HomeMy WebLinkAboutMiscellaneous - 285 HOLT ROAD 4/30/2018 (6)Del;eChiaie, Pamela
From: tat.boh@comcast.net
Sent: Monday, May 23, 20116:49 PM
To: fpmacmillan@comcast.net
Cc: DelleChiaie, Pamela; Grant, Michele; Sawyer, Susan; Ed Pease; Joe McCarthy; Larry Fixier
Subject: Re: wheelabrator walk thru with Tech
That's great- my suggestion is that just one of us go on this walk thru with Tech. That way there is no
risk of potential violation of open meeting law. We as a board don't seem to control any direct action
here, as I see it, but there is a large amount of money involved and I don't want to create any risk.
Thanks. Tom
----- Original Message -----
From: fpmacmillan(cD_comcast. net
To: "Susan Sawyee'<ssawyer(cD-townofnorthandover.com>, "Ed Pease"
<ePease(cD- brown rud nick. com>, "Joe McCarthy" <moemccvam(cD-comcast. net>, "Larry Fixler"
<Ifboardofhealthnorthandover(a)-yahoo.com>, "Tom Trowbridge" <tat. boh (o-)-com cast. net>
Cc: "Pamela DelleChiaie" <Pdellech(�D-townofnorthandover.com>, "Michele Grant"
<marant(Wtownofnorthandover.com>
Sent: Monday, May 23, 2011 5:15:17 PM
Subject: Re: wheelabrator walk thru with Tech
Okay, see you Wednesday 2PM at wheelabrator.
Frank
Sent via BlackBerry by AT&T
From: "Sawyer, Susan" <ssawyer(a-)-town ofn orth and over. co m >
Date: Mon, 23 May 2011 16:17:59 -0400
To: Ed Pease<.EPease(-a)-brownrudnick.com>; Francis P. MacMillan (E-
mail)<fpmacmillan(cD-comcast. net>; Joe McCarthy (E-mail)<eoemccyarn�D-corricast. net>; Larry Fixler
(E-mail)<Ifboardofhealthnorthandover(cD-yahoo.com>; TomTrowbridge (E-
mail)<tat. bohc@-comcast. net>
Cc: DelleChiaie, Pamela<pdellechC@-townofnorthandover.com>; Grant,
M iche le< mg ra nt(cD-townofno rth and over. co m >
Subject: FW: wheelabrator walk thru with Tech
We've changed the walk thru time to 2PIVI on Wednesday.
When you pull in the parking area, the far right office building with glass doors is the facility managers area. We can
meet there. Let me know if you are coming so we can wait.
thx
Susan
FYI Joe is out of town until Thursday. I spoke with him earlier
From: fpmmcmillan@comcast.net rmailto:fpmacmillan@comcast.net1
Senf,."Monday, May 23, 20113:04 PM
To: Sawyer, Susan
Subject: Re: wheelabrator walk thru
I could be avail 2-3?
Sent via BlackBerry by AT&T
From: "Sawyer, Susan" <ssgWerktownofhorthandover.com>
Date: Mon, 23 May 2011 14:10:05 -0400
To: Ed Pease<EPeasegbrownrudnick.com>; Francis P. MacMillan (E-mail)<fpmacmillankcomcast.net>; Joe
McCarthy (E-mail)<joemccvamgcomcast.net>; Larry Fixler (E-
mail)<Ifboardofhealthnorthandovergyahoo.com>; TornTrowbridge (E-rnail)<Lat.boh@,corncast.net>
Subject: wheelabrator walk thru
We have a Wed., 9:30 AM walk thru with Tech Environmental at Wheelabrator.
However, I have asked if it could be later in the day if any of you were interested, but I did not give a time of preference
as I haven't spoken with all of you.
Please email or call me as soon as possible if you plan to attend the AM or you would be able to attend an afternoon
inspection. And what time.
Thankyou
Susan
Stmatt Sawyet
Yub& Neaft Olwdo4
1600 (96g"d Stud
JDUg 2C, unit 2-36
NodA andam, Ata C1845
affke 978 6SS-954C
fax 978 6SS-8476
All email messages and attached content sent from and to this email account are public
records unless qualified as an exemption under the
[ http://www.sec.state.ma.us/pre/preidx.htm ]Massachusetts Public Records Law.
Please note the Massachusetts Secretary of State's office has determined that most emails to and from municipal offices and officials are public records. For more
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Please consider the environment before printing this email.
Del,�eChraie, Pamela
From:
fpmacmillan@comcast.net
Sent:
Monday, May 23, 20115:15 PM
To:
Sawyer, Susan; Ed Pease; Joe McCarthy; Larry Fixler; Tom Trowbridge
Cc:
DelleChiaie, Pamela; Grant, Michele
Subject:
Re: wheelabrator walk thru with Tech
Okay, see you Wednesday 2PM at wheelabrator.
Frank
Sent via BlackBerry by AT&T
From: "Sawyer, Susan" <ssLMerktownofhorthandover.corn>
Date: Mon, 23 May 2011 16:17:59 -0400
To: Ed Pease<EPeasekbrownrudnick.com>; Francis P. MacMillan (E-mail)<
pmacmillankcomcast.net>; Joe
McCarthy (E-mail)<joemccvarngcomcast.net>; Larry Fixler (E-
mail)<Ifboardofhealthnorthandovergyahoo.com>: TornTrowbridge (E-rnail)<Lqt.boh@corncast.net>
Cc: DelleChiaie, Pamela<pdellechgtownofnorthandover.com>; Grant,
Michele<mgrantgtownofnorthandover.com>
Subject: FW: wheelabrator walk thru with Tech
We've changed the walk thru time to 213M on Wednesday.
When you pull in the parking area, the far right office building with glass doors is the facility managers area. We can
meet there. Let me know if you are coming so we can wait.
thx
Susan
FYI Joe is out of town until Thursday. I spoke with him earlier
From: fpmacmillan(a)comcast. net rmailto:fpmacmillan(cbcomcast.net1
Sent: Monday, May 23, 20113:04 PM
To: Sawyer, Susan
Subject: Re: wheelabrator walk thru
I could be avail 2-3?
Sent via BlackBerry by AT&T
From: "Sawyer, Susan" <ssMerg
,townofnorthandover.com>
Date: Mon, 23 May 2011 14:10:05 -0400
To: Ed Pease<EPeasekbrownrudnick.com>; Francis P. MacMillan (E-mail)<Imacmillangcomcast.net>; Joe
McCarthy (E-mail)<joemccvamgcomcast.net>-. Larry Fixler (E-
mail)<Ifboardofhealthnorthandover@yahop�.com>; TornTrowbridge (E-rnail)<1g.boh@,corncast.net>
Subject: wheelabrator walk thru
We have a Wed., 9:30 AM walk thru with Tech Environmental at Wheelabrator.
However, I -- have asked if it could be later in the day if any of you were interested, but I did not give a time of preference
as l,"ven't spoken with all of you.
Please email or call me as soon as possible if you plan to attend the AM or you would be able to attend an afternoon
inspection. And what time.
Thank you
Susan
Stoan Sawyu
Yub& Neaft Dmzt"
1600 (96good Stud
2f4 2C, unit 2.36
Nadi andam, Ata C1845
offke 978 688-9540
f= 978 6884476
All email messages and attached content sent from and to this email account are public
records unless qualified as an exemption under the
[ http://www.sec.state.ma.us/pre/preidx.htm ]Massachusetts Public Records Law.
Please note the Massachusetts Secretary of State's office has determined that most emails to and from municipal offices and officials are public records. Formore
information please refer to: hftp://www.sec.state.ma.us/pre/preidx.htm.
Please consider the environment before printing this email.
Commonwealth of Massachusetts
Executive Office of Energy & Environmental Affairs
Department of Environmental Protection
Northeast Regional Office - 2058. Lowell Street, Wilmington MA 01887 978-694-3200
DEVAL L PATRICK RICHARD K SULLIVAN JR.
Governor Secretary
TIMOTHY P. MURRAY KENNETH L. KIMMELL
Lieutenant Governor CornmiGsioner
AUG 2� 3: 2011
CERTIFIED MAIL
Mr. Scott Emerson, Plant Manager
Wheelabrator North Andover Inc.
