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2023-02-07 CC Agenda - Public Communication related to Hyperion #3FILIBIL IC COMM J III: AD I IFnILATE E) TO li IYP� L:MO a Harada, Patricia° From: Weaver, Tracy (City Clerk) Sent: Thursday, January 26, 2023 10:07 AM To: Harada, Patricia; Sandoval, Lili Subject: Fwd: Another sewage spill (1-25-2023)- Public Comment, Case No. 1212-40 (Hyperion Order of Abatement) Attachments: image0 jpeg; Hyperion Air Monitoring Violation (3).pdf Please post Tracy Weaver City Clerk Begin forwarded message: From: Corrie Chitlik <corriezupo@gmail.com> Date: January 25, 2023 at 9:06:19 PM PST To: clerkofboard@aqmd.gov Cc: "Boyles,Drew (Mayor)" <dboyles@elsegundo.org>, "George, Darrell" <dgeorge@elsegundo.org>, "Sassoon, Elias" <esassoon@elsegundo.org>, Michelle Keldorf <michellekeldorf@gmail.com>, Tracey <tmillerzarneke@elsegundoccb.org>, Ryan Baldino<baldinoforelsegundo@gmail.com>, "Nicol, Scot (Council Member)" <snicol@elsegundo.org>, "Giroux, Lance (Council Member)" <Igiroux@elsegundo.org>, "Pirsztuk, Carol (Council Member)" <cpirsztuk@elsegundo.org>, "Pimentel, Chris (Mayor Pro Tem)" <cpimentel@elsegundo.org>, John Pickhaver <johnpickhaverjr@gmail.com>, Citizens El Segundo <elsegundo.cleanair@gmail.com>, Sarah Meyer <sarahmeyer426@gmail.com>, Kyle Wheeler <kyleburtonwheeler@gmail.com>, Avery Smith <asmith@elsegundoccb.org>, Mike Lewis <fml@wst2nrg.com>, Julie Stolnack <esnoitall@yahoo.com>, vzupo78@yahoo.com, Lisa Jacobs <Ijacobs@scng.com>, Rad <Rad.Nowroozi@sen.ca.gov>, Jessalyn <JWaldron@bos.lacounty.gov>, ALL ELECTED OFFICIALS <ALLELECTEDOFFICIALS@elsegundo.org>, Senator.Allen@senate.ca.gov, mhaynes@aqmd.gov, "Bates, Portland" <pbates@elsegundo.org>, karen.bass@lacity.org, Barbara Ferrer <BFerrer@ph.lacounty.gov> Subject: Another sewage spill (1-25-2023)- Public Comment, Case No. 1212-40 (Hyperion Order of Abatement) Hello, We had another sewage spill and I am VERY CONCERNED. I wasn't able to listen to todays AQMD hearing, but I hope there's urgency to get LASAN District to repair and maintain their equipment. We are on year 3 of continuous LASAN District negligence. -Corrie Zupo Sent from my iPhone On Jan 11, 2023, at 11:12 PM, Corrie Zupo <corriezupo@gmaii.com> wrote: Hello, I would like to re -submit this entire email thread as a public comment and include my updated attachment. My updated attachment needs to be provided to the Hearing Board ahead of time since it includes screenshots of scrubbed H2S exceedances (note that H2S limits were last undated in 1969, and USC is actively studying the City of Carson and El Segundo, so regulators have updated scientific data to hopefully update health and safety limits), potential pollutants of concern for fenceline monitoring, TO-15 testing recommendations during equipment breakdowns, emails on equipment mismanagement from violation P73348 (issued on 12/26/2022), and historical context on compliance monitoring mis-management. I do not plan to call into the Hearing since it's during working hours. I also request that the Board please be given all the City of El Segundo's comment letters (dating back to early 2022). These letters nicely summarized the needs of our community with common-sense solutions. Thank you and best regards, Corrie Zupo On Tue, Nov 29, 2022 at 3:23 PM Corrie Zupo <cordezam o grnail.com> wrote: Hello, I would like to add to my October 28th, 2022, public comment submittal for the upcoming December 15th, 2022, Hearing Board. I wanted to clarify that the CARB H2S limit is 30 ppb, but I do not agree with this archaic limit. It was established in 1969 and has not been updated since. The World Health Organization (WHO) uses a lower limit of 20 ppb. Our community generally starts smelling H2S around