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)
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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
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50
25
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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
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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
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Hyperion Air Monitoring Exceedance Log
8/31 /22:
Hyperion Air Monitoring Exceedance Log
Dail? Locatk)ri
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08/31 North
100
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20
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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
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Hyperion Air Monitoring Exceedance Log
10/19/2022:
10/19 North Monitoring Statid
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Hyperion Air Monitoring Exceedance Log
12/20/2022:
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06:00 AM 12:00 PM
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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
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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