Document G6Ekq1RwVOpN3Xq9e2NrL0x1v
MEMORANDUM
SUBJECT:
CLEAN AIR ACT INSPECTION REPORT Perham Resource Recovery Facility, Perham, Minnesota
FROM:
Charles Hall, Environmental Engineer AECAB (MN-OH)
THRU:
Brian Dickens, Section Chief AECAB (MN-OH)
TO:
File, Perham Resource Recovery Facility, Perham, Minnesota
BASIC INFORMATION
Facility Name: Perham Resource Recovery Facility (Perham RRF)
Facility Location: 201 6th Avenue NE, Perham, Minnesota
Date of Inspection: 12 September 2024
EPA Inspectors: 1. Erin DuMontelle, U.S. EPA, Region 5, ECAD, AECAB, MI-WI Section 2. Charles Hall, U.S. EPA, Region 5, ECAD, AECAB, MN-OH Section
Other Attendees: 1. Brian Schmidt, Facility Manager
Contact Email Address: bschmidt@plmswa.com
Purpose of Inspection: Small Municipal Waste Combustor inspection
Facility Type: Small Municipal Waste Combustor
Regulations Central to Inspection: The North Unit is subject to the emission standards and other requirements in the Federal Plan Requirements for SMWC Units Constructed on or Before August 30, 1999 (hereinafter, the SMWC FIP). The South Unit is subject to the emission standards and other requirements in the Standards of Performance for Small Municipal Waste Combustion Units for Which Construction is Commenced After August 30, 1999, or for Which Modification or Reconstruction is Commenced After June 6, 2001 (hereinafter, the SMWC NSPS). The Minnesota Pollution Control Agency issued the current Title V permit on April 17, 2013. The Perham RRF applied for a permit renewal in September 2017.
Arrival Time: 0835 hrs CDT Departure Time: 1240 hrs CDT
Inspection Type: Unannounced Inspection Announced Inspection
OPENING CONFERENCE
Presented Credentials Stated authority and purpose of inspection. Provided Small Business Resource Information Sheet. Small Business Resource Information Sheet not provided. Reason: If this box is checked,
you must enter a reason such as "Not a Small Business," here. Provided CBI warning to facility.
The following information was obtained verbally from Schmidt unless otherwise noted.
Company Ownership: In June 2011, the Prairie Lakes Municipal Solid Waste Authority (PLMSWA) purchased the facility from the City of Perham. The ownership of the facility has not changed since then.
Process Description:
PLMSWA collects municipal solid waste (MSW) from residences, institutions, and businesses in Becker, Clay, Otter Tail, Todd, and Wadena Counties, Minnesota. The MSW is sorted through a material recovery facility to remove, among other things, large items, recyclable metals, and glass before the remainder of the MSW is fed to either of the two 100-ton per day municipal waste combustion units.1 The North and South Units consist of primary and second combustion chambers that vent to a heat recovery boiler, superheater, and economizer. The Perham RRF injects activated carbon to control dioxin/furan and mercury emissions and injects
1 Perham RRF operates at approximately 75 tons per day per unit.
Page 2 of 6
calcium hydroxide to control hydrogen chloride (HCl) and sulfur dioxide (SO2) emissions. The North Unit uses a single compartment pulse jet fabric filter to control particulate matter. The South Unit uses a four-compartment pulse jet fabric filter to control particulate matter. Each MWC unit is equipped with continuous emission monitors (CEM) for carbon monoxide, sulfur dioxide, and oxygen, a continuous opacity monitor (COM), and continuous monitoring systems to monitor the activated carbon injection rate, dry sorbent injection rate, steam load, and fabric filter inlet temperature.
TOUR INFORMATION
EPA Tour of the Facility: Yes.
Data Collected and Observations:
The SMWC FIP, SMWC NSPS, and the facility's Title V permit require the Perham RRF, among other things, to continuously monitor carbon monoxide (CO) and SO2 emission concentrations and opacity and to comply with their respective emission standards. During the inspection, the inspectors collected the emission concentration data which is summarized in Table 1.
Table 1. Summary of CO, Opacity, and SO2 Emission Data.
