AIR EMISSION PERMIT NO IS ISSUED TO. Pope/Douglas Joint Solid Waste Management Board

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Pope/Douglas Joint Solid Waste Management Board POPE/DOUGLAS SOLID WASTE MANAGEMENT 2115 Jefferson Street South Alexandria, Douglas County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Issuance Date Action Number Total Facility Operating Permit 03/27/2009 / See below -003 Reissuance/Major Amendment 10/04/07 This permit authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Pt 70/Major Source for NSR Issue Date: January 20, 2010 Expiration: January 20, 2015 All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix A: Insignificant Activities and Applicable Requirements Appendix B: July 27, 2004 Variance Appendix C: Modeling Parameters

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: Pope/Douglas Solid Waste Management is a waste combustion facility, operating two waste combustors identified in the permit as emission units EU 001 and EU 002. Each waste combustor is an independent system, consisting of excess air mass burn refractory combustion chambers followed by heat recovery boilers. Flue gases from both systems exit through a common stack. The two waste combustors combined were, initially, capable of burning a total of 80 tons of mixed Municipal Solid Waste (MSW), Refuse-Derived Fuel (RDF), and/or other solid waste per day (based on an annual average). The waste combustors may be operated independent of each other. The original waste combustors were installed in 1986 and became operational in The replacement of the waste combustors commenced in October of 1997 and initial startup was in June of 1999.

4 Pollution control equipment consists of dry lime injection for the control of acid gases, activated carbon injection for the control of dioxin (and possibly mercury) and a fabric filter (FF) for the control of particulate matter and other metals. A portion of the flue gases are recirculated from the FF ductwork to the combustion chamber to regulate FF temperature. Exhaust gases enter the atmosphere through a single 70-ft. tall primary stack. Exhaust gases are continuously monitored for carbon monoxide, sulfur dioxide, opacity, and oxygen. A number of operating parameters, including fabric filter inlet temperature, steam flow rate, and activated carbon feed rate parameters are also monitored continuously. Ash produced in the course of waste combustion is loaded into a truck in an enclosed area at the facility. The ash is covered and transported via trucks to the Pope-Douglas Ash Landfill (permit number SW-410). Upfront of the incineration process, the facility operates a Materials Recovery Facility. This operation is housed within the incineration building, and its purpose is to manually and mechanically process waste to accomplish the following: - identify and remove problem materials - remove recyclables such as aluminum, ferrous metals, and cardboard - remove non-combustible material In addition to being a Total Facility Operating Permit Reissuance, this permit action authorizes the following for the existing waste combustor units (EU 001 and EU 002). First of all, this permit clarifies what previous performance testing has demonstrated the EU 001 and EU 002s charge capacity to be (60 tons per day each). Permit limits will be taken to restrict the NO X and MSW acid gases (HCl + SO 2 ) emissions to less than Federal New Source Prevention of Significant Deterioration (PSD) major thresholds (40 CFR 52.21). The stack height will be raised to 105 feet. This permit action also authorizes the addition of a new municipal waste combustion unit (EU 006). Similar to existing Units 1 and 2, the new municipal waste combustor (EU 006) will be an excess air mass burn refractory unit. The proposed unit will be rated at a nominal charge capacity of 120 tons of waste per day, depending on the heat content of the waste. The combustor will also be able to burn natural gas, which is used at start-up and as necessary in addition to waste combustion to maintain temperatures within the optimal range. The new combustion unit emissions will be controlled by a dry sorbent injection, powdered activated carbon injection, flue gas recirculation, and fabric filter baghouse.

5 TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do OPERATIONAL REQUIREMENTS hdr Why to do it The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. TESTING REQUIREMENTS Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A and/or B. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. 40 CFR pt. 50; Minn. Stat. Section , subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps. 1, 2 & 4; Minn. R Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr Minn. R. ch Minn. R , subp. 1-4, and Minn. R , subp. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Minn. R

6 TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Ash Testing: Conduct ash sampling at least quarterly in accordance with Minn. R to form an annual composite sample. The permittee shall analyze the annual composite sample in accordance with Minn. R , subp. 4, item A, tables 1 and 2. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. MONITORING REQUIREMENTS Monitoring Equipment: Install or make needed repairs to all monitoring equipment prior to the effective date of each applicable emission limit if monitoring equipment is not installed and operational on the date the permit is issued. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment that have manufacturer's calibration procedures and check the accuracy of meters and monitors that cannot be calibrated. If the accuracy of equipment that cannot be calibrated is outside of recommended manufacturer's specifications, it must be replaced (any requirements applying to continuous emission monitors are listed separately in this permit). Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Permittee shall maintain records adequate to document compliance at the stationary source, including at a minimum: (1) the date, place, and time of sampling or measurement; (2) the date or dates the analyses were performed; (3) the company or entity that performed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions existing at the time of sampling or measurement Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. Recordkeeping: Maintain a file of all measurements, maintenance reports and records for at least five years. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING/SUBMITTALS Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. Minn. R , subp. 3 Minn. R , subp. 2 (D) MSW Ash Combustor Variance of October 1996 hdr Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 4(D) hdr Minn. R , subp. 5(A) Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 1; Minn. R , subp. 5(C); 40 CFR 60.7(f) Minn. R , subp. 4 hdr Minn. R , subp. 3 At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over.

7 TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Ash Testing Report: Submit an annual ash testing report to the Commissioner by March 15 of each year. The report must contain at a minimum the information in Minn. R , subp. 10, items A - F. Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due 91 days after end of each calendar year following permit issuance (April 1). To be submitted on a form approved by the Commissioner. Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 10 Minn. R , subp. 2(D) Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R The accumulated amount of all ABM combusted, in any year, must be included in the Emission Inventory Reports. Final ABM Fuel Usage Report. The Permittee shall notify the MPCA within 30 days of when it reaches the 1000 ton limit, on ABM, authorized for test burns, by this permit action (-003). PLANS INDUSTRIAL SOLID WASTE MANAGEMENT PLAN: Permittee shall prepare and maintain a plan for management of industrial solid waste in accordance with Minn. R , subp. 5, items A and B. The plan shall include the contents listed in Minn. R , subp. 2. Permittee shall modify the industrial waste management plan whenever the management practices or solid waste identified in the plan have changed. Permittee shall submit the amended plan to the Commissioner for approval. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Ash Toxicity: Abide by a plan to reduce the level of toxic contaminants in ash, consistent with Minn. R , subp. 6(A). Abide by a plan for the disposal and/or utilization of ash and quench water consistent with Minn. R , subp. 7. Abide by the industrial waste management plan prepared in accordance with Minn. R Minn. R through Minn. R Minn. R , subp. 2 hdr Minn. R , subp. 1; Minn. R , subp. 3 Minn. R , subp. 6 Minn. R , subp. 7 Minn. R , subp. 2(E)

8 TABLE A: LIMITS AND OTHER REQUIREMENTS A-4 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Prepare (if not completed on the effective date of this permit) and keep the following plans with the Operating Manual. A. security requirements in part , subp. 3; B. general inspection requirements in part , subp. 4; C. household hazardous waste management requirements of part , subp. 6, D. emergency preparedness and prevention plans and emergency procedures shall be prepared in accordance with parts and E. contingency action plans in part ; F. closure plans and procedures in part ; G. solid waste transfer facility requirements as required in Minn. R ; H. infectious waste management plan (if Permittee chooses to accept infectious waste), in accordance with Minn. R to Plans (if not completed) shall be prepared within 90 days of permit issuance. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Ash Testing Plan: Submit amendments to the ash testing plan to the Regional Environmental Management, Northwest Region, Regular Facilities Unit for approval. The plan must contain the information in Minn. R , subp. 6(A) - (H). Prepare and regularly update a plan to identify, separate, and collect before combustion solid wastes which contain mercury. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. The Permittee shall implement a plan as described in part to identify, separate, and collect solid wastes which contain mercury before the mercury is combusted. QA Plan required: Develop and implement a written quality assurance plan which covers each CEMS and COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain the written procedures listed in Minn. R , subp. 1. Reporting: All submittals required by this permit must be certified by a responsible official as defined in Minn. R , subp. 21. Submittals which must be provided on forms approved by the Commissioner are noted in table B. All submittals must be postmarked or received by the date specified in the tables. Emergency Preparedness and Prevention: The Permittee shall maintain and test, at least annually, the required equipment for emergency preparedness and prevention. The Permittee must also prepare and maintain a procedural manual to use in times of emergency. Emergency Response and Reporting: In the event of an emergency, including but not limited to fire or explosion, submit to MPCA within two weeks a written report describing the emergency, the response, and an evaluation of the effectiveness of the response in accordance with Minn. R and Minn. R DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.2(r)(6)(vi)(a). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R Minn. R (A)-(H) Minn. R , subp. 2 Minn. R , subp. 2(D); Minn. R , subp. 6 Minn. R , subps. 1 & 3 Minn. R , subp. 2(F) Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 6; Minn. R , subp. 1 Minn. R Minn. R ; Minn. R ; Minn. R ; Minn. R , subp. 2 hdr Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subp. 2

9 TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R ; Minn. R , subp. 4; Minn. R , subps. 4 & 5 The Permittee shall maintain records of this documentation. The Permittee shall monitor the actual emissions of any regulated NSR pollutant Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. that could increase as a result of the project and that were analyzed using the ; Minn. R , subp. 4; Minn. R. ATPA test, and the potential emissions of any regulated NSR pollutant that could , subps. 4 & 5 increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. MODELING hdr PM2.5 Modeling: The parameters used in PM2.5 modeling for Permit # are listed in Appendix C of this permit. PM2.5 Modeling (continued) Minn. R , subp. 2 Minn. R , subp. 2 Modeling Triggers: For changes that do not require a permit amendment or that require a minor permit amendment, and that affect any modeled parameter or emission rate, a Remodeling Submittal requirement is not triggered. The Permittee shall keep updated records on site of all parameters and emission rates. The Permittee shall submit any changes to parameters and emission rates with the next required remodeling submittal. For changes that require a moderate or major permit amendment and affect any modeled parameter or emission rate, a Remodeling Submittal requirement is triggered. The Permittee shall include previously made changes to parameters and emission rates that did not trigger a remodeling submittal with this modeling submittal. PM2.5 Modeling (continued) Remodeling Submittal: The Permittee must submit to the Commissioner for approval changes meeting the above criteria and must wait for a written approval (in the form of an issued permit amendment) before making such changes. The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. PM2.5 Modeling (continued) Minn. R , subp. 2 Minn. R , subp. 2 Remodeling Submittal (continued): The plume dispersion characteristics due to the revisions of the information must be equivalent to or better than the dispersion characteristics modeled in Permit The Permittee shall demonstrate this equivalency in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must submit full remodeling.

10 TABLE A: LIMITS AND OTHER REQUIREMENTS A-6 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Subject Item: GP 001 Waste Combustors, Units 1 and 2 Associated Items: EU 001 MSW Incinerator Unit 1 EU 002 MSW Incinerator Unit 2 What to do A. APPLICABILITY hdr Why to do it Waste combustor units EU 001 and EU 002 are defined as Class C waste combustors, pursuant to the July 27, 2004 Variance from Minn. R , subp. 14 The 40 CFR part 60 subpart A general provisions and appendices to part 60 apply to part 62, except as follows: 40 CFR 60.7(a)(1), 60.7(a)(3), and 60.8(a) and where special provisions set forth under the applicable subpart of 40 CFR part 62 shall apply instead of any conflicting provisions. B. EMISSIONS LIMITS hdr Applicability of Standards: the standards of Minn. R , , subps. 2 and 5 and , subp. 2 apply at all times when waste is being continuously burned. The standards do not apply, up to a maximum of three hours, during periods of start-up, shutdown or malfunction. Fugitive emissions standards applicable to the ash conveying system do not apply during periods of maintenance and repair of the ash conveying system. The Permittee shall not cause to be emitted into the atmosphere from each waste combustor unit gases in excess of the applicable standards. Emissions, except opacity, shall be calculated under standard conditions corrected to seven percent oxygen on a dry volume basis. 07/24/2004 Variance from Minn. R , subp CFR Section 62.02(b)(2) Minn. R , subp. 4; Minn. R , subp. 1(A) 40 CFR ; 40 CFR During startup, shutdown, or malfunction periods longer than 3 hours, emissions data cannot be discarded from compliance calculations and all provisions under 40 CFR 60.11(d) apply. The Permittee shall use data from the continuous emission monitoring systems (CEMs) for nitrogen oxides to demonstrate continuous compliance with the applicable emission limits. The Permittee shall use data from the continuous emission monitoring systems (CEMs) for sulfur dioxide and carbon monoxide to demonstrate continuous compliance with the applicable emission limits. The Permittee shall use results of performance tests for dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash to demonstrate compliance with the applicable emission limits. Front-half Particulate Matter: less than or equal to 70 milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods, sampling time, sample volume, and other testing requirements. Total Particulate Matter: less than or equal to grains/dry standard cubic foot. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R regarding sampling methods, sampling time, sample volume, and other testing requirements. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Muni Waste Combust Organics: less than or equal to 500 nanograms/dscm. Muni Waste Combustor Organics means total of tetra-through octa-polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (Total PCDD/PCDF). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R regarding sampling methods, sampling time, sample volume, and other testing requirements. Muni Waste Combust Organics: less than or equal to 125 nanograms/dscm. Muni Waste Combustor Organics means total of tetra-through octa-polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (Total PCDD/PCDF). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods, sampling time, sample volume, and other testing requirements. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R CFR Section CFR Section CFR Section (a)(2) 40 CFR Section (a) Minn. R , Table 1; Minn. R Minn. R , Table 1 40 CFR Section (a)(2)

11 TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Muni Waste Combust Organics: less than or equal to 20.0 nanograms/dscm. Muni Waste Combustor Organics means total of tetra-through octa-polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (Total PCDD/PCDF). This limit is applied in accordance with Minn. R , , subps. 2 and 5 and , subp. 2. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods, sampling time, sample volume, and other testing requirements. Minn. R , subp. 2 This limit will apply to MSW Incinerator Unit 1 (EU 001) and MSW Incinerator Unit 2 (EU 002) within 180 days after achieving the maximum production rate at which MSW Incinerator 3 (EU 006) will be operated, but no later than 365 days after initial startup of MSW Incinerator Unit 3 (EU 006). This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Cadmium compounds: less than or equal to 0.10 milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) regarding sample volume. Lead: less than or equal to 1.6 milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart3(c) regarding sample volume.. Mercury: less than or equal to 100 micrograms/dscm (short term). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing requirements specified in Minn. R , subpart 3(C) and Minn. R , subpart 3(D). Mercury: less than or equal to 60 micrograms/dscm (long term). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R , subpart 3(C) and Minn. R , subpart 3(D). Mercury: less than or equal to milligrams/dscm or 85 percent reduction which ever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) and Minn. R , subpart 3(D). Mercury: less than or equal to 14.0 micrograms/dscm. This limit is applied in accordance with Minn. R , , subps. 2 and 5 and , subp. 2. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) and Minn. R , subpart 3(D). 40 CFR Section (a)(2); 40 CFR Section (a); 40 CFR Section ; Minn. R CFR Section (a)(2); 40 CFR Section ; Minn. R Minn. R , Table 1; Minn. R Minn. R , Table 1; Minn. R CFR Section (a)(2); 40 CFR Section ; Minn. R Minn. Stat , subd. 1a(e) Minn. R , subp. 2 This limit will apply to MSW Incinerator Unit 1 (EU 001) and MSW Incinerator Unit 2 (EU 002) within 180 days after achieving the maximum production rate at which MSW Incinerator 3 (EU 006) will be operated, but no later than 365 days after initial startup of MSW Incinerator Unit 3 (EU 006). This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Opacity: less than or equal to 10 percent. This limit is in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing requirements specified in 40 CFR Section and Minn. R , subpart 2. Carbon Monoxide: less than or equal to 100 parts per million using 4-hour Block Average. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the monitoring requirements specified in 40 CFR Section , 40 CFR Section and Minn. R subparts 3 and 4. Hydrochloric acid: less than or equal to 250 parts per million by volume or 50 % removal, whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing requirements specified in 40 CFR Section Nitrogen Oxides: less than or equal to 500 parts per million by volume. This limit is applied in accordance with the "Applicability of Standards" stated above. Minn. R , Table 1 40 CFR Section (a)(2) Minn. R , Table 1; Minn. R ; 40 CFR Section (a)(3); 40 CFR Section , 40 CFR CFR Section (a)(2); 40 CFR Section CFR Section (a)(2)

12 TABLE A: LIMITS AND OTHER REQUIREMENTS A-8 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Sulfur Dioxide: less than or equal to 77 parts per million using 24-hour Geometric Average or 50 percent removal, whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the monitoring requirements specified in 40 CFR Section , 40 CFR Section Fugitive Ash. Permittee shall not cause to be emitted into the atmosphere visible emissions of combustion ash from an ash conveying system, including conveyor transfer points, in excess of five percent of the observation period (i.e., 9 minutes per three-hour period), as determined by Code of Federal Regulations, Title 40, part 60, Appendix A, Method 22, as amended. This limit does not apply to visible emissions discharged inside buildings or enclosures of ash conveying systems; however, the emission limit does cover visible emissions discharged to the atmosphere from buildings or enclosures of ash conveying systems. Must follow the testing requirements specified in 40 CFR Section and Minn. R , subpart 2. Muni Waste Combust Acid Gases: less than or equal to 95.0 tons/year using a 12-month rolling sum. Emissions of muni waste combust acid gases (MWC Acid Gases) is the sum total of SO2 and HCl emissions. Nitrogen Oxides: less than or equal to 95 tons/year using 12-month Rolling Sum. C. OPERATIONAL LIMITS hdr 40 CFR Section (a)(2); 40 CFR Section ; 40 CFR Section Minn. R , subp. 1(B); Minn. R , subpart 2; 40 CFR (a)(2); 40 CFR Section Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Presence of certified operator. The person described in Minn. R , subp. 1 shall be present at the waste combustor facility at all times when solid waste is being combusted. The certified operator shall meet the minimum requirements of Minn. R , subp. 3(B) and Start-up on waste prohibited. During start-up from a cold furnace, auxiliary fuels shall be used to achieve combustion chamber operating temperature. The use of solid waste solely to provide thermal protection of the grate or hearth during the start-up period when solid waste is not being fed to the grate is not considered to be continuous burning. Auxiliary Fuel Use: Use natural gas to warm the combustion and pollution control devices and maintain good combustion conditions in the combustion chamber from the time the waste feed has been discontinued until the combustion chamber is clear of combustible material or active combustion ceases. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Allowed and Prohibited Fuels: 1) Normal Operating Conditions: Minn. R , subp. 1; 40 CFR Section ; 40 CFR Section Minn. R , subp. 3 Minn. R , subp. 2 Minn. R , subp. 2; Minn. R , subps. 4 & 5 The waste combustor may burn natural gas, solid waste, RDF, and mixed municipal solid waste, as defined in Minn. Stat. 115A.03, subp. 21, and other nonhazardous wastes approved through the Facility's Industrial Solid Waste Management Plan, except as noted elsewhere in Table A, of this permit. The facility is authorized to burn waste tires, yard waste, and household hazardous waste that are incidentally received co-mingled with municipal solid waste. The waste combustor shall not combust waste tires, yard waste, nor household hazardous waste as a separate waste stream. Allowed and Prohibited Fuels (Continued): Minn. R , subps. 4 & 5 2) Test burn conditions: limited to natural gas, solid waste, RDF, mixed municipal solid waste, and clean unadulterated wood-based biomass materials (wood chips, chunks, branches, bark, shavings and sawdust) only. The clean unadulterated wood-based biomass materials shall hereafter be referred to as Allowable Biomass Materials (ABM) for the purpose of this permit. Chemically processed or chemically-treated biomass materials are not permissible for use as a fuel. ABM allowed. The only ABM authorized, in this permit, for trial burns is/are unadulterated wood, wood chips, chunks, branches, bark, shavings, and/or sawdust materials. Alternative Fuel Testing Authorization: The Permittee is authorized to conduct test burns using ABM. When combusted under this paragraph, ABM may be fired individually or in combination with any other allowed fuel. Minn. R , subp. 4(a) Minn. R , subps. 4 & 5

13 TABLE A: LIMITS AND OTHER REQUIREMENTS A-9 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Alternative Fuel Testing Authorization: The Permittee is authorized to conduct any number of test burns until Dec. 31, 2012, using ABM as supplemental, renewable fuel. The maximum ABM permitted, under this permit action (-003), shall be a cumulative total of 1000 tons. Facility Operation: Properly maintain and operate air pollution control equipment at all times when the waste combustor is in operation and combusting waste. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions, in accordance with 40 CFR Section 60.11(d). The Permittee shall maintain an 8-hour block average mercury/pcdd/pcdf control additive feed rate at or above the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and most recent compliant PCDD/PCDF performance test. D. AVERAGING PERIODS hdr Minn. R , subps. 4 & 5 Minn. R , subp. 16(J); Minn. R , subp. 7; 40 CFR Section 60.11(d) Minn. R , subp. 2; Minn. R , subp. 3(B); 40 CFR (c) Averaging Periods: For emission limits or operational limits which are monitored continuously the following averaging periods shall be used: A) for particulate matter control device inlet temperature monitoring, four-hour arithmetic block averages calculated from four consecutive one-hour arithmetic averages. B) for unit load, a four-hour arithmetic block average, the four-hour arithmetic block averages shall be calculated from four continuous one-hour arithmetic averages. C) For opacity, a 6-minute average calculated using 36 or more data points equally spaced over a 6-minute period. D) for Hg/PCDD/PCDF control additive feed, eight-hour arithmetic block averages. Eight-hour block average means the average of all hourly control additive feed rates when the controlled incinerator operates and combusts municipal solid waste measured over any of three 8-hour periods of time: (1) 12 midnight to 8 A.M. (2) 8 A.M. to 4 P.M. (3) 4 P.M. to 12 midnight Averaging Periods (continued) E) for SO2, a geometric average of the 1-hour arithmetic average emission concentration during each 24-hour daily period measured from midnight to midnight. F) for carbon monoxide, an arithmetic average of the 1-hour arithmetic average emission concentration during each 4-hour block period measured from midnight to midnight. Minn. R , subp. 4; 40 CFR Section (a) and (b); 40 CFR Section (c) Minn. R , subp. 4; 40 CFR Section (a) and (b); 40 CFR Section (c) (continued) At least 4 data points equally spaced in time shall be used to calculate each 1-hour arithmetic average. For SO2 and CO, each 1-hour average shall be corrected to 7 % O2 on an hourly basis using the one-hour arithmetic average of the O2 or CO2 continuous emissions monitoring system. E. OPERATOR TRAINING & CERTIFICATION hdr The Permittee shall provide EPA or state-approved operator training to the following personnel: chief facility operators, shift supervisors and control room operators. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit after 5/6/2005 must complete a state approved or EPA operator training course by the date before an employee assumes the responsibilities of chief facility operators, shift supervisors and control room operators. The Permittee shall require each chief facility operator and shift supervisor to obtain and maintain a current provisional operator certification from the American Society of Mechanical Engineers QRO or a state program approved under 40 CFR Section 62, Subpart JJJ. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit on or after May 6, 2005 must obtain provisional certification 6 months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit. Control room operators shall be certified as described in Minn. R Individuals, if assuming the duties of control room operator for the first time, shall obtain certification as described in Minn. R within six months of assuming such duties. 40 CFR Section ; 40 CFR Section (a) 40 CFR Section (a) and (b); 40 CFR Section (a); Minn. R , subp. 1 Minn. R , subp. 1a(5)

14 TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Each chief facility operator and shift supervisor must obtain full certification by May 6, 2005, 6 months after EPA approval of a state operator training & certification program, 6 months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit, whichever is later. For purposes of this permit, "obtain" means a full certification from the American Society of Mechanical Engineers or EPA-approved state program or a full certification exam scheduled for the timeframes established above. The Permittee shall establish a program to review the plant-specific operating manual with people whose responsibilities affect the operation of the waste combustor. Initial review of the operating manual shall be completed by the date before an employee assumes responsibilities that affect operation of the waste combustor. The Permittee shall update and review the operating manual with staff annually. The Permittee must record the date of initial review and annual update and review. Develop and maintain the Operating Manual in accordance with Minn. R , subp. 3, items A through O; Update the manual following each performance test to include operational changes resulting from emission performance testing results. Include the revision dates within the Operating Manual; Store the Operating Manual in a location easily accessed by staff. Training Program: Persons without waste combustor or boiler operation experience must work under the direct supervision of a certified operator or a certified operator's designee for 40 hours before assuming job-related activities affecting air emissions. The Permittee must record the date of the training session and the number of hours training in each session. Training Program: The Permittee will implement a training program, based on the Operating Manual, designed to maintain compliance with this permit, Minn. Rules and federal regulations. Individual training must be specific to the position held. Waste combustor personnel who have responsibilities which affect the operation of the waste combustor must be trained in the operation of the facility. These personnel include, but are not limited to: - chief facility operators, - shift supervisors, - operator supervisors, - control room personnel, - ash handlers, - maintenance personnel, and - crane/load handlers. Training Program: (continued) The Permittee will: - Implement the required training; - Identify all people described above who must be trained; - Include a separate page for each of these people in the Operating Record; - Report the names of those who have been trained, the type of training received, and the date the training was completed, as required, in the Annual Report following training as required under Minn. R , subp. 4. Certified Operator: The Permittee shall: 1) Maintain at the facility a record of the names of all certified personnel. This record shall contain the exam dates, the content of the exam, the full name of the certified individual, the examiner's signature and the certification statement in Minn. R , subp. 3. 2) Maintain at the facility a record of the names of all personnel who have obtained provisional and/or full certification by ASME. 40 CFR Section (c) and (d); 40 CFR Section (a); Minn. R , subp. 1; Minn. R , subp. 1a 40 CFR Section (b), (c) and (d); Minn. R , subp. 1 Minn. R , subp. 3; 40 CFR Section (a); 40 CFR Section ; 40 CFR Section Minn. R , subp. 1(C)(1) Minn. R , subp. 1; Minn. R , subp. 2; Minn. R , subp. 4 Minn. R ; 40 CFR Section (b) 40 CFR Section Minn. R , subp. 1; Minn. R , subp. 2; Minn. R , subp. 4 Minn. R ; 40 CFR Section (b) 40 CFR Section (continued) Minn. R , subp. 3; Minn. R , subp. 3a 40 CFR Section The Permittee shall allow the Commissioner and/or Administrator to review all records related to the certification of operators including the facility's program for examination and certification of operators, the record required in Minn. R , subp. 3, and the content and results of an individual's exam. F. TESTING REQUIREMENTS hdr Performance Test: due before end of each year starting 09/23/2004 to measure Total PCDD/PCDF, total particulate matter, cadmium, lead, and opacity. A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months between test dates. (see the Technical Support Document -003 for an explanation). (Note Federal and State standards regarding reduced frequency. The Facility must meet the most stringent standard.) Minn. R , subp. 5; Minn. R (B); Minn. R , subp. 1; Minn. R , subp. 2

15 TABLE A: LIMITS AND OTHER REQUIREMENTS A-11 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Performance Test (continued) For state regulated pollutants, if all annual performance tests for a three-year period show compliance with Total PCDD/PCDF, total particulate matter, and opacity limits in this permit, the Permittee may choose to conduct performance tests every 2-1/2 years. At a minimum, a performance test shall be conducted every 2-1/2 years, but no more than 30 months following the previous compliance test. Minn. R (B); Minn. R , subp. 1; Minn. R , subp. 2 If a performance test indicates noncompliance with the limits, the Permittee shall resume annual testing, for three years, for that pollutant for which noncompliance was demonstrated. If all performance tests for the three-year period again show compliance with the limits, the Permittee may again conduct performance testing every 2-1/2 years. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Performance Test: due before end of each calendar year starting 05/06/2005 (or on the date as determined by the Administrator under 40 CFR part 62, subpart JJJ) to measure Total PCDD/PCDF, front-half PM, cadmium, lead, fugitive ash emissions, and opacity. A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months between test dates. (see the Technical Support Document -003 for an explanation). (Note Federal and State standards regarding reduced frequency. The Facility must meet the most stringent standard.) Performance Test (continued) For the federally regulated pollutants listed above, the Permittee may conduct performance tests every third year, if the following conditions are met: All performance tests for a given pollutant, over the 3 previous years, demonstrated compliance with the emission limit. The next performance test is conducted within 36 months of the anniversary date of the third consecutive performance test that demonstrates compliance with the emission limit. Thereafter, the Permittee shall conduct performance tests, every third year, but no later than 36 months following the previous performance tests. If a performance test does not demonstrate compliance with an emission limit, the Permittee shall conduct annual performance tests for that pollutant until all performance tests over 3 consecutive years demonstrate compliance with the emission limit for that pollutant. Performance Test: due before end of each calendar year starting 05/06/2005 (or on the date as determined by the Administrator under 40 CFR part 62, subpart JJJ) to measure hydrogen chloride (HCl). A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months between test dates. (see the Technical Support Document -003 for an explanation). (Note Federal and State standards regarding reduced frequency. The Facility must meet the most stringent standard.) Performance Test (continued) The Permittee is allowed to conduct HCl performance tests, at a less than an annual frequency, if both the MPCA Test Frequency Plan as well as the provisions in 40 CFR Section are satisfied. To satisfy the MPCA Test Frequency Plan, the Permittee must submit a Test Frequency request incorporating the most recently approved HCl performance test results and adhering to the MCPA Test Frequency Plan. 40 CFR Section (b); 40 CFR Section (a) 40 CFR Section (b); 40 CFR Section (a) 40 CFR Section (b); 40 CFR Section (a); Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R CFR Section (b); 40 CFR Section (a); Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R In addition, the Permittee may conduct performance tests every third year (as provided by 40 CFR Section ), if all HCl performance tests, over the 3 previous years, demonstrated compliance with the 40 CFR Section (a)(2) emission limit of 250 parts per million by volume. The next performance test is conducted within 36 months of the anniversary date of the third consecutive performance test that demonstrates compliance with the emission limit of 250 parts per million by volume.