ten ppb. USC is activel studying the health impacts of long-term H2S exposure since there's limited research on residential exposure greater than a year. I want to be clear that 30 ppb is too high, and we start experiencing acute symptoms around 10 ppb. I also wanted to note that my understanding is Hyperion did a 24-hour TO-15 VOC sampling on September 27th. I can not find their lab report in the FIND hearing board weekly status reports (Facility ID 800214). The public should have access to this report to ensure that the flow was indeed for 24 hours and that the reporting limits were below the air toxic thresholds. If the reporting limits are above the air toxic thresholds, the lab will report non -detect when in fact, there could be an air toxin present. The source testing protocol should also be made public. Under SCAM M' D Rule 14012, the District can ask a facility to prepare an Air Toxics Inventory Report, Health Risk Assessment, or a Risk Reduction Plan. I think it's unclear to the public the extent of chemicals being dumped on us every time the facility has an operational upset (which is frequent). There's a focus on H2S, but other chemicals are transported and mixed between the liquid and gas phases of transport. VOCs vary in their degree of volatility with factors such as water surface area, temperature, turbulence, concentrations, and retention time. Is there a dig to understand our health impacts from this mismanaged old facility? References; • htt : www„clan t_eeze.corru 2022 11 2 use -re earclier-iookin -atM impact. ot-hydrogen-sulfide-on-el-Segundo-residents • http:JIwww.a md. ov docs default -source rule -book ed N rule- 1402. df?sfvrsn=4 • htt s: www.e a. 'ov sites default files 2015-08 documents i105. df Best regards, Corrie Zupo From: Corrie Zupo <corriezu o ma'ILcom> Sent: Friday, October 28, 2022 8:23 AM To: clerlofboard a md. ov Cc: mha es a md, us; Boyles,Drew (Mayor) <dbo les else undo.or >; Darrell George <d eor e else undo.ur >; Sassoon, Elias <esassoon else undo.or >; Michelle Keldorf <michellekeldorl° mall.com>; Miller-Zarneke, Tracey <turnillerzarneke else undoccb.or >; Ryan Baldino <baldinoforelse undurraon>; Nicol, Scot (Council Member) <snicoll eliseg;undo.org>; Lance Giroux <I iu°ou.x eNse undo.or ?; Carol Pirsztuk (Mayor pro tem) <c irsztuk else undo.or >; Pimentel, Chris (Council member) <c imenttel else undo.or >; "ohn ickhaverJR rnall.com; Citizens El Segundo <EISe Lando.cleanair mail.corn>; Sarah Meyer <sarahrne er42 mail.com>; Kyle Wheeler <k leburronwheeler mall.com>; Avery Smith <asrnitliellse undoccb.ou° >; Mike Lewis <fml@wst2nrg.com>; Julie Stolnack <esnoitall ahoo.com>; vzu o78 ahoo.corn; Lisa Jacobs <I albs@sc >; Nowroozi, Rad <Rad.Nowroozi sen.ca. ov>; Waldron, Jessalyn <JWaldron bos.lacount . ov> Subject: Public Comment, Case No. 1212-39 (Hyperion Status Update for Modification of an Order of Abatement) Hello, I am a concerned mom and resident of El Segundo. I have provided numerous public comments on Hyperion, and I have attended all the previous Hearing Boards (I lost track of how many have occurred since 7/11/2021). 1 have also previously waited 4+ hours to make my comments, but at this time, I can't keep missing time away from work and my family to call in. Please include this email and attachments as a record of my public comment. I would also appreciate it if the Hearing Board received a copy of my email and attachments ahead of time. From my experience, the Hearing Board is not provided documentation ahead of time, and they base their decisions on presented information on the day of the hearing. I do not find this fair to the public since we are all volunteering our personal time to this health and environmental crisis. I am starting to lose