Pollutant North Unit Limit
North Unit
South Unit Limit
CO2
100 ppmV
07.7 ppmV
100 ppmV
Opacity3 010%
00.25%
010%
SO24
029 ppmV or 75% 21.0 ppmV
030 ppmV or 80%
reduction of
reduction of
potential emissions
potential emissions
South Unit 00.1 ppmV 01.22% 15.82 ppmV
The SMWC FIP, SMWC NSPS, and the facility's Title V permit require the Perham RRF to establish four operating limits during performance tests and to monitor and record the operating data continuously. The operating limits are a maximum steam load in pounds per hour (lbs/hr), minimum lime injection rate in lbs/hr, minimum activated carbon injection rate in lbs/hr, and maximum fabric filter inlet temperature in degrees Fahrenheit (F). During the inspection, the inspectors collected the operating parameter data which is summarized in Table 2. The records were taken at approximately 10:30 a.m. on September 12, 2024.
2 4-hour block average. The CO concentration is corrected to 7 percent oxygen. 3 6-minute average 4 24-hour geometric average. The SO2 concentration is corrected to 7 percent oxygen.
Page 3 of 6
Table 2. Summary of Operating Parameter Limit Data.
Operating Parameter
North Unit North Unit
Limit
Maximum Steam Load5
25,681 lbs/hr 22,806 lbs/hr
Minimum Sorbent Feed Rate6 126.67 lbs/hr 138.4 lbs/hr
Minimum Carbon Feed Rate7 3.8 lbs/hr
4.00 lbs/hr
Maximum Fabric Filter Inlet 396F
352F
Temperature3
South Unit Limit
27,715 lbs/hr 142 lbs/hr 4.00 lbs/hr 361F
South Unit
18,862 lbs/hr 154.9 lbs/hr 4.2 lbs/hr 329F
In addition to calculating the required averaging periods, the Perham RRF displays the current value and the 1-minute and 60-minute average values of the CO and SO2 emission concentrations, lime injection rate, activated carbon injection rate, and steam load. The Perham RRF also displays the 24-hour block average for CO, lime injection rate, activated carbon injection rate, and steam load. For opacity, the Perham RRF also displays the current value and the 1-minute and 60-minute averages. This additional information helps the control room operators recognize a problem more quickly than the required averaging time alone. For instance, if the activated carbon injection rate dropped to 0.00 lbs/hr, the control room operators would know that they needed to alert the maintenance staff to a problem in the activated carbon injection system.
The SMWC FIP, SMWC NSPS, and the facility's Title V permit require the Perham RRF to conduct periodic performance tests for dioxin/furan, cadmium, lead, mercury, opacity, particulate matter, and hydrogen chloride. Table 3 summarizes the results of the most recent performance test on each MWC.
Table 3. Summary of the Most Recent Performance Test on Each Unit.
Pollutant
SMWC FIP
Emission Standard8
Result of the
2023 Test on the North Unit9
SMWC NSPS Emission Standard
Dioxin/Furan 30 ng/dscm
0.014 ng/dscm
13 ng/dscm
Cadmium 0.040 mg/dscm 2.410-3 mg/dscm 0.020 mg/dscm
Lead
0.44 mg/dscm 1.910-2 mg/dscm 0.20 mg/dscm
Mercury
80 g/dscm or 85% reduction
1.9 g/dscm 85.9% reduction
0.080 mg/dscm or 85% reduction
Opacity10
10 percent
0.4 percent
10 percent
PM
27 mg/dscm 11.7 mg/dscm
24 mg/dscm
Result of the 2024 Test on the
South Unit
0.0034 ng/dscm 6.610-4 mg/dscm 0.0066 mg/dscm 1.3 g/dscm 96.0% reduction 0.0 percent 3.43 mg/dscm
5 4-hour block average. 6 3-hour block average. 7 8-hour block average. 8 Except for opacity, all emission standards are corrected to 7 percent oxygen. 9 Except for opacity, three run average concentration or emission reduction. 10 Highest of three test runs.
Page 4 of 6
Table 3. Summary of the Most Recent Performance Test on Each Unit.
Pollutant
SMWC FIP
Emission Standard8
Result of the
2023 Test on the North Unit9
SMWC NSPS Emission Standard
Condition 1
26.4 ppmV
29 ppmV or
90.3% reduction 25 ppmV
HCl 95% reduction
or 95% reduction
Condition 2
29.2 ppmV
94.5% reduction
Result of the 2024 Test on the
South Unit Condition 1 13.2 ppmV 98.1% reduction
Condition 2 24.3 ppmV 96.4% reduction
The SMWC FIP, SMWC NSPS, and the facility's Title V permit require the Perham RRF to submit periodic reports regarding deviations from the CO, opacity, and SO2 emission standards and the four operating parameters. During the inspection, the inspectors requested the semiannual reports from the second half of calendar year 2023 and the first half of calendar year 2024 and reviewed the reports after the inspection. Table 4 summarizes the deviations. In general, the opacity deviations were the result of monitoring problems such as a dirty monitor lens, and the CO were frequently the result of clink that was caught in a primary chamber's grates.