16 TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Performance Test (continued) Thereafter, the Permittee shall conduct performance tests, every third year, but no later than 36 months following the previous performance tests. If a performance test does not demonstrate compliance with the 40 CFR Section (a)(2) emission limit of 250 parts per million by volume, the Permittee shall conduct annual performance tests for HCl until all performance tests over 3 consecutive years demonstrate compliance with the emission limit of 250 parts per million by volume for HCl. The most restrictive testing frequency resulting from either the MPCA Test Frequency Plan or the 40 CFR provision shall determine the subsequent HCl performance testing frequency. Test Frequency Plan: due 60 days, after the HCl performance test, in which the Permittee seeks to change the HCl performance testing frequency. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month or 36-month intervals, or as applicable, shall be required upon written approval of the MPCA. Performance Test: due 1,095 days after 03/16/2008. If a mercury performance test shows that the emission limit is greater than 50% of the facility's Minnesota long-term mercury limit, the facility shall conduct annual mercury stack sampling. After 3 consecutive years of annual sampling that demonstrate that the mercury emissions are all, again, below 50 percent of the facility's long-term limit, the facility may resume testing every three years, upon notifying the Commissioner in writing. The Permittee shall use the performance test methods and procedures specified in Minn. R to except as modified in Minn. R and 40 CFR Section regarding sampling methods, sampling time, and other testing requirements. The Permittee shall conduct MWC organics tests with a minimum sampling time of 4 hours per test run. The Permittee shall determine the maximum demonstrated capacity of the waste combustor during the initial performance test for PCDD/PCDF and each subsequent performance test during which compliance with the PCDD/PCDF emissions limits in Minn. R and 40 CFR Section (a)(2) are achieved. Operation during performance testing. The Permittee shall report to the Commissioner the operating conditions including operating parameters of the air pollution control equipment, pressure drop across the fabric filters, flue gas temperatures, air flow rates, mercury/pcdd/pcdf control additive feed rate and acid gas control. Particulate matter control device temperature. Permittee shall determine and record the four-hour arithmetic average gas stream temperature as measured at the inlet to each particulate matter control device during the initial and each subsequent performance test for PCDD/PCDF demonstrating compliance with the PCDD/PCDF emission limits in Minn. R and 40 CFR Section (a)(2). The Permittee shall: Select a mercury/pcdd/pcdf control additive system operating parameter that can be used to calculate mercury/pcdd/pcdf control additive (additive) feed rate (for example, screw feeder speed). During each dioxins/furans and mercury performance test, the Permittee shall determine the average additive feed rate in kilograms (or pounds) per hour and determine the average operating parameter level that correlates to that additive feed rate. The Permittee shall also establish a relationship between the operating parameter and the additive feed rate in order to calculate the additive feed rate based on the operating parameter level. Exceedances of emission limits. If accurate and valid data results of a performance test demonstrate an exceedance of a standard of performance as described in this air emission permit after normal start-up, the Permittee shall undertake the actions in items A to D. A. The exceedance shall be reported to the Commissioner as soon as reasonably possible giving consideration to matters of plant or worker safety, or access to communications and the applicable reporting provisions of Minn. R , subpart 6, shall be met. B. Immediately undertake appropriate repairs or modifications to return the waste combustor to compliance as soon as possible. 40 CFR Section (b); 40 CFR Section (a); Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1 Minn. R (B); Minn. Stat , subd. 1a; Minn. R , subp. 1; 40 CFR Section (b) 40 CFR Section (a) Minn. R , subp. 1; 40 CFR Section (a) Minn. R , subp. 7; 40 CFR Section Minn. R , subp. 6; 40 CFR Section Minn. R , subp. 8; 40 CFR Section Minn. R , subp. 1; 40 CFR Section (a) and (b) Minn. Stat , subd 3; and Minn. R , subp. 11

17 TABLE A: LIMITS AND OTHER REQUIREMENTS A-13 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Exceedances of emission limits (continued): C. Conduct additional performance test(s) or shut the waste combustor down. If the waste combustor cannot demonstrate compliance within 60 days of the report of initial exceedance, the waste combustor shall be shut down on the 61st day after the report of the exceedance. The performance test shall be conducted and the test report received within those 60 days. Exceedances of emission limits (continued): D. If the Permittee cannot demonstrate compliance within 60 days of the report of the initial exceedance, the Permittee may restart the waste combustor for the purposes of compliance testing, provided that at least a 10-day notification has been provided to the Commissioner. The Permittee is allowed to operate the waste combustor until the completion of the test, after which the waste combustor must be shut down. The waste combustor may be restarted only after the Permittee receives notice from the Commissioner that it has achieved compliance with the emissions standards or restarts for the purpose and duration of additional testing after further repair or operational changes. G. MONITORING REQUIREMENTS hdr Minn. Stat , subd 3; and Minn. R , subp. 11 (continued) Minn. Stat , subd 3; and Minn. R , subp. 11 (continued) Continuous Monitoring: Permittee shall install, calibrate, maintain and operate, in accordance with Minn. R , subp. 5, monitors that continuously read and record: a) sulfur dioxide at the outlet of the air pollution control device, and carbon monoxide at the inlet of the air pollution control device. b) unit load level as determined through steam flow measurement. c) oxygen concentrations at each location where CO and SO2 emissions are monitored. d) temperatures of the flue gas at the inlet of each particulate matter control device. e) flue gas opacity. f) mercury/pcdd/pcdf control additive feed rate or other parameter for which a correlation between that parameter and the additive feed rate has been developed. Minn. R , subp. 2; Minn. R , subp. 3; Minn. R , subp. 3; 40 CFR Section ; 40 CFR Section ; 40 CFR Section ; 40 CFR Section If the Permittee chooses to demonstrate compliance by monitoring the percent reduction of sulfur dioxide, the Permittee shall install a continuous emission monitoring system for sulfur dioxide and oxygen at the inlet of the air pollution control device. Continuous Monitoring: The Permittee shall: - Continuously monitor the selected mercury/pcdd/pcdf control additive (additive) feed rate operating parameter during all periods when the municipal waste combustion unit is operating and combusting waste (effective 5/6/2005 or on the date as determined by the Administrator under 40 CFR part 62, subpart JJJ) - Calculate the 8-hour block average additive feed rate in kilograms (or pounds) per hour. - When calculating the 8-hour block average, exclude hours when the unit is not operating and include hours when unit is operating but the additive feed system is not working correctly. Continuous Monitoring: The Permittee shall obtain one-hour arithmetic averages from 4 or more data points equally spaced over each 1-hour period for: - Unit load level of the municipal waste combustion unit. - Temperature of the flue gases at the inlet of the particulate matter control device. - Mercury/PCDD/PCDF control additive feed rate (effective 5/6/05 or on the date as determined by the Administrator under 40 CFR part 62, subpart JJJ). 40 CFR Section (c) 40 CFR Section ; 40 CFR Section 60.13(h); 40 CFR Section 60.13(e)(2) Data recorded during periods of continuous system breakdown, repair, calibration checks, and zero and span adjustments shall not be included in the data averages computed, unless there are, at least, 2 data points per hour. Continuous Monitoring: The Permittee shall install the following monitoring systems such that representative measurements of the process parameters from the affected facility are obtained: - unit load, - flue gas temperature, and - mercury/pcdd/pcdf control additive. 40 CFR Section 60.13(f)

18 TABLE A: LIMITS AND OTHER REQUIREMENTS A-14 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Continuous NOx Monitoring: The Permittee shall install, calibrate, maintain and operate monitors that continuously read and record nitrogen oxide at the outlet of the air pollution control device. The Permittee must follow the monitoring averaging periods specified in Minn. R subp. 4(E). The monitor (MR 014) shall be operated and maintained in accordance with Minn. R. ch Continuous Monitoring: All continuous monitoring systems and monitoring devices required under 40 CFR 60, including CEMS and COMS shall be installed, operational, and certified prior to conducting performance tests under 40 CFR Sec Continuous Operation: Except for continuous monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments, all continuous monitoring systems (including CEMS and COMS) shall be in continuous operation during all periods of emission unit operation. This includes periods of emission unit start-up, shutdown, or malfunction. Steam flow measurement method. The method contained in ASME Power Test Codes: Test Codes for Steam Generating Units, PTC 4.1 (1972), section 4, shall be used for calculating the steam flow required under Minn. R , subpart 3, item A, subitem (2). The recommendations of Instruments and Apparatus: Measurement of Quantity of Materials, Interim Supplement 19.5 (1971), chapter 4, shall be followed for design, construction, installation, calibration, and use of nozzles and orifices, except that measurement devices such as flow nozzles and orifices are not required to be recalibrated after they are installed. All signal conversion elements associated with steam flow measurements must be calibrated according to the manufacturer's instructions before each PCDD/PCDF test, and at least once per year. This annual calibration shall be recorded in the daily operating record as described in Minn. R , subpart 2. Alternative continuous measuring methods in place of steam flow may be installed and operated, provided that the method continuously measures the waste combustor unit load, is equivalent to results obtained when using the method in Minn. R , subp. 4, and the use of the method is approved by the Commissioner and Administrator prior to installation. CEMS QA/QC: The Permittee shall operate, calibrate, and maintain each SO2 and CO CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F, section 3, as amended. CEMS QA/QC: The Permittee shall operate, calibrate, and maintain each NOx CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F, section 3, as amended. COMS Monitoring Data: The Permittee shall reduce all data to 6 minute averages. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the 6 minute averaging period. CEMS/COMS Continuous Operation: CEMS/COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit startup, shutdown, or malfunction. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS/COMS must not be bypassed except in emergencies where failure to bypass the CEMS/COMS would endanger human health, safety, or plant equipment. Monitoring data shall be obtained for at least 75 percent of the hours per day for 90 percent of the days per calendar quarter that the combustor is operating and combusting MSW. The Permittee shall use all valid data from the continuous monitoring systems in calculating emission concentrations and percent reductions. If CEM/COM data is unavailable, the Permittee shall meet the minimum data requirements using alternative methods set forth in 40 CFR part 60, Appendix A, Methods 19 and 6c for SO2; Method 10 for CO; Method 9 for opacity; Method 3A or 3B for O2 or CO2. The Permittee shall notify the Administrator according to 40 CFR (e) if the minimum data required for continuously monitored emissions and parameters are not obtained. CEMS/COMS Certification Test: due 90 days after first Excess Emissions Report. This requirement applies to any CO or SO2 CEMS which have not previously been certified. CEMS/COMS Certification Test: due 90 days after first Excess Emissions Report. This requirement applies to any NOx CEMS which have not previously been certified. CEM/COMS Certification Test Plan: due 30 days before CEM/COM Certification Test Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R CFR Section 60.13(b) 40 CFR Section 60.13(e); MInn. R , subp. 1 Minn. R , subp. 4; 40 CFR Section (a) Minn. R , subp. 4a; 40 CFR Section (b) Minn. R , subp. 5(G); 40 CFR Section (d) Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R ; Minn. R , subp. 5(G) Minn. R , subp. 1 & 2 Minn. R , subp. 1 Minn. R , subp. 5(B); 40 CFR Section (c) 40 CFR Section ; Minn. R , subp. 5(D); 40 CFR Section (e) 40 CFR Section (d); 40 CFR Section (d) Minn. R , subp. 1; 40 CFR Section (b); 40 CFR Section 60.13(b) Minn. R , subp. 1; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1 and 2

19 TABLE A: LIMITS AND OTHER REQUIREMENTS A-15 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: CEM/COMS Certification Test Pretest Meeting: due 7 days before CEM/COMS Certification Test CEM/COMS Certification Test Report: due 45 days after CEM/COMS Certification Test CEM/COMS Certification Test Report - Microfiche Copy: due 105 days after CEM/COMS Certification Test COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) opacity at least once daily from each COMS according to the procedures listed in 40 CFR CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures of 40 CFR CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CO and SO2 CEMS. CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures of 40 CFR CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for NOx CEMS. COMS Calibration Error Audit: due before end of each half-year following COMS Certification Test. Conduct audits at least 3 months apart but no greater than 8 months apart. Follow the procedures of 40 CFR 60, Appendix B, Performance Specification 1. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test except for quarters in which a RATA was performed. This requirement applies to each CO and SO2 CEMS as well as each diluent monitor. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test except for quarters in which a RATA was performed. This requirement applies to each NOx CEMS as well as each diluent monitor. CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test. Follow the procedure in 40 CFR pt. 60, Appendix F. The RATA shall be conducted during the calendar quarter in which a cylinder gas audit (CGA) is not performed. This requirement applies to each CO and SO2 CEMS individually. Conduct annual evaluations of your continuous emission monitoring systems no more than 13 months after the previous evaluation was conducted. CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test. Follow the procedure in 40 CFR pt. 60, Appendix F. The RATA shall be conducted during the calendar quarter in which a cylinder gas audit (CGA) is not performed. This requirement applies to each NOx CEMS individually. Conduct annual evaluations of your continuous emission monitoring systems no more than 13 months after the previous evaluation was conducted. Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA). Exceedances of Continuously Monitored Emissions: If accurate and valid data results collected from the sulfur dioxide and/or carbon monoxide monitors exceed emission limits, the following procedures shall be followed. (1) Exceedance shall be reported to the Commissioner as soon as reasonably possible. (2) Appropriate repairs or modifications to return the waste combustor to compliance must be commenced within 72 hours. If compliance cannot be achieved within 72 hours, then the waste combustor shall be shut down. If modifications to return the waste combustor to compliance require the amendment of this permit, the waste combustor shall shut down within 72 hours of the exceedance. Exceedances of Continuously Monitored Emissions (continued): Minn. R , subp. 3 Minn. R , subp. 1, 2, and 4 Minn. R , subp. 3 Minn. R , subp. 5(E); Minn. R , subp. 2 Minn. R , subp. 5(E); Minn. R , subp. 3; 40 CFR Section (b); 40 CFR Section (f) Minn. R , subp. 5(E); Minn. R , subp. 3; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp 3; Minn. R , subp. 2 Minn. R , subp. 5(G); Minn. R , subp CFR Section (b) Minn. R , subp. 5(G); Minn. R , subp. 2; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 5(G); Minn. R , subp. 2; 40 CFR Section (d); 40 CFR Section (a) Minn. R , subp. 5(G); Minn. R , subp. 2; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 2; MInn. R , subp. 2 Minn. R , subp. 7 Minn. R , subp. 7 (continued) (3) When repairs or modifications have been completed, The Permittee shall demonstrate to the Commissioner that the waste combustor is in compliance. The waste combustor may be started up after the Permittee has notified the Commissioner in writing of the date the Permittee plans to start up the waste combustor and the date that performance testing is schedule. Notification shall be given at least 10 days in advance of the compliance test date. H. RECORDKEEPING hdr Recordkeeping: Permittee will maintain a record of continuously measured parameters as specified in Minn. R , subp. 6. Minn. R , subp. 6; Minn. R , subp. 2; 40 CFR Section (a) and (b)

20 TABLE A: LIMITS AND OTHER REQUIREMENTS A-16 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Recordkeeping: Permittee will maintain a record of all continuously measured parameters to record the 24-hour daily arithmetic average NOx emission concentrations. The Permittee shall: - Keep all records on site in paper copy or electronic format. - Make all records available for submittal to the Administrator or Commissioner, or for on-site review by the Administrator or Commissioner. Recordkeeping: record in the daily operating record the four-hour arithmetic average gas stream temperature as measured at the fabric filter inlets (MR 006, MR 008) during the most recent PCDD/PCDF performance test demonstrating compliance with the PCDD/PCDF emission limits in part and 40 CFR (a)(2). Permittee shall maintain on site for five years after the report is generated, a paper copy of each quarterly report, initial compliance report, and performance test report required under Minn. R , subparts 3, 5, and 6 respectively. Daily Operating Record: The Permittee shall maintain on-site daily records for the operation of each waste combustor. Daily records include such things as the operator log book, operator daily log sheets, trend records, CEMS records, and the daily operating report. The record shall contain: A. the calendar date; B. the hours of operation; B1. the time when waste begins feeding and the steam load at the time; B2. the time the waste feed to the combustion chamber ceases; C. the total weight of waste combusted; D. the weight of waste requiring disposal at a solid waste land disposal facility, including separated noncombustibles, excess waste, and ash; E. the amount and description of industrial solid waste received each day, the generator's name, and the method of handling; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1; 40 CFR Section Minn. R , subp. 8; Minn. R , subp. 2; Minn. R , subp. 2; 40 CFR Section (b) Minn. R , subp. 1; 40 CFR Section (a) Minn. R , Minn. R , Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d) Minn. R , item B(3) regarding test frequency Daily Operating Record (Continued) F. the measurements and determination of emissions averages as required in Minn. R , subpart 6; G. results of performance tests conducted on waste combustor units as required in this permit; H. the names of persons who have completed initial review or subsequent annual review of the operating manual; I. Continuous monitoring system records including: I1. each one-hour emission average recorded by the CEMS; I2. each six-minute opacity average recorded by the COMS; I3. monitor certification test reports; I4. excess emissions reports; I5. cylinder gas audit reports; I6. calibration error audit reports; I7. relative accuracy test audits; Minn. R , Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d) Minn. R , item B(3) regarding test frequency (continued) Daily Operating Record (Continued) I8. linearity check reports; I9. results of daily calibration drift checks; I10. log of adjustments made to the CEMS or COMS and maintenance performed on the CEMS or COMS; I11. the reasons for exceeding any of the average emission rates, percent reductions, or operating parameters specified under Minn. R , subpart 6, item C, or six-minute average COMS measurements that exceed the opacity limit and a description of corrective actions taken; I12. reasons for not obtaining the minimum number of hours of sulfur dioxide or operational data (opacity, carbon monoxide emissions, steam flow, particulate matter control device temperature) and a description of corrective actions taken. I13. the date of the calibration of all signal conversion elements associated with steam flow monitoring as required in Minn. R , subp. 4. Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d) Minn. R , item B(3) regarding test frequency (Continued)

21 TABLE A: LIMITS AND OTHER REQUIREMENTS A-17 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Daily Operating Record (continued) J. the following for control of Hg or dioxins, with an additive: J1. a record of the average additive system operating parameter for each hour of operation. J2. if the required hourly average additive system operating parameter is not maintained, the reasons for not maintaining the additive system operating parameter as determined in Minn. R , subp. 2 and the corrective actions taken. J3. a record of the average additive mass feed rate for each hour of operation. J4. if the required hourly average additive mass feed rate is not maintained, the reasons for not maintaining the additive mass feed rates as determined in Minn. R , subp. 1 and the corrective actions taken. K. Record of the pressure drop across the fabric filters. L. Record of acid gas control. Recordkeeping: The Permittee shall maintain a file of the following CEMS or COMS information at the emission facility in a form suitable for inspection for at least five years from the date of each record. - all monitoring system information required by an applicable compliance document; and - an up-to-date monitor QA/QC plan. Recordkeeping, Exclusions of Data. The Permittee shall document each time data was excluded from calculation of averages for any of the following: - Sulfur dioxide emissions. - Carbon monoxide emissions. - Unit load levels. - Temperatures of the flue gases at the inlet of the particulate matter control device. Recordkeeping, Exclusions of Data. The Permittee shall document each time data was excluded from calculation of averages for any of the following: - Nitrogen oxide emissions. Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping, Training and Certification: The Permittee shall keep records of training courses completed and certifications achieved, including: i) Names of the chief facility operator, shift supervisors, and control room operators who are provisionally or fully certified by the American Society of Mechanical Engineers. - Dates of the initial provisional or full certifications. - Documentation showing current provisional or full certifications. ii) Names of the chief facility operator, shift supervisors, and control room operators who have completed the EPA or State municipal waste combustion operator training course. - Dates of completion of the operator training course. iii) Documentation showing completion of operator training course. - Names of persons who have reviewed the operating manual. - Date of the initial review. - Dates of subsequent annual reviews. Recordkeeping and Recording of Mercury/PCDD/PCDF Control Additive Use: The Permittee shall maintain a record of: - The average additive mass feed rate for each hour of operation. - All 8-hour block average mercury/pcdd/pcdf control additive feed rates in kilograms (pounds) per hour calculated from the monitored operating parameter. - Total mercury/pcdd/pcdf control additive purchased and delivered to the facility for each calendar quarter. Include supporting documentation. - Required quarterly usage of mercury/pcdd/pcdf control additive for the municipal waste combustion plant, calculated using the appropriate equation. - Supporting calculations. Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d) Minn. R , item B(3) regarding test frequency (continued) Minn. R CFR Section (e) Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 2 Minn. R , subp. 11; Minn. R ; Minn. R , subp. 2(I); 40 CFR Section (a), (b), (c), and (d) Minn. R , subp. 3; 40 CFR Section (a)

22 TABLE A: LIMITS AND OTHER REQUIREMENTS A-18 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Recordkeeping, Records of Low Mercury/PCDD/PCDF Control Additive Feed Rates: The Permittee shall keep the following records regarding the periods when the average mercury/pcdd/pcdf control additive feed rate over an 8-hour block was less than the average mercury/pcdd/pcdf control additive feed rates determined during the most recent mercury/pcdd/pcdf performance test mercury which demonstrated compliance with the emissions limits: - Calendar date(s) - Beginning and ending time - Reasons for the low mercury/pcdd/pcdf control additive feed rates. - Corrective actions taken to meet the 8-hour average mercury/pcdd/pcdf control additive feed rate requirement. 40 CFR Section (b) and (d) The Permittee shall also keep a record regarding data excluded from averaging calculations including the date(s) and time data was excluded from average feed rate calculations and the reasons the data were excluded. Recordkeeping - MWC Acid Gases: By the 15th day of each month, the Permittee shall demonstrate compliance with the MWC acid gases emission limit, for the previous month, by following the below MWC Acid Gases recordkeeping procedure. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Option 1 - Recordkeeping - MWC Acid Gases: 1. The Permittee shall conduct annual performance tests to validate that the HCl emissions are less than or equal to ppmdv HCl, at 7% O2. 2. By the 15th of the month, the Permittee shall calculate the previous monthly CEMS data averages to validate that the SO2 emissions are less than or equal to 54.0 ppmdv SO2, at 7% O2. 3. By the 15th of the month, the Permittee shall record the most recent MPCA approved, tested HCl concentration and the previous month average SO2 ppmdv concentration. Option 1 - Recordkeeping - MWC Acid Gases (continued): If either of the HCl or SO2 recorded values exceed ppmdv or 54.0 ppdmv, respectively, the Permittee shall: Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Within 10 working days, notify, in writing, the MPCA Compliance and Enforcement staff in the Northwest Regional Office. 2. Use Option 2 - Recordkeeping - MWC Gases. The use of Option 2 shall be continued until there are 3 consecutive months of data demonstrating that both the HCl levels have remained below ppmdv and the SO2 levels have remained below 54.0 ppmdv. Upon returning to Option 1, the Permittee shall notify, in writing, within 10 days, the MPCA Compliance and Enforcement staff in the Northwest Regional Office. Option 2 - Recordkeeping - MWC Acid Gases: By the 15th day of each month, the Permittee shall calculate and record the tons of MWC acid gases emitted during the previous calendar month, and the tons of MWC acid gases emitted during the previous 12-month period. Option 2 - Recordkeeping - SO2 emissions: The Permittee shall record the SO2 CEMs measured emission concentrations, in ppmdv, corrected to 7% O2. Option 2 - Recordkeeping - SO2 emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of SO2 emitted during the previous calendar month, and the tons of SO2 emitted during the previous 12-month period. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R The monthly emissions shall be calculated using the following equation: SO21 = * SO22 * MSW * 1/2000 where SO21 = SOx monthly emissions in tons/month SO22 = SOx 7% O2) from monthly CEMS average MSW = monthly sum of MSW combusted, based on total weight of waste combusted, as recorded in Daily Operating Record

23 TABLE A: LIMITS AND OTHER REQUIREMENTS A-19 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Option 2 - Monthly SO2 CEMs Average Calculation: The Permittee shall calculate the monthly average SO2 concentration by calculating an arithmetic average of all of the 24-hour daily block average SO2 concentrations (in ppmdv, corrected to 7% O2) recorded, for each day, in a given month, in which waste is combusted for at least 1-hour. Time periods when waste is combusted, but the CEMs is inoperable, (or is otherwise known to be incapable of recording valid data) shall be included in the monthly average SO2 calculation, using the CEMs data substitution procedure. Option 2 - Monthly SO2 CEMs Average Calculation (continued): If the CEMs is inoperable for one (1) or more hours during a calendar day in which waste was combusted for at least one hour, the 95% upper confidence level of 24-hour daily block average SO2 concentrations (ppmdv at 7% O2) from the previous calendar year shall be used as a substitute for each hour of CEMs downtime. An adjusted 24-hour daily block average concentration shall then be calculated for the applicable operating day by including the substituted data for applicable hours of CEMs downtime. Initially, the Permittee shall use ppmdv SO2 at 7% O2 as a SO2 substitution value for each hour of CEMs downtime. This value is based on the 95% upper confidence level of the 24-hour daily block average SO2 emissions from existing Units 1 and 2 during calendar year Option 2 - Monthly SO2 CEMs Average Calculation (continued): After an additional, complete calendar year of CEMs data becomes available, the 95% upper confidence level of 24-hour daily block average SO2 emissions (ppmdv at 7% O2) shall be calculated for that new year of CEMs data and then used for data substitution purposes under this paragraph in the following calendar year. Option 2 - Recordkeeping - HCl emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of HCl emitted during the previous calendar month, and the tons of HCl emitted during the previous 12-month period. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R The monthly emissions shall be calculated using the following equation: HCl1 = * HCl2 * MSW * 1/2000 where HCl1 = HCl monthly emissions in tons/month HCl2 = HCl 7% O2) from most recent approved performance test MSW = monthly sum of MSW combusted, based on total weight of waste combusted, as recorded in Daily Operating Record Recordkeeping - NOx emissions: The Permittee shall record the NOx CEMs measured emission concentrations in ppmv corrected to 7% O2. Recordkeeping - NOx emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of NOx emitted during the previous calendar month, and the tons of NOx emitted during the previous 12-month period. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R The monthly emissions shall be calculated using the following equation: NOx1 = * NOx2 * MSW * 1/2000 where NOx1 = NOx monthly emissions in tons/month NOx2 = NOx 7% O2) from monthly CEMS average MSW = monthly sum of MSW combusted, based on total weight of waste combusted, as calculated from the Daily Operating Record Monthly NOx CEMs Average Calculation: The Permittee shall calculate the monthly average NOx concentration by calculating an arithmetic average of all of the 24-hour daily block average NOx concentrations (in ppmdv, corrected to 7% O2) recorded, for each day, in a given month, in which waste is combusted for at least 1-hour. Time periods when waste is combusted, but the CEMs is inoperable, (or is otherwise known to be incapable of recording valid data) shall be included in the monthly average NOx calculation, using the CEMs data substitution procedure. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R

24 TABLE A: LIMITS AND OTHER REQUIREMENTS A-20 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Monthly NOx CEMs Average Calculation (continued): If the CEMs is inoperable for one (1) or more hours during a calendar day in which waste was combusted for at least one hour, the 95% upper confidence level of 24-hour daily block average NOx concentrations (ppmdv at 7% O2) from the previous calendar year shall be used as a substitute for each hour of CEMs downtime. An adjusted 24-hour daily block average concentration shall then be calculated for the applicable operating day by including the substituted data for applicable hours of CEMs downtime. Initially, the Permittee shall use ppmdv NOx at 7% O2 as a NOx substitution value for each hour of CEMs downtime. This value is based on the 95% upper confidence level of the 24-hour daily block average NOx emissions from existing Units 1 and 2 during calendar year Monthly NOx CEMs Average Calculation (continued): After an additional, complete calendar year of CEMs data becomes available, the 95% upper confidence level of 24-hour daily block average NOx emissions (ppmdv at 7% O2) shall be calculated for that new year of CEMs data and then used for data substitution purposes under this paragraph in the following calendar year. ABM Recordkeeping: Calculate, record and maintain the total usage of ABM for all test burns. For each ABM test burn, record the total weight, and types(s) of ABM fired, approximate moisture content(s) of each type of ABM fired, hourly mass rate and heat input of ABM and any other fuels. Record the starting and end times of the ABM test burn. I. REPORTING hdr Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 4 & 5 Quarterly Reports: The report shall contain the following items: A. calendar date; B. a graphic or tabular presentation of the sulfur dioxide and carbon monoxide emissions, the maximum waste combustor unit load level and particulate matter control device temperatures as recorded by Minn. R , subp. 6, item C, and the daily maximum opacity readings as recorded by Minn. R , subp. 6, item B, subitem (1). The graphs shall be prepared as follows: - (1) the graph shall represent one operating parameter or pollutant; - (2) the applicable limit of the parameter or pollutant shall be indicated on the graph; and - (3) data shall be expressed in the same units as the applicable operating parameter or emissions limit; Minn. R , subp. 3 Quarterly Reports (Continued): Minn. R , subp. 3 (Continued) C. the identification of operating days when any of the average emission concentrations, percent reductions, operating parameters specified under Minn. R , subp 6(C), Minn. R , subp. 2 exceeded the applicable limits or any 6 minute average opacity greater than the opacity limit. The report shall include the emission levels recorded during the exceedance, reasons for such exceedances as well as a description of corrective actions taken; D. the percent of the operating time for the quarter that the COMS was operating and collecting valid data; E. the identification of operating days for which the minimum number of hours that emission concentrations, percent reductions, operating parameters specified under Minn. R , subp. 6(C), Minn. R , subp. 2 or the opacity level data have not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken; Quarterly Reports (Continued) F. the results of daily sulfur dioxide, NOx, and carbon monoxide CEMS drift tests and accuracy assessments as required in Minn. R , subp. 5. G. the information required in Minn. R , subp 2(C), (D), and (E), summarized to reflect quarterly totals; H. a compliance certification as required in Minn. R , subp 6(C); and I. if an additive is used to comply with the mercury and/or PCDD/PCDF emission limits, the total additive used during the calendar quarter, as specified in Minn. R , subp. 3(B), with supporting calculations. The total amount of additive purchased and delivered to the facility must be equal to or greater than the required quarterly usage of additive. Quarterly usage of the additive shall be determined in accordance with 40 CFR Section Minn. R , subp. 3 (Continued); 40 CFR Section (d)

25 TABLE A: LIMITS AND OTHER REQUIREMENTS A-21 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Reporting to the Administrator: The Permittee shall submit to the Administrator an initial report and annual reports, plus semiannual reports for any emission or parameter level that does not meet the limits specified in this permit: - Submit the annual report no later than February 1 of each year that follows the calendar year in which data was collected. - Submit semiannual report for data collected during the first half of a calendar year, by August 1 of that year. For data collected during the second half of the calendar year, submit semiannual report by February 1 of the following year. - The Permittee shall retain a copy of all reports on site for 5 years. - All information shall be reported in the units in which the limit or parameter is expressed. Initial Report: The initial report shall contain the items listed in 40 CFR Section Initial Report: The initial report shall contain the following: A. The emission levels measured on the date of the initial evaluation of the continuous emission monitoring systems for all of the following pollutants or parameters as recorded in accordance with 40 CFR Section (b): A1. The 24-hour daily geometric average concentration of sulfur dioxide emissions or the 24-hour daily geometric percent reduction of sulfur dioxide emissions. A2. The 4-hour block arithmetic average concentration of carbon monoxide emissions. A3. The 4-hour block arithmetic average load level of each municipal waste combustion unit. A4. The 4-hour block arithmetic average flue gas temperature at the inlet of each particulate matter control device. Initial Report: (continued) B. The results of the initial performance tests for the following pollutants: B1. Dioxins/furans, Cadmium, Lead, Mercury, Opacity, Front-half particulate matter, Hydrogen chloride, Fugitive ash. C. The test report that documents the initial stack test including supporting calculations. D. The initial performance evaluation of continuous emissions monitoring systems. E. Operating Conditions during the initial performance tests. E1. The maximum demonstrated load of the waste combustion unit and the maximum demonstrated temperature of the flue gases at the inlet of the particulate matter control device. Use the values established during the initial test for dioxins/furans emissions and include supporting calculations. E2. The average feed rates of the additive to control mercury/pcdd/pcdf as recorded during the mercury and PCDD/PCDF emissions testing and supporting calculations as specified in 40 CFR Section (a)(1) and (2). Initial Report: (continued) F. If the Permittee chooses to monitor carbon dioxide instead of oxygen as the diluent gas, documentation of the relationship between oxygen and carbon dioxide, as specified in 40 CFR Section CFR Section CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section (continued) 40 CFR Section ; 40 CFR Section The initial performance tests were deemed compliant by the PCA on May 24, Annual Report The annual report shall contain a summary of the following: (a) The results of the annual performance test (b) A list of the highest average emission levels recorded, in the appropriate units. (c) The highest 6-minute opacity level measured. (d) For mercury/pcdd/pcdf control additive (additive) usage, (1) The average additive feed rates recorded during the most recent mercury performance tests. (2) The lowest 8-hour block average additive feed rate recorded during the year. (3) The total additive purchased and delivered to the facility (4) The required quarterly additive usage (e) The total number of days that the minimum number of hours of data was not obtained. Include the reasons for not obtaining the data and corrective actions taken to obtain the data in the future. (f) The number of hours data was excluded from the calculation of average levels (include the reasons for excluding it). 40 CFR Section (continued below)

26 TABLE A: LIMITS AND OTHER REQUIREMENTS A-22 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Annual Report (continued) (g) If eligible for reduced performance testing, a notice of the intent to begin a reduced performance testing schedule during the following calendar year (h) A summary of any emission or parameter level that did not meet the required limits (i) A summary of the data in paragraphs (a) through (d) of this section from the year preceding the reporting year. (j) Documentation of periods when all certified chief facility operators and certified shift supervisors are offsite for more than 12 hours. Semiannual Report to the Administrator: The Permittee shall submit a semiannual report if any recorded emission or parameter level does not meet the requirements specified in this permit. The semiannual report shall contain: (a) For any pollutants or parameters that exceeded the specified limits, include the calendar date, the averaged and recorded data for that date, the reasons for exceeding the limits, and corrective actions: (b) If the results of the annual performance tests show emissions above the specified limits, the semiannual report shall include a copy of the test report that documents the emission levels and corrective actions. Semiannual Report to the Administrator: (continued) 40 CFR Section (continued) 40 CFR Section CFR Section (continued) (c) If mercury/pcdd/pcdf control additive (additive) is used to control mercury and/or PCDD/PCD emissions, including two items: (1) Documentation of all dates when the 8-hour block average additive feed rate is less than the required additive feed rate. Including four items: - (i) Eight-hour average additive feed rate. - (ii) Reasons for the occurrences of low additive feed rates. - (iii) The corrective actions taken to meet the additive feed rate requirement. - (iv) The calendar date. Semiannual Report to the Administrator: (continued) 40 CFR Section (continued) (2) Documentation of each quarter when total additive purchased and delivered is less than the total required quarterly usage of additive. Including five items: - (i) Amount of additive purchased and delivered. - (ii) Required quarterly usage of additive. - (iii) Reasons for not meeting the required quarterly usage of additive. - (iv) The corrective actions taken to meet the required quarterly usage of additive. - (v) The calendar date. The accumulated amount of all ABM combusted, in any year, must be included in the Emission Inventory Reports. Final ABM Fuel Usage Report. The Permittee shall notify the MPCA within 30 days of when it reaches the 1000 ton limit, on ABM, authorized for test burns, by this permit action. Minn. R through Minn. R Minn. R , subp. 2

27 TABLE A: LIMITS AND OTHER REQUIREMENTS A-23 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: SV 001 Main incinerator stack Associated Items: EU 001 MSW Incinerator Unit 1 EU 002 MSW Incinerator Unit 2 MR 001 Units 1 and 2 - Opacity MR 010 Units 1 and 2 - O2 (Outlet) MR 013 Units 1 and 2 - SO2 (Outlet) MR 014 Units 1 and 2 - NOx (outlet) What to do SV 001 Stack Height: greater than or equal to feet above ground level. The Permittee shall start construction to increase the existing stack height of SV 001 within 180 days after achieving the maximum production rate at which MSW Incinerator 3 (EU 006) will be operated. The 105 foot stack will be operational no later than 365 days after achieving the maximum production rate at which EU 006 will be operated. Why to do it Minn. R , subp. 2 This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act.