trust in the processes and systems in place to protect our communities. The H2S monitors were installed in late August 2022. Since installation, there have been five (5) exceedances of 30 ppb on 8/27/22 (-140 ppb, the website now says "no data for this timeframe"), 8/30/22 (31.2 ppb), 8/31/22 (36.3 ppb and 43.5 ppb), and 10/19/22 (34.1 ppb). H2S is an air toxic according to MCA MIS Rule J401, page 19. Since 9/8/2022 (last Order of Abatement), there have been 11 additional Notices of Violations (NOVs). There is a total of 68 violations since 7/11/2021. We are experiencing long-term exposure to H2S (and over pollutants of concern), and El Segundo is a highly dense family -oriented community. Weekly hearing board updates are all 18 pages long with the same repeated updates. Can the updates please include tracking progress to completion of the John Zink Hamworthy Combustion and George T. Hall Company flare inspection and comprehensive evaluation report submitted on 6/29/22, tracking progress to completion of the Brown and Cadwell Implementation Plan submitted on 9/24/2022, and lastly, tracking progress to completion of the Los Angeles Public Works Report of the Ad Hoc Committee dated 2/11/2022. Can the hearing board updates please include the source test protocol for the flaring and for the TO-15 (determination of volatile organic compounds), also please include the actual source test reports. At this point, all confidence in the community has been lost, and we would like these protocols and reports made public. It is tedious to have to keep doing public record requests for this information when it can simply be put in the documents tab of Hyperion's FIND page. Lastly, please review my attachments with referenced links of proof. I have put a great deal of time into information gathering, and the information I am attaching has not been included in previous Order of Abatement discussions. Specifically, I have attached Violation P72978 issued on 2/29/2021 for a 2/19/2018 air monitoring failure. This is a cana in the coal mine as.it demonstrates a clear lack of gLoper emission monitoring 3 years be ore the 711112021 soill. My attachment also includes 5 exceedances for H2S. Thank you, A concern mom (aka Corrie Zupo) As you know, schools, businesses, and public offices are closed and/or imposing other restrictions amid the outbreak of COVID-19 (Coronavirus). Please be advised that PARRIS Law Firm is taking proactive measures to safeguard the health and safety of its employees, their families and our communities, by working remotely. 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Thank you. lilttblrcllealtli,l,Af"ottnly.gov Paceboti�k.ct inll.,A�Pulalicl3ealth For Immediate Release: January 25, 2023 Beach Closures Avoid Water Contact and Wet Sand LOS ANGELES — The Los Angeles County Department of Public Health has issued beach closures for the following areas due to the release of approximately 64,000 gallons of untreated sewage: • Mother's Beach in Marina Del Rey • Venice City Beach, %s Mile North of Marina entrance • Dockweder State Beach, %z Mile South of Ballona Creek Public Health officials are advising residents or visitors planning to visit Los Angeles County beaches to avoid contact with ocean water and wet sand in the areas noted above. The cause of the sewage discharge was a blocked [Hain line which resulted in sewage entering the storm drain system at the corner of Admiralty Way and Palawan Way. The blockage has been cleared at this time, and the immediate area cleaned. The Department of Public Health will conduct water sampling daily, and the closures will remain in effect until Public Health receives sampling results indicating that bacterial levels meet health standards. Recorded information