HomeMy WebLinkAbout07.a.1) Title V Annual Report - Summary memorandumCentral Contra Costa Sanitary District
January 26, 2012
TO:
VIA:
FROM:
HONORABLE BOARD OF DIRECTORS
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JAMES M. KELLY, P.E., GENERAL MANAGER
ANN E. FARRELL, P.E., DEPUTY GENERAL MANAGER
MARGARET P. ORR, P.E., DIRECTOR OF PLANT OPERATIONS 7v.1. 6,,,
SUBJECT: TITLE V ANNUAL REPORT
SUMMARY
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).
The Title V permitting program is designed to protect the air quality of the San Francisco
Bay Area. CCCSD was in full compliance in 2011 with no permit violations. There were
four deviations in the course of the year which is not unusual.
2011 PERFORMANCE
The four Title V Deviation Reports in 2011 are described as follows. The first deviation
occurred because a portable diesel pump engine was purchased at 58- horsepower
exceeding the 50- horsepower limit. The issue was resolved by getting the pump
permitted. The second deviation occurred when the furnace was cooled and sludge
feed stopped to allow for a maintenance activity. BAAQMD determined that the
temperature limit is only required when sludge is being fed. The third deviation
occurred when a contractor removing asbestos was not following all the stringent
abatement requirements, the District shut down the job, and the contractor was issued a
notice to comply by BAAQMD, compliance was achieved. The final deviation occurred
due to routine maintenance of the nitrogen oxides analyzer when doing maintenance on
the cogeneration system, this is a routine deviation.
BACKGROUND
Title V is a Federal program designed to standardize air quality permits and the
permitting process for major sources of emissions across the United States. The name
"Title W comes from Title V of the 1990 Federal Clean Air Act Amendments, which
required the United States Environmental Protection Agency ( USEPA) to establish a
national, operating permit program. Accordingly, USEPA adopted regulations Title 40 of
the Code of Federal Regulations, Chapter 1, Part 70, which require states and local
Honorable Board of Directors
January 26, 2012
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permitting authorities to develop and submit federally enforceable operating permit
programs for USEPA approval. The local permitting authority is the BAAQMD.
CCCSD submitted an application for a Title V permit renewal on June 9, 2011, and
BAAQMD has extended the term of the existing permit until the updated 5 -year permit
can be issued.
Title V only applies to "major sources." USEPA 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, and
extreme) of the geographic area and the criteria pollutant or HAP in which the facility is
located. The attainment status for the San Francisco Bay Area has not been met for
ozone and particulate matter in two sizes (PM10 or 2.5) per California standards, and has
not been met for the new 24 -hour small particulate matter (PM2.5) per Federal
standards. The overall attainment status for the San Francisco Bay Area is marginal.
CCCSD is part of this regulatory program because the District exceeds the MST for the
criteria pollutant ozone precursors, nitrogen oxides (NOx) and volatile organic
compounds (VOC), mainly from the multiple -hearth furnaces (MHF), cogeneration unit,
boilers and numerous other devices with in the plant. A total of 30 sources exist at the
plant, which does not include the fork lift fleet that was modified in 2009 and 2010 to
meet new stringent requirements for particulate material releases. CCCSD has 15
abatement devices, which reduce the potential to emit (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 tracked by the online computing
system, averaged every 20 seconds for compliance. CCCSD met all permit
requirements in 2011.
N: \POSUP \Board of Directors \Board - GM Reports \2012 \Title V Annual Report Memo 01- 26- 2012.doc