28 TABLE A: LIMITS AND OTHER REQUIREMENTS A-24 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: EU 001 MSW Incinerator Unit 1 Associated Items: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 003 Dry Sorbent Injection CE 005 Carbon Injection GP 001 Waste Combustors, Units 1 and 2 MR 002 Unit 1 - CO MR 006 Unit 1 - Temperature MR 007 Unit 1 - Steam Flow MR 011 Unit 1 - SO2 (Inlet) SV 001 Main incinerator stack What to do Steam Flow: less than or equal to lbs/hour using 4-hour Block Average (as determined during the 5/7/08 and 5/8/08 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the steam flow into this permit, the Permittee shall not exceed 110 percent of the steam load level established during that compliant performance test. Steam Flow (continued): The waste combustor is exempt from limits on the load level during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Steam Flow (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the combustor waste load level can be waived; 3) the length of time the project will take to complete. Why to do it Minn. R , subp. 2; Minn. R , subp. 3; 40 CFR Section (a) 40 CFR Section (b) Minn. R , subp. 2; Minn. R , subp. 3; 40 CFR Section (e) 40 CFR Section (e) (continued) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued)

29 TABLE A: LIMITS AND OTHER REQUIREMENTS A-25 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: EU 002 MSW Incinerator Unit 2 Associated Items: CE 002 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 004 Dry Sorbent Injection CE 006 Carbon Injection GP 001 Waste Combustors, Units 1 and 2 MR 004 Unit 2 - CO MR 008 Unit 2 - Temperature MR 009 Unit 2 - Steam Flow MR 012 Unit 2 - SO2 (Inlet) SV 001 Main incinerator stack What to do Steam Flow: less than or equal to lbs/hour using 4-hour Block Average (as determined during the 2/19/2007 and 2/21/2007 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the steam flow into this permit, the Permittee shall not exceed 110 percent of the steam load level established during that compliant performance test. Steam Flow (continued): The waste combustor is exempt from limits on the load level during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Steam Flow (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the combustor waste load level can be waived; 3) the length of time the project will take to complete. Why to do it Minn. R , subp. 2; Minn. R , subp. 3; 40 CFR Section (a) 40 CFR Section (b) Minn. R , subp. 2; Minn. R , subp. 3; 40 CFR Section (e) 40 CFR Section (e) (continued) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued)

30 TABLE A: LIMITS AND OTHER REQUIREMENTS A-26 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: EU 005 Auxiliary Boiler Associated Items: SV 004 Auxiliary Boiler Stack What to do Why to do it Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. The emission unit is permitted to burn only natural gas. Minn. R , subp. 2 Minn. R , subp. 4(B)

31 TABLE A: LIMITS AND OTHER REQUIREMENTS A-27 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: EU 006 MSW Incinerator Unit 3 Associated Items: CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 008 Dry Sorbent Injection CE 009 Carbon Injection MR 017 Unit 3 - Inlet O2 MR 020 Unit 3 - Inlet SO2 MR 022 Unit 3 - Temperature MR 023 Unit 3 - Steam Flow SV 015 MSW Incinerator Unit 3 PRECONSTRUCTION REQUIREMENTS What to do hdr Why to do it Materials Separation Plan: 40 CFR Section For the materials separation plan, the following must be completed: 1) Prepare a draft materials separation plan. 2) Make the draft plan available to the public. 3) Hold a public meeting on the draft plan. 4) Prepare responses to public comments received during the public comment period on the draft plan. 5) Prepare a revised materials separation plan. 6) Discuss the revised plan at the public meeting for review of the siting analysis. 7) Prepare responses to public comments received on the revised plan. 8) Prepare a final materials separation plan. 9) Submit the final materials separation plan. This requirement must be completed within 30 days of commencing construction of EU 006. Siting Analysis: 40 CFR Section For the siting analysis, the following must be completed: 1) Prepare an analysis. 2) Make the analysis available to the public. 3) Hold a public meeting on the analysis. 4) Prepare responses to public comments received during the public comment period on the analysis. 5) Submit the siting analysis. This requirement must be completed within 30 days of commencing construction of EU 006. EMISSIONS LIMITS hdr Applicability of Standards: the standards of Minn. R , , subps. 2 and 5 and , subp. 2 apply at all times when waste is being continuously burned. The emission limits must be met 60 days after EU 006 reaches the maximum load level but no later than 180 days after initial start up. The standards do not apply, up to a maximum of three hours, during periods of start-up, shutdown or malfunction. Fugitive emissions standards applicable to the ash conveying system do not apply during periods of maintenance and repair of the ash conveying system. Applicability of Standards (Continued): The Permittee shall not cause to be emitted into the atmosphere, from this waste combustor unit, gases in excess of the applicable standards. Emissions, except opacity, shall be calculated under standard conditions corrected to seven percent oxygen on a dry volume basis. Minn. R , subp. 4; Minn. R , subp. 1(A); 40 CFR Section ; 40 CFR Section ; 40 CFR Section Minn. R , subp. 4; Minn. R , subp. 1(A); 40 CFR Section ; 40 CFR Section ; 40 CFR Section During startup, shutdown, or malfunction periods longer than 3 hours, emissions data cannot be discarded from compliance calculations and all provisions under 40 CFR 60.11(d) apply. The Permittee shall use data from the continuous emission monitoring systems (CEMs) for nitrogen oxides to demonstrate continuous compliance with the applicable emission limits. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R

32 TABLE A: LIMITS AND OTHER REQUIREMENTS A-28 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: The Permittee shall use data from the continuous emission monitoring systems (CEMs) for sulfur dioxide and carbon monoxide to demonstrate continuous compliance with the applicable emission limits. The Permittee shall use results of performance tests for dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash to demonstrate compliance with the applicable emission limits. Front-half Particulate Matter: less than or equal to 24 milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods, sampling time, sample volume, and other testing requirements. Total Particulate Matter: less than or equal to grains/dry standard cubic foot. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R regarding sampling methods, sample volume, and other testing requirements. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Front-half Particulate Matter: less than or equal to grains/dry standard cubic foot. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R regarding sampling methods, sample volume, and other testing requirements. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Muni Waste Combust Organics: less than or equal to 30 nanograms/dscm. Muni Waste Combustor Organics means total of tetra-through octa-polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (Total PCDD/PCDF). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in Minn. R and 40 CFR Section regarding sampling methods, sampling time, and other testing requirements. Muni Waste Combust Organics: less than or equal to 13.0 nanograms/dscm. Muni Waste Combustor Organics means total of tetra-through octa-polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (Total PCDD/PCDF). This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods, sampling time, and other testing requirements. Cadmium compounds: less than or equal to milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) regarding sample volume. Lead: less than or equal to 0.20 milligrams/dscm. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) regarding sample volume. Mercury: less than or equal to 100 micrograms/dscm, or 85% removal (short term), whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing procedures specified in Minn. R , subpart 3(C) and Minn. R , subpart 3(D). Mercury: less than or equal to 60 micrograms/dscm, or 85% removal (long term), whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing procedures specified in Minn. R , subpart 3(C) and Minn. R , subpart 3(D). Mercury: less than or equal to milligrams/dscm or 85 percent reduction which ever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) and Minn. R , subpart 3(D). 40 CFR Section CFR Section CFR Section ; 40 CFR Minn. R , Table 2; Minn. R Minn. R , Table 2; Minn. R Minn. R , Table 2; Minn. R CFR Section , 40 CFR Section CFR Section ; 40 CFR Section , Minn. R CFR Section ; 40 CFR Section , Minn. R Minn. R , Table 2, Minn. R Minn. R , Table 2, Minn. R CFR Section ; 40 CFR Section ; Minn. R

33 TABLE A: LIMITS AND OTHER REQUIREMENTS A-29 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Mercury: less than or equal to 14.0 micrograms/dscm. This limit is applied in accordance with Minn. R , , subps. 2 and 5 and , subp. 2. The Permittee must follow the requirements specified in 40 CFR Section regarding sampling methods and other testing requirements and Minn. R , subpart 3(C) and Minn. R , subpart 3(D). This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Opacity: less than or equal to 10 percent opacity. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing requirements specified in 40 CFR Section and Minn. R , subpart 2. Carbon Monoxide: less than or equal to 100 parts per million by dry volume using 4-hour Block Average. The Permittee must follow the monitoring requirements specified in 40 CFR Section , 40 CFR Section and Minn. R , subpart 3 and Minn. R , subpart 4. Hydrochloric acid: less than or equal to 25 parts per million by volume or 95% removal, whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the testing requirements specified in 40 CFR Section Nitrogen Oxides: less than or equal to 500 parts per million by volume on a dry basis corrected to 7% O2. This limit is applied in accordance with the "Applicability of Standards" stated above. This limit applies at all times except during startup, shutdown, or malfunction. Sulfur Dioxide: less than or equal to 30 parts per million by dry volume using 24-hour Geometric Average or 80 percent removal, whichever is less stringent. This limit is applied in accordance with the "Applicability of Standards" stated above. The Permittee must follow the monitoring requirements specified in 40 CFR Section , 40 CFR Section Fugitive Ash: Permittee shall not cause to be emitted into the atmosphere visible emissions of combustion ash from an ash conveying system, including conveyor transfer points, in excess of five percent of the observation period (i.e., 9 minutes per three-hour period), as determined by Code of Federal Regulations, Title 40, part 60, Appendix A, Method 22, as amended). This limit does not apply to visible emissions discharged inside buildings or enclosures of ash conveying systems; however, the emission limit does cover visible emissions discharged to the atmosphere from buildings or enclosures of ash conveying systems. Must follow the testing requirements specified in 40 CFR Section and Minn. R , subpart 2. Nitrogen Oxides: less than or equal to 95 tons/year using 12-month Rolling Sum. OPERATIONAL LIMITS Minn. R , subp. 2 Minn. R , Table 2; 40 CFR Section ; 40 CFR Section Minn. R , Table 2; Minn. R ; 40 CFR Section ; 40 CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section (This also satisfies Minn. R , Table 2.) 40 CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section ; 40 CFR Section ; Minn. R , Table 2 Minn. R , subpart 1(B); Minn. R , subpart 2; 40 CFR Section ; 40 CFR Section Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R hdr Steam Flow: less than or equal to lbs/hr using 4-hour Block Average, (to be determined upon the initial PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the steam flow rate into this permit, the Permittee shall not exceed 110 percent of the steam load level established during that compliant performance test. Steam Flow (continued): The waste combustor is exempt from limits on load level during any of three situations: (1) Annual tests for PCDD/PCDF. (2) The 2 weeks preceding annual tests for PCDD/PCDF. (3) Whenever approved in writing by the Administrator and Commissioner for any of the following activities: (i) Evaluate system performance. (ii) Test new technology or control technologies. (iii) Perform diagnostic testing. (iv) Perform other activities to improve the performance of the waste combustor. (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Minn. R , subp. 5; Minn. R , subp. 3; 40 CFR Section (a) Minn. R , subp. 5; Minn. R , subp. 3; 40 CFR Section (e)

34 TABLE A: LIMITS AND OTHER REQUIREMENTS A-30 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Steam Flow (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the waste combustor load level can be waived; 3) the length of time the project will take to complete. Presence of certified operator. The person described in Minn. R , subp. 1 shall be present at the waste combustor facility at all times when solid waste is being combusted. The certified operator shall meet the minimum requirements of Minn. R , subp. 3(B) and Start-up on waste prohibited. During start-up from a cold furnace, auxiliary fuels shall be used to achieve combustion chamber operating temperature. The use of solid waste solely to provide thermal protection of the grate or hearth during the start-up period when solid waste is not being fed to the grate is not considered to be continuous burning. Auxiliary Fuel Use: Use natural gas to warm the combustion and pollution control devices and maintain good combustion conditions in the combustion chamber from the time the waste feed has been discontinued until the combustion chamber is clear of combustible material or active combustion ceases. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Allowed and Prohibited Fuels: Minn. R , subp. 5; Minn. R , subp. 3; 40 CFR Section (e) Minn. R , subp. 1; 40 CFR Section ; 40 CFR Section Minn. R , subp. 3 Minn. R , subp. 2 Minn. R , subp. 2 1) Normal Operating Conditions: The waste combustor may burn natural gas, solid waste, RDF, and mixed municipal solid waste, as defined in Minn. Stat. 115A.03, subp. 21, and other nonhazardous wastes approved through the Facility's Industrial Solid Waste Management Plan, except as noted elsewhere in Table A of this permit. The facility is authorized to burn waste tires, yard waste, and household hazardous waste that are incidentally received co-mingled with municipal solid waste. The waste combustor shall not combust waste tires, yard waste, nor household hazardous waste as a separate waste stream. Allowed and Prohibited Fuels (Continued): Minn. R , subps. 4 & 5 2) Test burn conditions: limited to natural gas, solid waste, RDF, mixed municipal solid waste, and clean unadulterated wood-based biomass materials (wood chips, chunks, branches, bark, shavings and sawdust) only. The clean unadulterated wood-based biomass materials shall hereafter be referred to as Allowable Biomass Materials (ABM) for the purpose of this permit. Chemically processed or chemically-treated biomass materials are not permissible for use as a fuel. ABM allowed. The only ABM authorized, in this permit, for trial burns is/are unadulterated wood, wood chips, chunks, branches, bark, shavings, and/or sawdust materials. Alternative Fuel Testing Authorization: The Permittee is authorized to conduct test burns using ABM. When combusted under this paragraph, ABM may be fired individually or in combination with any other allowed fuel. Alternative Fuel Testing Authorization: The Permittee is authorized to conduct any number of test burns until Dec. 31, 2012, using ABM as supplemental, renewable fuel. The maximum ABM permitted, under this permit action (-003), shall be a cumulative total of 1000 tons. Facility Operation: Properly maintain and operate air pollution control equipment at all times when the waste combustor is in operation and combusting waste. Minn. R , subp. 4(a) Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 Minn. R , subp. 16(J); Minn. R , subp. 7; 40 CFR Section 60.11(d) At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions, in accordance with 40 CFR Section 60.11(d).

35 TABLE A: LIMITS AND OTHER REQUIREMENTS A-31 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: The Permittee shall maintain an 8-hour block average mercury/pcdd/pcdf control additive feed rate at or above the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and most recent compliant PCDD/PCDF performance test. AVERAGING PERIODS Averaging Periods: For emission limits or operational limits which are monitored continuously the following averaging periods shall be used: A) for particulate matter control device inlet temperature monitoring, four-hour arithmetic block averages calculated from four consecutive one-hour arithmetic averages. B) for unit load, a four-hour arithmetic block average, the four-hour arithmetic block averages shall be calculated from four continuous one-hour arithmetic averages. C) For opacity, a 6-minute average calculated using 36 or more data points equally spaced over a 6-minute period. D) for Hg/PCDD/PCDF control additive feed, eight-hour arithmetic block averages. Eight-hour block average means the average of all hourly control additive feed rates when the controlled incinerator operates and combusts municipal solid waste measured over any of three 8-hour periods of time: (1) 12 midnight to 8 A.M. (2) 8 A.M. to 4 P.M. (3) 4 P.M. to 12 midnight Averaging Periods (continued) E) for SO2, a geometric average of the 1-hour arithmetic average emission concentration during each 24-hour daily period measured from midnight to midnight. F) for carbon monoxide, an arithmetic average of the 1-hour arithmetic average emission rates concentration during each 4-hour daily period measured from midnight to midnight. At least 4 data points equally spaced in time shall be used to calculate each 1-hour arithmetic average. For SO2 and CO, each 1-hour average shall be corrected to 7 % O2 on an hourly basis using the one-hour arithmetic average of the O2 or CO2 continuous emissions monitoring system. OPERATOR TRAINING & CERTIFICATION The Permittee shall provide EPA or state-approved operator training to the following personnel: chief facility operators, shift supervisors and control room operators. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit after 5/6/2005 must complete a state approved or EPA operator training course by the date before an employee assumes the responsibilities of chief facility operators, shift supervisors and control room operators. The Permittee shall require each chief facility operator and shift supervisor to obtain and maintain a current provisional operator certification from the American Society of Mechanical Engineers QRO or a state program approved under 40 CFR Section 60, Subpart AAAA. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit on or after November 6, 2004 must obtain provisional certification 6 months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit. Control room operators shall be certified as described in Minn. R Individuals, if assuming the duties of control room operator for the first time, shall obtain certification as described in Minn. R within six months of assuming such duties. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit before November 6, 2004 must obtain full certification by 5/6/2005 or earlier if required by the USEPA. Each chief facility operator and shift supervisor hired or transferred to the municipal waste combustion unit on or after November 6, 2004 must obtain full certification 6 months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit. Minn. R , subp. 2 Minn. R , subp. 3(B); 40 CFR (c) hdr Minn. R , subp. 4; 40 CFR Section (a) and (b); 40 CFR Section (c) CONTINUED: Minn. R , subp. 4; 40 CFR Section (a) and (b); 40 CFR Section (c) hdr 40 CFR Section CFR Section (a) and (b); Minn. R , subp. 1 Minn. R , subp. 1aA(5) 40 CFR Section (c) and (d); Minn. R , subp. 1; Minn. R , subp. 1a For purposes of this permit, "obtain" means a full certification from the American Society of Mechanical Engineers or a EPA-approved state program or a full certification exam scheduled for the timeframes established above.

36 TABLE A: LIMITS AND OTHER REQUIREMENTS A-32 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Develop and maintain the Operating Manual in accordance with Minn. R , subp. 3, items A through O; Update the manual following each performance test to include operational changes resulting from emission performance testing results. Include the revision dates within the Operating Manual; Store the Operating Manual in a location easily accessed by staff. The Permittee shall establish a program to review the plant-specific operating manual with people whose responsibilities affect the operation of the waste combustor. Initial review by the date before an employee assumes responsibilities that affect operation of the waste combustor unit. The Permittee shall update and review the manual with staff annually. The Permittee must record the date of initial review and annual update and review. Training Program: Persons without waste combustor or boiler operation experience must work under the direct supervision of a certified operator or a certified operator's designee for 40 hours before assuming job-related activities affecting air emissions. The Permittee must record the date of the training session and the number of hours training in each session. Training Program: The Permittee will implement a training program, based on the Operating Manual, designed to maintain compliance with this permit, Minn. Rules and federal regulations. Individual training must be specific to the position held. Waste combustor personnel who have responsibilities which affect the operation of the waste combustor must be trained in the operation of the facility. These personnel include, but are not limited to: chief facility operators, shift supervisors, operator supervisors, control room personnel, ash handlers, maintenance personnel, and crane/load handlers. Training Program: (continued) The Permittee will: - Implement the required training; - Identify all people described above who must be trained; - Include a separate page for each of these people in the Operating Record; - Report the names of those who have been trained, the type of training received, and the date the training was completed, as required, under Minn. R , subp. 4. Certified Operator: The Permittee shall: 1) Maintain at the facility a record of the names of all certified personnel. This record shall contain the exam dates, the content of the exam, the full name of the certified individual, the examiner's signature and the certification statement in Minn. R , subp. 3. 2) Maintain at the facility a record of the names of all personnel who have obtained provisional and/or full certification by ASME. The Permittee shall allow the Commissioner and/or Administrator to review all records related to the certification of operators including the facility's program for examination and certification of operators, the record required in Minn. R , subp. 3, and the content and results of an individual's exam. TESTING REQUIREMENTS Initial Performance Test: due 60 days after achieving maximum capacity (load) but no longer than 180 days after EU 006 achieves the initial startup to measure Total PCDD/PCDF emissions, Front-half Particulate Matter, Total Particulate Matter, cadmium, lead, HCl, mercury, and opacity. Performance Test: due before end of each year following Initial Performance Test to measure Total PCDD/PCDF, Front-half Particulate Matter, Total Particulate Matter, cadmium, lead, HCl, and opacity. A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months between test dates. (see the Technical Support Document -003 for an explanation). (Note Federal and State standards regarding reduced frequency. The Facility must meet the most stringent standard.) Minn. R , subp. 3; 40 CFR Section (a); 40 CFR Section ; 40 CFR Section CFR Section (b), (c) and (d); Minn. R , subp. 1 Minn. R , subp. 1(C)(1) Minn. R , subp. 1; Minn. R , subp. 2; Minn. R , subp. 4; Minn. R ; 40 CFR Section (b); 40 CFR Section Minn. R , subp. 1; Minn. R , subp. 2; Minn. R , subp. 4; Minn. R ; 40 CFR Section (b); 40 CFR Section Minn. R , subp. 3; Minn. R , subp. 3a; Minn. R , subp. 4; 40 CFR Section hdr Minn. R , subp. 5; Minn. R (B); Minn. R , subp. 1; Minn. R , subp. 2 Minn. R , subp. 5; Minn. R (B); Minn. R , subp. 1; Minn. R , subp. 2

37 TABLE A: LIMITS AND OTHER REQUIREMENTS A-33 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Performance Test (continued) For state regulated pollutants, if all annual performance tests for a three-year period show compliance with Total PCDD/PCDF, Front-half Particulate Matter, Total Particulate Matter, HCl and opacity limits in this permit, the Permittee may choose to conduct performance tests every 2-1/2 years. At a minimum, a performance test shall be conducted every 2-1/2 years, but no more than 30 months following the previous compliance test. Minn. R (B); Minn. R , subp. 1; Minn. R , subp. 2 If a performance test indicates noncompliance with the limits, the Permittee shall resume annual testing, for three years, for that pollutant for which noncompliance was demonstrated. If all performance tests for the three-year period again show compliance with the limits, the Permittee may again conduct performance testing every 2-1/2 years. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Performance Test: due before end of each calendar quarter following Initial Performance Test to measure mercury emissions. The facility may implement testing for mercury not less than once every three years under the following conditions: the facility has demonstrated that mercury emissions have been below 50 percent of its facility permitted mercury limit for three consecutive years; and the Permittee has submitted a request for an administrative amendment according to the procedures of part Initial Performance Test: due 60 days after achieving maximum capacity (load) but no longer than 180 days after EU 006 achieves the initial startup to measure Total PCDD/PCDF, Front-half Particulate Matter, HCl, opacity, cadmium, lead, mercury, and fugitive ash. Performance Test: due before end of each calendar year following Initial Performance Test to measure Total PCDD/PCDF, Front-half Particulate Matter, HCl, opacity, cadmium, lead, mercury, and fugitive ash. A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months between test dates. (see the Technical Support Document -003 for an explanation). (Note Federal and State standards regarding reduced frequency. The Facility must meet the most stringent standard.) Performance Test (continued) For the federally regulated pollutants listed above (Total PCDD/PCDF, front-half Particulate Matter, HCl, opacity, cadmium, lead, mercury, and fugitive ash), the Permittee may conduct performance tests every third year, if the following conditions are met: All performance tests for a given pollutant, over the 3 previous years, demonstrated compliance with the emission limit. The next performance test is conducted within 36 months of the anniversary date of the third consecutive performance test that demonstrates compliance with the emission limit. Minn. R (B); Minn. Stat , subd. 1a; Minn. R , subp. 1; Minn. R , subp CFR Section (b); 40 CFR Section CFR Section (b); 40 CFR Section (a) 40 CFR Section (b); 40 CFR Section (a) Performance Test (continued) Thereafter, the Permittee shall conduct performance tests, every third year, but no later than 36 months following the previous performance tests. If a performance test does not demonstrate compliance with an emission limit, the Permittee shall conduct annual performance tests for that pollutant until all performance tests over 3 consecutive years demonstrate compliance with the emission limit for that pollutant. The Permittee shall use the performance test methods and procedures specified in Minn. R to except as modified in Minn. R and 40 CFR Section regarding sampling methods, sampling time, and other testing requirements. The Permittee shall conduct MWC organics tests with a minimum sampling time of 4 hours per test run. The Permittee shall determine the maximum demonstrated capacity of the waste combustor during the initial performance test for PCDD/PCDF and each subsequent performance test during which compliance with the PCDD/PCDF emissions limits in Minn. R and 40 CFR Section are achieved. Operation during performance testing. The Permittee shall report to the Commissioner the operating conditions including operating parameters of the air pollution control equipment, pressure drop across the fabric filters, flue gas temperatures, air flow rates, mercury/pcdd/pcdf control additive feed rate and acid gas control. 40 CFR Section (b); 40 CFR Section (a) Minn. R , subp. 1; 40 CFR Section (a) Minn. R , subp. 7; 40 CFR Section Minn. R , subp. 6; 40 CFR Section

38 TABLE A: LIMITS AND OTHER REQUIREMENTS A-34 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Particulate matter control device temperature. The Permittee shall determine and record the four-hour arithmetic average gas stream temperature as measured at the inlet to each particulate matter control device during the initial and each subsequent performance test for PCDD/PCDF demonstrating compliance with the PCDD/PCDF emission limits in Minn. R and 40 CFR Section The Permittee shall: Select a mercury/pcdd/pcdf control additive system operating parameter that can be used to calculate mercury/pcdd/pcdf control additive (additive) feed rate (for example, screw feeder speed). Minn. R , subp. 8; 40 CFR Section Minn. R , subp. 1; 40 CFR Section (a) and (b) During each PCDD/PCDF and mercury performance test, the Permittee shall determine the average additive feed rate in kilograms (or pounds) per hour and determine the average operating parameter level that correlates to that additive feed rate. The Permittee shall also establish a relationship between the operating parameter and the additive feed rate in order to calculate the additive feed rate based on the operating parameter level. Exceedances of emission limits. If accurate and valid data results of a performance test demonstrate an exceedance of a standard of performance as described in this air emission permit after normal start-up, the Permittee shall undertake the actions in items A to D. A. The exceedance shall be reported to the Commissioner as soon as reasonably possible giving consideration to matters of plant or worker safety, or access to communications and the applicable reporting provisions of Minn. R , subpart 6, shall be met. B. Immediately undertake appropriate repairs or modifications to return the waste combustor to compliance as soon as possible. Exceedances of emission limits (continued): C. Conduct additional performance test(s) or shut the waste combustor down. If the waste combustor cannot demonstrate compliance within 60 days of the report of initial exceedance, the waste combustor shall be shut down on the 61st day after the report of the exceedance. The performance test shall be conducted and the test report received within those 60 days. Exceedances of emission limits (continued): D. If the Permittee cannot demonstrate compliance within 60 days of the report of the initial exceedance, the Permittee may restart the waste combustor for the purposes of compliance testing, provided that at least a 10-day notification has been provided to the Commissioner. The Permittee is allowed to operate the waste combustor until the completion of the test, after which the waste combustor must be shut down. The waste combustor may be restarted only after the Permittee receives notice from the Commissioner that it has achieved compliance with the emissions standards or restarts for the purpose and duration of additional testing after further repair or operational changes. MONITORING REQUIREMENTS Minn. Stat , subd. 3; and Minn. R , subp. 11 CONTINUED: Minn. Stat , subd. 3; and Minn. R , subp. 11 CONTINUED: Minn. Stat , subd. 3; and Minn. R , subp. 11 hdr Continuous Monitoring: Permittee shall install, calibrate, maintain and operate, in accordance with Minn. R , subp. 5, monitors that continuously read and record: a) sulfur dioxide and carbon monoxide at the outlet of the air pollution control device. b) unit load level as determined through steam flow measurement. c) oxygen concentrations at each location where CO and SO2 emissions are monitored. d) temperatures of the flue gas at the inlet of each particulate matter control device. e) flue gas opacity. f) mercury/pcdd/pcdf control additive feed rate or other parameter for which a correlation between that parameter and the additive feed rate has been developed. If the Permittee chooses to demonstrate compliance by monitoring the percent reduction of sulfur dioxide, the Permittee shall install a continuous emission monitoring system for sulfur dioxide and oxygen at the inlet of the air pollution control device. Continuous Monitoring: The Permittee shall: - Continuously monitor the selected mercury/pcdd/pcdf control additive (additive) feed rate operating parameter during all periods when the municipal waste combustion unit is operating and combusting waste - Calculate the 8-hour block average additive feed rate in kilograms (or pounds) per hour. - When calculating the 8-hour block average, exclude hours when the unit is not operating and include hours when unit is operating but the additive feed system is not working correctly. Minn. R , subp. 2; Minn. R , subp. 3; Minn. R , subp. 3; 40 CFR Section ; 40 CFR Section ; 40 CFR Section ; 40 CFR Section CFR Section (c)