on beach conditions is available 24- hours a day on the County's beach closure hotline: 1-800- 525-5662. To view the map of impacted locations and for more information, please visit: pu�RGm ll°:V�it h.t a���u��w..titb�°`l::lachl. The Department of Public Health is committed to promoting health equity and ensuring optimal health and well -being for all 10 million residents of Los Angeles County. Through a variety of programs, community partnerships and services, Public Health oversees environmental health, disease control, and community and family health. Nationally accredited by the Public Health Accreditation Board, the Los Angeles County Department of Public Health comprises nearly 4,500 employees and has an annual budget of $1.2 billion. To Iearn more about the LA County Department of Public Health and the work they do, visit Pu ilia• leatIli, LA ()uubty,gov, and follow Public Health on social media at ��tid�a°r.ca.�aroa�t..�"tl�"arab�lo�°lia�rl�h, lio^l�K�ual, �:�rmn;l_��a'�duh&ia:lls�w�Bttl� _and va�ahCaaba:.a^a�gau°1�Al��l�Iv�:I�r�ixl�. Los Angeles County Department of Public Health works to protect health, prevent disease, and promote health and well- being. Hyperion Air Monitoring Exceedance Log Summary: Part 1 of this document includes screenshots of the H2S exceedances in 2022 and a potential list of pollutants of concern for fenceline monitoring (pulled from Hyperion's air permit). It is important to note that H2S monitoring didn't begin until late August 2022. It is also relevant to note that the 812712022 exceedance over 140 ppb H2S is now no longer available to view to the public on Hyperion's monitoring website. The 1212512022 exceedance of 77.2 ppb H2S has also disappeared. I was able to screenshot the exceedances before they were scrubbed from the record. We as a community also want to know why only H2S is monitored along the fence line. Hyperion's air permit list 20 pollutants of concern (listed below in Part 1). TO-15 testing was recently done during a normal operating day, but normal operation is not representative of our ambient air conditions during breakdowns. We want to know what the TO-15 results would be during a breakdown. Part 2 of this document questions why public nuisance violations were given on 12/26/2022, instead of a failure to comply with Permit No. F66769, A/N 424861, condition #2 (operated and maintained in good operating condition at all times), and condition #4 (no raw gas escaping), condition #6 (checking pressure drop). Please see the email thread from Hyperion outlining the negligence. Part 3 of this document outlines Violation P72978 issued on 2/29/2021 for a 2/19/2018. This violation was everyone's warning that Hyperion's air monitoring equipment was not properly been maintained since 2018. Reference Information„ • Hyperion Monitoring Website: LINK • Hyperion violation count from 7/11 /2022-1 /22/2023: 70 • Violation P72978 issued on 2/29/2021 for a 2/19/2018 air monitoring failure: LINK Hyperion Air Monitoring Exceedance Log Part 1: 1-12S Exceedances & potential air pollutants of concern Pollutant of Concern List from Hyperions Permit. Why do we only have fenceline monitoring for H2S? of one of the carbon vessels. The samples shall be speciated and shall include be limited to the compounds listed below: 1. Ben7eue 2. Carbon tetrachloride 3. Chloroform 4. t:hlorobenxene 5. Dichloroben=ne 6. Ethylben7gne 7. Ethylene dichloride 8. Methylene chloride 9. TetrachloroeffivIene 10, styrene 11, 1,IJ-Trichloraethane 12. Trichloroethylene 13, Toluene 14. Vinyl chloride 15. Vinylidene chloride 16. Xylenes 17. MTBE 18, Total reduced sulfur as HxS South Coast Air Quality Mana4gernent District Section 21865 Copley Drive, Diamond Bar, CA 91765-4178 Facaky i