285 Holt Road
North Andover, MA 0 1845,
RE: NORTH ANDOVER- Solid Waste/COR
Wheelabrator North Andover, Inc.
285 Holt Road
Construction of Enclosure Walls and Dewatering System
Approval
Transmittal No. X239026 -
IMF #132771
Dear Mr. Emerson:
irowN OF ,_0,R,,'T4hAN,0,0,v7R
The Massachusetts Department of Environmental Protection, Northeast Region, Bureau of Waste
Prevention, Solid Waste Management Section ("MassDEP" or the "Department") has� reviewed
your application for construction of enclosure walls, stormwater curbingand collection systems, and
the installation of a dewatering system at the Wheelabrator North Andover, Inc. ("WNAI") facility
located at 285 Holt Road, North Andover, Massachusetts.
The application includes one bound document titled "Wheelabrator North Andover Inc., Enclosure
Project, Permit Application BWP SW 16, Transmittal T�o. X239026, July 2011", containing a
WNAI cover letter dated July 20, 2011, a project narrative, stormwater calculations, miscellaneous
background information, and a set of thil ty-tW6 plari§ -(listed in'the attached Fact Sheet,)�
Project Background
Currently, the area of the Wheelabrator North Andover facility containing the air emission control
equipment and ash conveyors is not totally enclosed by walls and stormwater from the area is not
contained. During certain maintenance activities, the equipment is opened creating the potential for
ash to enter the environment.
This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622 or 1-617-574-6868
MassDEP Website: www,mass.gov/dep
Printed on Recycled Paper
1;
North Andover Page 2 of 5
Wheelabrator North Andover, Inc. Decision Enclosure Walls & Dewatering System
Facility contact water is currently collected in u -drains and conveyed to a materials recovery sump
locatedin the boiler building. The materials recovery sump is pumped to the contact water storage
tank. Solids tend to drop out of the contact water and accumulate in this tank diminishing the tank
capacity. The contact water from the tank is used for ash quenching and flue gas cooling. A second
method used for removal of solids from contact water is the use of geo-tubes, large membrane bags
which contain the solids and allow the contact water to drain through the geo-tube membrane. This
water is then drained to the materials recovery sump and pumped to the contact water storage tank.
Proiect Proposals
Ilk
Wall Enclosures
WNAI is proposing to construct new walls in several locations so that the area around and under the
air emission control equipment and ash conveyors is enclosed and better controlled. The wall
enclosures will improve ash containment when this equipment is opened. The walls will be
constructed with steel columns and support members and a fiberglass reinforced plastic skin. The
project area has been divided into 12 sections of which 10 will be modified with new wall
enclosures and or, concrete curbs. Attachment I of the attached Fact Sheet provides a list of Plans
prepared by Emanuel Engineering related to the proposed building modifications. Attachment 2 of
the attached Fact Sheet lists the proposed changes in each area which may include new concrete
curbing, new wall sections, new or relocated man doors, new rollup doors and concrete ramps and
references the applicable plans.
Stormwater Curbs
The walls will be curbed at the base to enhance the collection of stormwater runoff that may contact
air emission control equipment. In areas with an existing concrete foundations and walls, a concrete
curb will be constructed on top of the existing foundation and the existing wall will be modified to
match the new curb. Where no existing foundation exists, a reinforced concrete curb will be
constructed. In some areas, walls will be constructed above the new curb.
Stonnwater Collection
The project will include re -grading the existing asphalt pavement in two enclosed areas, referred to
as the "Large Courtyard" and the "Small Courtyard", to capture stormwater for use in the plant's
contact water system. Stormwater will be collected in one catch basin in each area and pumped to
the facility's contact water system for reuse within the plant. The catch basins and pumping system
have been designed to control the 100 year storm event. As designed, during storm events, some
stormwater will temporarily pond in the enclosed areas. As necessary, roof drains will be
reconstructed to redirect accumulated precipitation to outside the enclosed areas.
Dewatering Syste
The project will include enlarging the existing materials recovery sump and installing an enhanced
dewatering system to remove solids from contact water, including stormwater that falls within the
WS1encX239026Apv2O1 I—Aug_22 8/22/11
North Andover Page 3 of 5
Wheelabrator North Andover, Inc. Decision Enclosure Walls & Dewatering System
enclosed areas. The dewatering system will include a filter screen on the existing u -drains at the
materials recovery sump, a dump storage tank, a filter press, conveyors to transport the filter cake to
the ash conveyors and supporting pumps, pipe, power and controls. The filtrate will be reused
within the facility and the solids will be returned to the ash handling system for disposal, Except for
the new dump storage tank, the entire system will be located within the enclosed area of the facility.
The attached fact sheet provides a detailed description of the system elements. Attachment I to the
attached Fact Sheet provides a list of mechanical plans prepared by Jacobs related to the proposed
equipment.
Waste Definitions
Within Attachment 8 of the application, WNAI has proposed to revise the definitions of
"Acceptable Waste" and "Unacceptable Waste" as currently defined in their Authorization to
Operate ("ATU) pursuant to 3 10 CMR 19.000, the Massachusetts Solid Waste Regulations and the
facility's Air Operating Permit pursuant to 3 10 CMR 7. 00, the Massachusetts Air Pollution Control
Regulations. WNAI indicates in the application. that the proposed changes are intended to make the
definitions consistent with the current definitions in 3 10 CMR 19.00 and 3 1.0 CMR 7.00,
1 e
The proposed changes will require modification of the facility's ATO. Therefore, please resubmit
the request to MassDEP as anapplication category 13WP SW45. In addition to the proposed
definitions, please include in the application copie's of the definitions of acceptable and unacceptable
waste as currently specified in the. current ATO and the air operatingpermit for the facility. Also
please document that the proposed clarification is consistent with the Facility's Site Assignment
from the Town of North Andover Board of Health.
Decision
Pursuant to 3 10 CMRI 9.000, MassDEP has determined the proposed modifications will adequately
protect public health, safety and the environment. MassDEP, therefore, approves the proposed
building modifications and dewatering equipment installation, subject to WNAI's compliance with
the requirements of 310 CMR 19.000, the Massachusetts Solid Waste Regulations including, but
not limited to 310 CMR 19.043(5) Standard Conditions; and VVNAI's compliance with the
conditions of this decision imposed by MassDEP pursuant to 3 10 CMR 19.043(l) Items Subject to
Conditions.
1. WNAI shall notify MassDEP in writing when construction begins, and again when construction
is completed, so that peni odic inspections can be scheduled.
2. The issuance of this conditional approval is limited to the facility modification as described in
the application and does not relieve "Al from the responsibility to comply with all other
regulatory or permitting requirements.
3. Within thirty days of the date of completing the installation of the proposed dewatering
equipment, manufacturer's data including, but not limited to, product information and
WS1encX239026Apv201 I—Aug_�22 8/22/11
North Andover Page 4 of 5
Wheelabrator North Andover, Inc. Decision Enclosure Walls & Dewatering System
operations and maintenance manuals for the equipment shall be submitted to MassDEP for its
records and incorporated -in the Facility's Operation and Maintenance Plan.
4. Within thirty days of completion of building modifications and equipment installation, WNAl
shall submit a certification signed pursuant to 310 CMR 19.011 by a Massachusetts registered
professional engineer and an authorized representative of WNAl that all work has been
completed in accordance with the approved plans.
NOTICE OF RIGHT TO APPEAL
Wheelabrator North Andover,. Inc. is hereby notified that it may within twenty-one (2 1) days file a
request that this decision be deemed a provisional decision under 310 CMR 19.037(4)(b), by
submitting a written statement of the basis on which Wheelabrator North Andover, Inc. believes it
is aggrieved, together with any supporting materials. Upon timely filing of such a reques t, the
decision shall be deemed a provisional decision with an effective date twenty-one (21) days after
the Department's receipt of the request. Such a request shall reopen the administrative record,
and the Department may rescind, supplement, modify, or reaffirm its decision. Failure by
Wheelabrator North Andover,, Inc. to exercise the right provided in this section shall constitute a
waiver of Wheelabrator North Andover,, Inc's right to appeal.