39 TABLE A: LIMITS AND OTHER REQUIREMENTS A-35 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Continuous Monitoring: The Permittee shall obtain one-hour arithmetic averages from 4 or more data points equally spaced over each 1-hour period for: - Unit load level of the municipal waste combustion unit. - Temperature of the flue gases at the inlet of the particulate matter control device. - Mercury/PCDD/PCDF control additive feed rate. Data recorded during periods of continuous system breakdown, repair, calibration checks, and zero and span adjustments shall not be included in the data averages computed, unless there are, at least, 2 data points per hour. Continuous Monitoring: The Permittee shall install the following monitoring systems such that representative measures of the process parameters from the affected facility are obtained: - unit load, - flue gas temperature, and - mercury/pcdd/pcdf control additive. Continuous NOx Monitoring: The Permittee shall install, calibrate, maintain and operate monitors that continuously read and record nitrogen oxide at the outlet of the air pollution control device. The Permittee must follow the monitoring averaging periods specified in Minn. R , subp CFR Section ; 40 CFR Section 60.13(h); 40 CFR Section 60.13(e)(2) 40 CFR Section 60.13(f) Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R The monitor (MR 019) shall be operated and maintained in accordance with Minn. R. ch Continuous Monitoring: All continuous monitoring systems and monitoring devices required under 40 CFR 60, including CEMS and COMS shall be installed, operational, and certified prior to conducting performance tests under 40 CFR Section Continuous Operation: Except for continuous monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments, all continuous monitoring systems (including CEMS and COMS) shall be in continuous operation during all periods of emission unit operation. This includes periods of emission unit start-up, shutdown, or malfunction. Steam flow measurement method. The method contained in ASME Power Test Codes: Test Codes for Steam Generating Units, PTC 4.1 (1972), section 4, shall be used for calculating the steam flow required under Minn. R , subpart 3, item A, subitem (2). The recommendations of Instruments and Apparatus: Measurement of Quantity of Materials, Interim Supplement 19.5 (1971), chapter 4, shall be followed for design, construction, installation, calibration, and use of nozzles and orifices, except that measurement devices such as flow nozzles and orifices are not required to be recalibrated after they are installed. All signal conversion elements associated with steam flow measurements must be calibrated according to the manufacturer's instructions before each PCDD/PCDF test, and at least once per year. This annual calibration shall be recorded in the daily operating record as described in Minn. R , subpart 2. Alternative continuous measuring methods in place of steam flow may be installed and operated, provided that the method continuously measures the waste combustor unit load, is equivalent to results obtained when using the method in Minn. R , subp. 4, and the use of the method is approved by the Commissioner and Administrator prior to installation. Installation Notification: due 60 days before installing the COMS/CEMS. Install the CEMS according to the procedures in 40 CFR Appendix B. CEMS QA/QC: The Permittee shall operate, calibrate, and maintain each CO and SO2 CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F, section 3, as amended. CEMS QA/QC: The Permittee shall operate, calibrate, and maintain each NOx CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F, section 3, as amended. COMS Monitoring Data: The Permittee shall reduce all data to 6 minute averages. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the 6 minute averaging period. CEMS/COMS Continuous Operation: CEMS/COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit startup, shutdown, or malfunction. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS/COMS must not be bypassed except in emergencies where failure to bypass the CEMS/COMS would endanger human health, safety, or plant equipment. 40 CFR Section 60.13(b) 40 CFR Section 60.13(e); Minn. R , subp. 1 Minn. R , subp. 4; 40 CFR Section (a) Minn. R , subp. 4a; 40 CFR Section (b) Minn. R , subp. 1 Minn. R , subp. 5(G); 40 CFR Section (d) Minn. R , subp. 1; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1 & 2 Minn. R , subp. 1

40 TABLE A: LIMITS AND OTHER REQUIREMENTS A-36 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Monitoring data shall be obtained for at least 75 percent of the hours per day for 90 percent of the days per calendar quarter that the combustor is operating and combusting MSW. The Permittee shall use all valid data from the continuous emission monitoring systems in calculating emission concentrations and percent reductions. Minn. R , subp. 5(B); 40 CFR Section (c) 40 CFR Section ; Minn. R , subp. 5(D); 40 CFR Section (e) If CEM/COM data is unavailable, the Permittee shall meet the minimum data requirements using the alternative methods set forth in 40 CFR part 60, Appendix A, Methods 19 and 6c for SO2; Method 10 for CO; Method 9 for opacity; Method 3A or 3B for O2 or CO2. The Permittee shall notify the Administrator according to 40 CFR Section (e) if the minimum data required for continuously monitored emissions and parameters are not obtained. CEM/COMS Certification Test: due 90 days after first Excess Emissions Report. This requirement applies to any CO and SO2 CEMS which have not previously been certified. CEMS/COMS Certification Test: due 90 days after first Excess Emissions Report. This requirement applies to any NOx CEMS which have not previously been certified. CEM/COMS Certification Test Plan: due 30 days before CEM/COM Certification Test. CEM/COMS Certification Test Pretest Meeting: due 7 days before CEM/COMS Certification Test. CEM/COMS Certification Test Report: due 45 days after CEM/COMS Certification Test. CEM/COMS Certification Test Report - Microfiche Copy: due 105 days after CEM/COMS Certification Test. COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) opacity at least once daily from each COMS according to the procedures listed in 40 CFR Section CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures of 40 CFR CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CO and SO2 CEMS. CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures of 40 CFR CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for NOx CEMS. COMs Calibration Error Audit: due before end of each half-year following COMs Certification Test. Conduct audits at least 3 months apart but no greater than 8 months apart. Follow the procedures of 40 CFR 60, Appendix B, Performance Specification 1. CEMs Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEMs Certification Test except for quarters in which a RATA was performed. This requirement applies to each CO and SO2 CEMS as well as each diluent monitor. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test except for quarters in which a RATA was performed. This requirement applies to each NOx CEMS as well as each diluent monitor. CEMs Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEMs Certification Test. Follow the procedure in 40 CFR pt. 60, Appendix F. The RATA shall be conducted during the calendar quarter in which a cylinder gas audit (CGA) is not performed. This requirement applies to each CO and SO2 CEMS individually. Conduct annual evaluations of your continuous emission monitoring systems no more than 13 months after the previous evaluation was conducted. CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test. Follow the procedure in 40 CFR pt. 60, Appendix F. The RATA shall be conducted during the calendar quarter in which a cylinder gas audit (CGA) is not performed. This requirement applies to each NOx CEMS individually. Conduct annual evaluations of your continuous emission monitoring systems no more than 13 months after the previous evaluation was conducted. Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA). 40 CFR Section (d); 40 CFR Section (d) Minn. R , subp. 1; 40 CFR Section (b); 40 CFR 60.13(b) Minn. R , subp. 1; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1 and 2 Minn. R , subp. 3 Minn. R , subp. 1, 2, and 4 Minn. R , subp. 3 Minn. R , subp. 5(E); Minn. R , subp. 2 Minn. R , subp. 5(E); Minn. R , subp. 3; 40 CFR Section (b); 40 CFR Section (f) Minn. R , subp. 5(E); Minn. R , subp. 3; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 3; Minn. R , subp. 2 Minn. R , subp. 5(G); Minn. R , subp. 2; 40 CFR Section (b) Minn. R , subp. 5(G); Minn. R , subp. 2; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 5(G); Minn. R , subp. 2; 40 CFR Section (d); 40 CFR Section (a) Minn. R , subp. 5(G); Minn. R , subp. 2; Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 2; MInn. R , subp. 2

41 TABLE A: LIMITS AND OTHER REQUIREMENTS A-37 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Exceedances of Continuously Monitored Emissions: If accurate and valid data results collected from the sulfur dioxide and/or carbon monoxide monitors exceed emission limits, the following procedures shall be followed. (1) Exceedance shall be reported to the Commissioner as soon as reasonably possible. (2) Appropriate repairs or modifications to return the waste combustor to compliance must be commenced within 72 hours. If compliance cannot be achieved within 72 hours, then the waste combustor shall be shut down. If modifications to return the waste combustor to compliance require the amendment of this permit, the waste combustor shall shut down within 72 hours of the exceedance. Exceedances of Continuously Monitored Emissions (continued): (3) When repairs or modifications have been completed, the Permittee shall demonstrate to the Commissioner that the waste combustor is in compliance. The waste combustor may be started up after the Permittee has notified the Commissioner in writing of the date the Permittee plans to start up the waste combustor and the date that performance testing is scheduled. Notification shall be given at least 10 days in advance of the compliance test date. RECORDKEEPING Minn. R , subp. 7 CONTINUED: Minn. R , subp. 7 hdr Recordkeeping: Permittee will maintain a record of continuously measured parameters as specified in Minn. R , subp. 6. Recordkeeping: Permittee will maintain a record of all continuously measured parameters to record the 24-hour daily arithmetic average NOx emission concentrations. The Permittee shall: Keep all records on-site in paper copy or electronic format. Make all records available for submittal to the Administrator or Commissioner, or for on-site review by the Administrator or Commissioner. Recordkeeping: record in the daily operating record the four-hour arithmetic average gas stream temperature as measured at the fabric filter inlets during the most recent PCDD/PCDF performance test demonstrating compliance with the PCDD/PCDF emission limits in part and 40 CFR (a)(2). The Permittee shall maintain on-site for five years after the report is generated, a paper copy of each quarterly report, initial compliance report, and performance test report required under Minn. R , subparts 3, 5, and 6 respectively. Daily Operating Record: The Permittee shall maintain on-site daily records for the operation of the waste combustor. Daily records include such things as the operator log book, operator daily log sheets, trend records, CEMS records, and the daily operating report. The record shall contain: A. the calendar date; B. the hours of operation; C. the weight of waste combusted; D. the weight of waste requiring disposal at a solid waste land disposal facility, including separated noncombustibles, excess waste, and ash; E. the amount and description of industrial solid waste received each day, the generator's name, and the method of handling; F. the measurements and determination of emissions averages as required in Minn. R , subpart 6; Daily Operating Record (Continued) G. results of performance tests conducted on waste combustor units as required in this permit; H. the names of persons who have completed initial review or subsequent annual review of the operating manual; I. Continuous monitoring system records including: I1. each one-hour emission average recorded by the CEMS; I2. each six-minute opacity average recorded by the COMS; I3. monitor certification test reports; I4. excess emissions reports; I5. cylinder gas audit reports; I6. calibration error audit reports; I7. relative accuracy test audits; Minn. R , subp. 6; Minn. R , subp. 2; 40 CFR Section (a) and (b) Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 1; 40 CFR Section Minn. R , subp. 8; Minn. R , subp. 2 Minn. R , subp CFR Section (b) Minn. R , subp. 1; 40 CFR Section (a) Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d); Minn. R , item B(3) regarding test frequency CONTINUED: Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d); Minn. R , item B(3) regarding test frequency

42 TABLE A: LIMITS AND OTHER REQUIREMENTS A-38 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Daily Operating Record (Continued) I8. linearity check reports; I9. results of daily calibration drift checks; I10. log of adjustments made to the CEMS or COMS and maintenance performed on the CEMS or COMS; I11. the reasons for exceeding any of the average emission rates, percent reductions, or operating parameters specified under Minn. R , subpart 6, item C, or six-minute average COMS measurements that exceed the opacity limit and a description of corrective actions taken; I12. reasons for not obtaining the minimum number of hours of sulfur dioxide or operational data (opacity, carbon monoxide emissions, steam flow, particulate matter control device temperature) and a description of corrective actions taken. I13. the date of the calibration of all signal conversion elements associated with steam flow monitoring as required in Minn. R , subp. 4. Daily Operating Record (Continued) J. the following for control of Hg or dioxins, with an additive: J1. a record of the average additive system operating parameter for each hour of operation. J2. if the required hourly average additive system operating parameter is not maintained, the reasons for not maintaining the additive system operating parameter as determined in Minn. R , subp. 2 and the corrective actions taken. J3. a record of the average additive mass feed rate for each hour of operation. J4. if the required hourly average additive mass feed rate is not maintained, the reasons for not maintaining the additive mass feed rate as determined in Minn. R , subp. 1 and the corrective actions taken. K. Record of the pressure drop across the fabric filters. L. Record of acid gas control. Recordkeeping: The Permittee shall maintain a file of the following CEMS or COMS information at the emission facility in a form suitable for inspection for at least five years from the date of each record. - all monitoring system information required by an applicable compliance document; and - an up-to-date monitor QA/QC plan. Recordkeeping, Exclusions of Data. The Permittee shall document each time data was excluded from calculation of averages for any of the following: - Sulfur dioxide emissions. - Carbon monoxide emissions. - Unit load levels. - Temperatures of the flue gases at the inlet of the particulate matter control device. Recordkeeping, Exclusions of Data. The Permittee shall document each time data was excluded from calculation of averages for any of the following: - Nitrogen oxide emissions. Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping, Training and Certification: The Permittee shall keep records of training courses completed and certifications achieved, including: i) Names of the chief facility operator, shift supervisors, and control room operators who are provisionally or fully certified by the American Society of Mechanical Engineers. - Dates of the initial provisional or full certifications. - Documentation showing current provisional or full certifications. ii) Names of the chief facility operator, shift supervisors, and control room operators who have completed the EPA or State municipal waste combustion operator training course. - Dates of completion of the operator training course. iii) Documentation showing completion of operator training course. - Names of persons who have reviewed the operating manual. - Date of the initial review. - Dates of subsequent annual reviews. CONTINUED: Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d); Minn. R , item B(3) regarding test frequency CONTINUED: Minn. R ; Minn. R ; Minn. R , subp. 2; 40 CFR Section (a), (b), (c), and (d); Minn. R , item B(3) regarding test frequency Minn. R CFR Section (e) Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Minn. R , subp. 2 Minn. R , subp. 11; Minn. R ; Minn. R , subp. 2(I); 40 CFR Section (a), (b), (c), and (d)

43 TABLE A: LIMITS AND OTHER REQUIREMENTS A-39 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Recordkeeping and Recording of Mercury/PCDD/PCDF Control Additive Use. The Permittee shall maintain a record of: - The average additive mass feed rate for each hour of operation. - All 8-hour block average mercury/pcdd/pcdf control additive feed rates in kilograms (pounds) per hour calculated from the monitored operating parameter. - Total mercury/pcdd/pcdf control additive purchased and delivered to the facility for each calendar quarter. - Include supporting documentation. - Required quarterly usage of mercury/pcdd/pcdf control additive for the municipal waste combustion plant, calculated using the appropriate equation. - Supporting calculations. Recordkeeping, Records of Low Mercury/PCDD/PCDF Control Additive Feed Rates: The Permittee shall keep the following records regarding the periods when the average mercury/pcdd/pcdf control additive feed rate over an 8-hour block was less than the average mercury/pcdd/pcdf control additive feed rates determined during the most recent mercury/pcdd/pcdf performance test which demonstrated compliance with the emissions limits: - Calendar date(s) - Beginning and ending time - Reasons for the low mercury/pcdd/pcdf control additive feed rates. - Corrective actions taken to meet the 8-hour average mercury/pcdd/pcdf control additive feed rate requirement. Minn. R , subp. 3; 40 CFR Section (a) 40 CFR Section (b) and (d) The Permittee shall also keep a record regarding data excluded from averaging calculations including the date(s) and time data was excluded from average feed rate calculations and the reasons the data were excluded. Recordkeeping - NOx emissions: The Permittee shall record the NOx CEMs measured emission concentrations in ppmv corrected to 7% O2. Recordkeeping - NOx emissions: By the 15th day of each month, the Permittee shall calculate and record the tons of NOx emitted during the previous calendar month, and the tons of NOx emitted during the previous 12-month period. Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R The monthly emissions shall be calculated using the following equation: NOx1 = * NOx2 * MSW * 1/2000 where NOx1 = NOx monthly emissions in tons/month NOx2 = NOx 7% O2) from monthly CEMS average MSW = monthly sum of MSW combusted, based on total weight of waste combusted, as calculated from the Daily Operating Record Monthly NOx CEMs Average Calculation: The Permittee shall calculate the monthly average NOx concentration by calculating an arithmetic average of all of the 24-hour daily block average NOx concentrations (in ppmdv, corrected to 7% O2) recorded, for each day, in a given month, in which waste is combusted for at least 1-hour. Time periods when waste is combusted, but the CEMs is inoperable, (or is otherwise known to be incapable of recording valid data) shall be included in the monthly average NOx calculation, using the CEMs data substitution procedure. Monthly NOx CEMs Average Calculation (continued): If the CEMs is inoperable for one (1) or more hours during a calendar day in which waste was combusted for at least one hour, the 95% upper confidence level of 24-hour daily block average NOx concentrations (ppmdv at 7% O2) from the previous calendar year shall be used as a substitute for each hour of CEMs downtime. An adjusted 24-hour daily block average concentration shall then be calculated for the applicable operating day by including the substituted data for applicable hours of CEMs downtime. Initially, the Permittee shall use ppmdv NOx at 7% O2 as a NOx substitution value for each hour of CEMs downtime. This value is based on the 95% upper confidence level of the 24-hour daily block average NOx emissions from existing Units 1 and 2 during calendar year Monthly NOx CEMs Average Calculation (continued): After an additional, complete calendar year of CEMs data becomes available, the 95% upper confidence level of 24-hour daily block average NOx emissions (ppmdv at 7% O2) shall be calculated for that new year of CEMs data and then used for data substitution purposes under this paragraph in the following calendar year. REPORTING Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21(b); Minn. R hdr

44 TABLE A: LIMITS AND OTHER REQUIREMENTS A-40 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Notify: due 30 days after Start Of Construction the Notice of Construction. The Notice of Construction shall include: 1) A statement of intent to construct EU ) The planned initial startup date of EU ) The types of fuels to be combusted in EU ) The capacity of EU 006 including supporting capacity calculations as specified in 40 CFR Sections (d) and (e). 5) The siting analysis, as specified in 40 CFR Section ) The final materials separation plan, as specified in 40 CFR Section (b). 7) The notice of the second public meeting (siting analysis meeting), as specified in 40 Section (b). 8) A transcript of the second public meeting, as specified in 40 CFR Section (d). 9) A copy of the document that summarizes the Permittee's responses to the public comments received during the second public comment period, as specified in 40 CFR Section (a). 10) The final siting analysis, as specified in 40 Section (c). Quarterly Reports: The report shall contain the following items: A. calendar date; B. a graphic or tabular presentation of the sulfur dioxide and carbon monoxide emissions, the maximum waste combustor unit load level and particulate matter control device temperatures as recorded by Minn. R , subp. 6, item C, and the daily maximum opacity readings as recorded by Minn. R , subp. 6, item B, subitem (1). The graphs shall be prepared as follows: (1) the graph shall represent one operating parameter or pollutant; (2) the applicable limit of the parameter or pollutant shall be indicated on the graph; and (3) data shall be expressed in the same units as the applicable operating parameter or emissions limit; 40 CFR Section ; 40 CFR Section ; 40 CFR Section Minn. R , subp. 3 Quarterly Reports (Continued): C. the identification of operating days when any of the average emission concentrations, percent reductions, operating parameters specified under Minn. R , subp. 6(C), Minn. R , subp. 2 exceeded the applicable limits or any 6 minute average opacity greater than the limit. The report shall include the emission levels recorded during the exceedance, reasons for such exceedances as well as a description of corrective actions taken; D. the percent of the operating time for the quarter that the opacity CEMS was operating and collecting valid data; E. the identification of operating days for which the minimum number of hours that emission concentrations, percent reductions, operating parameters specified under Minn. R , subp. 6(C), Minn. R , subp. 2 or the opacity level data have not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken; Quarterly Reports (Continued) F. the results of daily sulfur dioxide and carbon monoxide CEMS drift tests and accuracy assessments as required in Minn. R , subp. 5. G. the information required in Minn. R , subp 2(C), (D), and (E), summarized to reflect quarterly totals; H. a compliance certification as required in Minn. R , subp 6(C); and I. if an additive is used to comply with the mercury and/or PCDD/PCDF emission limits, the total additive used during the calendar quarter, as specified in Minn. R , subp. 3(B), with supporting calculations. The total amount of additive purchased and delivered to the facility must be equal to or greater than the required quarterly usage of additive. Quarterly usage of the additive shall be determined in accordance with 40 CFR Reporting to the Administrator: The Permittee shall submit to the Administrator an initial report and annual reports, plus semiannual reports for any emission or parameter level that does not meet the limits specified in this permit: - Submit the annual report no later than February 1 of each year that follows the calendar year in which data was collected. - Submit semiannual report for data collected during the first half of a calendar year, by August 1 of that year. For data collected during the second half of the calendar year, submit semiannual report by February 1 of the following year. - The Permittee shall retain a copy of all reports on site for 5 years. - All information shall be reported in the units in which the limit or parameter is expressed. Initial Report: The initial report shall contain the items listed in 40 CFR Section CONTINUED: Minn. R , subp. 3 CONTINUED: Minn. R , subp. 3; 40 CFR (d) 40 CFR Section CFR Section ; 40 CFR Section

45 TABLE A: LIMITS AND OTHER REQUIREMENTS A-41 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Initial Report: The Initial Report shall contain the following: A. The emission levels measured on the date of the initial evaluation of the continuous emission monitoring systems for all of the following pollutants or parameters as recorded in accordance with 40 CFR Section (b): A1. The 24-hour daily geometric average concentration of sulfur dioxide emissions or the 24-hour daily geometric percent reduction of sulfur dioxide emissions. A2. The 4-hour block arithmetic average concentration of the carbon monoxide emissions. A3. The 4-hour block arithmetic average load level of each municipal waste combustion unit. A4. The 4-hour block arithmetic average flue gas temperature at the inlet of each particulate matter control device. Initial Report: (continued) B. The results of the initial performance tests for the following pollutants: B1. Dioxins/furans, Cadmium, Lead, Mercury, Opacity, Front-half particulate matter, Hydrogen chloride, Fugitive ash. C. The test report that documents the initial stack test including supporting calculations. D. The initial performance evaluation of continuous emissions monitoring systems. E. Operating Conditions during the initial performance tests. E1. The maximum demonstrated load of the waste combustion unit and the maximum demonstrated temperature of the flue gases at the inlet of the particulate matter control device. Use the values established during the initial test for dioxins/furans emissions and include supporting calculations. E2. The average feed rates of the additive to control mercury/pcdd/pcdf as recorded during the mercury and PCDD/PCDF emissions testing and supporting calculations as specified in 40 CFR Section (a)(1) and (2). Initial Report: (continued) F. If the Permittee chooses to monitor carbon dioxide instead of oxygen as the diluent gas, documentation of the relationship between oxygen and carbon dioxide, as specified in 40 CFR Section Annual Report The annual report shall contain a summary of the following: (a) The results of the annual performance test (b) A list of the highest average emission levels recorded, in the appropriate units. (c) The highest 6-minute opacity level measured. (d) For mercury/pcdd/pcdf control additive (additive) usage, (1)The average additive feed rates recorded during the most recent mercury performance tests. (2) The lowest 8-hour block average additive feed rate recorded during the year. (3) The total additive purchased and delivered to the facility. (4) The required quarterly additive usage. (e) The total number of days that the minimum number of hours of data was not obtained. Include the reasons for not obtaining the data and corrective actions taken to obtain the data in the future. (f) The number of hours data was excluded from the calculation of average levels (include the reasons for excluding it). Annual Report (continued) (g) If eligible for reduced performance testing, a notice of the intent to begin a reduced performance testing schedule during the following calendar year. (h) A summary of any emission or parameter level that did not meet the required limits. (i) A summary of the data in paragraphs (a) through (d) of this section from the year preceding the reporting year. (j) Documentation of periods when all certified chief facility operators and certified shift supervisors are offsite for more than 12 hours. Semiannual Report to the Administrator: The Permittee shall submit a semiannual report if any recorded emission or parameter level that does not meet the requirements specified in this permit. The semiannual report shall contain: (a) For any pollutants or parameters that exceeded the specified limits, include the calendar date, the averaged and recorded data for that date, the reasons for exceeding the limits, and corrective actions. (b) If the results of the annual performance tests show emissions above the specified limits, the semiannual report shall include a copy of the test report that documents the emission levels and corrective actions. 40 CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section CFR Section ; 40 CFR Section CFR Section CONTINUED: 40 CFR Section CFR Section (a) and (b)

46 TABLE A: LIMITS AND OTHER REQUIREMENTS A-42 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Semiannual Report to the Administrator: (continued) (c) If mercury/pcdd/pcdf control additive (additive) is used to control mercury and/or PCDD/PCDF emissions, include two items: (1) Documentation of all dates when the 8-hour block average additive feed rate is less than the required additive feed rate. Include four items: (i) Eight-hour average additive feed rate. (ii) Reasons for the occurrences of low additive feed rates. (iii) The corrective actions taken to meet the additive feed rate requirement. (iv) The calendar date. Semiannual Report to the Administrator: (continued) (2) Documentation of each quarter when total additive purchased and delivered is less than the total required quarterly usage of additive. Include five items: (i) Amount of additive purchased and delivered. (ii) Required quarterly usage of additive. (iii) Reasons for not meeting the required quarterly usage of additive. (iv) The corrective actions taken to meet the required quarterly usage of additive. (v) The calendar date. CONTINUED: 40 CFR Section (c) CONTINUED: 40 CFR Section (c)

47 TABLE A: LIMITS AND OTHER REQUIREMENTS A-43 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 001 Fabric Filter - High Temperature, i.e., T>250 Degrees F Associated Items: EU 001 MSW Incinerator Unit 1 What to do Temperature: less than or equal to 401 degrees F using 4-hour Block Average as measured at the inlet to the PM control device (as determined during the 5/8/08 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the new PM control device inlet temperature into this permit, the PM control device inlet temperature shall not exceed a temperature greater than 30 degrees Fahrenheit (17 degree C) greater than the PM control device inlet temperature established during that compliant performance test. Temperature (continued): The waste combustor is exempt from limits on temperature at the inlet of the particulate matter control device during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Temperature (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the particulate matter control device inlet gas temperature limit can be waived; 3) the length of time the project will take to complete. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 10 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. The recommended range of pressure drop shall be documented in the facility Operations and Maintenance Plan. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions indicate evidence of fabric filter malfunction; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Why to do it Minn. R , subp. 2 Minn. R , subp CFR Section (b) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 and 14 Minn. R , subp. 4 and 5 Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5, and 14 Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary Minn. R , subp. 4 monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

48 TABLE A: LIMITS AND OTHER REQUIREMENTS A-44 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

49 TABLE A: LIMITS AND OTHER REQUIREMENTS A-45 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 002 Fabric Filter - High Temperature, i.e., T>250 Degrees F Associated Items: EU 002 MSW Incinerator Unit 2 What to do Temperature: less than or equal to 401 degrees F using 4-hour Block Average as measured at the inlet to the PM control device (as determined during the 2/20/07 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the new PM control device inlet temperature into this permit, the PM control device inlet temperature shall not exceed a temperature greater than 30 degrees Fahrenheit (17 degree C) greater than the PM control device inlet temperature established during that compliant performance test. Temperature (continued): The waste combustor is exempt from limits on temperature at the inlet of the particulate matter control device during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Temperature (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the particulate matter control device inlet gas temperature limit can be waived; 3) the length of time the project will take to complete. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 10 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. The recommended range of pressure drop shall be documented in the facility Operations and Maintenance Plan. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions indicate evidence of fabric filter malfunction; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Why to do it Minn. R , subp. 2 Minn. R , subp CFR Section (b) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 and 14 Minn. R , subp. 4 and 5 Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5, and 14 Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary Minn. R , subp. 4 monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

50 TABLE A: LIMITS AND OTHER REQUIREMENTS A-46 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

51 TABLE A: LIMITS AND OTHER REQUIREMENTS A-47 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 003 Dry Sorbent Injection Associated Items: EU 001 MSW Incinerator Unit 1 What to do Reagent feedrate: For acid gas control (HCl), maintain reagent injection feedrate equal or greater than the most recent MPCA approved hourly feedrate performance test. Once per calendar day, there is to be a feedrate calibration. The compliance test is to be demonstrated, based on the average of three one-hour tests (lbs/hr). During the 2/13/08 HCl compliance test, the average lime feed rate to the spray dryer was 50 lb/hr. The Permittee shall use the same or similar reagent as used during the most recent compliant acid gas compliance test. The Permittee shall operate and maintain the reagent injection at all times that any emission unit controlled, by the reagent injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Hourly visual inspection to ensure that control equipment is properly operating (i.e., no plugging of reagent, proper reagent injection feedrate being maintained, etc.) Recordkeeping: Why to do it Minn. R , subp. 3a Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Keep an hourly record of the dry sorbent injection equipment inspection. The record will note any required corrective actions. Keep a daily record of the reagent feedrate calibrations to verify that the feedrate is equal to or greater than the hourly feedrate during the most recent MPCA approved compliance test. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of reagent injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the reagent injection is in operation. Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the reagent injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

52 TABLE A: LIMITS AND OTHER REQUIREMENTS A-48 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 004 Dry Sorbent Injection Associated Items: EU 002 MSW Incinerator Unit 2 What to do Reagent feedrate: For acid gas control (HCl), maintain reagent injection feedrate equal or greater than the most recent MPCA approved hourly feedrate performance test. Once per calendar day, there is to be a feedrate calibration. The compliance test is to be demonstrated, based on the average of three one-hour tests (lbs/hr). During the 4/09/08 HCl compliance test, the average lime feed rate to the spray dryer was 55 lb/hr. The Permittee shall use the same or similar reagent as used during the most recent compliant acid gas compliance test. The Permittee shall operate and maintain the reagent injection at all times that any emission unit controlled, by the reagent injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Hourly visual inspection to ensure that control equipment is properly operating (i.e., no plugging of reagent, proper reagent injection feedrate being maintained, etc.) Recordkeeping: Why to do it Minn. R , subp. 3a Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Keep an hourly record of the dry sorbent injection equipment inspection. The record will note any required corrective actions. Keep a daily record of the feedrate calibrations to verify that the feedrate is equal to or greater than the hourly feedrate during the most recent MPCA approved compliance test. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of reagent injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the reagent injection is in operation. Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the reagent injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

53 TABLE A: LIMITS AND OTHER REQUIREMENTS A-49 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 005 Carbon Injection Associated Items: EU 001 MSW Incinerator Unit 1 What to do Mercury additive feedrate: greater than or equal to 1.7 lbs/hour using 8-hour Block Average for CE 005 (as determined during the 5/08/08 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF or mercury performance test and prior to incorporation of the new mercury/pcdd/pcdf control additive feed rate into this permit, the Permittee shall maintain the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and the most recent compliant PCDD/PCDF performance test. Mercury Additive Feedrate (continued): The waste combustor is exempt from limits on the mercury additive feedrate during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Mercury Additive Feedrate (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the activated carbon feedrate limit can be waived; 3) the length of time the project will take to complete. The Permittee shall operate and maintain the carbon injection, at all times, that any emission unit controlled, by the carbon injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Daily visual inspection to ensure that carbon injection control equipment is properly operating (i.e., no plugging of carbon, etc.) Keep a daily record of the carbon injection equipment to verify that there is no plugging of the carbon. Keep a record of the carbon injection rate at all times the waste combustor is in operation. The Permittee shall evaluate total mercury/pcdd/pcdf control additive (additive) usage for each calendar quarter for each unit. Why to do it Minn. R , subp. 2; 40 CFR Section (c) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 4(B) Minn. R , subp. 2; 40 CFR Section (d) The total amount of additive purchased and delivered to the facility must be equal to or greater than the required quarterly usage of additive. Quarterly usage of additive shall be determined in accordance with 40 CFR Section Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of carbon injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the carbon injection is in operation. Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4

54 TABLE A: LIMITS AND OTHER REQUIREMENTS A-50 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the carbon injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