Revisice FAC3,11,11TY PERMIT TO OPERATE 19, Total non -methane hydrocarbon as CH¢ 20, Ammonia 8/27/202Z Hyperion Air Monitoring Exceedance Log 125 CL CL 0 100 m CL 75 50 25 0 27. Aug 12:00 PM The data are preliminary and for informational) purposes only. Data are subject to change following quality control and auditing. Potential Sources Hyperion Air Monitoring Exceedance Log 8/30/2Z Hyperion Air Monitoring Exceedance Log ilea L c C d L I r I 08/30 North Monitoring Statid """ 2S (P"'Pfl 1-Hour Average 100 ff Q 60 0 Fn N a- U) 40 20 Historic � 08 30-2022 11:00 AM: 0 40 12:00 PM 03:00 PM 06:00 PM 09:00 PM The data are preliminary and for informational purposes only. Data are subject to change following quality control and auditing. Potential Sources IPefi oleG..jrn Yt rie.. e mate ir. II....a n df ii C U 'o i c n i c IH O t S iD it i ino s Site deli ned by I...iylperion Water Reclamation Pliant Hyperion Air Monitoring Exceedance Log 8/31 /22: Hyperion Air Monitoring Exceedance Log Dail? Locatk)ri Monitoring 08/31 North 100 :m a �- 60 0 40 Ca 20 0 31. Aug (F' I �) 1-Hour Average 06:00 AM 12:00 PM 06:00 PM The data are preliminary and for informational purposes only. Data are subject to change following quality control and auditing. Potential Sources � Itow �G 1BARS 1 1 1 1i I it I e t r ollI iu im Waste Water a in f ui Ili Vo Ic __. :.�mu�mliim:; IIV...i�u�ll� ��u::)u�iunmi, Hyperion Air Monitoring Exceedance Log 10/19/2022: 10/19 North Monitoring Statid H2S (PP ) 1 -Hour Average WIN M CL 60 0 01) al 40 cu a_ cl 0 - - — — -------- 40 t-%.-+ f%a.nn ARA ORA r%r-.nr% ORA Site designed by flypef,ion Water Ikeclarnai.Jon Kant Hyperion Air Monitoring Exceedance Log 12/20/2022: () Nia i....ocatioire 12/20/2022 Central Monitoring b 100 60 0 oa m a_ W 40 ca a 20 0 20. Dec S (PPB) 1-Hour Average 06:00 AM 12:00 PM ,+II-Wo:181 The data are preliminary and for informational purposes only. Data are subject to change following quality control and auditing. Hyperion Air Monitoring Exceedance Log 12/25/2022: Date Location 12/25 60 Central Monito, H (,r,% P B) 1-Hour Average 100 [EEO C. CL C: OV .2 C. 0 40 a_ RE 0 25. . " � � WW-%F%f F-.. I - %, %, I ... Home Watch Marketplace Groups RA 11��t i f a 11 t l 1[I I' VS Menu Hyperion Air Monitoring Exceedance Log Part 2-. Violation P73348 was issued on 12/26/2022 for public nuisance under Rule 402 The activated carbon filter was spent and this was properly due to not monitoring the pressure drop and not having extra filters in storage. Besides a Rule 402 violation, why isn't this also a violation issued under Rule 204? Email from Ms. Durrell on 12/23/2022: On Dec 23, 2022, at 2.20 PM, Tonya Durrell ejqUy4_dq(jq.lj&XftgW> wrote: Corde, Thank you for your patience as we awaited information from our vendor and AQMD on this issue. The change out of the saturated activated carbon is scheduled December 26, 2022. After the change out, the activated carbon filter will be placed online. Please lot me know if you have any other questions. Very best, Tonya Tanya DurreU Pul[Ak iinfonrnatkwi Diwector LA Sanitation and Envivoiniment Cornimunky Services Group Phone:: 213-485 5303 Email: web: 24 hour Customer Caren J.1002LUMR LLLJ�-;10 - .. On Dec 21, 2022, at 10*39 PM, Tonya Durrell cLoqyAdurreI@j ad , "o> wrote, Good evening all, In response to the recent inquiries regarding odor complaints at Hyperion, please note that on 12/20, Hyperion staff became immediately aware of d near the south end of the Primary Battery D., near the El Segundo side, The unit was installed to augment the Primary Centralized Scrubber System- Even without the activated carbon filter, the main system— Primary Centralized Scrubber System, should work independently for most of the collection and treatment of the foul