Appeal. Any person aggrieved by the issuance of this decision, except as provided for under
3 10 CMR 19.037(4)(b), may file an appeal for judicial review of said decision in accordance
with the provisions of M.G.L. c. I 11, s. 150A, and M.G.L. c. 30A, not later than thirty (30) days
following the receipt of the final decision. The standing of a person to file an appeal and the,
procedures for filing such appeal shall be governed by the provisions of M.G.L. c. 30A. Unless
th e person requesting an appeal requests and is granted a stay of the terms. and conditions of the
decision by a court of competent jurisdiction, the decision shall remain effective.
Notice of Action. Any aggrieved person intending to appeal this decision to the Superior Court
shall first provide notice to the Department of their intention to commence such action. Said
notice of intention shall include the Department file number and shall identify with particularity
the issues and reasons why it is believed the decision was not proper. Such notice shall be
provided to the Office of General Counsel of the Department and the Regional Director for the
regional office which processed the application. The appropriate addresses to which to send
such notices are:
General Counsel
Department of Environmental Protection
One Winter Street - 3rd Floor
Boston, MA 02108
Regional Director
Department of Environmental Protection
WS1encX239026Apv201 I—Aug_22 8/22/11
North Andover Page 5 of 5
Wheelabrator North Andover, Inc. Decision Enclosure Walls & Dewatering System
Northeast Regional Office
205B Lowell Street
Wilmington, MA 01887
No allegation shall be made in any judicial appeal of this decision unless the matter complained
of was raised at the appropriate point in the administrative re I view procedures established in those
regulations, provided that a matter may be raised upon a showing that it is material and that. it
was not reasonably possible w,ith,due diligence to have been -raised.lduring such procedures, or
that matter sought to be raised is of critical importance to the environmental impact of the
permitted activity.
When submitting any ftiture documents relative -to this application please refer to the File Number
X239026. Please also include the Facility Master File Facility Number (IMF #132771) on all
documents relative to this facility. -
If you have any questions regarding this matter, please contact David Adams at (978) 694-3295.
1
Sincerely,
J00 A. Carrigan
Vction Chief
Solid Waste Manage nt
.JAC/DC/dc
enclosure: Fact Sheet
cc: North Andover Board of Health
1600 Osgood Street
Building 20; Suite 2-36
North Andover, MA 01845
Certified Mail No. 7010 0290 00012570 5139
WS1encX239026Apv201 I—Aug_22 8/22/11
FACT SHEET
Wheelabrator North Andover, Inc.
Enclosure Project
Applicant: Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 0 1845
Facility: Wheelabrator North Andover Inc.
285 Holt Road
North Andover, MA 01845
File Number: X239026
Page I of 7
ID: I'Lility Numbe r: 132171
Regulated Object Number: 172782
SWMID Number: RR0210.01
Permit Number: NESW-CF-005
Lo cationi. 7 1' 7' 18" W Longitude 420 431 3511 N Latitude
MSPCS: 23 1,000 mN, 941,810 mE Mainland Zone NAD 83
Application:
Type: BWP SW 16: Combustion Facilities
Construction of Enclosure Walls and Dewatering System
Transmittal.Number: X239026
Mechanical Engineer of Record:
Jacobs
Ronald D Roberts, P.E.
Structural/Civil Engineer of Record
Emanuel Engineering Inc.
Fred Emanuel, P.E.
MEPA: The current application does not trigger MEPA review thresholds.
Submissions relative to this application:
report:
Wheelabrator North Andover, Inc.
Enclosure Project
Permit Application BWP SW 16
Transmittal No. X239026
July 2011 .
' For reference only. Estimated from MassGIS.
x239026 fs201 I—AUg_1 8 8/18/11
FACT SHEET
Wheelabrator North Andover, Inc.
Enclosure Project
Discussion:
File Number: X239026
Page 2 of 7
Currently the area of the Wheelabrator North Andover facility containing the air emission control
equipment and ash conveyors is not totally enclosed by walls and stormwater from the area is not
contained. During certain maintenance activities the equipment is opened creating the potential
for ash to enter the environment.
'�NNAI is proposing to construct new walls in several locations so that the area around and under
the air emission control equipment and ash conveyors is enclosed and better controlled. The wall
enclosures will improve ash containment when this equipment is opened. The walls will be
constructed with steel columns and support members and a fiberglass reinforced plastic skin. The
project area has been divided into 12 sections of which 10 will be modified with new wall
enclosures and or concrete curbs. Attachment I of this Fact Sheet provides a list of Plans
prepared by Emanuel Engineering related to the proposed building modifications. Attachment 2
of this Fact Sheet lists the proposed changes in each area which may include new concrete
curbing, new wall sections, new or relocated man doors, new rollup doors and concrete ramps and
references the applicable plans.
The walls will be curbed at the base to enhance the collection of stormwater runoff that may
contact air emission control equipment. In areas with an existing concrete foundations and walls, a
12 -inch reinforced concrete curb will be constructed on top of the existing foundation. and the
existing wall will be modified to match the new curb. Where no existing foundation exists, a
reinforced concrete curb extending two feet below grade and one foot above grade will be
constructed. In some areas, walls will be constructed above the new curb. (See Attachment 2)
The project will include re -grading the existing asphalt pavement in two enclosed areas, referred
to as the �'Large Courtyard'? and the "Small Courtyard", to capture stormwater for use in the
plant's contact water system. Stormwater will be collected in catch basins, one in each area and
pumped to the facility's contact water system for reuse within the plant. The catch basins and
pumping system have been designed to control the 100 year storm event. As designed, during
storm events, some stormwater will temporarily pond in the enclosed areas. It is anticipated that
water will pond to a maximum depth of approximately 0.7 feet and drain within approximately
two hours. As necessary, roof drains will be reconstructed to redirect ac cumulated precipitation to
outside the enclosed areas..
Facility contact water is currently collected in u -drains and conveyed to a materials recovery sump
located in the boiler building. The materials recovery sump is pumped to the contact water storage
tank. Solids tend to drop out of the contact water and accumulate in this tank diminishing the tank
capacity. The contact water from the tank is used for ash quenching and flue gas cooling. A
second method used for removal of solids from contact water is the use of geo-tubes, large
membrane bags which contain the solids and allow the contact water to drain through the geo-tube
membrane. This water is then drained to the materials recovery sump and pumped to the contact
water storage tank.
x239026 fs201 I—AUg_1 8 8/18/11
FACT SHEET File Number: X239026
Wheelabrator North Andover, Inc. Page 3 of 7
Enclosure Project
The project will include an enhanced dewatering system to remove solids from contact water,
including stormwater that falls within the enclosed areas. The dewatering system will include a
filter screen on the existing, u -drains at the materials recovery sump, a dump storage tank, a filter
press, conveyors to transport the filter cake to the ash conveyors and supporting pumps, pipe,
power and controls. The filtrate will be reused within the facility and the solids will be returned to
the ash handling system for disposal. Except for the new dump. storage tank, the entire system will
be located within the enclosed area of the facility. The attached fact sheet provides a detailed
description of the system elem6rits-Attaoliment-I to this Fa �Sheet provides a list of mechanical
plans prepared by Jacobs related to the proposed equipment.
The proposed filter screen is manufactured by Aqua Guard and will remove the larger objects
and debris from the contact water. Removed materials will added to the ash conveyor system
for eventual disposal with ash.
The new dump storage tank will have a conical bottom and an approximate capacity of 20,000
gallons. The tank will be agitated anid/or recirculated to maintain a homogeneous mixture of
ash laden water to prevent settling and accumulation of solids in the bottom of the tank.