55 TABLE A: LIMITS AND OTHER REQUIREMENTS A-51 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 006 Carbon Injection Associated Items: EU 002 MSW Incinerator Unit 2 What to do Mercury additive feedrate: greater than or equal to 1.7 lbs/hour using 8-hour Block Average for CE 006 (as determined during the 2/20/07 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF or mercury performance test and prior to incorporation of the new mercury/pcdd/pcdf control additive feed rate into this permit, the Permittee shall maintain the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and the most recent compliant PCDD/PCDF performance test. Mercury Additive Feedrate (continued): The waste combustor is exempt from limits on the mercury additive feedrate during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Mercury Additive Feedrate (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the activated carbon feedrate limit can be waived; 3) the length of time the project will take to complete. The Permittee shall evaluate total mercury/pcdd/pcdf control additive (additive) usage for each calendar quarter for each unit. Why to do it Minn. R , subp. 2; 40 CFR Section (c) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2; 40 CFR Section (d) The total amount of additive purchased and delivered to the facility must be equal to or greater than the required quarterly usage of additive. Quarterly usage of additive shall be determined in accordance with 40 CFR Section The Permittee shall operate and maintain the carbon injection, at all times, that any emission unit controlled, by the carbon injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Daily visual inspection to ensure that carbon injection control equipment is properly operating (i.e., no plugging of carbon, etc.) Keep a daily record of the carbon injection equipment to verify that there is no plugging of the carbon. Keep a record of the carbon injection rate at all times the waste combustor is in operation. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of carbon injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the carbon injection is in operation. Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 4(B) Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4

56 TABLE A: LIMITS AND OTHER REQUIREMENTS A-52 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the carbon injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

57 TABLE A: LIMITS AND OTHER REQUIREMENTS A-53 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 007 Fabric Filter - High Temperature, i.e., T>250 Degrees F Associated Items: EU 006 MSW Incinerator Unit 3 What to do Temperature: less than or equal to the temperature (degree F) using 4-hour Block Average as measured at the inlet to the PM control device (to be determined during the initial PCDD/PCDF compliance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emission unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the new PM control device inlet temperature into this permit, the PM control device inlet temperature shall not exceed a temperature greater than 30 degrees Fahrenheit (17 degree C) greater than the PM control device inlet temperature established during that compliant performance test. Temperature (continued): The waste combustor is exempt from limits on temperature at the inlet of the particulate matter control device during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Temperature (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the particulate matter control device inlet gas temperature limit can be waived; 3) the length of time the project will take to complete. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 10 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. The recommended range of pressure drop shall be documented in the facility Operations and Maintenance Plan. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions indicate evidence of fabric filter malfunction; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Why to do it Minn. R , subp. 2 Minn. R , subp CFR Section (b) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 Minn. R , subp CFR Section (e) Minn. R , subp. 2 and 14 Minn. R , subp. 4 and 5 Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5, and 14 Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary Minn. R , subp. 4 monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

58 TABLE A: LIMITS AND OTHER REQUIREMENTS A-54 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

59 TABLE A: LIMITS AND OTHER REQUIREMENTS A-55 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 008 Dry Sorbent Injection Associated Items: EU 006 MSW Incinerator Unit 3 What to do Reagent feedrate: For acid gas control (HCl), maintain reagent injection feedrate equal or greater than the most recent MPCA approved hourly feedrate compliance test (to be determined during the initial compliance test). Once per calendar day, there is to be a feedrate calibration. The compliance test is to be demonstrated, based on the average of three one-hour tests (lbs/hr). The Permittee shall use the same or similar reagent as used during the most recent compliant acid gas performance test. The Permittee shall operate and maintain the reagent injection at all times that any emission unit controlled, by the reagent injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Hourly visual inspection to ensure that control equipment is properly operating (i.e., no plugging of reagent, proper reagent injection feedrate being maintained, etc.) Recordkeeping: Why to do it Minn. R , subp. 3a Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Keep an hourly record of the dry sorbent injection equipment inspection. The record will note any required corrective actions. Keep a daily record of the feedrate calibrations to verify that the feedrate is equal to or greater than the hourly feedrate during the most recent MPCA approved compliance test. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of reagent injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the reagent injection is in operation. Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the reagent injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

60 TABLE A: LIMITS AND OTHER REQUIREMENTS A-56 01/20/10 Facility Name: Permit Number: Pope/Douglas Solid Waste Management Subject Item: CE 009 Carbon Injection Associated Items: EU 006 MSW Incinerator Unit 3 What to do Mercury additive feedrate: greater than or equal to the hourly feedrate (lb/hr) using 8-hour Block Average for CE 009 (to be determined during the initial PCDD/PCDF compliance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF or mercury performance test and prior to incorporation of the new mercury/pcdd/pcdf control additive feed rate into this permit, the Permittee shall maintain the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and the most recent compliant PCDD/PCDF performance test. Mercury Additive Feedrate (continued): The waste combustor is exempt from limits on the mercury additive feedrate during any of three situations: (1) Annual tests for dioxins/furans. (2) The 2 weeks preceding annual tests for dioxins/furans. (3) Whenever approved in writing by the Administrator and Commissioner for any of following activities: - (i) Evaluate system performance. - (ii) Test new technology or control technologies. - (iii) Perform diagnostic testing. - (iv) Perform other activities to improve the performance of the waste combustor. - (v) Perform other activities to advance the state of the art for emission controls for the waste combustor. Mercury Additive Feedrate (continued) The Permittee shall provide written notification submitted to the Commissioner and Administrator 30 days prior to undertaking any of the activities described above in 3(i) - (v), with the following information: 1) a description of the proposed project, and the outcome the project is designed to evaluate; 2) how the project conforms with the activities described above for which the activated carbon feedrate limit can be waived; 3) the length of time the project will take to complete. The Permittee shall operate and maintain the carbon injection, at all times, that any emission unit controlled, by the carbon injection, is in operation. The Permittee shall document periods of non-operation of the control equipment. Daily visual inspection to ensure that carbon injection control equipment is properly operating (i.e., no plugging of carbon, etc.) Keep a daily record of the carbon injection equipment to verify that there is no plugging of the carbon. Keep a record of the carbon injection rate at all times the waste combustor is in operation. The Permittee shall evaluate total mercury/pcdd/pcdf control additive (additive) usage for each calendar quarter for each unit. Why to do it Minn. R , subp. 2; 40 CFR Section (c) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2 Minn. R , subp CFR Section (e) (continued) Minn. R , subp. 2 and 14 Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 4(B) Minn. R , subp. 2; 40 CFR Section (d) The total amount of additive purchased and delivered to the facility must be equal to or greater than the required quarterly usage of additive. Quarterly usage of additive shall be determined in accordance with 40 CFR Section Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - fabric filter cleaning cycle indicates evidence of carbon injection malfunction; - the recorded feedrate is outside the required operating range; or - the reagent injection or any of its components are found during the inspections to need repair. Corrective actions shall return the feedrate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording feedrate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the carbon injection is in operation. Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4

61 TABLE A: LIMITS AND OTHER REQUIREMENTS A-57 01/20/10 Facility Name: Pope/Douglas Solid Waste Management Permit Number: Periodic Inspections: At least once semi-annually, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. The Permittee shall operate and maintain the carbon injection in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R , subp. 4, 5 and 14 Minn. R , subp. 14

62 TABLE B: SUBMITTALS Facility Name: Pope/Douglas Solid Waste Management Permit Number: Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. B-1 01/20/10 Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota

63 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Pope/Douglas Solid Waste Management Permit Number: B-2 01/20/10 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit Initial Compliance Status Report due 60 days after achieving maximum EU006 capacity (i.e., the maximum load level) at which EU 006 will operate, but no later than 180 days after its initial startup. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup EU006 Notification of the Date Construction Began due 30 days after Start Of Construction. Submit the unit name, number of EU 006, and the date construction began. Notification due 60 days after achieving maximum capacity Notification due 60 days before Equipment Installation (the continuous emissions monitoring system). EU006 EU006 EU006

64 TABLE B: RECURRENT SUBMITTALS Facility Name: Pope/Douglas Solid Waste Management Permit Number: B-3 01/20/10 What to send When to send Portion of Facility Affected COMS Calibration Error Audit Results Summary due 30 days after end of each calendar quarter following Permit Issuance in which the COMS Error Audit was completed. MR001, MR015 Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendar quarter following Permit Issuance in which the CGA RATA was completed. Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter following Permit Issuance. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. Quarterly Report due 30 days after end of each calendar quarter following Permit Issuance (-003) Quarterly Report due 30 days after end of each calendar quarter starting 09/23/2004. Semiannual Compliance Report due 31 days after end of each calendar half-year following Permit Issuance (-003). The Permittee shall submit to the Administrator a semiannual report on any recorded emission or parameter level that does not meet the requirements specified. The Permittee shall submit semiannual report for data collected during the first half of a calendar year, by August 1 of that year. For data collected during the second half of the calendar year, submit semiannual report by February 1 of the following year. The Permittee shall retain a copy of all reports on site for 5 years. All information shall be reported in the units in which the limit or parameter is expressed. Semiannual Compliance Report due 31 days after end of each calendar half-year following Permit Issuance The Permittee shall submit to the Administrator a semiannual report on any recorded emission or parameter level that does not meet the requirements specified. The Permittee shall submit semiannual report for data collected during the first half of a calendar year, by August 1 of that year. For data collected during the second half of the calendar year, submit semiannual report by February 1 of the following year. The Permittee shall retain a copy of all reports on site for 5 years. All information shall be reported in the units in which the limit or parameter is expressed. Semiannual Deviations Report due 30 days after end of each calendar half-year starting 09/23/2004. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year starting 09/23/2004 (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Relative Accuracy Test Audit (RATA) Results Summary due 30 days after end of each calendar year following Permit Issuance in which a RATA was completed. MR002, MR003, MR004, MR005, MR010, MR011, MR012, MR013, MR014, MR016, MR017, MR018, MR019, MR020, MR021 Total Facility EU006 GP001 EU006 GP001 Total Facility Total Facility MR002, MR003, MR004, MR005, MR010, MR011, MR012, MR013, MR014, MR016, MR017, MR018, MR019, MR020, MR021

65 TABLE B: RECURRENT SUBMITTALS Facility Name: Pope/Douglas Solid Waste Management Permit Number: B-4 01/20/10 Waste Composition Study due before end of each 60 months following Permit Issuance to measure the noncombustible fraction of solid waste as required by Minn. R , subp. 2(C) and Minn. R , subp. 2(A). Total Facility

66 APPENDIX A APPENDIX MATERIAL Facility Name: Pope/Douglas Solid Waste Management Permit Number: Insignificant Activities and Applicable Requirements Lime Storage Silo Household Hazardous Waste Collection Facility MSW Unloading/Tipping Floor Materials Recovery Facility (MRF), including the following components: o Trash in-feed hopper o In-feed Conveyor o Enclosed Four Station Picking Station o Trommel o 60-inch magnet and conveyor o 48-inch magnet and conveyor o Eddy current separator o Overhead conveyors o Baler o Processing Tipping Floor Minn. R , subpart 4(B) 4(C)(1) Rule Description of the Activity Emission units with potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs - Lime Handling - Household Hazardous Waste Collection Operation Emission units with potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in Minn. R , subpart 5 - Household Hazardous Waste Collection Operation Applicable Requirement Minn. R /0715 Minn. R /0715

67 APPENDIX B July 27, 2004 Variance

68

69

70

71

72

73

74 APPENDIX C Modeling Parameters Pope/Douglas Solid Waste Management Air Dispersion Modeling Source Parameters Modeled Parameters Source Description UTM Easting (m) UTM Northing (merers) Base Elevation (m) Base Elevation (ft) Stack Height (m) Stack Height (ft) SV001 Unit 1 and Unit 2 Stack 315, ,082, SV004 Aux. Boiler 315, ,082, SV015 New Unit 3 Stack 315, ,082, Source Exhaust Temperature (K) Exhaust Temperature (deg F) Exit Velocity (m/s) Exit Velocity (ft/min) Exhaust Flowrate (acfm) Exit Diameter (m) Exit Diameter (ft) SV ,242 29, SV , SV ,242 29,

75 Pollutan t SV001, Units 1 and 2, Short- Term Potential Emissions SV001, Units 1 and 2, Annual Potential Emissions SV004, Aux. Boiler, Short-Term Potential Emissions (lb/hr) (g/s) (ton/yr) (g/s) (lb/hr) (g/s) PM PM SO NOx NA NA NA NA CO NA NA Pollutant Potential Emissions Term Potential Emissions Annual Potential Emissions (ton/yr) (g/s) (lb/hr) (g/s) (ton/yr) (g/s) PM PM SO NOx NA NA CO NA NA NA NA

76 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft/proposed permit. CONTENT: 1. GENERAL INFORMATION 1.1. Applicant and Stationary Source Location 1.2. Description of the Facility 1.3. Description of the Permit Action Permit Permitting History Permitting Issues FIP/State Rules/Variance Definition of Emissions Units Ash Testing Variance Performance Testing Mercury Testing Frequency Operator Training and Certification Operating Parameters Listed in the Permit 1.4. Emissions of the Facility Emissions Summary Limited, Controlled Potential to Emit and Uncontrolled, Unlimited Potential to Emit Calculations Waste Combustor Calculations

77 2. APPLICABLE RULES (REGULATORY AND/OR STATUTORY BASIS OF EMISSION LIMITS) 2.1. Federal Permitting Regulations Federal New Source Review (NSR) Stationary Source Classification 2.2. Federal Standards of Performance CFR 60.50, Subpart E, Standards of Performance for Incinerators CFR Part 60, Subpart AAAA, Standards of Performance for Small Municipal Waste Combustion Units for Which Construction is Commenced After August 30, CFR Part 60, Subpart BBBB, Emissions Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, Federal Implementation Plan, 40 CFR Part 62, Subpart JJJ, Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed on or Before August 30, National Environmental Standards for Hazardous Air Pollutants (40 CFR pt. 61 and 63) CFR 61.50, Subpart E - National Emission Standards for Mercury National and State Ambient Air Quality Standards (40 CFR pt. 50 and Minn. R. ch. 7009) CFR 60, Subpart A, General Provisions State Rules Performance Standards Environmental Assessment 2.4. State-only enforceable requirements 2.5 Summary of Applicable Regulations 3. SPECIFIC PERMIT CONDITIONS 3.1. Total Facility 3.2. Emission Limits Mercury Emissions Limits 3.3. Monitoring Requirements CEMS/COMS Compliance Assurance Monitoring Periodic Monitoring 3.4. Performance Testing 3.5. Permit Table B Requirements 3.6. Insignificant Activities 3.7. Deviations from Delta Norms 4. TECHNICAL ISSUES

78 4.1 Indian Tribes Contact 4.2 Federal Land Managers Review 4.3 Air Dispersion Modeling Air Dispersion Modeling Review Modeling Methods Environmental Review Permitting PM/PM10/PM2.5 Basis 4.4 Class C Applicability 4.5 PM AERA and Human Health Risk Assessment 4.7 CEMs 4.8 Mercury Reductions Needed for the Minnesota Mercury TMDL 5. COMMENTS RECEIVED AND CHANGES TO THE DRAFT/PROPOSED PERMIT 5.1 Comments Received 5.2 Changes to the Draft/Proposed Permit 6. CONCLUSION

79 1. General Information 1.1. Applicant and Stationary Source Location: Applicant/Address Pope/Douglas Waste Management 2115 South Jefferson Alexandria, MN Contact: Pete Olmscheid Phone: 320/ Stationary Source/Address (SIC Code: 4953) 2115 South Jefferson Street Alexandria, MN Douglas County 1.2. Description of the Facility The facility covered by the permit, Air Emissions Permit No , is a municipal waste combustor owned by the Pope/Douglas Joint Solid Waste Management Board, Alexandria, MN (Facility). The existing Facility is being regulated as a Class C waste combustor under state rules and as a Small Class II waste combustor under Federal rules. Under Federal rules, waste combustors with a 35 to 250 ton per day charge are classified as small. The Facility generates steam which is sold locally. The Facility also operates a small steam turbine for generating electricity. The existing waste combustors are identified, in the permit, as emission units EU 001 and EU 002. Each waste combustor is an independent system, consisting of excess air mass burn refractory combustion chambers followed by heat recovery boilers. Flue gases from both systems exit through a common stack after independent air pollution control equipment trains. From the inlet chute to the stack breeching, the two combustion trains are identical with respect to all equipment components. The original waste combustors were installed in 1986 and became operational in The facility provided that the original waste combustor units each had a nominal charge rate of 40 tons per day. The replacement of the waste combustors commenced in October, 1997, and initial startup was in June, These waste combustors and their construction were the subject of a Compliance Agreement, dated May 6, 1999, which required the facility to apply for a variance, which was granted. In 2001, the facility sought approval to replace the waste heat recovery boilers, and received approval from EPA and MPCA in letters dated February 26, 2002 and April 15, The waste heat recovery boiler replacements occurred January through April, At the time of approval for replacing the heat recovery boilers, EPA acknowledged that each of the units had a nominal capacity of 50 tons of MSW per day. According to the facility s performance tests as far back as July 2001, the combination of the current waste combustors and the old waste heat recovery boilers demonstrated the capability of a municipal solid waste (MSW) charge rate in excess of 60 tons of MSW per day.

80 The two existing waste combustors combined are, currently, capable of burning a total of 120 tons of mixed MSW, refuse-derived fuel (RDF), and/or other solid waste per day (based on an annual average). This currently translates into a heat input rate of 27.5 million British thermal units per hour (Btu/hr) for each waste combustor (assuming a heat content of 5,500 Btu/lb). Natural gas is used to warm-up the waste combustor and pollution control equipment at start-up and as necessary to maintain proper combustion conditions. The waste combustors may be operated independent of each other. Pollution control equipment consists of dry lime injection for the control of acid gases, activated carbon injection for the control of dioxin (and possibly mercury) and a fabric filter for the control of Particulate Matter (PM) and other metals. A portion of the flue gases are recirculated from the fabric filter outlet to the combustion chamber (i.e., flue gas recirculation). Exhaust gases enter the atmosphere through an existing single 70-ft. tall primary stack. Exhaust gases are continuously monitored for Carbon Monoxide (CO), Sulfur Dioxide (SO 2 ), opacity, and Oxygen (O 2 ). A number of operating parameters, including fabric filter inlet temperature, steam flow rate, and activated carbon feed rate parameters are also monitored continuously. The facility also has an existing 3.5 MMBtu/hr auxiliary boiler (EU 005). Ash produced in the course of waste combustion is loaded into a truck in an enclosed area at the Facility. The ash is covered and transported via trucks to the Pope-Douglas Ash Landfill (permit number SW-410). Upfront of the combustion process, the facility operates a Materials Recovery Facility (MRF). This operation is housed with the waste combustors, and its purpose is to manually and mechanically process waste to accomplish the following: - Identify and remove problem materials. - Remove recyclables, such as aluminum, ferrous metals, and cardboard. - Remove non-combustible material. Emissions from the MRF are classified as insignificant under Minnesota Rules. The lime storage silo is another insignificant source of PM emissions. On the same property as the incinerator is the Household Hazardous Waste collection center. This facility collects household hazardous waste and, in some situations (such as latex paints), repackages reusable materials. Emissions from this operation are also treated as insignificant. The existing Pope/Douglas Waste Management facility is subject to: Minn. R to ; limited variances from Minnesota Rules signed on October 18, 1996, December 22, 1997, and July 27, 2004; and the Federal Plan (FP) codified in 40 CFR Part 62, Subpart JJJ. The Permit cites Minnesota statutes, Minnesota Rules, the variances, and the FP as the authority and basis for the permit conditions contained within. The Permit also contains conditions necessary to demonstrate compliance with Minnesota statutes and rules, variances, and the FP. 1.3 Description of the Permit Action

81 This permit action is a total facility operating permit re-issuance. In addition, this permit action also rolls a major amendment for the proposed municipal waste combustor (EU 006). The permit satisfies the permitting requirements under Title V of the 1990 Clean Air Act Amendments, codified in 40 CFR pt. 70. The permit meets the requirements of Minn. R and , which respectively, specify the conditions necessary for Part 70 operating permits and waste combustor air emission permits. As for the existing municipal solid waste incinerators (EU 001 and EU 002), this permit action does several items. The capacities of Units 1 and 2 are being corrected in this permit action from 40 tons per day per unit to 60 tons per day per unit (both on an annual average basis). As noted earlier, this is being done to reflect the true capacity realized by these units during annual compliance tests. The stack height for EU 001 and EU 002 is being raised from 70 feet to 105 feet. In addition, a NOx CEMs will be required. State-only MWC organics (total dioxin/furan) as well as mercury emission limits for the two existing incinerators will also be added. In addition, this permit action (-003) proposes to install an additional municipal solid waste incinerator, Unit 3 (EU 006). The new unit will be an excess air mass burn refractory combustion unit. Unit 3 will have a total waste combustion capacity of 120 tons per day. This translates into a heat input rate of 55 million Btu/hr (assuming a heat content of 5,500 Btu/lb). Pollution control equipment consists of dry lime injection for the control of acid gases, activated carbon injection for the control of dioxin (and possibly mercury) and a fabric filter for the control of Particulate Matter (PM) and other metals. A portion of the flue gases are recirculated from the fabric filter outlet to the combustion chamber (i.e., flue gas recirculation). Exhaust gases enter the atmosphere through a single 110-ft. tall primary stack. Exhaust gases are continuously monitored for Carbon Monoxide (CO), Sulfur Dioxide (SO 2 ), Nitrogen Oxides (NOx), opacity, and Oxygen (O 2 ). A number of operating parameters, including fabric filter inlet temperature, steam flow rate, and activated carbon feed rate parameters are also monitored continuously. In addition, this permit action (-003) also rolls in one applicability determination and three MPCA re-openings. The applicability determination (DQ 1249) was withdrawn during this major amendment review. The three re-openings (DQ 550, 661, and 1228) were based on performance test conditions Permit The existing MWC #1 (EU 001) and MWC #2 (EU 002) are subject to Minnesota Rules to (Class C Combustors), and the Federal Implementation Plan (FIP) codified in 40 CFR Part 62, Subpart JJJ. The proposed MWC Unit #3 (EU 006) will be subject to Minnesota Rules to (Class II Combustors) and the New Source Performance Standard (NSPS), Subpart AAAA codified in 40 CFR Part to The permit cites Minnesota statutes, Minnesota rules, the FIP, and Subpart AAAA as the authority and basis for the permit conditions contained within. The permit also contains conditions necessary to demonstrate compliance with Minnesota statutes and rules, the December 22, 1997 variance, the FIP, and NSPS, Subpart AAAA.

82 Permitting History The original Title V permit was issued on September 23, The MPCA received the MWC #3 expansion air application on October 4, The MPCA received the Title V re-issuance application on March 27, Permit Number and Action Authorized Issuance Date Part 70 permit issued. September 23, Administrative Amendment June 29, Construction of Unit #3 and Part 70 Re-issuance Permitting Issues The following were major items of analysis and discussion during the review of the Pope/Douglas permit application: FIP/State Rules/Variance As stated earlier in this TSD, the existing waste combustors at the Pope/Douglas facility are subject to Minnesota statutes, Minn. R to , and the January 31, 2003, Federal Implementation Plan (FIP) codified in 40 CFR pt. 62, Subpart JJJ. The MPCA promulgated rules regulating waste combustors in 1994, in response to federal emission guidelines that were promulgated in New federal rules were promulgated in December The rules were vacated by the federal courts in December The MPCA amended the Minnesota waste combustor rules in May New federal Emissions Guidelines were promulgated in December The MPCA is in the process of preparing rules to adopt these federal Emissions Guidelines for Small Municipal Waste Combustion Units codified in 40 CFR Part 60, Subpart BBBB. When the MPCA promulgates these rules, the Pope/Douglas will no longer be subject to the FIP and the federal Emissions Guidelines will be implemented through Minnesota rules. When the MPCA promulgates these rules, the variance to Minnesota rules will also expire, except for the variance from mercury testing scheduled to expire with permit issuance. Another limited variance was issued on December 22, The existing permit (-002) had a PM limit based on the 1997 variance. That variance limit was replaced in this permit action (- 003). The reason the variance was originally put in place was to give facilities time to retrofit their facilities when the new federal rule (Dec. 2000) became effective. That federal rule has already become effective, in Minnesota, as a FIP. Accordingly, the underlying reason for the

83 variance is no longer applicable for MWC #1 and #2. With a fabric filter, the actual PM emissions would be expected to be far below the variance PM limit of 0.040gr/dscf. Moreover, the variance was never intended for new units (MWC #3) Definition of Emissions Units The FIP and emissions guidelines (upon which the FIP is based), states that the municipal waste combustion unit boundary starts at the municipal solid waste pit hopper and extends through three areas: 1. The flue gas system which ends immediately after the heat recovery boiler; 2. The combustion unit bottom ash system which ends at the truck loading station; and 3. The combustion unit water system which starts at the feed water pump and ends at the piping that exits the steam drum or superheater Ash Testing Variance The permit contains the variance from ash testing requirements for waste combustor ash for the existing units. Minn. R , subp. 2, item E requires air emission permits for waste combustors to contain a schedule for the testing of waste combustor ash as required in part Minn. R , subp. 3, requires quarterly samples and an annual composite sample formed from equal portions of the quarterly samples must be analyzed according to Minn. R , subp. 5. On October 18, 1996, a letter was sent to owners and operators of municipal waste combustors explaining the variance the rule granted by the MPCA. The permit establishes the testing frequency allowed under the 1996 variance and cites the Minn. R , subp. 3, the variance and Minn. R (Minnesota s variance rules). The new unit (EU 006) is subject to Minn. R , subp. 3 which also requires quarterly samples and an annual composite sample formed from equal portions of the quarterly samples Performance Testing Initial Performance Testing The FIP, under 40 CFR (b), requires the owner or operator to demonstrate compliance with the FIP limits within one year of the effective date of the FIP (January 31, 2003) or submit a schedule for demonstrating compliance with increments of progress. Pope/Douglas tested for initial compliance demonstration, ending March 16, The MPCA deemed the tests compliant on May 24, Under Subpart AAAA, Pope/Douglas will need to conduct its initial compliance demonstration for MWC #3. The initial compliance demonstration must be conducted within 60 days after reaching maximum load level but no later than 180 days after initial start up Annual Performance Testing

84 The FIP, under 40 CFR , requires Pope/Douglas to conduct annual stack tests, on MWC #1 and #2, for the pollutants listed below. In addition, Subpart AAAA, under 40 CFR , requires the owner to conduct annual stack tests for the same pollutants listed below. The permit provides in part: Annual Performance Test: due no later than 13 months after the previous test to measure: - dioxins/furans, - cadmium, - lead, - mercury, - front-half particulate matter, - opacity, - hydrogen chloride, and - fugitive ash. These performance tests may be conducted concurrently with performance tests required under Minn. R , or in addition to performance tests required under Minn. R The Annual Report required under 40 CFR /40 CFR is due no later than February 1 of each year that follows the year in which the data was collected. The results of the Annual Performance Tests required under 40 CFR (a)/40 CFR (b) are to be included in the annual report. Minn. R , subp. 2, requires stack test reports to be submitted within 45 days following completion of the performance tests unless an alternative schedule is given in the applicable compliance document. Deadlines may be extended if justifiable. The permit will require submittal of test reports as per Minnesota rules. It is noted that for state regulated pollutants (Minn. R. ch. 7011), if all annual performance tests for a three-year period (for a particular pollutant) show compliance with the permit limits, Pope/Douglas may chose to conduct performance tests every 2 1/2 years. However, noncompliance will require Pope/Douglas to resume annual testing. It is noted that the Minn. Rules require the testing of lead and cadmium, even though there are no emission limits. Minn. R and It is noted that for Federal regulated pollutants (Subparts JJJ and AAAA), if all annual performance tests for a three-year period (for a particular pollutant) show compliance with the permit limits, Pope/Douglas may chose to conduct performance tests every 3 years. However, noncompliance will require Pope/Douglas to resume annual testing. It is noted that the HCl emission limit of 250 ppm, for MWC #1 and MWC #2, is subject to both Subpart JJJ as well as a Title I synthetic minor requirement. Hence the HCl test frequency will be determined by the most restrictive frequency of either Subpart JJJ or the Minn. Test Frequency Plan Performance Test Methods

85 The FIP, under 40 CFR , requires Pope/Douglas to follow specific test methods and procedures for stack tests. In addition, subpart AAAA, under 40 CFR will require Pope/Douglas to follow specific test methods and procedures for stack tests. Minn. R also requires specific test methods and procedures. Therefore, where applicable, the permit contains citations of both rules to ensure compliance with both state and federal requirements. A difference between state and federal rules is in the minimum required sampling time for PCDD/PCDF. The Minnesota rules allow minimum sampling time of 3-hour for each sampling run of PCDD/PCDF for Class C waste combustors such as the Pope/Douglas Facility. The federal rule requires a minimum sampling time of 4-hour for each sampling run of PCDD/PCDF. The permit will require 4-hour sample time unless Pope/Douglas obtains authorization from EPA to shorten this time Mercury Testing Frequency In Permit Action -002, the results of Pope/Douglas semi-annual Hg testing were reviewed. The Pope/Douglas facility was below the 50% of the 60 ug/dscm limit for 3 years. Hence, Permit action -002 authorized a 3-year mercury testing schedule which is maintained in this permit action (-003). It is also noted that for there is a December 22, 1997, variance. The 1997 variance allowed the owners and operators of the Pope/Douglas to conduct mercury tests every six months, until the issuance of a permit with a mercury emissions limit. For this permit action, there are two provisions that address the frequency of mercury testing: Minn. R and Minn. Stat The rule requires the listed waste combustors to conduct mercury performance tests every year. Minn. Stat , subd. 1a, requires the owner or operator of an incinerator with a permit that contains emission limits for mercury to conduct performance testing for mercury every three months. If the testing demonstrates that mercury emissions have been below 50 percent of the facility's permitted mercury limit for three consecutive years, the owner may choose to conduct performance testing once every three years. Because Minn. Stat is more restrictive, the 3 month testing frequency is required for the new unit (EU 006). In addition, 40 CFR (a), allows the facility to relax its testing schedule to once every three years if it demonstrates compliance with its federal limit. In this permit action (-003), an additional mercury emission limit of 14 ug/dcsm is added. This limit was proposed, by the facility, upon the completion of the EAW health risk assessment. This limit is below the long-term mercury state emission limit. The mercury emission test results were reviewed in Delta. From , the 3 years of mercury test results ranged between ug/dcsm. Accordingly, the mercury test frequency, for the existing units, did not change. It is noted that the next scheduled testing of the 2 existing units, for mercury, will be in Spring Spring 2011 is about when EU 006 should be coming on-line Operator Training and Certification