Table 4. Total Number of Deviations.
Pollutant or Parameter North Unit
2nd Half 2023
CO
1
Opacity
9
SO2
0
Steam Load
0
Sorbent Feed Rate
0
Carbon Feed Rate
0
Fabric Filter Inlet
0
Temperature3
North Unit 1st Half 2024
0 7 0 3 1 0 0
South Unit 2nd Half 2023
12 00 00 00 00 00 00
South Unit 1st Half 2024
1 2 0 0 0 0 0
Photos were and Videos were not taken during the inspection.
Field Measurements were not taken during the inspection.
RECORDS REVIEW
The inspectors did not review any records during the inspection.
CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility.
Page 5 of 6
Requested documents: In an e-mail sent after the inspection, the inspectors requested the following documents:
Activated Carbon SDS and mesh size if not in the SDS, Sorbent SDS and mesh size if not in the SDS, The executive summary and report body from the most recent performance test for
each Unit; no appendices, The 2nd quarter 2024 COMS Error Audit for each COMs, The report from the most recent RATA for each Unit, The 2nd half 2023 and 1st half 2024 semiannual reports, and The CEMS daily log for each Unit for September 12, 2024. Compliance Assistance: The inspectors did not provide compliance assistance. Concerns: The inspectors did not point out deficiencies or concerns during the inspection. DIGITAL SIGNATURES
CHARLES HALL Date: 2024.10.03 11:47:22 -05'00' Digitally signed by CHARLES HALL
Report Author:
BRIAN DICKENS Date: 2024.10.04 08:58:12 -05'00' Digitally signed by BRIAN DICKENS
Section Chief:
Page 6 of 6
APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log
Appendices Page 1 of 2
Facility Name: Perham Resource Recovery Facility Facility Location: 201 6th Avenue NE, Perham, Minnesota Date of Inspection: 12 September 2024
APPENDIX A: DIGITAL IMAGE LOG
Photographer: Charles Hall Camera: Olympus TG-6 #1 EPA Bar Code: SZ4061
File Name P9120025.jpg P9120026.jpg P9120027.jpg P9120028.jpg P9120029.jpg P9120030.jpg P9120031.jpg P9120032.jpg P9120033.jpg P9120034.jpg P9120035.jpg P9120036.jpg P9120037.jpg P9120038.jpg P9120039.jpg P9120040.jpg P9120041.jpg P9120042.jpg P9120043.jpg P9120044.jpg P9120045.jpg P9120046.jpg P9120047.jpg P9120048.jpg P9120049.jpg P9120050.jpg P9120051.jpg P9120052.jpg
Date and Time 09/12/24 10:32 09/12/24 10:34 09/12/24 10:34 09/12/24 10:34 09/12/24 10:34 09/12/24 10:34 09/12/24 10:38 09/12/24 10:38 09/12/24 10:48 09/12/24 10:51 09/12/24 10:57 09/12/24 11:02 09/12/24 11:19 09/12/24 11:19 09/12/24 11:20 09/12/24 11:25 09/12/24 11:26 09/12/24 11:29 09/12/24 11:30 09/12/24 11:33 09/12/24 11:34 09/12/24 11:34 09/12/24 11:35 09/12/24 11:38 09/12/24 11:38 09/12/24 11:38 09/12/24 11:47 09/12/24 11:48
Description of Image CEM System Overview Screen for North and South Units Screen Steam Flow to Bongards Creameries and Tuffy's Screen Steam Flow to Bongards Creameries and Tuffy's Screen #1 Combustion Unit Process Overview Screen Feed Water System for North and South Unit Screen #2 Combustion Unit Process Overview Screen Unit 1 Carbon System Detail Screen Unit 2 Carbon System Detail Screen Lime System Detail Screen Unit 1 Flue Gas System Screen South Bag House System Screen General System Log Screen South Unit undergrade and grates (Part 1) South Unit undergrade and grates (Part 2) North Unit undergrade and grates North Unit super heaters with vortex cleaners Lime System Room Magnehelic gauge for North Unit baghouse North Baghouse Unit bottom side North Unit Baghouse vent to stack North Unit sampling port box and stack opacity (left) North Unit sampling port box and stack opacity (right) North Unit sampling ort box with CEMS probe South Unit stack opacity monitor (left) South Unit stack sampling port box South Unit stack opacity monitor Components of the activated carbon injection system Supersacks of activated carbon on weigh feeders
Appendix Page 1 of 1