Mechanical dewatering of the contact water will be performed with a Siemens J -Press 60 cubic
foot filter press (or equivalent), located over the materials recovery sump in the boiler building.
x239026 fs201 I—Aug_18 8/18/11
FACT SHEET File Number: X23 9026
Wheelabrator North Andover, Inc. Page 4 of 7
Enclosure Project
Fact Sheet - Attachment I - List of Plans
Drawing Number
Date
Title
Prepared By:
1131-01.22-001 rev 0
6/24/2011
Existing 5 ite Plan
Venture Engine&ing & Construction
1131-01.22-0002 rev C
6/24/2011
Proposed Site Plan
Venture Engineering & Construction
09-28,-P100 rev 2
9/9/1999
Ash Handling System
S/D Engineers
Flow Diagram
0802 -PFD rev 0
3/3/2009
Materials Recovery
Stangle Associates
Project Process Flow Diagram
Figure 3
7/12/2010
Water Flow Diagram
Brown & Caldwell
T1
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Title Sheet
S1.1
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
General Notes and
typical Details
S1.2
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Typical Details
S2.1
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Foundation & Enclosure Wall
Key Plans
S2.2
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Foundations Enclosure Wall &
Upper Level Framing
52.3
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Foundations Enclosure Wall &
Upper Level Framing
S2.4
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Foundations Enclosure Wall &
Upper Level Framing
x239026 fs201 I—Aug_l 8 8/18/11
6
FACT SHEET File Number: X239026
Wheelabrator North Andover, Inc. Page 5 of 7
Enclosure Project
x239026 fs201 I—Aug_l 8 8/18/11
Fact Sheet - Attachment I - List of Plans (cont'd)
Drawing Number
Date
Title
Prepared By:
S3.1
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Enclosure Wall Framing Elevations
.S3.2
12/22/2010,
Enclosure Wall Modifications
Emanu-el,Engineering
Enclosure Wall Framing Elevations
S3.3
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Wall Sections
S3.4
12/22/2010
Enclosure Wall Modifications
Emanuel Engineering
Sections & Details
C1
12/22/2010
Courtyard General Arrangement Plan
Emanuel Engineering
WS1
12/22/2010
Large Courtyard Grading Plan
Emanuel Engineering
WS2
12/22/2010
Small Courtyard Grading Plan
Emanuel Engineering
17MN9807-53-1-004
6/24/2011
Process Contact Water Collection
Jacobs
17MN9807-53-1-001
6/23/2011
Process Contact Water Screening
Jacobs
17MN9807-53-1-002
6/23/2011
Process'Filter Press System
Jacobs
17MN9807-53-1-003
6/23/2011
Process Contact Water Tank
Jacobs
17MN9807-58 G-001
6/23/2011
Mechanical Dewatering Building Ground Jacobs
Floor General Arrangement
17MN9807-58-G-002
6/23/2011
Mechanical Dewatering Building 2nd
Jacobs
Floor General Arrangement
17MN,9807-58-G-003
6/23/2011
Mechanical Dewatering Building 3rd
Jacobs
Floor General Arrangement
.17MN9807-58-S-001
6/23/2011
Mechanical Dewatering Building
Jacobs
Building East-West Cross Section
.17MN9807-58-S-002
6/23/2011
Mechanical Dewatering Building
Jacobs
Building North-South Cross Section
x239026 fs201 I—Aug_l 8 8/18/11
11
FACT SHEET
Wheelabrator North Andover, Inc.
Enclosure Project
File Number: X239026
Page 6 of 7
Fact Sheet - Attachment I - List of Plans (cont'd)
Drawing Number Date Title Prepared By:
17MN9807-53-L-001 6/23/2011 Process Symbols & Identification P&I Diagram Jacobs
17MN9807-56-S-001 6/23/2011 Electrical Single Line Diagram Jacobs
No 09 -MCC -105A
17MN9807-56-S-002 6/23/2011 Electrical Single Line Diagram Jacobs
No 09 -MCC -105B
17MN9807-56-S-003 6/23/2011 Electrical Single Line Diagram Jacobs
No 09 -MCC -106A
x239026 fs201 I—Aug_18 8/18/11
6
FACT SHEET
IV Wheelabrator North Andover, Inc.
Enclosure Project
File Number: X239026
Page 7 of 7
Fact Sheet Attachment 2 — Enclosure locations/ plan sections/descriptions
Drawing S 2.1 Key Plan
Area I Between boiler bldg and baghouse #1
Foundation and framing: 1,2,3S2.2 new concrete curb and ramp
Elevation S3.1 new walls with roll -up door and man door
Area 2 Baghouse #I
Foundation I S.2.2 new concrete curb
Area 3 Baghouse#1
Framing 4,582.2 no new foundation
Elevation 3 S3.2 existing wall with man door, construct wall above
Area 4 Precip B Idg #1
Foundation and framing 1,2S2.3
Elevation 2S3.1
Area 5 Between Precip #I and Precip #2
Foundation and framing 1,2,3 S2.3
Elevation I S3.2
Area 6 Precip Bldg #2
Foundation and framing 1, 2 S2.3
Elevation 3 S3.1
Area 7 none
Area 8 Baghouse #2
Framing
7,8S2.2
Elevation
4S3.2
Area 9 Pump Building
Foundation and framing
1,2,3S2.4
Elevation
2,5S3.2
Area 10 Contact water tank
Foundation
1,S2.4
new concrete curbs at existing walls,
new concrete ramp at door
new wall section
new concrete curbs at new walls
new wall sections
new concrete curbs at existing walls,
new concrete ramp at door
new wall section above relocated door
no new foundation
existing wall w/ man door, construct wall above
new concrete curb and wall with man door
and roll -up door, relocate existing man door
new concrete curb, ramp and wall, new doors
new concrete curb
Area I I none
Area 12 Ash Handling Building
Foundation and framing 4,5 S2.3 new concrete curb, ramp
Elevation 6S3.2 relocate existing door
x239026 fs201 I—Aug_18 8/18/11
W../'
Town of North Andover
Office of the Director
vuLu'LuJL�'V 'cvvc uFULCIlt MR Seir vices Divisio.
400 Osgood Street
North Andover, Massachusetts 01845
Division Director
Heidi Griffin
Any appeal shall be filed
within (20)days after
the date of filing this
notice in the office
of the Town Clerk,
Town of North Andover
I r., -'45�"Tllc"�"' ��
Telephone (978) 688-9531
Fax (978) 688-9542
NOTICE OF DECISION Cogge-01-tC4 00,01
Dite: December 8, 2004
Date of First Hearing: September 7, 2004
Date of Decision: December 7, 2004
Petition of Wheclabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845
Premises aff-ected: 285 Holt Road, North Andover
Map 34, Lot 21
Referring to the above petition for a minor Modification to Condition #2b(i) (6)
Special Permit for Refustech Inc., of which was originally issued on 8125/98.
So as to allow: i) Most recent Compliance Data: The latest monitored emissions and
operating levels, compared with permit limits (graphical format), specifically;
(6) Mercury, Dioxin, and any other parameter that is tested but not subject to continuous
emissions monitoring d" the latest test results. NM shall test bi-yearly for dioxin in
July & in December of 2005, for one year from the date of this decision, If at any time
during this one-year period the dioxin/furan missions test results exceed 7 ng/dsm� the
applicant will be required to conduct quarterly dioxin/furan tests in accordance with the
original decision issued on 8/25/98. However, if the dioxin/furan emissions test results
stay at, or are less than 7ng/dscm, the applicant may then, after one year of continuous
results in this category, conduct tests and submit the results every 9 months in accordance
with MADEP requirements.
Page I of 2
BOARD OF APPEALS 698-9541 BIALDING698-9545 CONSERVATION 688-9530 HEALTH688-9540 PLANNING 688-9535
-�W
If any time in the future the dioxin and ffiran emission test results exceed 7ng1dscm, the
applicant must begirt submitting these dioxin/furan test results every quarter. Howayer,
the appikant may re -petition the Planning Board and the Planning Board reserves J�LF c'
right to wrieW this condition and allow less frequent testing if the test results reveal
levels of dioxin that am at or below 7 ng/dscm.
Please note, that this modification to the original condition is being granted since your
F I Ilo cd per
aL
.,,,ties oper
ations b'.
ave been signfficantly less than the maximum yie d a w
Department of Environmental Protection Regulations (30 nanogranis per dry standard
cubic mctcr.)
After a public hearing given on December 7, 2004, the Planning Board voted to
AppROVE the minor Modification to Condition # 2b(i)(6) Special Permit I fo r
wheeiabrutor, Refustech Inc. originally issued, on 8125/98.
Signed
Albcrto Angles, Chairr=
Richard Nardella.
John Simons
Felipe Schwarz
Gcorgc Whitc
Jarms Phinncy
cc: Applicant
Enginccr
T)PW
Building DL -pt.
Conservation Dept.
Dept.