86 Under current Minnesota rules (1998), operators of small municipal waste combustors must obtain and maintain a certification. The operator training and certification requirements are included in Minnesota rules and federal regulations because both the MPCA and EPA recognize the specialized skills required to safely and effectively operate a waste combustor. Operators of large municipal waste combustors must also obtain and maintain this same certification. EPA recognizes the training and certification program for large municipal waste combustors in Minnesota rules through the approval of Minnesota s 111(d) plan. Because Minnesota has not yet promulgated rules incorporating the emissions guidelines for small municipal waste combustors, EPA has no 111(d) plan for Minnesota that can be approved. Therefore, EPA and the FIP under 40 CFR (a) and 40 CFR (a) do not recognize Minnesota's operator training and certification program. In a Jan. 24, 2006 memo to the Red Wing incinerator, William MacDowell, of EPA Region V provided, in part, the following to address the issue of Operator Training and Certification Requirements. The Small MWC FIP does not include any provision under which U.S. EPA can approve an extension to comply with its operator training and certification requirements. Consequently, we cannot extend the date by which the chief facility operator(s) and shift supervisor(s) must obtain provisional or full operator certification under American Society of Mechanical Engineers (ASME) standard QRO As of this date, MPCA has not submitted Minnesota s 111(d) Plan for Small MWC Units. However, the Small MWC Plants in Minnesota, including the Red Wing SWBF, have been subject to the operator training and certification requirements in Minnesota Rules , , , , , and since May On August 12, 1998, U.S. EPA approved these rules as part of Minnesota s 111(d) Plan for Large MWCs. We anticipate that MPCA will submit, and that U.S. EPA will approve, these rules for Minnesota s 111(d) Plan for Small MWCs. According to your letter, ASME QRO focuses primarily on boiler operation and the Minnesota training and certification program focuses on combustion practices. We do not have any reason to dispute this statement. Further, we have not attempted to quantify the additional environmental benefit that might result from ASME QRO certification. U.S. EPA reviewed Minnesota s operator training and certification requirements for Class C waste combustors, which is equivalent to an existing Small MWC Unit, as those terms are defined or designated in the Small MWC FIP. We found one substantive difference between the applicable Minnesota rules and the Small MWC FIP: The Minnesota rules required Class C waste combustors to comply with the operator training and certification requirements 6 years before the Small MWC FIP. The remaining issue is federal enforceability. At this time, U.S. EPA cannot enforce Minnesota Air Rules , , , , , , and at Small MWC Units because they are not part of the approved Minnesota s 111(d) Plan for Small MWC Units. However, we have not identified any additional environmental benefit that would result from enforcement of the

87 Small MWC FIP s requirement regarding full ASME certification for each chief facility operator and shift supervisor. Provided that the Red Wing SWBF has complied with the operator training and certification requirements in Minnesota Air Rules , , , , , , and , U.S. EPA believes that enforcement action would not produce any environmental benefit that the Minnesota operator training and certification requirements do not already achieve Operating Parameters Listed in the Permit The permit contains three operating parameters that are, by rule, subject to change as a result of performance tests. These parameters are: flue gas temperature at the inlet to the PM control device (FF); combustion unit load as measured by steam production rate; and mercury/dioxin control additive (activated carbon) feed rate. The requirement for the operating range of each of these parameters is established in the FIP, Subpart AAAA, and the Minnesota rules. 40 CFR and 40 CFR (a) establish that the waste combustor owner or operator must: a) not operate the municipal waste combustion unit at loads greater than 110 percent of the maximum demonstrated load of the municipal waste combustion unit. (4-hour block average), as specified under ``Definitions'' (Sec and ) b) not operate the municipal waste combustion unit so that the temperature at the inlet of the particulate matter control device exceeds 17 o C above the maximum demonstrated temperature of the PM control device (4-hour block average), as specified under ``Definitions'' (Sec and ). c) maintain an 8-hour block average carbon feed rate at or above the highest average level established during the most recent dioxins/furans or mercury test if activated carbon is used to control mercury or dioxins. Section and state Maximum demonstrated load of a municipal waste combustion unit means the highest 4-hour block arithmetic average municipal waste combustion unit load achieved during 4 consecutive hours in the course of the most recent dioxins/furans stack test that demonstrates compliance with the applicable emission limit for dioxins/furans specified in this subpart. Maximum demonstrated temperature of the particulate matter control device means the highest 4-hour block arithmetic average flue gas temperature measured at the inlet of the PM control device during 4 consecutive hours in the course of the most recent stack test for dioxins/furans emissions that demonstrates compliance with the limits specified in this subpart. Regarding maximum demonstrated capacity, the permit states specifically the value of 110 percent of the maximum demonstrated capacity of each combustion system as determined during the last PCDD/PCDF performance test. The permit states, in part: Steam Flow: less than or equal to lbs/hour for EU001 using 4-hour Block Average, (as determined during the 05/07/08 and 05/08/08 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon

88 the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the steam flow rate into this permit, the Permittee shall not exceed 110 percent of the steam load level established during that compliant performance test. Regarding the maximum particulate matter control device inlet temperature as determined during the last PCDD/PCDF performance test, the permit states specifically the value of this parameter for each fabric filter. The permit states, in part: Temperature: less than or equal to 401 degrees Fahrenheit for CE 001 using 4-hour Block Average as measured at the inlet to the PM control device (as determined during the 05/08/08 PCDD/PCDF performance test). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF performance test and prior to incorporation of the new PM control device inlet temperature into this permit, the PM control device inlet temperature shall not exceed a temperature greater than 30 degrees Fahrenheit (17 degrees C) greater than the PM control device inlet temperature established during that compliant performance test. Regarding carbon injection feed rate, as determined during the last PCDD/PCDF or mercury performance test the permit states specifically the value of this parameter for each control system. The permit states, in part: Mercury additive feed rate: greater than or equal to 1.7 lbs/hour for CE 005 using 8-hour Block Average (as determined during 05/08/08 mercury and dioxin performance tests). Notwithstanding the previous sentence, upon the Commissioner's written notification that the emissions unit has demonstrated compliance under the conditions of a PCDD/PCDF or mercury performance test and prior to incorporation of the new mercury/pcdd/pcdf control additive feed rate into this permit, the Permittee shall maintain the greater of the following: the additive feed rate determined during the most recent compliant mercury performance test and most recent compliant PCDD/PCDF performance test. Each of these permit conditions are stated with specific operating limits rather than referring to the applicable rule. The permit will be re-opened to incorporate the results of every annual compliance test required by 40 CFR part 62 Subpart JJJ and 40 CFR part 60 Subpart AAAA. In situations when operating conditions during mercury performance tests as per Minn. Stat , subd. 3, are such that the mercury/pcddf additive feed rate needs to be more strict than the permit, then this requirement will be defined via Agency notification as per Minn. R , subp. 3. In cases when the Permittee seeks to relax the feed rate of mercury and PCDD/PCDF control additive rate, then a compliance demonstration test for PCDD/PCDF and mercury must be conducted. In the later case, the permit will be re-opened to change the permit condition under the major modification provisions. The rationale for this approach is as follows:

89 Under Minn. R , and 40 CFR , the owner and operator must conduct performance tests that re-establish the maximum demonstrated capacity, (maximum demonstrated load), the maximum demonstrated temperature of the PM control device and the average carbon feed rate at least annually. Minn. Stat , subd. 3 and Minn. R requires the re-establishment of the carbon feed rate as often as quarterly. Both the Minnesota rules and the federal regulations were established under the state and federal rulemaking procedures with full opportunity for public participation. As a result of these rulemakings, the operation of municipal waste combustors is heavily regulated and well documented in the public record at both the state and federal levels. The requirement to test annually for dioxins and furans under state and federal rule is an applicable requirement enforceable by the EPA Administrator and citizens under the Clean Air Act. The requirement to test quarterly for mercury is only in state rule, but it is federally enforceable as this rule has been approved into the Minnesota State Implementation Plan (SIP) In the process of obtaining full approval of Minnesota s Title V permitting program, EPA received comments from the National Wildlife Federation regarding the public noticing and comment period on plans submitted under a permit condition. In addressing this comment, EPA noted that the MPCA established enforceable operating limits that resulted from performance tests through issuing a letter to the Permittee, and that these limits were established without public notice or an opportunity for comment. As a result of these comments, the MPCA committed to the quarterly opening all part 70 permits for which a performance test established new operating parameters under the major amendment procedures. These procedures include public notice and the opportunity for comment. Under this commitment, the MPCA is expected to reopen the Title V permits for six small municipal waste combustors, four large municipal waste combustors and one medical waste combustor at least annually to establish conditions from testing requirements that are applicable requirements under the Clean Air Act and possibly as frequently as quarterly. The context of the comments and commitments was establishing operating parameters for emissions for which the public was not previously given notice or the opportunity to comment. In the case of the waste combustors, this is not the case because the operating parameters are clearly established in rule at both the state and federal levels with public notice and full opportunity to comment. However, EPA is of the opinion that specific permit conditions derived from applicable requirements enforceable under the Clean Air Act must be defined in Title V permits with opportunity for public comment. In the case of state-only requirements of testing for mercury, and given the frequency at which waste combustor permits would have to be reopened as a result of performance tests, the number of waste combustors in Minnesota, and the fact that the operating parameters are in state rule and were subject to public notice and comment, and the time delays inherent in MPCA s review and approval of test reports, it is reasonable to impose more strict operating conditions via written notification from the Commissioner rather than requiring reopening as frequently as quarterly. Agency notification as per Minn. R , subp. 3, are enforceable to the same extent as a permit condition. Minn. R , subp. 3, it also approved in the Minnesota SIP and as such it is also federally enforceable.

90 1.4. Emissions of the Facility Emissions Summary Table 1 presents the limited, controlled potential to emit from the existing facility, prior to the addition of the proposed MWC #3 project as well as prior to mercury and dioxin limits taken in this permit action (-003). It does reflect the NOx and MWC acid gases synthetic limits taken in this permit action (-003). Pollutant Table 1 Existing MWC Unit 1 and 2 Potential to Emit Summary (@ 60 tons per day charge capacity) Limited, Controlled Potential to Emit from Existing Unit (MWC #1) (tons/year) Limited, Controlled Potential to Emit from the Existing Unit (MWC #2) (tons/year) Limited, Fugitive Controlled (roadway Potential to FS 002) Emit from (ton/year) the Existing Unit Aux. Boiler (EU 005) (tons/year) Limited, Controlled Potential to Emit from Total Facility Prior to Expansion (tons/year) Particulate Matter (PM) Front-half Particulate Matter Particulate Matter (PM10) Particulate Matter (PM2.5) Sulfur Dioxide (SO 2 ) Nitrogen Oxides (NO x ) Carbon Monoxide (CO) Volatile Organic Compounds (VOCs) Lead E MWC Acid Gases Sulfuric Acid Mist MWC Organics (total dioxins and furans) Hydrogen Chloride 1.35E E E

91 Mercury Cadmium Notes: - MWC #1 and MWC #2 are each 60 tons per day charge capacity - MWC acid gases (SO2 + HCl) - MWC acid gases and 95.0 tpy (synthetic minor limit) for MWC #1 and #2 combined - Front half PM, from roadway dust assumed to be equal to PM10, even though front half PM is only filterable PM Table 2 presents a summary of the limited, controlled potential emission rates in tons per year (tpy), after the proposed expansion of the facility. For this calculation, MWC #1 and #2 each have a 60 ton per day charge capacity. MWC #3 has a 120 ton per day charge capacity. Mercury and MWC organic emission limits, taken in this permit action -003, are reflected in this table. The limited PTE shown in Table 2 represents the maximum emissions which the facility, including pollution control equipment, could emit without violating permit limits (for example, 70 mg/dscm PM). For pollutants that are not affected by permit limits, the limited PTE represents the maximum potential emissions expected if control equipment is operating. Table 2 After Proposed MWC #3 Addition Potential to Emit Summary Pollutant Limited, Controlled Potential to Emit (MWC #1) (tons/year) Limited, Controlled Potential to Emit (MWC #2) (tons/year) Limited, Controlled Potential to Emit (Aux. Boiler -EU 005) (tons/year) Limited, Controlled Potential to Emit After Modificatio n (MWC #3) (tons/year) Fugitive roadway FS 002) (ton/year) Limited, Controlled Potential to Emit from Total Facility After Expansion (tons/year)

92 Particulate Matter (PM) Front-half Particulate Matter Particulate Matter-10 (PM10) Particulate Matter-2.5 (PM2.5) Sulfur Dioxide (SO 2 ) Nitrogen Oxides (NO x ) Carbon Monoxide (CO) Volatile Organic Compounds (VOCs) Lead E MWC Acid Gases Sulfuric Acid Mist MWC 2.16E E E E-06 Organics (total dioxins and furans) Hydrogen Chloride Mercury Cadmium Notes: - MWC #1 and MWC #2 are each 60 tons per day charge capacity - MWC #3 120 tons per day charge capacity - MWC acid gases (SO2 + HCl) - MWC acid 95.0 tpy (synthetic minor limit) for MWC #1 and #2 combined - NOx based on combined Unit 1 and 2 emission limit of 95.0 tpy (synthetic minor limit) and Unit 3 emission limit of 95.0 tpy (synthetic minor limit) Table 3 presents the difference in the total facility limited, controlled PTE between the existing facility and the proposed modifications/emission limits.

93 Pollutant Table 3 Difference in PTE Due to Expansion Potential to Emit Summary Limited, Controlled Total Facility Prior to Modification PTE (tons/year) Limited, Controlled Total Facility After Modification PTE (tons/year) Difference in Limited, Controlled PTE Due to Modification (tons/year) Particulate Matter (PM) Front-half Particulate Matter Particulate Matter (PM10) Particulate Matter (PM2.5) Sulfur Dioxide (SO 2 ) Nitrogen Oxides (NO x ) Carbon Monoxide (CO) Volatile Organic Compounds (VOCs) Lead MWC Acid Gases Sulfuric Acid Mist MWC Organics 2.70E E E-05** (total dioxins and furans) Hydrogen Chloride Mercury ** Cadmium * Note: The PSD significant threshold for the MWC #3 expansion is 100 tons per year. The threshold was not exceeded for any pollutant. This was because the facility was able to synthetic minor MWC #1 and #2 for both MWC Acid Gases and NOx. And this was also because the facility was able to synthetic minor MWC #3 for NOx. ** Permitted total dioxin and furan as well as mercury emissions will decrease as a result of this permit action Limited, Controlled Potential to Emit and Uncontrolled, Unlimited Potential to Emit Calculations The calculations for the proposed facility expansion are in Delta.

94 There are several methods that can be used to calculate the emissions from this facility. One method is based on the using the airflows. Another method is based on using the fuel heat input and f factor. All of the emissions from the MWC were calculated using the f factor. Additionally, particulate matter (total and filterable) emissions were also calculated using the stack airflow method for determining compliance with State limits. The following section describes the f factor method Waste Combustor Calculations. For the criteria pollutants other than Volatile Organic Compounds (VOC), the Uncontrolled, Unlimited Potential to Emit estimates are based on an AP- 42 (Compilation of Air Pollutant Emission Factors, Fifth Edition, January 1996) emissions factor and AP-42 control efficiencies. No VOC factors were presented in the above publication, so VOC estimates are based on AP-42 Fourth Edition, supplement C (September 1990). For pollutants for which an emissions limit exists, the Limited, Controlled Potential to Emit estimates are based on an F factor and the applicable rule limit. For additional pollutants (primarily HAPs), emissions were calculated for the AERA. These emissions were based on performance tests conducted in 2004 at the Olmsted County Waste-to-Energy (OWEF) MWC Units 1 and 2. The OWEF MWC units use a similar type of waste stream to the MWC at the Pope/Douglas. Dioxin emissions were calculated based on Pope/Douglas own performance tests conducted on MWC #1 and #2. An F factor is the calculated exhaust gas flow rate per unit of heat input corrected to standard conditions (1 atm, 68 degrees Fahrenheit, and 0 percent O 2 ). The emission estimates in Tables 1-3 are based on an F factor of 9,570 dscf/mmbtu and a heat content of 5,500 Btu/lb of MWC (both of these values are the values used in AP-42). An F factor calculation is based on fuel analysis, the relative portions of hydrogen, carbon, nitrogen, sulfur, and oxygen and the heat value of the fuel. Emission estimates based on an F factor were calculated as follows, as an example. For Front-half PM, the emission limit is 70 mg/dscm corrected to 7 percent O 2. The proposed MWC #3 can operate at its capacity of tons/day (or 5.0 ton/hr). Because the rules allow the unit to be operated at 110 percent of its maximum demonstrated capacity, the maximum hourly waste throughput per unit is 1.1 x tons/day. The 110 percent was factored out of the annual emission calculations. The detailed calculations are included in a spreadsheet workbook found in Delta lb of PM = hr 70 mg dscm g 1000 mg lb 454 g Limited Hourly Emission Rate 3 m ft 9570 dscf lb of PM 8760 hr 1 ton tons of PM / year = (1 / 1.1) hr year 2,000 lb. Btu Maximum Annual Emission Rate 5500 Btu lb 2000 lb ton 5.0 ton hr 110 % 100 %

95 Several of the emission limits for gaseous pollutants are expressed part per million by volume (ppm) corrected to 7 percent O 2. The conversion from ppm to mg/dscm is derived as follows: volume of gaseous pollutant volumes ( pollutant + air) dry basis = 1 ppm The mass concentration of a pollutant (mass/volume) is calculated by assuming the polluted gas is an ideal gas as follows: m vol V air pol = ρ pol V pol V airpol P M pol ρ pol R u T = V pol V airpol P M pol R u T where M pol is the molar mass of the pollutant and R u = atm*m 3 /kg mol* o K. At standard conditions, T =20 o C ( 68 o F, 293 o K); P = 1 atm, the equation reduces to: m vol V air pol = V pol V airpol M pol = kg pol dscm = ppm pol 6 10 M pol To convert to mg/dscm, the equation becomes: mg pol dscm = ppm pol M pol The molar mass for pollutants whose limits are expressed in ppm are: SO 2 = 64 HCl = 36.5 CO = 28 NO 2 = 46 The conversion factor for each pollutant is: mg SO 2 /dscm = ppm SO 2 mg HCl/dscm= ppm HCl mg CO/dscm = ppm CO mg NO 2 /dscm = ppm NO 2 Estimated annual emissions based on AP-42 emission factors expressed as pounds of pollutant per ton of waste for MWC combusted were calculated as follows:

96 E 04 lb of Cr tons of Cr / yr= ton of MSW 5.0 ton of MSW hr ton 2,000 lb 8,760 hr yr 2. APPLICABLE RULES (REGULATORY AND/OR STATUTORY BASIS OF EMISSION LIMITS) 2.1. Federal Permitting Regulations New Source Review (NSR) The NSR permit program was established by the 1977 Clean Air Act Amendments. This program sets emission thresholds for six criteria pollutants as well as MWC organics, MWC acid gases, and MWC metals, based on a facility s PTE. The program applies to new major stationary sources or modifications to existing sources, which could result in significant increases of one or more pollutants over specified levels. ( Major stationary source, modification, significant increase, and potential to emit (PTE) are all defined in 40 CFR pt. 52.) If the PTE of a new source or modification exceeds the set emission thresholds, the facility must demonstrate that Best Available Control Technology (BACT) will be used to control emissions prior to receiving a permit authorizing construction of the new source or modification. Alternatively, rather than conducting a BACT analysis, a facility may accept emission limits in a federally enforceable permit which reduce the PTE to below the applicable thresholds. Under the 1977 Clean Air Act, municipal incinerators capable of charging more than 250 tons of refuse per day was one of the 28 PSD 100 ton per day PSD emission categories. When Pope/Douglas was initially permitted (1986), MWC #1 and #2 each had a charge capacity of 40 tons per day. Under the CAA amendments of 1990, municipal incinerators capable of charging more than 250 tons of refuse per day category was amended to 50 tons of refuse per day. Clean Air Act (CAA), Section 169(1), as amended by Section 305(b) of the 1990 CAA Amendments. This PSD major source threshold of 100 tons per year has applied, since 1999, because the MSW units had a capacity greater than 50 tons MSW per day. EPA municipal waste incinerator rules (40 CFR 52.21(b)(1)(i)(a)) have not been amended to reflect this PSD threshold category change. Likewise, MPCA forms have not been amended to reflect this PSD threshold category change. In 1997, Pope/Douglas commenced replacement of the 40 ton per day MWC #1 and #2 units to 60 ton per day charge units. Initial startup of the upgraded units was June These waste combustors and their construction were the subject of a Compliance Agreement, dated May 6, 1999, which required the facility to apply for a variance, which was granted. In 2001, the facility sought approval to replace the waste heat recovery boilers, and received approval from EPA and MPCA in letters dated February 26, 2002 and April 15, The waste heat recovery boiler replacements occurred January through April, At the time of

97 approval for replacing the heat recovery boilers, EPA acknowledged that each of the units had a nominal capacity of 50 tons of MSW per day. According to the facility s performance tests as far back as July 2001, the combination of the current waste combustors and the old waste heat recovery boilers demonstrated the capability of a municipal solid waste (MSW) charge rate in excess of 60 tons of MSW per day. In 2004, the initial Title V permit was issued. The permit contained a NOx limit of 500 ppm. With a 120 ton per day charge capacity (60 tons/day per unit), at the Subpart JJJ 500 ppm limit, the NOx emissions exceeded 100 tons per year. With a 120 ton per day charge capacity (60 tons/day per unit), potential acid gas (HCl and SO2) emissions were also greater than 100 ton/yr, based on the Subpart JJJ HCl and SO2 limits. For this permit action (-003), EPA Region V was consulted. Attachment 1 provides the information submitted to EPA pertaining to this issue. EPA Region V concluded that because the existing facility does have a processing capacity greater than 50 tons per day and does have a PTE of one pollutant in excess of 100 tons/year, Pope/Douglas was a major PSD source, prior to this permit action (-003). In order to resolve the PSD issue, the Nov. 17, 1998 EPA memo entitled Guidance on the Appropriate Injunctive Relief for Violations of Major New Source Review Requirements was followed. It was also noted that Pope/Douglas HCl 2007 performance tests, 2007 SO2 CEM results, and 2007 NOx CEM results demonstrated that the facility s actual emissions did not exceed the 100 ton per year PSD emission threshold. It was determined that the existing MWC #1 and #2 would be allowed to take a synthetic PSD limit for both MWC acid gases and NOx, in this permit action (-003). It is noted that being allowed to take a synthetic minor limit within this permit action authorizing additional emission increases was a unique case-by-case determination. The underlying rational for this decision was that EPA had not updated the PSD rules to reflect the 1990 CAA Amendments in relation to the 250 tons MSW/day to 50 tons MSW/day. A NOx CEMs will be used to demonstrate compliance. A SO2 CEMs and HCl performance testing will be used to demonstrate compliance. In addition, Pope/Douglas was required, as part of the Injunctive Relief Memo, to do a PSD Best Available Control Technology (BACT) analysis for MWC #3. For MWC #3, the control technology that the Permittee proposed to meet the Best Available Control Technology (BACT) equivalent emission limit for the NO x emission is flue-gas recirculation (FGR). The Permittee also evaluated the technical and economic feasibility of installing Selective Non-Catalytic Reduction (SNCR) on MWC Unit #3. The Permittee estimated that SNCR would result in a NOx emission reduction of 37 tons per year. This provided a $12,100 per ton value for cost effectiveness. Based on this information, SNCR was rejected as an alternative. The BACT cost analyst is provided as Attachment 2. Based on the results of BACT cost analysis, the cost of SNCR was determined to be cost prohibitive. A higher level of NOx control for the proposed new Unit 3 would likely be provided by SCR. However, as of yet, there are no applications of SCR to small municipal waste combustor facilities in the U.S. Also, a recent issued PSD permit (August 2007) for the new 200 ton/day waste combustor at the Olmsted County Waste-to-Energy Facility (OWEF) determined that SCR did not represent BACT because it was cost-prohibitive. Therefore, SCR was similarly rejected as a BACT-equivalent control option for the proposed

98 120 ton/day MWC Unit 3. Flue Gas Recirculation (FGR) was selected as a cost-effective technology. Moreover, a 95 tpy NOx synthetic emission limit was applied to MWC #3. A NOx CEMs will be used to demonstrate compliance. In any subsequent modifications, Pope/Douglas is classified as a major PSD source. Subsequent modification emissions will need to be compared to the PSD significance thresholds to determine if the subsequent modification will be subject to PSD. In 2008, EPA Region V verbally concurred in this resolution. It is noted that, as part of the injunctive relief, the PSD analysis of increment air dispersion modeling as well as evaluation the impact of air, ground, and water pollution on solids, vegetation, and visibility caused by project-related emissions and associated growth were not considered. However, as part of the Environmental Assessment Worksheet (EAW), the Permittee conducted an ambient air dispersion modeling analysis of criteria air pollutants for Minnesota and National Ambient Air Quality Standards. Also, the Permittee evaluated the impacts of the proposed project on visibility, soils, and vegetation, as part of the NSPS, Subpart AAAA Siting Analysis Stationary Source Classification As shown in Table 4 below, the area in which the facility is currently located is designated as attainment for all criteria pollutants. Table 4 Facility Classification after the Proposed Unit 3 Project Classification Major Synthetic Minor Minor Prevention of Significant Deterioration X Non Attainment Area NA Part 63, Hazardous Air Pollutants NA* Operating Permit Program X ** * Municipal waste incinerators are not a listed NESHAP category. * * This stationary source category is required to obtain a part 70 operating permit under Minn. R , subp. 4 and 40 CFR Federal Standards of Performance CFR 60.50, Subpart E, Standards of Performance for Incinerators. New Source Performance Standard 40 CFR 60.50, Subpart E does not apply to the Pope/Douglas. 40 CFR provides that any facility covered by subpart AAAA (MWC #3) and JJJ (MWC #1 and #2) is not subject to Subpart E CFR Part 60, Subpart AAAA, Standards of Performance for Small Municipal Waste Combustion Units for Which Construction is Commenced After August 30, 1999.

99 MWC #3 (EU 006) is subject to the Subpart AAAA CFR Part 60, Subpart BBBB, Emissions Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before August 30, The emissions guidelines promulgated by the EPA compel states to promulgate standards of performance for small waste combustors constructed on or before August 30, The MPCA has yet to promulgate the required standards of performance. Pope/Douglas is not subject to these regulations Federal Implementation Plan, 40 CFR Part 62, Subpart JJJ, Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed on or Before August 30, Because Minnesota has not promulgated rules incorporating the requirements of 40 CFR Subpart BBBB, small municipal waste combustors in Minnesota are subject to the Federal Implementation Plan (FIP). The FIP contains all of the requirements of the emissions guidelines and is codified under 40 CFR pt. 62, Subpart JJJ, Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed on or Before August 30, MWC #1 (EU 001) and MWC #2 (EU 002) are subject to these regulations National Environmental Standards for Hazardous Air Pollutants (40 CFR pt. 61 and 63). At the Facility, no air emission units are listed source categories for which National Environmental Standards for Hazardous Air Pollutants under 40 CFR pt. 63. Therefore, the Pope/Douglas Waste Management facility is not subject to these regulations CFR 61.50, Subpart E - National Emission Standards for Mercury. This regulation does not apply to the facility because it does not incinerate sewage sludge National and State Ambient Air Quality Standards (40 CFR pt. 50 and Minn. R. ch. 7009). The National Ambient Air Quality Standards (NAAQS), as found in 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards (MAAQS), set the maximum concentration of pollutants allowed in the ambient air. As such, these standards apply to all air emissions sources. Ambient air monitoring and dispersion modeling is used to determine whether a facility s emissions could cause a violation of these standards. Air dispersion modeling was done for this permit action (-003). As part of the Minn. EAW, the modeling was conducted following Minnesota health risk assessment guidance. The NAAQS were used as benchmarks. It is noted that the NAAQS modeling methodology differs from the PSD increment modeling methodology.

100 CFR 60, Subpart A, General Provisions. Because the Pope/Douglas is subject to the Federal Implementation Plan (40 CFR Part 62, Subpart JJJ), it is also subject to the General Provisions of 40 CFR pt. 60, as specified in 40 CFR State Rules Performance Standards In 1998, the Minnesota waste combustor rules were promulgated. In general, these rules are not, at least, as stringent as the federal emission guidelines for small waste combustors. Pope/Douglas is, therefore, subject to the FIP. The Minnesota waste combustor rules are also applicable requirements and will continue to be so until new rules incorporating the federal emissions guidelines are promulgated and incorporated into Minnesota s SIP. The permit incorporates the requirements of Minnesota statutes, Minnesota rules, the FIP (Subpart JJJ), Subpart AAAA, and the 1997 air emissions rules variance. The permit includes provisions that regulate, in addition to the above-listed emission limits, operator training and certification, combustor unit and control equipment operating conditions, record keeping and reporting, types of fuels allowed in the combustor units, performance testing, emissions monitoring, and ash disposal. The only other Minnesota standards of performance, than the waste combustor rules, that apply are the Indirect Heat Fossil Fuel Burning Equipment rule to the auxiliary boiler as well as the Industrial Process Equipment rule to some of the insignificant activities Environmental Assessment Under Minn. R. ch. 4410, this permit is subject to environmental review. As part of this review, an Environmental Assessment Worksheet was submitted to the MPCA. The public comment period for the EAW will be in October/November, State-only enforceable requirements The language This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act, and which have not been approved as part of the Minnesota SIP. State rules approved as part of the Minnesota SIP are considered federally enforceable and are applicable requirements. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law but are not federally enforceable. State law requirements which would not be enforceable by EPA or by citizens under the federal Clean Air Act, are fully enforceable by the MPCA and citizens under provisions of state law.