air from the primary treatment area, Typically when an activated carbon filter is used up or saturated, it will no longer work properly. The saturated activated carbon will have to be replaced before the filter resumes its operations. Yesterday, 12120/2022, the operations staff, in response to the high 1-12S reading measured at the Central Monitoring Station, determined that the activated carbon filter was no longer working effectively. The unit was immediately secured. Hyperion staff are wormng on replacing the activated carbon and placing the filter back online. Meanwhile, the main, Primary Centralized Scrubber System, is or has been online doing its function as usual. As part of our communications protocols, this information was provided to the El Segundo Public Works Director last night when the event occurred. Thank you, Tonya Durrell Public Information Director LA Sanitation and Environment Community Services Group Hyperion Air Monitoring Exceedance Log PERN11T TO OPERATE Permit No.F66769 AN 424961 Equipment Description: fligh Purity Oxygen Reactor's Air Pollution Control System No. 1, consisting of. I. Two Activated Carbon Vessels (one standby), each with a 6' Dia. x 3' H. darbon bed containing US filter Midas OCM carbon. 2_ Two )exhaust Blowers (one standby), each 10 11P, 1080 cfm maximum capacity, venting the high purity oxygen reactor influent channels. Conditions: 1. Construction and operation of this equipment shall be conducted in compliance with all data and specifications submitted with the application under which this pemi t is issued unless otherwise: noted below. [Rule 204] This equipment shall be properly maintained and kept in good opentiug condition at all times. 3. [Rule 204] 1 This equipment shall be operated and maintained by personnel properly trained in its operation. [Rule 101, t, The exhausi fan associataxi with this equipment Shall not be operated unless it is vented to the carbon vessel described in this permit. At no time, the operator shall allow the escape of raw gas into the atmosphere_ [Rule 402]] 5. A pressure gauge shall be installed to indiuite, in inches of water colunm, the pressure drop across the carbon adsorber- [Rule 4021 tre, The pressure drop across the carbon adsorber shall not exceed 5.0 inches of water column - [Rule 4021 Part 3: Violation P72978 was issued on 2/19/2021 for a 2/19/2018 air monitoring failure This violation was issued on 2/19/2021 was the cannery in the coal mine that Hyperion was negligent in ensuring our community wasn't being poisoned. I mentioned my concern with this specific violation to Tim Dafeta (Hyperion Plant Manager) on July 21, 2021, via email and phone call. I have been vocal for months that Hyperion has been poisoning our town with not just H2S, but with criteria pollutants (ex. NOx). I created a petition requesting the SCAQMD do a pilot Hyperion Air Monitoring Exceedance Log study on our air emission, similar to the study that was done in Boyle Heights: LINK. I emailed this petition with nearly 1,000 signatures. We are all concerned and we need help holding Hyperion accountable. Facilloy Inforaim adem Business Name Facility ID LA CITY, SANITATION BUREAU (HTP) 800214 Violatkin Informadon VOW$I)n (*vvtPvmw M02(cXl) Figure to operate a TITte V kpafity Polrvrin, Lt Permit F.388916 Coed! 6, M PennR G15556 Cond 5, 7; NIMR G15557ConJ S, 7; Pea a G212.428 Comd 5n 7, B� Nmid G15554 Cord 5, � 8a Nnonit G2232%Cood 6,. 