Assessors
Police Chief
Fire Chief
M"awww"M""
Pagc 2 of 2
Environmental, L L C
advise * rernediate * sustain
September 17, 2012
Mr. Thomas Trowbridge
Board of Health Chairman
Town of North Andover
1600 Osgood Street building 20; suite 2-26
North Andover, Massachusetts 0 1845
Re: /1' Notice of Availabilijy oMesponse A(
Wheelabrator North A)nd ver Inc.
285 Holt Road
North Andover, Ma�> chusetts 0 1845
DEP �RN4 -'3 , 0954
1P
SAK Proiect No.: 06.13.54
Dear Mr. Trowbridge:
RE
5
TOWN OF NORTH ANDOven
—tLEALTH DFP,0*"—.—
This letter has been prepared in accordance with the public notification requirements of
the Massachusetts Contingency Plan (MCP) regulations (3 10 CMP 40.1403) notifying
you that a Class A- I Response Action Outcome (RAO) Statement has been submitted to
the Massachusetts Department of Environmental Protection (MADEP) for a release of
oil/hazardous material at the above referenced location. This submittal is available for
public review at MADEP Northeast Region Office at 205B Lowell Street Wilmington,
MA and online via MADEP's website at www.mass.izqy/deR.
If you have any questions, please contact Greg Griffin, Wheelabrator North Andover, Inc.
Environmental Manager at (978)-688-9011 x223.
Sincerely,
SAK Environmental, LLC
By:
Stephen J. Dowaliby
Environmental Scientist
cc: DEP Northeastern Region Office
Greg Griffin, Matt Hughes (Wheelabrator North Andover, Inc.)
Mr. Andrew W. Maylor (Town Manager)
231 Sutton Street, Suite 2G * North Andover, MA 01845 0 phone: 978 688 7804 * fax: 978 688 7801 * www.sakenvironmental.com
SDO/SOMWBA Certified WBE & DBE
-/-P
9IL4 Environmental, LLC
advise * remediate sustain
December 19,2011
Ms. Susan Y. Sawyer
Health Director
Town of North Andover
1600 Osgood Street building 20; Suite 2-26
North Andover, Massachusetts 01845
Re: Wheelabrator North Andover Inc.
285 Holt Road
North Andover, Massachusetts 01845
MADEP RTN# 3-30441
SAK Project No.: 06.13.43
Dear Ms. Sawyer:
RECEIVED
JAN 10 ZOR
TOWNOFN
IORTH ANDOVER
This letter has been prepared in accordance with the public notification requirements of
the Massachusetts Contingency Plan (MCP) regulations (310 CMP 40.1403) notifying
you that a Class A- I Response Action Outcome (RAO) Statement has been submitted to
the Massachusetts Department of Environmental Protection (MADEP) for a release of
hydraulic oil at the above referenced location. This submittal is available for public
review at MADEP Northeast Region Office at 205B Lowell Street Wilmington, MA and
online via MADEP's website at www. mass. izov/dep.
If you have any questions, please contact Greg Griffin, Wheelabrator North Andover, Inc.
Environmental Manager at (978)-688-9011 x222.
Sincerely,
SAK Environmental, LLC
By:
Vincent P. Helfrich
Environmental Engineer
cc: DEP Northeastern Region Office
Greg Griffin, Matt Hughes (Wheelabrator North Andover, Inc.)
Mr. James Purcell (Town Manager of North Andover)
231 Sutton Street, Suite 2G North Andover. MA 01845 -phone* 978 688 7804 fax: 978 688 7801 www.sakenvironmental.com
SDO/SOMWBA Certified WBE & DBE
I
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a
I
I
I
I
I
I
I
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I
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R
AIR QUALITY MODELI-NG
A KI A I VCIC CNE -rUE %A/UEE
L/A D N/A I kJ N
F
17� NORTH ANDOVER FACILITY
17_1
USING THE
OCTOBER 2004 PERFORMANCE
CERTIFICATION TEST DATA
Prepared for:
ED Wheelabrator North Andover, Inc.
M
M 285 Holt Road
1=1 North Andover, MA 01845
r-1
EPSILONASSOCIATES INC.
Engineers E3 Environmental Consultants
Prepared by.
M
Epsilon Associates, Inc.
150 Main Street
C3
Maynard, MA 01754
M
Im
M
En
M
March 31, 2005
t
EPSILONASSOCIATES INC.
Engineers E3 Environmental Consultants
AIR QUALITY MODELING
ANALYSIS OF THE WHEELABRATOR
NORTH ANDOVER FACILITY
USING THE
OCTOBER 2004 PERFORMANCE
CERTIFICATION TEST DATA
Prepared for:
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845
Prepared by.
Epsilon Associates, Inc.
150 Main Street
Maynard, MA 01754
March 31 f 2005
TABLE OF CONTENTS
1.0
INTRODUCTION
2.0
SOURCE DESCRIPTION
3.0
METEOROLOGICAL DATA
4.0
MODELING ANALYSIS
5.0
RESULTS
REFERENCES
APPENDIX
PAGE
1
2
3
4
6
I IHendrickorojectslnandovefiOdO4lrep 1004.doc Page i Table of Contents
1.0 INTRODUCTION
Wheelabrator North Andover (WNA) (formerly Massachusetts REFUSETECH Inc.) has
retained Epsilon Associates Inc. of Maynard, Massachusetts to perform an air quality analysis
for the municipal waste combustor facility in North Andover.
The air quality dispersion modeling is in response to Policy 91-001 of the Massachusetts
Department of Environmental Protection (DEP) that was adopted by the DEP to provide
guidance on the air quality impact analyses required for municipal waste combustors subject
to 21H Section 5C of the Massachusetts General Laws and 3.10 CMR 7.08. The 21H
legislation requires the operators of municipal waste combustors to test for dioxins and
furans in MWC emissions and ash every nine months. Wheelabrator also performs
additional stack testing for other pollutants that Massachusetts currently regulates, as agreed
to with the DEP regional office. In addition to the stack testing, dispersion modeling is
performed with the stack parameters measured during the testing to assess the air quality
impacts from the facility.
The modeling analysis is conducted in accordance with the methodologies described in the
revised modeling protocol (Hendrick, 2004). This report summarizes the air quality
dispersion modeling analysis for the North Andover facility. The stack parameters from the
October 2004 stack tests are modeled with a unit emission rate of 1 g/s. The model results
are then scaled by the pollutant emission rates determined by the October 2004 stack testing
to assess ambient impacts. ,
0
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nI 11-lendrickjorojects lnandoverlOaO-4 Irep 1004 doc Page 1 Introduction
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E2.0 SOURCE DESCRIPTION
The WNA facility is located in North Andover, Massachusetts at UTM coordinates 326.293
km east and 4732.393 km north (zone 19). These coordinates were identified through field
measurements using global positioning system (GPS) equipment. The coordinates obtained
from the GPS were then overlaid onto an orthographic image to validate their accuracy.
Figure 1 shows the WNA facility location on a USGS topographic map.
Li The base elevation of the facility is 66 feet (20.1 m) above mean sea level. The products of
combustion from each municipal waste combustor are emitted through individual flues of
one dual flue stack, the top of which is 230 feet (70.1 m) above ground level. Each
individual flue has an inside exit diameter of 7 feet (2.1 m). The stack diameter used in the
modeling is an effective diameter, that is the diameter of an effective stack that is equal in
area to the area of the two flues combined, (i.e., (square root of 2) * 2.1 m = 3.02 m). Based
on the October 2004 dioxin stack tests the Unit 1 flue had an average air flow rate of
161,100 ACFM and an average temperature of 301.51F. The Unit 2 flue had an average
flow rate of 158,067 ACFM and an average temperature of 303.70F. For modeling purposes,
that yields a stack gas exit velocity of 21.03 m/s and an average exit temperature of 423.51K.
Table 1 summarizes the flue gas parameters from the stack test. The October 2004
PCDD\PCDF stack test parameters are presented in the appendix, along with the emission
rates for all of the pollutants.
Application of the Good Engineering Practice (GEP) formula to the facility structures
indicates a maximum GEP stack height for the facility of 307.5 ft (93.73 m). The main boiler
building is found to be the controlling structure with the structure's height of 123 ft (37.49 m)
being the critical dimension. Since the WNA stack is 230 feet (70.1 m) in height (below GEP
height), building clownwash effects were modeled in the ISCST3 dispersion modeling
analysis.