101 2.5 Summary of Applicable Regulations Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment EU, GP, or SV GP 001 Applicable Regulations 40 CFR Title I limit to avoid New Source Review (PSD) Comments: Prevention of Significant Deterioration. Synthetic minor PSD limits set for NO x and MWC acid gas (HCl and SO 2 ) emissions from EU 001 and EU 002 to avoid major source classification under 40 CFR GP CFR pt. 62, subp. JJJ Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999 applies to EU 001 and EU 002. GP 001 MN Rule 7011 MN Waste Combustor Rule applies to EU 001 and EU 002 EU 005 MN Rule 7011 MN Indirect Heat Fossil Fuel Burning Equipment Rule EU CFR Title I limit to avoid New Source Review (PSD) Prevention of Significant Deterioration. Synthetic minor PSD limits set for NO x emissions from EU 006 to avoid major source classification under 40 CFR EU CFR pt. 60, subp. AAAA Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed After August 30, 1999 applies to EU 006. EU006 MN Rule 7011 MN Waste Combustor Rule applies to EU SPECIFIC PERMIT CONDITIONS The basis for permit terms is described in this part. This document contains discussion primarily of conditions that are unique to the Pope/Douglas and discussion of how specific requirements are to be implemented through this permit by the Permittee. There are many conditions in the permit that will not be discussed in this document. A discussion of these conditions can be found in the Statements of Need and Reasonableness for the Minnesota waste combustor rules that were promulgated on June 20, 1994, and May 18, 1998, the Preamble to the FIP which was published in the federal Register (Vol. 66, No. 115) on June 14, 2001, or the Preamble to Subpart AAAA which was published in the federal Register (65 FR 76355) on Dec. 6, Total Facility Total facility requirements that are applicable to all facilities in Minnesota are not discussed in this document. Minn. R and , contain permit application content and permit content requirements for all waste combustor permit applications and permits. These requirements are

102 common to all waste combustors and will not be discussed in this document beyond the unique circumstances for the Pope/Douglas. The permit requires several plans from the Permittee. Required plans include the following: Industrial Waste Management Plan; Security Plan; Inspection Plan; Household Hazardous Waste Management Plan; Emergency Preparedness and Prevention Plan; Facility Closure Plan; Contingency Plan; Fugitive Emission Control Plan Operation and Maintenance Plan; Infectious Waste Management Plan (if applicable); Ash Toxicity Reduction Plan; Ash Testing Plan; and Ash Management Plan 3.2. Waste Combustor Emission Limits Pollutant Table 6 Waste Combustor Emission Limits, regulated to burn MWC (Concentrations corrected to 7 percent O 2, except opacity) Emission Limit, regulated as a Class C under state limitations (MWC #1 and 2) Emission Limit, regulated as a Class II under state limitations (MWC #3) Emission Limit, regulated as a Class II under federal limitations (Subpart JJJ) Emission Limit, regulated as a Class II under federal limitations (Subpart AAAA) SO ppmv or 80% reduction 77 ppmv or 50% reduction 30 ppmv or 80% reduction HCl ppmv or 90% reduction 250 ppmv or 50% control 25 ppmv or 95% reduction CO 100 ppmv 100 ppmv 100 ppmv 100 ppmv Front-half PM gr/dscf 70 mg/dscm 24 mg/dscm Total PM gr/dscf 0.02 gr/dscf --- Opacity 10 percent 10 percent 10 percent 10 percent Lead mg/dscm 0.20 mg/dscm Dioxins/Furans 500 ng/dscm 30 ng/dscm 125 ng/dscm 13 ng/dscm (PCDD/PCDF) Cadmium mg/dscm mg/dscm NO x ppmv 500 ppmv Mercury (short term) µg/dscm or 85% removal 100 µg/dscm or 85% removal

103 Mercury 60 µg/dscm or 60 µg/dscm or (long term) 85% removal 85% removal Mercury mg/dscm or 85% reduction Fugitive Ash Visible emissions for no more than 5 percent of hourly observation period mg/dscm or 85% reduction Visible emissions for no more than 5 percent of hourly observation period It is noted that this permit action (-003) will contain total dioxin/furan emissions, for EU 001 and EU 002, as well as mercury emission limits, for all three waste combustors, that are more restrictive than the above waste combustor emission limits Mercury Emissions Limits Minnesota Statutes , subd. 1a(e) states [I]in amending, modifying, or reissuing a facility's air emissions permit which contains a provision that restricts mercury emissions from the facility the Commissioner shall, at a minimum, continue that permit restriction at the same level unless the applicant demonstrates that no good cause exists to do so. The permit contains the mercury emissions limits of 100 µg/dscm (short term) and 60 µg/dscm (long term) as required under Minn. R , and the FIP limit of 80 µg/dscm (0.08 mg/dscm). These limits are applicable to all waste combustors. Minn. Stat , subd. 1a(e) requires each permit to contain mercury emissions limits that are at least as stringent as the previous permit limit. In this permit action (-003), an additional mercury emission limit of 14 ug/dscm is added. This limit was proposed, by the facility, upon the completion of the EAW health risk assessment. On September 21, 2009, the 14 ug/dscm mercury emission limit was accepted by the MPCA Risk Managers. This limit is a state-only limit Monitoring Requirements CEMS/COMS For the existing waste combustors (MWC #1 and MWC #2), continuous monitoring systems for CO, O 2, SO 2, unit load (steam flow), opacity, and PM control device (fabric filter) inlet temperature have been installed. The MWC #1 and MWC #2 combined NOx CEM was certified on April 27, The FIP and permit requires the installation and calibration of a mercury/pcdd/pcdf control additive feed rate monitor. Pope/Douglas has submitted copies of MWC Units #1 and #2 CEM certification reports to EPA pursuant to 40 CFR

104 For the proposed waste combustor (MWC #3), continuous monitoring systems for NOx, CO, O 2, SO 2, unit load (steam flow), opacity, and PM control device (fabric filter) inlet temperature are required. Subpart AAAA and permit requires the installation and calibration of a mercury/pcdd/pcdf control additive feed rate monitor. Pope/Douglas will be required to submit copies of the MWC #3 CEM certification reports to EPA pursuant to 40 CFR A copy of the initial the MWC #3 CEM evaluation reports will be required for MPCA review and approval pursuant to Minn. R , subp. 3 and subp Compliance Assurance Monitoring 40 CFR Part 64 contains the Federal Compliance Assurance Monitoring (CAM) provisions. However, units subject to emission limitations or standards proposed by EPA after November 15, 1990, pursuant to section 111 or 112 of the Clean Air Act are not subject to CAM. Subparts JJJ and AAAA were both promulgated after November 15, Periodic Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considers the following: The likelihood of violating the applicable requirements; Whether add-on controls are necessary to meet the emission limits; The variability of emissions over time; The type of monitoring, process, maintenance, or control equipment data already available for the emission unit; The technical and economic feasibility of possible periodic monitoring methods; and The kind of monitoring found on similar units elsewhere. To achieve this objective, EPA issued guidance (September 15, 1998 memorandum Periodic Monitoring Guidance for Title V Operating Permits Programs) on periodic monitoring requirements for permitted sources. In this guidance, EPA indicates that monitoring required by recently promulgated federal regulations meet the requirements for periodic monitoring. Subpart JJJ applies to the existing waste combustors. Subpart AAAA applies to the proposed waste combustor. Therefore, the three MWC units are not required to add periodic monitoring requirements to show compliance with these rules. The auxiliary boiler is restricted to natural gas only Performance Testing The permit has the following language defining a year and describing what that means. A year is defined as 12 months. The tests shall be conducted at an interval not to exceed 12.5 months. The Minn. R B., says that testing shall be done no more than 12 months following the previous performance test. The federal rule allows 13 months after the previous performance

105 test to conduct the annual stack test. It is obvious that testing cannot be scheduled on the same day every year and there must be some latitude in arranging performance testing around weekends, holidays, weather events and testing firm schedules. A strict interpretation of 12 months in the Minnesota rule would in fact push back testing each year as the Permittee would have to plan for the test sometime in the 11 th month and leave time for potential problems with testing. The federal rule allows 13 months to account for such test scheduling and contingency concerns. The MPCA performance testing staff have considered this problem and decided that since the rule calls for 12 months and not 12.0 months we can assume that there is some leeway on either side of the 12 month deadline. The performance testing staff have, as a general rule, defined 12 months as the period of time 11.5 months to 12.5 months after the previous test. Assuming that the Permittee has no reason or incentive to schedule testing much earlier than required, the permit language says the test shall be conducted at an interval not to exceed 12.5 months Permit Table B Requirements The permit includes a section identified as Table B which contains requirements that call for submittals or MPCA notifications. These requirements are set out separately to allow compliance to be tracked using the MPCA s DELTA database system. Not all submittals or MPCA notifications, however, are contained in Table B. The permit contains numerous reporting requirements. The MPCA staff has attempted to consolidate reporting requirements where possible Insignificant Activities Some emission units at the Pope/Douglas facility are considered insignificant activities. Insignificant activities are those activities or emission units that have potential (or in some cases actual) emissions that are of little or no consequence. While the emissions from these activities may be quite small, some are still none-the-less subject to certain requirements that must be included in the permit (lime storage silos, for example). Those insignificant activities with applicable requirements are included in the Additional Appendix Material that is attached to the permit. The ash system is, by definition, a part of the municipal waste combustion unit and as such was not considered as a separate emissions unit or activity, insignificant or otherwise. The following activities/emissions units are insignificant activities for which applicable requirements exist: MN Rules , subp. 3A Space Heaters MN Rules , subp. 3H Welding Equipment

106 MN Rules , subp. 3I Lime Storage Silo MWC Unloading/Tipping Floor Materials Recovery Facility (MRF), including the following components: Trash in-feed hopper In-feed Conveyor Enclosed Four Station Picking Station Trommel 60-inch magnet and conveyor 48-inch magnet and conveyor Eddy current separator Overhead conveyors Baler Processing Tipping Floor MN Rules , subp. 3K Infrequent use of spray paint equipment MN Rules , subp. 4 Household Hazardous Waste Collection Facility The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities Insignificant Activity Materials Recovery Facility Household Hazardous Waste Collection Facility as defined in Minn. R , subp. 4 General Applicable Emission limit PM, variable depending on airflow or process weight rate Opacity < 20% (Minn. R /715) PM, variable depending on airflow or process weight rate Opacity < 20% (Minn. R. Table 7. Insignificant Activities Discussion For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible. For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible. It would be

107 Insignificant Activity Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source Lime Storage Silo General Applicable Emission limit Discussion /715) difficult to calculate emission given the materials may not be full when brought to the facility. PM, variable depending on airflow or process weight rate Opacity < 20% (Minn. R ) PM, variable depending on airflow or process weight rate Opacity < 20% (Minn. R /715) While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible. For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible. 3.7 Deviations from Delta Norms The permit and this TSD are written in accordance with the norms established for Delta permits and TSD with the following exception. Rule citations of federal regulations do not contain the word Section. The norm is to write the citations as 40 CFR The character was replaced for the word Section. 4.0 TECHNICAL ISSUES 4.1. Tribal Contacts The Mille Lac, Upper Sioux and Lower Sioux Tribes were contacted about this permit action. On Feb. 4, 2009, they were contacted by telephone. The contacts were asked about how much involvement they wanted in the permitting review process. The Lower and Upper Sioux Tribe contact asked to receive a public notice of the permit action. The Mille Lac Tribe contact did not respond the telephone voice mail. All three tribes were ed the public notice and draft period FLM Review Because this permit action was neither a Federal Environmental Assessment nor was a Class I impact analysis required, there was no Federal Land Manager review.

108 4.3 Air Dispersion Modeling Air Dispersion Modeling Review The Criteria Pollutant Air Dispersion Modeling Analysis was conducted for the proposed addition of a third municipal solid waste combustor (Unit 3) at the waste-to-energy facility located in Alexandria, MN. The purpose of the modeling was to demonstrate compliance with the National Ambient Air Quality Standards and the Minnesota Ambient Air Quality Standards (MAAQS) for the Environmental Assessment Worksheet and for permitting. The modeling shows that the facility meets the NAAQS and MAAQS as required for the EAW and the permit. A summary of impacts for the EAW and permit are provided below Modeling Methods AERMOD-PRIME, version was used to complete the modeling analysis, building downwash and building dimensions used in the AERMOD-PRIME model were calculated using USEPA Building Profile Input Program Plume Rise Model Enhancements (BPIP-PRIME), version Receptor elevations were determined using the AERMOD terrain preprocessor (AERMAP), version 03107, and USGS 7.5-minute resolution DEM files. Five years of representative, hourly National Weather Service (NWS) observations were used in the analysis. The modeling used Alexandria, Minnesota, NWS Station No surface data and upper air sounding data from the Minneapolis, Minnesota, NWS Station No for meteorological years 2004 through The meteorological data was processed and provided to the consultant by the MPCA. AERMET Version was used to process the surface and upper air meteorological data. Surface meteorological data was obtained from the National Climatic Data Center's (NCDC) Integrated Surface Database website, Upper air data was obtained from the NOAA/ESRL Radiosonde Database's website, AERSURFACE Version was used to determine surface characteristics (albedo, Bowen ratio and surface roughness) for the area around the surface station and was applied in Stage 3 of AERMET Environmental Review The modeled 1-Hour, 3-Hour, 24-Hour, and Annual SO 2 impacts were below the NAAQS and MAAQS standards. When background concentrations were added to the modeled concentrations the 1-Hour, 3-Hour, 24-Hour, and Annual SO 2 impacts remain below the current NAAQS and MAAQS standards. The modeled NO x Annual average was below the NAAQS and MAAQS standards. When the background concentration was added to the modeled concentrations the Annual NO x impacts remain below the current NAAQS and MAAQS standards. The modeled 1- Hour, 8-Hour CO impacts were below the NAAQS and MAAQS standards. When background concentrations were added to the modeled concentrations the 1-Hour, 8-Hour CO impacts remain below the current NAAQS and MAAQS standards. The modeled 24-Hour, and Annual PM 10 and PM 2.5 impacts were below the NAAQS and MAAQS standards. When background concentrations were added to the modeled concentrations 24-Hour, and Annual PM 10 impacts remain below the current NAAQS and MAAQS standards (Table 1).

109 Permitting A PM Hour modeled concentration of 30 µg/m 3 is 90% of the 35 µg/m 3 NAAQS standard leaving a Moderate Allowable Growth Level (Moderate is a modeled concentration 75%-90% of the standard) with a Tier 2 modeling requirement. A Tier 2 Moderate Allowable Growth Level in general requires that for minor permit amendments and those changes that affect any modeled parameter or emission rate, that the Permittee should keep updated records of all parameters and emission rates. For changes that require a moderate or major permit amendment and affect any modeled parameter or emission rate, the facility will be required to remodel to determine air impacts. TABLE 8 MODELED CRITERIA POLLUTANT CONCENTRATIONS IN COMPARISON TO THE AMBIENT AIR QUALITY STANDARDS Averaging Period Pope/Douglas Modeled Concentration (μg/m 3 ) Background Concentration (μg/m 3 ) Total Ambient Impact (μg/m 3 ) National Ambient Air Quality Standard (μg/m 3 ) Minnesot a Ambient Air Quality Standard (μg/m 3 ) PM Hour Average 1 Annual Average 2 24-Hour Average 3 Annual Average 4 1-Hour Average 5 3-Hour Average 5 24-Hour Average 5 Annual Average 4 Annual Average PM SO , ,300 1, NO x

110 1-Hour Average 5 8-Hour Average 5 3-Month Average (Rolling) CO ,400 4, ,000 40, ,300 2, ,000 10,000 Lead High sixth high concentration over the modeled period 2 High annual average concentration 3 98 th percentile concentration 4 High 3-year average concentration 5 High second high concentration for an individual year 6 These Minnesota Ambient Air Quality Standards have not yet been updated with the revisions to the national standards PM/PM10/PM2.5 Basis There are a number of PM emission limits in the permit. The following Table 9 demonstrates the basis of the PM emissions used in the air dispersion modeling. Table 9 Summary of Various Particulate Matters Used in Modeling PM total State (filterable + organic condensables) PM front half State (filterable) PM10 (filterable + organic condensables + inorganic condensables + safety factor) PM 2.5 (filterable + organic condensables + inorganic condensables) PM front half Federal (filterable) gr/dscf mg/dscm lb/hr (MN Limi (MN Limi (Fed. Limi From Minn. R (and Minn. R , the Class II and C Units State PM contains filterable and organic condensables. The State PM limit does not include inorganic condensables. The limit is gr/dscf gr/dscf * lb/7000 gr * mg/lb * dscf/dscm = mg/dscm From Minn. R , the Class II Units State PM front half contains only the filterable catch. The limit is gr/dscf.

111 0.015 gr/dscf * lb/7000 gr * mg/lb * dscf/dscm = mg/dscm The Pope/Douglas highest historic Unit 1 and Unit 2 inorganic condensable stack test result was mg/dscm. Based on current MPCA policy, PM2.5 is equal to the sum of the filterable + organic condensables + inorganic condensables fractions. The value of the filterable + organic condensables fractions is 45.7 mg/dscm. The value of the PM inorganic condensable fraction is mg/dscm. Hence, the sum of the filterable plus organic condensables plus inorganic condensables is equal to 45.7 plus or rounded up to 70 mg/dscm. This value met the NAAQS. The facility expects that the actual test results of the filterable plus organic condensables will be less than the 45.7 mg/dscm used in this modeling. For PM10, the facility used the PM2.5 value (70 mg/dscm) plus a factor of conservatism (60 mg/dscm) as a basis of the 130 mg/dscm factor used in modeling. For purposes of PTE calculations, PM2.5 emissions were based on 70 mg/dscm. This reflects the current MPCA policy of PM2.5 being equal to the sum of the filterable + organic condensables + inorganic condensables fractions. PM10 was assumed to equal PM2.5 for the PTE calculations. Hence, the PM10 emissions were also based on 70 mg/dscm. A factor of conservatism was not used, as it was for the PM10 modeling Class C Applicability Class C MWCs are existing municipal waste combustors with a total heat input for all combustors of 15 MMBtu/hr to MMBtu/hr for which construction was commenced on or before September 20, Class II MWC is a municipal waste combustor unit with a heat input of 15 MMBtu/hr to MMBtu/hr for which construction was commenced after September 20, 1994, or modification or reconstruction is commenced after June 19, As a result of modifications made at the facility starting in 1997, the Pope/Douglas waste combustor (Units #1 and #2) was reclassified under Minnesota Rule from a Class C to a Class II waste combustor. A variance from the Class II definition was issued on July 27, 2004, allowing the waste combustor to continue to be regulated as a Class C. The permit was written in accordance with this variance. MWC #3 is being constructed after September 20, 1994 with a heat input of 55 MMBtu/hr and therefore will be classified as Class II unit PM 2.5 The PM2.5 emission level did not exceed the 100 tpy PSD threshold. Accordingly, PM 2.5 was not subject to a PSD applicability review. PM 2.5 was, however, included in the AERA. The control strategy to control PM 2.5 emissions consists of dry lime injection, carbon injection, and a fabric filter. This strategy is deemed appropriate for control of PM AERA and Human Health Risk Assessment

112 The MPCA has developed an Air Emissions Risk Analysis (AERA) process to provide for: (1) a streamlined health review of facility air emissions; and (2) a consistent format for presenting the quantitative risk estimates, along with qualitative information to provide context to these risk estimates. An AERA estimates cancer and non-cancer risks to human health from a proposed project and/or an existing facility. In general, facility risk guidelines have been developed by the MPCA, in consultation with the Minnesota Department of Health (MDH) that are consistent with U.S. Environmental Protection Agency (EPA) guidance. The guidelines were established such that the chance of a person getting cancer over the course of their lifetime from exposure to the carcinogenic chemicals emitted from a given facility should be less than 1 in 100,000 (1E-05). The facility guideline for non-carcinogenic chemicals is that the sum of the risks (called hazard indices ) should be less than 1. If emissions from a facility result in estimated risks in excess of these levels, MPCA staff evaluates whether further refinement of the analysis, or modifications to the facility are warranted. More detailed information on the air risk analysis process can be found at Pope Douglas first screened risks from the existing facility and proposed expansion using the AERA process. The Pope/Douglas AERA was submitted in January Pope Douglas then conducted a more refined analysis using an EPA risk assessment model (Industrial Risk Assessment Protocol, or IRAP) to estimate potential cancer risks and non-cancer hazard indices to people in the surrounding community from the total facility after the proposed expansion. These analyses assessed risks from over 60 pollutants emitted from the proposed Unit 3 MWC project as well as from the existing Units 1 & 2 MWCs. The initial IRAP model was submitted to the MPCA in June The IRAP human health risk assessment contains an assessment of potential cancer risks and non-cancer risks (termed hazard indices) to people in the area surrounding the facility. Farmer Cancer Risks The farming scenario was evaluated in areas where farming is zoned to occur, south east of the facility, and under the conditions where it is currently occurring. The scenario where farming cancer risks are above facility risk guidelines assumes than an individual gets some fraction of their food supply, including milk, from the impacted area. Approximately 75 percent of the estimated farmer cancer risk is attributable to milk consumption. There is currently no dairy farming done in areas where the farmer cancer risks, including milk production, are higher than facility risk guidelines. Without risks from dairy production the farmer cancer risks are below facility risk guidelines. Non-Cancer Ingestion Subsistence Fisher Risks If Alexandria residents routinely consumed fish caught in Lake Victoria and Lake Burgen, the non-cancer ingestion risks would be above facility risk guidelines. The assumption underlying this risk estimate was that the fishers would eat about a half-pound of fish 4 to 5 times a week. There are existing fish consumption advisories for Lakes Victoria and Burgen advising pregnant women, women who may become pregnant and children against eating more than 1 meal per

113 month of Northern Pike and the general public to eat no more than 1 meal per week of Northern Pike because of mercury. One meal per week is roughly equivalent to the recreational fisher consumption level, which did not show risks above the facility risk guidelines. The Subsistence Fisher Risks estimates also assume that residents eat garden produce from the most impacted area, which is just north of the facility on Alexandria Technical College property, closest to the new police training academy. It is unlikely that vegetables are grown at the most impacted area. Subsistence Fisher Risks for the maximally impacted current residential areas are not above facility risk guidelines. Cumulative Impacts To form a more complete picture of risks from exposure to outside air pollution to people in the vicinity of the Pope Douglas facility, monitoring data from an average of areas in the state with similar population density were considered along with risks from the facility. These averaged risk estimates reflect emissions from industrial facilities, traffic, gas stations, wood-burning stoves, etc. and distant emissions sources that contribute to a regional level of pollutants that have been detected at similar levels across Minnesota. The non-cancer hazard indices associated with air monitoring data reflect only the respiratory portions of the total background hazard index values since the inhalation non-cancer hazard indices related to potential Pope Douglas emissions are based on respiratory system effects. It is standard risk assessment practice that only those pollutant-specific non-carcinogenic hazard quotients be added together that would impact the same human systems or organs, e.g., liver or respiratory system. For potentially carcinogenic pollutants, it is standard risk assessment practice for estimated cancer risks to be added together regardless of tumor location or type. Due to a combination of increasing the stack height of the current facility and taking more stringent limits on mercury and dioxins/furans, the risks from the facility at the potential maximum emission levels are predicted to decrease as a result of this modification. The cumulative risks from the facility and background levels will also decrease. The contribution to the total cumulative inhalation risks from the proposed 3 rd unit at the maximally impacted receptor are less than 10% as seen in Tables 10 and 11. Table 10 - Risk Estimates from Pope Douglas and Averaged Ambient Monitoring Data Max Chronic Max Acute Respiratory Hazard Index Respiratory Non- Cancer Hazard Index Max Cancer Risk Risks from averaged intermediate population ambient monitoring data E-05 Total facility risks after modification at site of maximum impact Total Cumulative Sum at site of maximum impact E E-05 Risks from Unit 3 alone E-07 % contribution by Unit 3 8% 3% 1%

114 Total Cumulative Sum at current maximally impacted residential area E-05 Table 11 - Summary of MN Mercury Risk Estimation Method for Fish Consumption Pathway Results Subsistence Fisher 1 Recreational Fisher 2 Emissions Scenario Water Body Ambien t Hazard Quotient Facility Tota l % facility contribute s to Total Ambien t Hazard Quotient Facility Tota l % facility contribute s to Total Pre- Modificatio n Potential to Emit (Units 1 & 2 at 26 lb/yr) Post- Modificatio n Potential to Emit, All Units (at 12 lb/yr) Post- Modificatio n Potential to Emit, Unit 3 (at 6 lb/yr) Post- Modificatio n Projected Actual Emissions, All Units (at 1.5 lb/yr) Lake Burgen Lake Victoria Lake Burge n Lake Victoria Lake Burgen Lake Victoria Lake Burgen Lake Victoria % % % % % % % % % % % % % 2.0 < <5% 9.4 < <1% 2.0 < <5% Notes: 1 2 Roughly equivalent to 2.2 pounds of fish consumed per week, 52 weeks per year, from the listed water body. Roughly equivalent to 0.5 pounds of fish consumed per week, 52 weeks per year, from the listed water body. There are existing fish consumption advisories for Lakes Victoria and Lake Burgen advising pregnant women, women who may become pregnant and children, against eating more than 1 meal per month of Northern Pike and the general public to eat no more than 1 meal per week of

115 Northern Pike because of mercury. One meal per week is roughly equivalent to the assumed recreational fisher consumption level. Due to a combination of increasing the stack height of the current facility and taking more stringent limits on mercury and dioxins/furans, the estimated risks from the expanded facility at the potential maximum emission levels are predicted to decrease as a result of this modification. A mercury emission limit of 14 mg/dcsm was proposed for all three waste combustor units. A municipal waste combustor organics (i.e., total dioxins and furans) emission limit of 20 nanograms/dcsm was proposed, individually, for both existing waste combustor units 1 and 2. The existing stack height (SV 001) for the existing waste combustor units 1 and 2 was raised to 105 feet. The estimated risks from the overall expanded facility are below facility risk guidelines with the exception of risks due to conditions that are unlikely to occur. On September 21, 2009, the Impact Statement was presented to the MPCA Risk Managers. It is noted that the proposed mercury and combustor organic emission limits for existing waste combustor units 1 and 2 will become effective after Unit 3 is operational. The Permittee needs to shut down existing units 1 and 2 to raise the stack height. In order to meet steam demands, etc., the Permittee cannot shut down all 3 waste combustion units concurrently. 4.7 CEMS It is noted that during the proposed modification that all of the existing CEMs will be replaced. The MR numbering in this permit action reflects the numbering that will reflect the replaced MRs. 4.8 Mercury Reductions Needed for the Minnesota Mercury TMDL In 2007, the MPCA adopted a Total Maximum Daily Load (TMDL) for mercury. By its terms, Minnesota established that mercury air emissions in the state should be reduced from 1990 levels by 93% to a total of 789 pounds of mercury per year by the To reach the total reductions, the MPCA developed a mercury TMDL Implementation Plan in consultation with representatives of mercury-emitting sources. The State of Minnesota, through its MPCA, will implement the Mercury TMDL Implementation Plan. The MPCA implementation of the Mercury TMDL Implementation Plan will include continued implementation of the "Guidelines for New and Modified Mercury Air Emission Sources." Under these guidelines, proposed new or modified sources with a permit limit of greater than 3 lb/year or equivalent must install best available controls for mercury and provide for additional reductions in the state to account for existing sources. Pope Douglas is installing carbon injection on Unit 3 to control mercury. Units 1 and 2 already employ this control for mercury and other pollutants. These controls are identified as the best available controls for mercury from municipal waste combustors.

116 Pope Douglas has prepared a plan to reduce mercury emissions elsewhere should annual actual mercury emissions be greater than 3 lb/yr. A compliance agreement describing the implementation of the plan and timing of actions, including reporting to the MPCA, has been executed separately from this permit. 5. COMMENTS RECEIVED AND CHANGES TO THE DRAFT/PROPOSED PERMIT Public Notice Period: 11/5/ /4/2009 EPA 45-day Review Period: 11/5/ /19/ Comments Received There were no public comments received. EPA had a concurrent 45-day review. Comments were not received from EPA during their review period Changes to the Draft/Proposed Permit During the public comment period, the MPCA corrected the mercury test frequency to address the requirements found in Minn. Stat The permit was corrected to reflect the 3-month mercury test frequency found in Minn. Stat Because the permit was changed from an annual to a more restrictive quarterly testing schedule, the change was made to the draft permit. 6. CONCLUSION Based on the information provided by Pope/Douglas, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Bruce Braaten (permit writer/engineer) Rachel Peters (enforcement) Andy Place (stack testing) Ruth Roberson (air modeling) Heather Magee-Hill (risk analyst) Bonnie Nelson (peer reviewer) AQ file N0: 2097, DQ 661, DQ 550 Attachments: 1. PCA memo to EPA about PDS applicability 2. Wenck cost estimates 3. Wenck Updated Criteria Pollutant Ambient Air Dispersion Modeling 4. Wenck Air Dispersion Modeling Summary 5. AERA Recommendation Decision

117 ATTACHMENT 1 Feb. 26, 2008 Dear Jennifer: As discussed this morning, I am working on an air permit application for the Pope/Douglas Waste-to- Energy expansion proposal. The application has a PSD issue that I request EPA to provide a determination/guidance upon. I have had preliminary discussions, about this issue, with Mr. Dan Deroeck, of your Headquarters. Could you please forward this information to Mr. Deroeck? Please also note that this facility has committed to taking additional MWC by Jan In order to meet the facility s aggressive construction schedule, we ask for you expedite our request as promptly as possible. The issue is as follows: Is the facility currently (i.e., prior to proposed condenser addition and Unit 3 expansion proposals) considered a minor or major source for PSD? There appear to be three sub-issues that need to be addressed within resolving this minor/major status determination: 1) Did Region V adopt the 50 ton per day charge rate for establishing the 100 ton per day PSD threshold, as provided in the Aug. 3, 1993 Region I memo? Or do the 40 CFR provisions of a 250 ton per day charge rate stay in place? 2) With the promulgation of CFR Part 62 Subpart JJJ, is the limited NOx PTE 139 tpy (as based on Subpart JJJ 500 ppm limit) or less than 100 tpy (as calculated by AP-42 emission factors and supported by 2007 CEMs data)? In other words, prior to 2003, the NOx PTE was based on AP-42 factors. With the promulgation of Subpart JJJ, a federally based limit (which was higher than the AP-42 factor) was added to the permit. Does this, in itself, cause the facility to be a major PSD source? 3) Does the original condenser serve as a physical bottleneck to limit the MWC Acid Gases to less than 100 tpy? If not, are MWC Acid Gases regulated PSD pollutants? In order to make your determination, I have provided you with background information. The information is broken into 5 sections. The first section provides a chronological background of the facility. The second section contains the Region I Aug. 3, 1993 memo. The third section provides two definitions from 40 CFR Section The fourth section provides some notes provided by the facility s consultant to try to present their perspective. The fifth section provides the facility s 2007 actual emission data calculations.

