA) and the BAAQMD each January 31. The Annual Report was sent to the regulatory agencies and is attached. BACKGROUND Title V is a federal program designed to standardize air quality permits and the permitting process for major sources of emissions across the Country. The name "Title VTV comes from Title V of the 1990 Federal clean Air Act Amendments which required the USEPA to establish a national, operating permit program. Accordingly, USEPA adopted regulations Title 40 of the code of Federal Regulations, chapter 1, Part 79, which require states and local permitting authorities to develop and submit federally enforceable operating permit programs for EPA approval. The local permitting authority is the BAAQMD. CCCSD submitted. an application for a Title V permit on October 23, 1995. Being a new program, the first permit was issued on May 17, 2000. Permits are renewed every five years. Title V only applies to `major sources." EPA defines a major source as a facility that emits or has the potential to emit any criteria pollutant or hazardous air pollutant (HAP) at levels equal to or greater than Major source Thresholds (MST). The MST for criteria pollutants may vary depending on the attainment status (e.g. marginal, serious, extreme) of the geographic area and the Criteria Pollutant or HAP in which the facility is located. The attainment status for the Say Area has not been met for Ozone, Particulate Matter in two sizes (PM1o California standards and has not been met for Nitrogen oxides (NOx) per Federal standards. The overall attainment status for the Bay Area is marginal. CCCSD is part of this regulatory program because the District exceeds the MST for the criteria pollutant Nitrogen Oxides (NOX) mainly from the multiple - hearth furnaces (MHF), cogeneration unit, boilers and numerous other devices within the Plant. A total of 31 sources exist at the Plant, which does not include the fork lift fleet that was modified in 9009 and 2010 to meet new stringent requirements for particulate material releases. CCCSD has 15 abatement devices, which reduce the Potential to Emit (PTE). Enforcement is done on actual emissions, not on PTE. Similar to the National Pollution. Discharge Elimination System (NPDES) permit that regulates CCCSD discharge to waters of the state, the Title v permit provides for robust protection of the air. Fifty -seven parameters are tacked by the online. computing system, averaged every 20 seconds for compliance. 2010 PERFORMANCE There were two Reportable Compliance Activities (RCA) in 2010. First, the opacity. on the MHF was greater than 20% for 4 minutes and 7 seconds from 1 7:59:49 and 18 :03 :58 on January 1, 2010.. The permit allows for a 3- minute variance, Sludge and scum were being fed to the MHF. Scum is made up of high BTU fats, oils, and grease, along with a little water. Scum has a much higher BTU content than sludge. Scum can vary significantly in both BTU value and water content. as it is fed into the MHF. After a few hours of adding scum, the burn zone flared, causing a localized oxygen - deficit zone, which resulted in the opacity excursion. CCCSD notified BAAQMD of the RCA. Enforcement action from BAAQMD is still pending and may not occur, as similar short excursions have not resulted in fines. The last opacity fine was $500 in 1999. Second, the indicated opacity on MHF was greater than 20% for 14 minutes and 34 seconds starting at 8:05:52 and ending at 08 :20 :25 on May 12, 2010, due to a mechanical failure of the monitoring system. The Plant operator took the appropriate actions which included visually checking the stack, establishing that all other operation parameters were good, and then immediately cabling CCCSD's Instrument Shop. The Instrument Shop Technician arrived promptly, diagnosed the problem, and made the appropriate repairs. The actual opacity did not exceed 20 %. No enforcement action is expected. BAAQMD rules require any diesel engine ? 50 HP have a valid BAAQMD Permit to Operate. A 4 -inch Gorman Rupp Pump was purchased in July 2009. It was recently discovered that this pump is rated for a maximum continuous break horsepower of 51.3 and does not have a valid BAAQMD Permit to Operate. CCCSD has stopped using the pump and submitted a permit application. Fees are anticipated for use that occurred without a permit in 2010. SUMMARY CCCSD's systems and procedures are working to meet the stringent requirements of the Title v permitting program which is designed to protect the air quality of the Bay Area.