When conducting a dispersion modeling analysis, one needs to determine whether the land -
use pattern in the environs of the plant is urban or rural for modeling purposes. As described
in the revised modeling protocol, greater than 50% of the area within 3 km of the North
Andover Facility is rural for modeling purposes. Therefore, rural dispersion coefficients are
0 used in the modeling analyses.
P
I
A closed landfill, wooded areas, and light to heavy industrial facilities characterize the
immediate vicinity of the site. Within 5 km of the site, elevations range from sea level to
greater than 108 m. The closest point at which the terrain height exceeds the facility stack
top elevation (90.2 m) is 2.25 km to the south-southeast at Osgood Hil I.
I lHendrick1projects lnandoverlOctN�pp 1004.doc Page 2 Source Description
I
3.0 METEOROLOGICAL DATA
Five years of surface meteorological data (1991-1995) collected by the National Weather
Service (NWS) at Boston's Logan International Airport have been acquired from the National
Climatic Data Center (NCDC) or the EPA SCRAM Bulletin Board and are used in the refined
modeling analysis. Logan Airport is located approximately 39 km to the south-southeast of
the facility site.
The historical five-year period, 1991-1995, of hourly meteorological data has not been
updated to reflect more recent data' collection because National Weather Service offices
became automated after 1995. The observer at the stations was removed when the
automation process went into effect. A key observed parameter (total opaque sky cover) that
is necessary for stability class determination for dispersion modeling is no longer available
from the automated stations. Therefore, the period 1991-1995 is the most recent data set
with the appropriate parameters for use in dispersion modeling analyses.
The hourly surface observations include wind direction, wind speed, temperature, cloud
cover, and ceiling height. The surface data were combined with concurrent mixing height
data from NWS upper -air observations made in Portland and Gray, Maine. In September of
1994, the upper air station at Portland ceased operation and observations were resumed at
Gray, ME. Gray is approximately 20 miles north-northeast of Portland. The Portland surface
temperature was used to initialize the soundings for all of the five years. These observation
sites were chosen because they are the closest stations to the project site that collect the
necessary meteorological data of the required quality for modeling studies.
I V-IendricklorojectsinandoveriOdO4lrL-p 1004. doc Page 3 Meteorological Data
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4.0 MODELING ANALYSIS
This refined air quality modeling analysis using the October 2004 stack test data follows the
revised modeling protocol that was submitted to DEP in July 2004.
The ISCST3 model (Version 02035) is a steady-state Gaussian plume model that can be used
to assess pollutant concentrations from a wide variety of industrial sources. It accounts for
plume rise as a function of downwind distance and can apply terrain adjustments to the
plume. ISCST3 also incorporates the. COMPLEX I screening model algorithms for receptors
above stack top, i.e., complex terrain (receptor elevation above the plume height) and
intermediate terrain (receptor elevation between the release height and plume height). For
intermediate terrain receptors the model treats the receptor as both simple terrain and
complex terrain and retains the higher predicted concentration for that receptor for that hour.
U A network of receptors was selected for the ISCST3 refined analysis of the facility to ensure
that the highest calculated concentrations will be captured by the mathematical modeling. A
discrete polar grid with thirty-seven concentric ring distances, centered on the stack and
combined with 36 radials at ten -degree intervals (i.e., 100, 200, ... 3600) was developed for
the modeling analysis. The refined modeling receptors were placed at the following
downwind distances: 100, 200, 300, 400, 500, 600, 700, 800, 9001 1000, 1100, 1200,
1300, 1400, 1500, 1600, 1700, 1800, 1900, 2000, 2200, 2400, 2600, 2800, 3000, 3200,
3400, 3600, 3800, 4000, 4500, 5000, 6000, 7000, 8000, 9000, and 10000 meters from the
stack. United States Geological Survey (USGS) 1:25,000 scale topographic maps were used
to hand-pick the receptor elevations. The closed landfill to the south of the facility is not
depicted on the USGS maps, therefore receptor elevations for the landfill area were obtained
from landfill site plans provided by the Massachusetts DEP. The highest terrain elevation in
each sector (defined as the area extending from one interval ring to the next downwind ring
bounded by the area extending halfway to each of the adjacent radials) was used to represent
the elevation for each receptor. in addition, discrete receptors were located along the
fenceline of the WNA facility. The polar grid receptors that lie inside the fenceline were
removed for the modeling analysis, so that offsite impacts are assessed. A total of 1322
receptors were modeled with ISCST3. The elevations assigned to each receptor in the
discrete polar grid are presented in Table 2 and the fenceline receptor locations and
elevations are presented in Table 3.
During the October 2004 stack tests both Unit 1 and Unit 2 were sampled. The refined
modeling was performed using a single stack with parameters derived from each flue. The
regulatory options of the ISCST3 model were used in the modeling analysis. The EPA
recommended options for plume rise, buoyancy induced dispersion, vertical potential
temperature gradients, treatment of calms, wind profile exponents, and enhanced dispersion
coefficients were selected. One non -default model option, HE>Zl, was also invoked to limit
the plume centerline height (HE) to be less than or equal to the mixing height (ZI). This is
important in situations when the receptor elevation is below the stack base elevation. Rural
� 0 1 lHendrlcklorojectsinandovellOctO4LTp 1004.doc Page 4 ModelingAnalysis
I
dispersion coefficients were used in the modeling analysis. The October 2004 stack test data
along with five years (1991-1995) of hourly meteorological data were used in the refined
modeling analysis. A unit emission rate of 1 g/s was used in the modeling to predict
normalized concentrations.
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5.0 RESULTS
The highest normalized concentrations for several averaging periods for each of the five
years modeled are presented in Table 4. The overall highest normalized concentration for
each averaging period is summarized in the rightmost column of Table 4. The 24-hour and
annual average normalized concentrations were used to calculate the ambient air quality
impacts associated with the operations at the WNA facility.
The October 2004 PCDD/PCDF stack test data are presented in the Appendix. The October
2004 stack test data were used to calculate a dioxin emission rate using DEP's October 1991
Toxic Equivalency Factors. These emission rate calculations for Unit I and Unit 2 are
presented in the Appendix.
Annual average and 24-hour average ambient concentrations have been calculated using the
October 2004 stack test emissions data for trace metals, ammonia, hydrogen chloride and
dioxins. The predicted modeled concentrations for each pollutant are presented in the
Table 5. The modeled impacts for each pollutant are below the respective Massachusetts
DEP annual average AALs and the 24-hour average TELs.
I
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DI IHendrickOrOjectsInandoveriOctO4 �ep 1004.doc Page 6 Results
6 m
miPSILONASSOCIATES INC.
66Engineeirs 0 Environmental Consultants
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TABLE 1
Stack Parameters for the WNA Facility
Unit 1 1 Unit 2
Stack base elev. (m) 20.1
Stack height (m) 70.1
Stack diameter (m)
per flue
2.1 2.1
equivalent diameter
3.02
Air flow rate (ACFM)
161,100 1 158,067
Exit velocity (nVs)
21.03
Exit ternp (F)
301.5 1 303.7
Average Exit ternp (K)
423.5
Building height (m)
37.49
Max. building width (m)
76.88
Stack location
UTM-E (knn)
326.293
UTM-N (krn)
4732.393
Note: Unit 1 and Unit 2 parameters from the Method 23 testing performed in October 2004.
I Wendrickorojects WandoverlOctO41rep 1004.doc Page 8
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TABLE 3
FENCELINE RECEPTOR LOCATIONS AND ELEVATIONS
Receptor
Number
x
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y
(M)
Elevation
(M)
1
-157.1
145.9
9.
2
-105.0
136.6
9.
3
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126.7
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39.3
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88.1
90.3
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136.8
79.0
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51.4
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9
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113.7
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76.9
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12
36.0
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27.