118 Please let me know if you need any additional information or have any questions on this matter. Thank you for your assistance. Yours truly, Bruce Braaten MPCA 507/

119 I. FAC ILITY BACKGROUND 1986 Both waste combustors were, originally, built in EU001 MWC charge design capacity = 40 tons per day EU002 MWC charge design capacity = 40 tons per day Initial permit lists a MWC charge design capacity of 40 tons per day for each unit calculated PTE, as based on 80 tons per day of MWC charge: NOx = 58 tpy SO2 = 58 tpy HCl = 88 tpy 1987? Amendment #1 (somewhere about 1987) Permit amendment adds a 40 tons per day MWC charge, on a monthly basis, limit on each combustor unit Pre-1990 CAA, PSD 100 ton per year threshold = 250 ton per day charge rate Post CAA, PSD 100 ton per year threshold = 50 ton per day charge rate (See Aug. 3, 1993 Region I memo to Commonwealth Resource Management Corporation) 1999 EU001 and EU002 waste combustors replaced/rebuilt. The records show a different combustor manufacturer for the replaced/rebuilt units. EU001 MWC charge design capacity = 60 tons per day EU002 MWC charge design capacity = 60 tons per day However, the initial steam condenser remained, in operation, at a charge rate of 80 tons per day. Both waste combustors are capable of operating at 60 tons per day (during individual performance tests.) In addition, during high steam demand periods, the facility can operate waste combustors above 80 tons per day. However, without a steam demand (summer months), the condenser capacity limits total waste combustion to 80 tons per day (typical scenario). Both combustors are controlled by fabric filter, carbon injection, flue gas recirculation, and lime injection. Emissions taken from1999 Part 70 application (calculated PTE, as based on 80 tons per day of MWC charge and AP-42 emission factors): NOx = 36 tpy SO2 = 50.6 tpy HCl = 93.6 tpy An EU 005 also had a PTE of an additional 1.5 tpy of NOx Title V Permit Issuance incorporates the, then, recently promulgated January 31, CFR Part 62, Subpart JJJ (Federal Plan Requirements for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999) Subpart JJJ limits put into operating permit: NOx limit = 500 ppm HCl limit = 250 ppm SO2 limit = 77ppm No annual limit for NOx or MWC acid gas No permit limit restricting charge rate, per combustor, to 40 tons per day. At 80 tons per day, limited PTE: MWC Acid Gas (HCl and SO2) = 96.8 tpy (HCl = 62.8 tpy, SO2 = 34.0 tpy)

120 (Based on NSPS limits) NOx (based on AP-42) = 41.0 tpy (*basis of 2004 permit) NOx (based on NSPS limit of 500 ppm) = 139 tpy * From technical support document: Because the PTE is less than the rule-limited PTE, the limited annual NOx emissions are estimated to be 41.0 tons. For the Part 70 issuance, the facility was considered a PSD minor Actual Emissions (based on NOx CEM and SO2 & HCl performance tests background data provided in Section V below) NOx = 18 tpy (combined combustion units) SO2 = 6 tpy (combined combustion units) HCl = 41 tpy (combined combustion units) 2007 Amendment Proposal Add a new condenser to debottleneck EU 001 and EU 002 to 120 tons per day (original) design waste combustion charge capacity for combined units NOx = 208 tpy (500 ppm at 120 tons per day waste) NOx = 61.5 tpy (based on AP-42 factor at 120 tons per day waste) HCl = 94 tpy (250 ppm at 120 per day waste) SO2 = 50 tpy (77 ppm at 120 tons per day waste) MWC Acid Gases (HCl & SO2) = 144 tpy at 120 tons per day waste The 2007 proposal not acted upon due to the need for a Minnesota EAW to be completed on the project. The EAW projected out 3 years and needed to include the proposed Unit 3 waste combustor Amendment Proposal Add new condenser to debottleneck EU 001 and EU 002 (i.e., 2007 proposal) as well as add Waste Combustor Unit #3 Add Waste Combustor Unit #3 120 tons per day MWC charge design capacity Unit 3 proposed to be controlled by fabric filter, carbon injection, and lime injection. Unit 3 would be housed in the same building as the two existing combustors. A common waste pit would serve all three units. Unit #3 NSPS limits: NOx = 500 ppm HCl = 25 ppm SO2 = 30 ppm

121 II. REGION I AUG. 3, 1993 MEMO UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS AUG 03 l993 Thomas Yersanian, Principal Commonwealth Resource Management Corporation 74 Pleasant Street Mansfield, MA Dear Mr. Yersanian: Thank you for your July 6, 1993 letter requesting EPA-Region I's determination on the applicability of its regulations and the Clean Air Act Amendments of 1990 (CAAA) to the Montachusett Regional Recycling Facility (MRRF). You indicated that EPA's Office of Air Quality Planning & Standards suggested you contact this office for the determination. As you know, the CAAA revised section 169(1) of the Clean Air Act by expanding the list of major emitting facilities that are subject to the PSD requirements if they emit or have the potential to emit 100 tons per year (TPY) or more of any regulated pollutant. The revised list now includes municipal waste combustors capable of charging more than 50 tons per day (as opposed to the previous PSD requirement of 250 tons of waste per day). Your letter also correctly points out that EPA, in its transitional guidance, did not address the requirements of new projects given the discrepancy between the CAAA and the current codified regulations. However, EPA's office of General Counsel (OGC) has informed us that this statutory change is considered to be immediately effective (i.e., as of the date of enactment of the CAAA). Though Headquarters has not written this into any policy or guidance memorandum, Region I has informed its states that the above change is indeed in effect. I have attached two documents for your information. These are background technical support documents for two final rulemaking actions. Please note that on page 2 of each document, under the "Municipal Waste Combustor Provisions" section, it states that "EPA interprets this statutory change as being immediately effective". Therefore, TIRU's MRRF project is subject to the 50 tons of waste per day statutory limit of the CAAA, and not the 250 tons of waste per day threshold of the PSD regulations found under 40 CFR SS In this case, the statute takes precedence over the codified requirement. On the basis of our response, it would appear the issue you raised concerning the heterogeneity of refuse and the averaging time used for determining the charging rate may be a moot point. However,

122 for your information, it should be noted that 40 CFR Part 60, Subpart Ea uses a standard HHV of 4500 BTU/pound in calculating a municipal waste combustors capacity and not the 5500 BTU/hr used in the TIRU application. I am hopeful that this response addresses your concerns. If you have any questions, please contact John Courcier of my staff at (617) Sincerely, Linda M. Murphy, Director Air, Pesticides & Toxics Management Division Attachments cc: M. Sewell, OAQPS

123 III. 40 CFR SECTION DEFINITIONS Additional material taken from 40 CFR pertaining to whether MWC Acid Gases are a regulated NSR pollutant. The definition of significant includes MWC acid gases: 23) (i) Significant means, in reference to a net emissions increase or the potential of a source to emit any of the following pollutants, a rate of emissions that would equal or exceed any of the following rates: Pollutant and Emissions Rate Carbon monoxide: 100 tons per year (tpy) Nitrogen oxides: 40 tpy... Municipal waste combustor organics (measured as total tetra- through octa-chlorinated dibenzo-p-dioxins and dibenzofurans): megagrams per year ( tons per year). Municipal waste combustor metals (measured as particulate matter): 14 megagrams per year (15 tons per year) Municipal waste combustor acid gases (measured as sulfur dioxide and hydrogen chloride): 36 megagrams per year (40 tons per year) The definition of regulated NSR pollutant provides: (50) Regulated NSR pollutant, for purposes of this section, means the following: (i) Any pollutant for which a national ambient air quality standard has been promulgated and any constituents or precursors for such pollutants identified by the Administrator (e.g., volatile organic compounds and NO X are precursors for ozone); (ii) Any pollutant that is subject to any standard promulgated under section 111 of the Act; (iii) Any Class I or II substance subject to a standard promulgated under or established by title VI of the Act; or (iv) Any pollutant that otherwise is subject to regulation under the Act; except that any or all hazardous air pollutants either listed in section 112 of the Act or added to the list pursuant to section 112(b)(2) of the Act, which have not been delisted pursuant to section 112(b)(3) of the Act, are not regulated NSR pollutants unless the listed hazardous air pollutant is also regulated as a constituent or precursor of a general pollutant listed under section 108 of the Act. It is noted that HCl is a HAP. Subpart JJJ, however, provides a HCl ppm limit, as opposed to a MWC Acid Gas limit. IV. CONSULTANT S NOTES I thought I might recap some of the things we discussed so that you would have them handy for your internal meeting today. 1. Units 1 & 2 can each operate at a rate of 60 tpd right now, and Pope/Douglas could provide data to show steam generation rates amounting to simultaneous operation of both units at these levels. 2. The existing steam condenser and the proposed new steam condenser are not emission units, but serve as heat sinks for times when customers steam demands are not at maximum levels.

124 3. Pope/Douglas could forego the installation of a new steam condenser under the U1 & U2 proposal. Or, they could look into a design where a new condenser was installed to serve U3 only. Either proposal would be more complicated than the proposals on the table, but if it helps to clarify permitting questions, these could be looked into. 4. Given 1 3 above, we do not feel that the classic permitting issue of debottlenecking is applicable. 5. Even if MPCA continues to believe that debottlenecking is applicable, Pope/Douglas is prepared to accept federally-enforceable limitations that keep the existing facility a minor source for PSD purposes. Pope/Douglas actual emission levels show that our proposed federally-enforceable minor source limits are indeed viable. 6. The question of whether the U3 project must fit under the 100 tpy major source threshold, or the much lower PSD major modification threshold boils down to whether the existing facility is a minor source for PSD purposes. Again, the viability of federally-enforceable limits (and actual emissions data to back them up) would indicate that the source is and can be made to be in a federally-enforceable sense, if need be a minor source. 7. The permitting question of sham permitting was raised. We discussed how sham permitting typically means the deliberate splitting of an otherwise single project into multiple, smaller projects for the purposes of avoiding PSD review. This was deemed to be a viable definition. 8. The existing facility was constructed some ~20 years earlier than the U3 proposal, and can already operate at the rates and federally-enforceable emission limitations requested in the U1 & U2 permit application. 9. Given Items 7 & 8, Pope/Douglas and Wenck do not feel that questions of sham permitting are applicable here. 10. Because the existing facility can be shown to be a minor source and the two permit applications are not otherwise related to each other, the appropriate source threshold for the U3 project should be 100 tpy per pollutant, not the lesser PSD major modification thresholds. 11. The sole reason that the permit applications are being processed together is because MPCA elected to require an EAW for the projects together. That decision should not be construed as somehow forcing an interrelationship between the U1/U2 and the U3 proposals for PSD purposes. Nor does the fact that one permit may end up authorizing both actions somehow force an interrelationship under PSD if the units have been constructed and operated under the timeframes and conditions described above. Hopefully this is a helpful recap of our discussion. Please let me know if further questions arise today on these subjects. These are obviously important questions to the scope and design of the Unit 3 project, so we d be glad to assist in further defining the project if that is helpful to your discussions. V ACTUAL EMISSIONS DATA

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128 ATTACHMENT 2 Memorandum 1800 Pioneer Creek Center, Maple Plain, MN Phone: Fax: T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc To: Bruce Braaten, Minnesota Pollution Control Agency From: Ed Hoefs, Wenck Associates, Inc. Luke Taylor, Wenck Associates, Inc. cc: Pete Olmscheid, Pope/Douglas Solid Waste Management Date: September 10, 2008 Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 On behalf of Pope/Douglas Solid Waste Management (PDSWM), Wenck Associates, Inc (Wenck) submits this Best Available Control Technology (BACT)-equivalent Analysis for the third waste combustor (Unit 3) proposed to be installed at the PDSWM facility located in Alexandria, Minnesota. A formal BACT analysis is required when a project triggers review under federal Prevention of Significant Deterioration (PSD)/New Source Review (NSR) regulations. Even though the proposed project at PDSWM will not be subject to PSD (through federally-enforceable permit conditions limiting emissions below the major source threshold), the Minnesota Pollution Control Agency (MPCA) requested that an analysis equivalent to a PSD BACT analysis be completed for NOx emissions from proposed PDSWM Unit 3. This memorandum summarizes the approach and the BACT-equivalent analysis for NOx emissions. BACT-Equivalent Analysis Methodology Unit 3 will be the only emissions source associated with the project that will emit NOx emissions; there will be no other new or modified source of NOx emissions. Therefore, the following analysis addresses NOx emissions from Unit 3. US EPA has recommends a specific procedure for determining BACT in PSD permits. This process is known as the top-down approach. This approach was first described in a US EPA policy memorandum. Subsequently, the top-down BACT procedure has been described further in draft US EPA guidance documents, and in proposed, US EPA regulations. The top-down approach is a systematic methodology consisting of the following steps, to be conducted for each pollutant subject to PSD review: 1. Identify control options that are available and demonstrated in practice. 2. Evaluate the technical feasibility of these control options. 3. Rank each of these control options by overall control effectiveness, with the most effective control alternative at the top. 4. Accept top control option as BACT or demonstrate that energy, environmental and/or economic impacts preclude its use. Memorandum to Bruce Braaten

129 Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 2 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc 5. If the top control option is not justified, continue to evaluate second and subsequent control options, in order of ranking, until a particular option is identified which can not be eliminated based on consideration of energy, environmental and/or economic factors. This analysis for the non-psd, PDSWSM Unit 3 project follows the top-down format, modified with guidance provided by MPCA. Identification of Candidate Control Technologies and Precedent Emission Limits The first step in a standard PSD BACT analysis is to identify, for each pollutant, the control options that are available and have been demonstrated in practice for the same or similar emissions-source category. With these options established, the next step is to document the most stringent emissions limitations that have been set for a given source category. Accordingly, the remainder of this section and the following one are both devoted to the procedure for determining a BACT-equivalent emission limitation for the proposed PDSWM Unit 3. The control technology options and emission limitation precedents applicable to Unit 3 have been researched, as follows: 1. Search the US EPA s RACT/BACT/LAER Clearinghouse, via web database inquiry, to determine the BACT/LAER control technologies, the BACT/LAER permit limitations, and other permit limitations that have been established nationally for boilers fueled with municipal solid waste. 2. Communications with air pollution control technology vendors. 3. Review of relevant regulations promulgated by US EPA that impose limits nationally on the same emissions-source category Based on discussions with MPCA, it was agreed that candidate, BACT-equivalent control technologies for control of NOx emissions from PDSWM Unit 3 consist of: o Flue Gas Recirculation (FGR); and, o FGR plus Selective Non-Catalytic Reduction (SNCR). The above assessment was based on an MPCA permit issued in August 2007 for a 200-ton/day mass-burn waste combustor, which contained a PSD BACT limit for NOx emissions. In that project, a third control strategy was also evaluated Selective Catalytic Reduction (SCR). However, MPCA determined that application of SCR did not represent BACT in that instance because it was determined to be cost-prohibitive. PDSWM stipulates, and MPCA has agreed, that application of SCR to the PDSWM Unit 3 project would be even costlier on cost per ton removed basis, due to economies of scale with the smaller PDSWM unit. Wenck reviewed USEPA s RACT/BACT/LAER Clearinghouse for any NOx BACT entries made since January The new entries found for other national MWC projects included BACT control Memorandum to Bruce Braaten

130 Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 3 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc technology selection decisions similar to what was reviewed when MPCA made its last NOx BACT determination for an MWC project. As part of this evaluation, PDSWM obtained a cost estimate for application of SNCR to the PDSWM Unit 3 project from an established NOx control vendor. A separate cost estimate was not pursued for FGR, since the equipment vendor selected for the Unit 3 project already incorporates FGR into the base design of its units. Cost Estimating Approach The economic evaluation of alternative control technologies in this BACT analysis is based on developing study cost estimates (+30% accuracy) using US EPA cost methodologies and related recognized methodologies. The cost for a given control technology is comprised of two elements, the total capital investment (i.e., the installed capital cost) and the annual operating and maintenance cost. The components of the total capital investment include purchased equipment costs as well as direct and indirect installation costs. Purchased equipment costs include the cost of the primary control device, auxiliary equipment (e.g. ductwork), instrumentation, sales taxes, and freight. Primary control device cost and auxiliary equipment costs are obtained from vendor estimates where possible. The costs for instrumentation, sales tax, and freight are typically factored from the total cost of the primary control device and auxiliaries. Direct installation costs are comprised of the costs for foundations and supports, erecting and handling the equipment, electrical work, piping, insulation, and painting. Indirect installation costs include engineering costs, construction and field expenses, contractor fees, start-up and performance test costs, and contingencies. Both the direct and indirect installation costs are normally factored from the total purchased equipment cost (which includes the costs for instrumentation, sales taxes, and freight) using standard indices. Overall factors representing both direct and indirect installation costs have been published for various types of air pollution control equipment. The published cost factors are presented in Table 1. Memorandum to Bruce Braaten

131 Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 4 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc TABLE 1 Direct and Indirect Installation Cost Factors Air Pollution Control Device Installation Cost Factor Air Pollution Control Device Installation Cost Factor Electrostatic Precipitator 2.27 Venturi Scrubber 1.94 Fabric Filters 2.21 Thermal Incinerator 1.63 Catalytic Incinerator 1.63 Adsorber 1.63 Absorber 2.24 Condenser 1.76 For this NOx BACT-equivalent analysis, no generalized installation-cost factors were found in the published literature for add-on NOx controls such as Selective Non-Catalytic Reduction (SNCR). In order to develop installed costs, a nominal factor of 2.0 has been applied. This represents a middle ground in relation to the published factors presented above. The total installed capital investment is annualized in this BACT analysis using a capital recovery factor, in accordance with standard methodology. The capital recovery factor is defined as follows: CRF = i (1 + i)n (1 + i) n 1 where: CRF = Capital Recovery Factor i = real interest rate n = equipment life in years The recommended, standard, US EPA assumptions of a 7% interest rate and a 10-year equipment life are used in this BACT analysis, resulting in a capital recovery factor of The total operating and maintenance (O&M) cost is comprised of direct and indirect costs. Direct costs include labor (operating, supervisory, and maintenance), raw materials (e.g., reagent), utilities (e.g., electricity, water), maintenance materials, spare parts, and waste treatment and disposal. Indirect costs include overhead, administrative charges, taxes and insurance. Some of these O&M costs are estimated based on specific project information, for example vendor-quoted utilities requirements, while other costs are estimated using published factors based on the total capital investment allocated to the air pollution control equipment. Memorandum to Bruce Braaten Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 5 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc

132 The total annualized cost of the air pollution control equipment is determined by summing the annualized, total installed capital investment and the total annual operating and maintenance cost. Cost effectiveness of the control alternative is determined as follows: CE = Total Annualized Cost (TAC) Pollutant Removed (PR) where: CE = Cost Effectiveness reported in dollars per ton of pollutant removed, and: TAC = Total Annualized Cost reported in dollars per year, and PR = Pollutant Removed reported in tons per year. Control of NOx Emissions To meet the proposed annual limit for NO emissions from its proposed new Unit 3, PDSWM x proposes the control technology of flue gas recirculation (FGR), which is a combustion control for NO. x NOx is generated in one of three forms; fuel NOx, thermal NOx, and prompt NOx. Fuel NOx is produced by oxidation of nitrogen in the fuel source. Combustion of fuels with high nitrogen content produce greater amounts of NOx than those with low nitrogen content. Thermal NOx is formed by the fixation of molecular nitrogen and oxygen at temperatures greater than 3600 o F. Prompt NOx forms from the oxidation of hydrocarbon radicals near the combustion flame and produces an insignificant amount of NOx. In an FGR system, a portion of the flue gas is recycled from the stack to the burner windbox. Upon entering the windbox, the recirculated gas is mixed with combustion air prior to being fed to the burner. The recycled flue gas consists of combustion products which act as inerts during combustion of the fuel/air mixture. The FGR system reduces NOx emissions by two mechanisms. Primarily, the recirculated gas acts as a dilutant to reduce combustion temperatures, thus suppressing the thermal NOx mechanism. To a lesser extent, FGR also reduces NOx formation by lowering the oxygen concentration in the primary flame zone. The amount of recirculated flue gas is a key operating parameter influencing NOx emission rates for these systems. In addition to FGR, potential add-on NOx control technologies for municipal solid waste combustors include Selective Catalytic Reduction (SCR) and Selective Non-Catalytic Reduction (SNCR). A higher level of NOx control for the proposed new Unit 3 would likely be provided by SCR. However, as of yet, there are no applications of SCR to municipal waste combustor facilities in the U.S. Also, as noted earlier, a recent, MPCA-issued PSD permit (August 2007) for the new 200 ton/day waste combustor at the Olmsted County Waste-to-Energy Facility (OWEF) determined that SCR did not represent BACT because it was cost-prohibitive. With Memorandum to Bruce Braaten Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 6 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc

133 MPCA concurrence, SCR was similarly rejected as a prospective BACT-equivalent control option for the proposed 120 ton/day PDSWM Unit 3 project based on economies of scale. SNCR has been proven to be technically feasible and has been applied to several municipal waste combustor units nationally. SNCR is based on the chemical reduction of NOx into molecular nitrogen (N ) and water vapor (H O). A nitrogen based reducing agent (reagent), such 2 2 as ammonia or urea, is injected into the post combustion flue gas. The reagent can react with a number of flue gas components. However, the NOx reduction reaction is favored over other chemical reaction processes for a specific temperature range and in the presence of oxygen. Therefore, the process is considered a selective process. The BACT-equivalent analysis for SNCR is described below. Economic Feasibility of SNCR An economic analysis was conducted for applying a SNCR system to control NOx from Unit 3. The analysis shows that the cost of installing and operating an SNCR system is prohibitive. Capital costs and installation costs for a technically feasible SNCR system are based on vendor cost estimates. Operating costs are derived based on the approach described above in this memorandum. According to recent permit limits for other waste combustors, an SNCR system will reduce NOx emissions from Unit 3 down to approximately 150 7% O on 24-hour 2 average basis. Cost effectiveness ($ per ton of emission reduction) is calculated based upon the limited potential annual NOx emissions of 99 tons/yr for Unit 3, which is equivalent to approximately 240 7% O on annual average basis. The cost calculations are 2 documented in attached Tables A-1 through A-3. According to the PSD permit application submitted in May 2007 for the proposed OWEF Unit 3 project, the cost effectiveness for SNCR was determined to be $1,500/ton of NOx emissions reduced. As shown in the summary table below, the cost effectiveness of installing SNCR on the proposed PDSWM Unit 3 is $12,100/ton of NOx emissions reduced, which is more than eight times the cost effectiveness for installing SNCR on OWEF Unit #3. This is not unexpected because, as implied earlier with respect to SCR, installation of identical add-on controls will generally be more expensive on a dollars-per-ton-removed basis on a smaller emissions unit (when compared to a larger emissions unit) due to less favorable economies of scale. On the basis of cost effectiveness, we suggest that FGR alone represents BACT-equivalent control for the PDSWM Unit 3 project. Memorandum to Bruce Braaten Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 7 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc TABLE 2

134 Summary of SNCR Cost Benefit for NOx Emissions from Unit 3 Operating Assumption Limited Potential to Emit (PTE) * Uncontrolled NOx Emissions (tons/yr) NOx Emission Reduction (tons/yr) SNCR System Total Annualized Cost ($/yr) Average Cost Effectivenes s ($/ton) OWEF Average Cost Effectivenes s ($/ton) $449,800 $12,100 $1,500 * PDSWM has proposed a synthetic minor limit of 99 tons/yr without SNCR.. This was used as the baseline case. Energy and Environmental Analysis of SNCR In addition to technical and economic feasibility, the PSD rules also require that energy and environmental impacts be considered when selecting BACT. These factors also weigh in favor of selecting FGR alone for BACT-equivalent NOx control from PDSWM Unit 3. In order to operate the SNCR system, additional power for the PDSWM facility will be required. The additional power consumption will result in an increase demand on the grid and create additional emissions from the utilities providing power to the grid. The NOx reduction reaction for an SNCR system occurs within a specific temperature range where adequate heat is available to drive the reaction. At lower temperatures the reaction kinetics are slow and ammonia passes through the furnace (ammonia slip). At higher temperatures the reagent oxidizes and additional NOx is generated. Ammonia slip from an SNCR system will result in ammonia emissions out of the waste combustor stack, potentially causing a new source of odors in the immediate vicinity of the PDSWM facility. Also, EPA has identified ammonia as one of the possible precursors to PM2.5 formation. Therefore, additional PM2.5 emissions would also be generated. The NOx reducing agent (e.g., ammonia or urea) used for SNCR system would be stored in an aboveground storage tank at the facility. Having on-site storage of a potentially hazardous material creates a risk for releases to the environment, added security risks, as well as additional secondary emissions from transportation of the NOx reagent to the PDSWM facility. To illustrate the secondary emissions impact, assume that the NOx reagent would be delivered by tanker truck from the Minneapolis-St. Paul metropolitan area to the PDSWM facility located in Alexandria, MN. The round trip distance is approximately 260 miles, which will result in

135 Memorandum to Bruce Braaten Subject: BACT-Equivalent Analysis for Proposed PDSWM Unit 3 Page 8 of 8 September 10, 2008 T:\1221\07 Unit 3 Application\Technical\24 Assist MPCA\SNCR Evaluation\PDSWM BACT-Equivalent Analysis Memo doc secondary source emissions from the diesel truck engine. If urea was selected, it may be shipped from even more distant, licensed suppliers. However, if only FGR is used to control NOx emissions, no additional secondary emissions will be generated. Even with the proper training and preventative maintenance, anytime a hazardous material is being transported and stored, there is a risk of release to the environment. If the tanker truck container or on-site storage tank were to fail, the ammonia would be released and potentially endanger human health and the environment. There is also a risk of a release of ammonia or urea from the SNCR system and during transfer from the tanker truck to the on-site storage tank. FGR for the proposed Unit 3 will result in low NOx emissions without add-on control and there will be no adverse environmental impact or security risk. If SNCR were installed to control NOx emissions, additional power will be needed for the system, additional ammonia emissions and PM2.5 emissions will be generated; secondary emissions from transportation of the ammonia and utilities providing power to the grid would occur; and there will be a risk of ammonia releases which may endanger human health and the environment and added security risk. Conclusion on NOx BACT-Equivalent for Proposed Unit 3 Application of SNCR should be rejected as a BACT-equivalent means of controlling NOx emissions from the proposed PDSWM Unit 3 project. SNCR has been shown to be costprohibitive relative to a recent NOx PSD permit issued for another waste combustor in Minnesota. SNCR also carries potential health risks, adverse environmental impacts, and adverse energy impacts. Adverse potential health risks from SNCR include the risk of ammonia releases which may endanger existing businesses that are in close proximity to the PDSWM facility. On the other hand, FGR is a cost-effective means of reducing NOx emissions from the project and it carries none of the adverse environmental, health, or energy impacts associated with SNCR. Using FGR alone, PDSWM can readily demonstrate compliance with applicable NOx performance standards, as well as meet a proposed 99 ton/year synthetic minor limit for the addition of the Unit 3 project. Compliance would be demonstrated through use of a certified NOx CEMS. Table A-1 SNCR Capital Cost Calculations TPD Capacity I. Turnkey Installed Cost Provided by Vendor Quoted Turnkey Cost $1,290,000 (1) Associated Unit 3 Stack Gas Exhaust Rate 13,190 7% O2 (Estimated based on stoichiometric f-factor) Combustor Size 120 TPD Quoted No. Units 1 II. Calculation of Total Installed Capital Cost Turnkey Installed Cost Equipment design, fabrication & installation $1,290,000from I. above Interconnecting ductwork 0not applicable Instrumentation 0assumed included in scope of supply Sales taxes 0assumed included in scope of supply Freight 0assumed included in scope of supply Turnkey installed cost, TIC $1,290,000 Owner's administrative overhead (OAO) $0 assumed included in scope of supply Total Capital Investment = TIC + OAO $1,290,000

136 III. References (1) Quote from Wrigley Mechanical, Inc. and Fuel Tech, Inc. (09/2008) PopeDouglas SNCR Costs Analysis at 99tpy_ Table 1 Page 1 of 1 9/10/2008 Table A-2 SNCR Intermediate Calculations TPD Capacity Limited Uncontrolled NOx Emissions of 99 tons/yr I. Number of Units and Annual Operating Hours Assumptions Number of Units 1 Annual operating hours 8,760 hr/yr II. Capital Recovery Factor for Equipment Annual rate of return 7 % SNCR equipment life 10 years SCR Capital recovery factor III. Quoted Urea Consumption Quoted 50% Urea required 7.0 gal/hr/facility (Fuel Tech, Inc. 09/2008) IV. Design NOx Control Design Uncontrolled NOx emissions 240 ppmdv@7%o2 based on annual average NOx limit of 99 tons/yr Design Controlled NOx emissions 150 ppmdv@7%o2 Design NOx removed (concentration) 90ppmdv@7%O2 Design NOx controlled/unit (mass) 8.5lb/hr/unit = 90 ppmdv@7%o2 / 10^6 x 13,190 dscfm@7%o2 x 60 min/hr x 46 lb/lbmol / R- lbmol/cu.ft.-atm x 1 atm / 528 deg.r Design NOx controlled (mass) 8.5lb/hr/facility V. Urea (50%) Unit Cost Urea (50%) Unit Cost 1.70 $ /gal delivered (Fuel Tech, Inc. 09/2008) VI. Design Utility Consumption Design Electricity 41.0kW(Wrigley Mechanical, Inc. & Fuel Tech, Inc. 09/2008) Design Compressed Air 3,600scfh(Wrigley Mechanical, Inc. & Fuel Tech, Inc. 09/2008) Design Water 0gph(Wrigley Mechanical, Inc. & Fuel Tech, Inc. 09/2008) PopeDouglas SNCR Costs Analysis at 99tpy_ Table 2 Page 1 of 1 9/10/2008 Table A-3 SNCR Annual Cost Calculations TPD Capacity Limited Uncontrolled NOx Emissions of 99 tons/yr I. Calculation of Direct Annual Costs Direct Annual Costs II. Operating labor Operator 13, $25.07/hr ($/hr from Pope/Douglas) Supervisor 2,10015% of operator Operating materials 50% Urea (ref. Table A-2) 104,200at $1.70 per gal Maintenance Labor & Materials 25,000(Fuel Tech, Inc. 09/2008) Utilities 45,000(Fuel Tech, Inc. 09/2008) Electricity (ref. Table A-2) Included Aboveat $ per kwh (from Pope/Douglas) Water (ref. Table A-2) 0at $1.50/1000 gal Compressed air (ref. Table A-2) Included Aboveat $1.02/1000 scf Total direct costs, DC $190,000 Calculation of Indirect Annual Costs Indirect Annual Costs III. Overhead 24,50060% of Operating labor and Maintenance Labor and Material Administrative charges 25,8002% of TCI (TCI = Total Capital Investment, ref. Table A-1) Property taxes 12,9001% of TCI Insurance 12,9001% of TCI Capital recovery (ref. Tables A-1 & A-2) 183,700= CRF x TCI Total indirect costs, IC $259,800 Total Annual Cost is Sum of Direct and Indirect Annual Costs Total annual cost (DC + IC) $449,800 IV. Calculate Cost Effectiveness Tons NOx controlled (ref. Table A-2) 37tons/yr= (Design NOx Controlled in lb/hr) x (Operating Hours) Cost effectiveness $12,100 $/ton = (Total Annual Cost) / (Tons NOx controlled) PopeDouglas SNCR Costs Analysis at 99tpy_ Table 3 Page 1 of 1 9/10/2008 ATTACHMENT 3

137 Wenck Associates, Inc Pioneer Creek Ctr. P.O. Box 249 Maple Plain, MN (763) Fax (763) TECHNICAL MEMORANDUM To: From: cc: Heather Magee-Hill Minnesota Pollution Control Agency Stephanie Kuphal, Ed Hoefs, Libbie Henderson Wenck Associates, Inc. Pete Olmscheid, Pope/Douglas Solid Waste Management Date: August 26, 2009 Subject: Updated Criteria Pollutant Ambient Air Dispersion Modeling Unit 3 Project Pope/Douglas Solid Waste Management Facility Air dispersion modeling was completed for the Pope/Douglas Solid Waste Management Facility for criteria pollutants. Initial air dispersion modeling was submitted to support the Air Emissions Risk Analysis and Environmental Assessment Worksheet for the Unit 3 project in April Pope/Douglas has decided to increase the stack height of the existing Units 1 and 2 stack, SV001. The updates to the modeling and predicted concentrations are described below. Unless otherwise noted, all other air dispersion modeling inputs are consistent with the earlier air dispersion modeling for the project. Modeling Updates The updated modeling uses a proposed stack height of 105 feet for the existing SV001 Units 1 and 2 stack. This stack height increase reduces the maximum predicted concentrations, improving air quality near the facility. The modeled stack parameters are shown in Table 1. Source Table 1. Updated Stack Parameters UTM Coordinates Base Exhaust Stack Elevatio Temperatur Height n e X (m) Y (m) (m) (m) (K) Exit Diamete r (m) Exhaus t Velocity (m/s)

138 SV001 (Units 1 and 2) SV004 (Aux. Boiler) SV015 (Unit 3) Road1-315,826.4 Road4 1 through 315, , ,082, , ,082, , ,082, ,082, (releas e height) NA NA NA 1 Paved roadways were included for PM 10 and PM 2.5 modeling as four area sources.

139 Wenck corrected the station description in the meteorological data modeling inputs. While the station description is not used by the model, the station description was incorrect and confusing in previous criteria pollutant modeling runs. This change does not affect modeling results. The LEADPOST EPA program was used to identify rolling 3-month lead concentrations rather than the Excel calculations submitted previously. While the LEADPOST program provided the same results as the manual Excel calculations in the earlier modeling, the LEADPOST program results are easier to duplicate. Modeling Results Estimated criteria pollutant ambient air concentrations surrounding the Pope/Douglas facility are shown in Table 2 below in comparison to the National and Minnesota Ambient Air Quality Standards. The Pope/Douglas modeling demonstrates compliance with all ambient air quality standards after construction and operation of Unit 3. Averaging Period Table 2. Pope/Douglas Predicted Ambient Air Concentrations Pope/Douglas Background Total Modeled Concentratio Ambient n Impact Concentratio n (μg/m 3 ) (μg/m 3 ) (μg/m 3 ) National Ambient Air Quality Standard (μg/m 3 ) Minnesota Ambient Air Quality Standard (μg/m 3 ) PM Hour Average Annual Average PM Hour Average Annual Average 4 1-Hour Average SO ,300 3-Hour Average ,300 1, Hour Average Annual Average NO x Annual Average

140 2 1-Hour Average 5 8-Hour Average 5 3-Month Average (Rolling) CO ,400 4, ,000 40, ,300 2, ,000 10,000 Lead High sixth high concentration over the modeled period 2 High annual average concentration 3 98 th percentile concentration 4 High 3-year average concentration 5 High second high concentration for an individual year 6 These Minnesota Ambient Air Quality Standards have not yet been updated with the revisions to the national standards. Wenck will contact MPCA to submit updated electronic modeling files through a file transfer from a Wenck ftp site. ATTACHMENT 4

141 Criteria Pollutant Air Dispersion Modeling Analysis Pope/Douglas Solid Waste Management Facility Alexandria, Minnesota Wenck File # Phase 23 Prepared for: POPE/DOUGLAS SOLID WASTE MANAGEMENT 2115 South Jefferson Alexandria, MN Prepared by: WENCK ASSOCIATES, INC Wooddale Drive Woodbury, MN (651) April 2009