29, 11, Pernut 64 Ml 7 Cciml 7, 1 %g [ od ") 'v k N') Sun I + ", Mi 4, T wm 1114n&ng "loom 1. Hyperion Permit: LINK Address 12000 VISTA DEL MAR PLAYA DEL REY, CA 90; Equipownt Desc6pVon Pennit G48628 iEa nd 1, 15"nift G48628 Con Pon* RN20469 Cand 22. ftnnit F66769 COW 212 X2.) uut maintArdng CIMS in good wwkii 2181(b)(4KC) no RATA every.12 unonths Hyperion Air Monitoring Exceedance Log Responsible Person who's ultimately accountable but he no longer works for Hyperion: LINK SECTION A: FACILITY INFORMATION LEGAL OWNER WOR OPERATOR., LA CITY, SAWITATION BUREAU (HM LEGAL OPERATOR (if different than owner); EQUIPMENT LOCATION- 12000 VISTA DEL MAR PLAYA DEL REY, CA 902934504 MAILING ADDRESS: 1200D VISTA DEL MAR RESPONSIBLE OFFICIAL, ENRIQUEZALDIVAR DIRECTOR AND GENERAL MANAGER TELEPHONE NUMBER: (213)495-2210 CONTACT PERSON: T1MEYIN DAFETA TITLE; PLANT MANAGER TELEPHONE NUMBER: (310)64&5555 TITLE V PERMIT ISSUED: Auskig 27,2019 TITLE V PERMIT EXPIRATION DATE.- August 26, 2024 TITLE V RECLAIM YES NOx: NO sox; NO CYCLE: o ZONE- COASTAL As the Designated Tille V Respoasibe Okd for the above company, I hereby designate and assiqn the dirties of Trifle 'V Responsbe Citkial to the person or persons fisted Woc Each person listed Now qualifies as a Tide V Responsdal in accoMance A AMID Rulle XOO(b)(29)*. TM delegation Mudesa) Otten reports far die fdow-upvarbally reported of Ernergency,Breakdown„ and Excessssewe Emission Deviations (AQMD Form 500-114 b) Comphance Plans and Qaali% Improvement Plains (ACIMID, Form 500-U); c) te Me V Seri*AnnualftoOng Report (AQMD Form SSSAft); d) the T&V Annual CompliaAce Certification (AWD Form l 90-ACC): and e) any and all perrNt appticalion form for fis faidlo. Hyperion Air Monitoring Exceedance Log 1.2. Violated Permit Condition Locations nc following is a list of all Peamiis io CansuucNOpemte end Permits eu Operate At Utis facility: 56 528 8 � 649645 { Std042e Twk lkQU04AS ammonia sollnion 0 90 5s1em tJxidizer Tanks mmmm 57T8B4 ............... ,,, 64S5F7.. ................. __. Odor Control System — Jnfluent and Headworks 44 579356 G42943 Mier, 62 MNIATUft, digester gac & netutnl gas 103 726 R-G441fl4 ICE }590lIP, stationary, enwr6ency electric generator. 10 1.3. 3002(c)(1) Failure to operate a Title V Facility Permit: LINK c Duty to Comply (1) A person shall construct and operate a Title V facility and all equipment located at a Title V fiacility in compliance with all terms, requirements, and conditions specified in the Title V permit at all times_ Hyperion Air Monitoring Exceedance Log 1.4. Permit F66769 Cond 6 (pg. 17) (L 11W prenuve tdrupn acwss The scirubber shall xuea exceed 6A inches of wamer cohx=. 1.5. Permit F66769 Cond 10 (pg. 17) p CI,, .,fie pm.,ssnare uiM1t!wm:sifiai acmuiss the wiru:ubbew and Vie rwhan xstis adwr, scurAudaunnlg Aso lnntionm Rise to simtire, mind the n,,,o br;w rnl iaa n m:ui` @uyrpmuwl, zi;illfAe� at tfte vidnr wa siusill be wwssiunuwl and mco. uvierd am ItmM t Kv, a day, 1.6. IPerrnot G15556 Cond 5 (pg.. 1 ) 5. 'The, preamm. xdmT ;across Ow gm.abIber shall nap exceed 6A iwhes of waw.T copuuxuun« daily avcwsr 1.7. Permit G 15556 Cond 7 (pg. 19) 7. A p-m-we n.upz iinm lczmimo@I� psilp shall 1w, ianmrsii d ud p ito;wrpy nasimatmm ned at she dischugc Qpaura rm cadh urrurru:uuxpada ni ptnanapn d'pann eswlia sci niIiA.0 II% Dmnai:ng rropLiunt.u.on OrI. ., air qau Elution wntnyl systeamw„ shit 11m a. swain limdi in d ling^ cart Saaxge sha li Rae m bnlratined at km t:lliaaux runt ca,pu.usp' to 5 puspt:� deally aveaa gig, 1.8. Permit G15557 Cond 5 (pg. 21) 5. The ptesswe drop acposs Qlk scrubber slant[ noQ moved 6.4 inches of warr codaouxi i, dR. Hy tu+wrea'wappc. [dtxale 2Ry�� 1.9. IPerm!� -t G 1555.7 Cond 7 (pg.. 22) 7. A pairessrarc gouge indi :nUng Og •shall be insWlwl and IKaWly rnsirwakw d of the 6scharge Aline ofCiac r. t>L`circupi2ion p twmpr for r^ suubba, Duning opaew-amion or dic adxpxAlutiorrn r ntn&arap wystewn, the pmssurr 9rxsdicaP l by ewlu p agge shall be, inainlained. at V w thm oir al" tu:x 23 psi& a'6ruipy average. 