14
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15
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-160.1
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17
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18
-158.0
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19
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45.6
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20
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DI iHendrlck0rojectsL'7andoverlOctO4 Imp 1004.doc Page 12
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TABLE 5
MAXIMUM ISCST3 (02035) AMBIENT CONCENTRATIONS
Pollutant
October 2004
Emission Rates
Unit 1 Unit 2
Ob/hr) (lb/hr)
ISCST3
Total (Units 1&2)
Modeled Concentrations
24 -Hour AnnualA
wgW) wg/m3)
Ammonia (NH3)
2.34E-01
2.42E-01
1.09E-01
6.27E-03
Cadmium (Cd)
1.84E-04
2.13 E-04
9.1 OE -05
5.23E-06
Lead (Pb)
4.96E-03
9.29E-03
3.27E-03
1.88E-04
Mercury (Hg)
7.24E-03
4.05E-03
2.59E-03
1.49E-04
Hydrogen Chloride (HCI)
7.999
8.264
3.73E+00
2.14E-01
WS)
(pgIM3)
PCDD/PCDF
(MA Toxic Equiv.)
8.77E-1 0
5.08E-09
N/A
6.2 3 E-04
^ Assumes 90% Availability (based on five year average: 1996-2000)
I ]HendrlckorojectslnandoveriOctO4lrep 1004.doc Page 14
References
REFERENCES
DEECO, 2004: Stationary Source Sampling Report - Wheelabrator North Andover, Reference No.04-
2136, Test Dates: October 2004. DEECO, Cary, NC.
k
Hendrick, E., 2004: Air Quality Modeling Protocol for Fmis5ions from Wheelabrator North Andover
Inc, Fp5ilon Associates, Inc Maynard, MA.
I lHendricktorojectslnandovefiOctO4lrep 1004 doc Page 15 References
APPENDIX
Wheelabrator North Andover Stack Test Results
October 2004 Stationary Source Sampling Report, DEECO Inc., Cary, NC
Source Parameters for Modeling:
• PCDD/PCDF Flue Gas Parameters Summary, Unit #1
• PCDD/PCDF Flue Gas Parameters Summary, Unit #2
Emission Rates for Modeling:
• Three Run Average PCDD/PCDFs MA DEP Toxic Equivalencies Emissions, Unit #1
• Unit 1 Outlet: Metals and Mercury Test Results
• Unit 1 Outlet: Hydrogen Chloride and Ammonia Test Results
• Three Run Average PCDD/PCDFs MA DEP Toxic Equivalencies Emissions, Unit #2
• Unit 2 Outlet: Metals and Mercury Test Results
• Unit 2 Outlet: Hydrogen Chloride and Ammonia Test Results
I
COMPanY. WheeMrgor North Andover
Sounmr Unft No. I Outlet
Job ID: 04-21136
Train Type: EPA Method 23
1 U26104
2
I OM04
3
10/27104
735-1219
1255-1710
725-1140
Average
Initial Meter Volume, 1`13
1 38.300
192-700
366 * 155
Final Meter Volume, ft3
191.602
365.778
533.874
Intra -Port Leak Check Volume, ft3
0.w
0.243
0.114
Total Sample Volume, d
152.359
172.835
167.605
164.266
DGM Calibration Factor
1.006
1.006
1.006
1.006
Average DGM Temp, F
'59.5
67.6
63.1
63.4
Average DGM delta H, "H20
1.49
1.67
1.57
1.58
Barometric Pressure, wHg
30.03
30.03
30.06
30.04
Comected Sample Vol,dscf
156,861
175.288
171.574
167-908
Corrected Sample Vol,dscm
4A42
4.964
4"
4.755
Oxygen, %
8.8
8.9
8.7
8.8
Carbon Dio)dde,%
10.6
10.5
10.8
10.6
Nitrogen, %
80.6
80.6
80.5
80.6
Stack Gas Excess Air., %
70.5
71.9
69.3
70A
Total Moisture Catch Weight, grams
10".7
1125.3
1118.5
1082.8
Stack.Gas Molsture, %
.23.2
23.2
23.5
.-23.3
Stack Gas Dry Molecular Weight IbAbmole
30.05
30.04
30.076
30.05
Stack Gas Wet Molecular Weight lbnbmole
27.25
27.24
27.24
27.24
Average Stack Temp, F
299.1
302.6
302.0
301.5
Stack Static (Guage) Pressure, "H20
-10.00
-10.00
-10.00
-10.00
Stack Gas Actual Pressure, "Hg
2929
.29.29
29.32
29.30
Average Sqn delta P
0.570
0.595
0.590
0.585
Rot Tube Coefficient
0484
0.84
0.84
0.84
Stack Gas Velooft, ftfsecond
39.92
41.77
41AI
41.03
Nozzle Inside Diameter, inches
0.311
0.311
0.311
Total Sample Time, rnin
240
240
240
240
Ilsokilnetic Rate,, %
99.10
106.2
104.2
103.5
Stack Dimensions 124 x 76 in.
124 x 76 in.
124 x 76 In.
Stack Area, sq ft
65.44
65.44
65.44
65.44
Stack Gas Flow Rate, aafm
156,M
164,000
162,000
161,100
Stack Gas Flow Rate, acmrn
Stack Gas Flow Rate, dschn
.4,437
$2,000
.4,644
95,400
4j604
84,400
4,562
83,933
Stack Gas Flow Rat, dscmm
2,322
Z418
1 2j390
2j377
Company: Wheelabrat" North Andover
Source: Unit No. 2 Outlet
Job -113: 04-2136
Train Type. ]EPA Method 23
Initial Meter Volume, W
Final Meter Volume, V
Intra -Port Leak Check Volume, ft3
Total Sample Volume, d
DGM Calibration Factor
Average DGM Temp, F
Average DGM delta H, "H20
Barometric Pressure, *Hg
Corrected Sample VolAsd
Corrected Sample VolAscm
-Oxygen, %
Carbon Dioxide, %
Nitrogen, %
Stack Gas Excess Air, %
Total Moisture Catch Welght grams
S -k GaS AlloWture, %
tac
Stack Gas Dry Molecular Weight, bfibrnole
Stack Gas Wet Molecular Weight, IbAbmole
Average Stack Temp, F
Stack Static (Guage) Pressure, "H20
Stack,.Gas Actual Pressure, 'Hg
Average So delta P
Pilot Tube C;oeffident
Stack Gas Wocity, ftfsecond
..Nozzle Inside Diameter, inches
Total SampleTime, min
Isokinatic; Rate,-%
Stack Dimensions
StISPAAM, aq ft
Stack Gas FlawlRate, achn
Stack Gas Flow Rate,
Stack Gaeflow Rate, doeft
Stock Gas Row Role, dscmm
1
2
4
'10127/04
10127104
lafnM
728-1138
1159-1609
1150-1601
Averaga
226 -SW
399.602
713.767
399.210
571.616
880.717
0109
os000
0.000
172.539
172.114
166.9,50
170.534
0.997
0.997
0.997
0.997
73.8
84..6
79.5
79.3
1150
1.46
1.39
1.46
30.06
30.06
30.23
30.12
171.507
167.671
165.079
168.086
,4.857
4.746
4.975
4.7,60
9.9
10.1
10.0
10so
.9.5
9.5
9.4
-9.5
$0.6
80.4
80.6
80.5
87.0
90.8
88.7
$8.8
890.7
871.4
836.6
866.2
19A
19.7
� 19.3
19.5
29.92
29.92
29.904
29.91
27.58
.27.57
27.61
27.59
.304.0
303.2
303.8
1j
'103.7
-9' ' 20
-9 ' 20
-9.20
-9.20
29.38
29.38
29.55
29A4
-0.689
0.578
0.567
0.578
0.84
0.84
0.84
0.84
41.07
40.29
39.40
40.25
0.311
0.311
0.311
240
.240
. 240
240
100.8
100.5
100.2
100.5
124 x 76 in.
124 x 76 In.
124 x 76 in.
65.44
65-.44
65.44
65.44
161,300
158,M
154,700
158,067
- 4.568
4,381
4,476
.880000
84=1
85,200
achwo
2.492
2,444
2,413
2,450
oil �! --oft-N-0-ft ---- a --- NW-NMO
�Iwzilw
oil
I !