1.10. Permit G22328 Cond 5 (pg. 23) 5, 'The pmultm dtop wrote .Ru scrubbut-shall not cxccW 4.0 inches urwmtiderr w1lumn. If>< We 204] Hyperion Air Monitoring Exceedance Log 1.11. Permit G22328 Cond 7 (pg. 24) A pimum jrmgm indkatluudd p,.UII!T, &MU k finslaRNI AW propCAY fn3int%bWA] iA dir, &WOWgi- hi.ne Ofeach rn6irWzdqapu.uqi rer cach.wnibNt, During opexilmama of rheakpolladipn coaRrollsymem, ON jpmsillm lndicaled b cwdI-h puge sholl he at. lewt 25 psi& 1.12. Permit G22328 Cond 8 (pg. 24) a.. A pII wWORF ifficluiidudl he imssafled mW 1piroprwIly mabkWx-Od to indicake Or, PH awl ORP vahm of the m.-mbbiii-lig solution ined iin 4mch uwrukbha% 'The IpH of kh,am-yubbing sobaion AM he maintanilIxA, at 9.0 or ligheiir" ptule 20411 1.13. Permit G 15554 Cond 5 (pg. 25) 5, TIw W.tsspre, drop wirms each scrubber Towi-ir shaIIII irmik r.,r.Lvcd 9 incks of w3w, dailly avcrwge [Ruk 204] 1.14. Permit G15554 Cond 6 (pg. 25) T1wassirameuvtt naiilnvim ofquilftm cmpound% calrAdmcdas hydmgen suffide, vi 4e oudet to the atmo,pNire of&wv,-Mrber Rysum shaU be uarueasured marecus-ded Iiily accord.ing, to a naethod approved lrw the South Cmist AQR011. "Be froqui!nicy ofthrmrsmarmerit nwy be, r1tangrd witb a wriffca approval fiom the Smsdi Cow AQVI), [Ri*204] 1.15. Permit G 15554 Cond 8 (pg. 26) 8, A pm. sure gauge indlocafing pgig shaB be In. Wlhuf and pcq:w.dy mnrrnita nod w. Iht diwim.rF. line of rich irm iwilLWun pump fut each saubber lwwr, Dwring opmfion of fts a:luipnmvm, the pirmurr indioded. by ear-h Zsuggr sh011 raw excved 25 t.w.ft, daily average. [jkluW 7041 1.16. Permit 22329 Cond 6 (Pg. 53) & 1111C Coll-weillizalliou of hydrogen su] fide in da wchwmashmll k messwed and iiewirded at IeWA once each day. [R4Die 2o,q 1. 1 T. Il erront 22329 Cond 7 (Pg, 53) hr° Downwirs-, ffidicafing mime scrulbbills F0111.11don finvyl-mrs in 01.0inq 1pRT Minute."] be ingalled fin =h sembbing sage, Themrubbing 90hiftion flowrabm rJwall he inankowd awA riumirded dafly I[We 204] Hyperion Air Monitoring Exceedance Log 1.18. Permit 22329 Cond 9 (Pg. 53) 9'. A pil indicator rmd im"i tralkysballi ix iMMUcd swW w.maintain. W for =hmage of the =.0iron m. , The pH of the wnWAing solusions, stioll be detamined during dw, scrubber opdmizadon wirks andaW11 be verified with Ix-rformance tirsLs. The pH of 11he smubbing sa➢udcjins sM[ be vionhwrd and gircorded daily. [Ruk-2041 1.19. IPeirmiit 22329 Coirid 11 (lPg. 53) 11. DiffcTrWial Ipm-w-we gages indic.01ing the pressure d4Tp acmm pukinp, and sipinI glik-mm for VIVAU81 MI4a810firIg oi-pab:king shafi beinstakd and Nnanatained frwwawh stw.m of the scirubbms.. The pi. king -Aha011 be visuailly inoniku-iod for adequate wrming mid pwiWr cloggiirki; on chilly basis-, Thr prr.movir drop amss, tfic p"ing sbell be monhored as rircord W dailly.. [P,iijle2O4j 1.20. Permit G48627 Cond 7 (Pg. 96) 7 Of ➢uyr Du .1c (�'6) at Ehe, ouidet to the awwsjj4xqr,- of ewhi odor girn nulfig LI J conizah",cm exhanst stncks2wi D tx rnin-nutred Al'shill'? .' crAw-hilw1ric INJ10:11cs. Rnalywils, am viith)tv "!gym Uth Cciak AKN41D appmwO vaeltivads and recordiul, as knm awe, cacti day, (III ule AWJ 1.21. Permit G48627 Cond 15 (Pg. 97) r, i. Until Conmxtilln i;-C=nP1r.'trA' thr Dpemlorshmll keepadm[ly kig ofop eratingpiamrinietews.gaff" the sclubhv% QW-L WF-2, HWK, 1WIWK-2, HIWK-3) and carbon adwrbem (CAT IF-i, CAWNF-2 or CA'ir-114F-3) indlAng, btirt irwit iiinited to, 0* premurr drop in ijx-tw* ofwaleir ofdw, diwbmge pmauzeafffic irwirce.66anpionp inr.m.� dwpHauk' ft, Rwirvulailing 9djution the godfigim hypociacrim-mW caunic feed rates, Ehe diiff6tvatiA press we scroas endi scnxb1vr (INF- 1, DW-2, I MK- 1, ITWK-2, 14WK-3) and each rarbon iidsorbrx (1C.AT-INF-➢, CAT IN F 2 or C.A'r-Wr,-�O, and Tfir owlet RA canmitsunwh in pllxnv., [ Rule 204.1