RIB1 9 V _A.4 0--Cqcv d
9L
uj
Flo
Avg r4 9
MUMMIES 11 111 In
51 �s
6 th th Lb
dddo d dd
da-1111didid1d
d_ CA
Ik fit
log
I I jog 1 :5 1 -4 1 -N."! Hill I Nlailiffiflin
2
CNAPOW: Wheddwoor kofth Andovw
5
37.0
27-001-04
$Gums. Unk NIL I oudd
20-0cl-04
15.08
1326-1551
JObID.- 04-2130
11194338
Avemw
1;68
1.96
Train Type: EPA mow n
1.37
0.881
0.011
0.771
'WW I I VAIUM bdow I I lb SWU
0.802
0.940
0.932
NOW AvwapEWUAWM*Md@WrmWM"ft
8.02E-04
9ADE-04
9.32E-04
6.69E-04
2.27E-04
274)CW)4
2.511E-04
IME -04
7.WE-07
8.45E-07
1025-1241
UIE-07
Cadrnkun Toted Catch VK Lig
�ND(
0.2
Com. uofdwm
NO(
0.080
CoM. UGMSOM 07% 02
NO(
0.094
COM, M~ 07% 02
NO(
9.37E.05
Emission PAD. MW
NO(
2.65E-05
EffftSbn Ratel. bfMMBTU
NO(
8.42E.W
Lead Total Catch VK ug
i.0
Cone., LWdsorn
0.308
Conc.. tQfdsom @7% 02
0.469
Conc., mg/dscm @7% 02
4.69E -G4
Emissi,on Rate, bft
i.32E-04
Emission Rate, bWMBTU
4.21E-07
Mal-" Toted Catch Wt, ug
326
Conc� LQWS-
12.97
Conc., ug/dwrn @7% 02
Cakm. m~ @7% 02
16.28
0.016
r-I&I'M Fb*W
4.32E-03
EMbdDn P2* IWMMBTU
1.37E-05
2
3
5
37.0
27-001-04
26-Od-04
20-0cl-04
15.08
1326-1551
734-1010
11194338
Avemw
1;68
1.96
1.82
1.37
0.881
0.011
0.771
0.561
0.802
0.940
0.932
0.6"
8.02E-04
9ADE-04
9.32E-04
6.69E-04
2.27E-04
2.69E-04
2.511E-04
IME -04
7.WE-07
8.45E-07
8.37E-07
UIE-07
37.4
$5.0
24.6
37.0
15A6
34.33
10.42
15.08
17.85
40.78
12.59
17.92
0.018
0.041
0.013
0.018
5.06E-03
0.011
&39E-03
4.SeE-03
1.60r=-05
3.66E-05
1.13E-05
1.61E-05
26.6
106.5
50.4
54.0
10.78
43.01
21M
2203
IZ70
51.10
25M
2822
0.013
0.051
0.026
0.026
3.60E-03
0.014
0.94E-03
r24S4)S
1.14E-05
4.59E-05
Z32E-05
23SE-05
CompaW. Wheelabrator North Andover
Source. Unit No. I Outlet
Job ID: 04-2136
Train Type: EPA Method 5/26A
-IMO- derKin vskus bdow ddKtIon Mft
NoW Average 9XMDES NWs4pftd nm'resaft
Hydrogen Chloride
Ammonia
Catch Wt, mg
Conc., mQfdScm
Conc., mqIdscm @7% 02
Conc�, nVftom @12% CO2
Conc, Wwwd
Conc., ppmvd @7% 02
Cory-, ppmvd 012% CO2
Emission Rate, lb/hr
Errdssion Rate, b7AMBTU
Catch M mg
Conc., mgIdscm
Conc., rng/dscm @7% 02
Conc., mgldscm @ 12% CO2
Cone., ppmvd
Conc., ppmvd @7% 02
Conc.. ppmvd @12% CO2
Emission Rate. bfhr
Emission Rate, bWBTU
I
27-W-04
1255-1525
56.7
23.88
27.90
27.66
15.74
18.39
18.16
7,568
0.025
0.933
0.393
0.459
0.453
0.556
0.650
0.642
O.M
4.12E-04
2
2S -W-04
734-1018
63.8
27.21
32.05
M.39
17.93
21.12
20.69
8.581
0.029
2.166
0.924
1.088
1.066
1.307
1.540
1.508
0291
9.77E-04
3
28 -Oct -04
1119-1338
57.4
2425
29.67
28.53
15.98
19.4,q
18.80
7.848
0.027
2.101
0.888
1.082
1.044
1.256
1.531
1.478
0.287
9.72E-04
Average
59.3
25.11
2D.84
2DA6
16.65
19.68
19.22
Tgw
0.027
1.733
0.735
0.876
0.855
1.040
1.240
1.209
0.234
7.SM-04
Ell
th ds iho ibth�j dit
vi 0;.6 4 .6 14 4 d qcil:ci i.
Fla
-1! 1 4: An ?; I a qm 3 s4d
11111M _jJ; 11 wo 11111!
H M! UMA Oka Pl
s S! !b! g& !h I LFb 2 11 s 2 S n 56; 11
4s to ,i 6 ci id
E9 S
d2d.'ddgddd; dd d1dilloilddl Ift; Md
1;di1v91Md!5d IdMIM1115-1d'd 11! w;
d dg2;;; ddeddd ddd d
d
4,f
203
ling
p 111111-11 P1111 i
ai"Plil-Ho I inn 1 11 Ill
2
3
4
70-8
26-Od-04
CmaP=r Whnbbndor North Amlww
27-OCW
.25.16
11043-11266
SOWCO: UrA No. 2 00d
728-M
Average
4.02
Job Uk *I,"*
US
IAS
1.682
O=
TrWn Tps: IEPA U*MW 20
0.647
Z036
0363
0.916
WV " 1 1, b0owddIdleeffift
Z04E-03
ME -04
Q.i5E-04
829E-04
-6.20E-04
9.40E-05
- 2-34E-04
1.83E-05
2Wd-04
8.2211-07
7.44E-07
7364006
Cahlurn Total Catch VK ug
ND(
02
Cam, uqfdsom
MN
0.078
Conc., ug(&m.Q7% 02
NX
0.100
Com. mgftm 07% 02
ND(.
OME-05
Emission Rft, b4w.
ND(
, ZS"
BrJ$dm Rete, lb/MMBTU
ND(
0.97E -M
Load Total Catch Wt, Lig
2.1
Com. t#dsan
0.815
Cam, ugtdsom 07% 02
1.040
Corrm. mgtdscin @7% 02
1.05F-03
Emissiont Rate. bhr
2.69E-04
EmiWm Rate, lb/MMBTU
9.42E-07
mercury Total Catch VK ug
4&9
Conc,..uofdwn
17.04
Corrm, uofdacm @7% 02
OOM. M~ @?% 02
.211.93
-OAM
Emission Rd% Wr
5.62E.03
EmWm Rvft� bWW7U
1.97E-05
2
3
4
70-8
26-Od-04
25-Od-04
27-OCW
.25.16
11043-11266
1347 -ISM
728-M
Average
4.02
0.71
US
IAS
1.682
O=
0.718
0.647
Z036
0363
0.916
O.M
Z04E-03
ME -04
Q.i5E-04
829E-04
-6.20E-04
9.40E-05
- 2-34E-04
1.83E-05
3.2X -O7
8.2211-07
7.44E-07
WA
28.1
109.4
70-8
56.43
11.36
44.11
.25.16
7263
U.35
56.25
36.07
0.073
0.014
0.056
0.038
I.&M-02
3.72E-03
1.4SE-02
9.29E -M
6.52E-06
12DE-05
5.OSE-05
&24E-05
24.0
.25.2
27.9
31.0
0.445
11.40
11.25
12.28
IZIS
14.40
14.W
i&TI
0.012
OB14
0.014
0.016
&IOE-03
&74E-03
&73E-03
4.VSE-W'
1.0"
1.2"
1.2"
IME -05
Hydrogen Chlorlde
Ammonia
Catch VK mg
Corlr-. Mg/dwn
COM. MOMSCM 07% 02
Conc- nVklscm 012% CO2
cw-. ppmw
Corw� Rxmod 07% 02
Conc.. wmvd @12% CO2
Emission Rale. bRv
Emission Rate, b?AMBTU
Catch Wt, mg
Conc., mgIdscm
Conc- mgtdscrn 07% 02
COM- mgfdscm 012% CO2
Com-,, pMW
Co-, ppffTvd @7% 02
Cone., wmvd @12% CO2
Frnission:ftate, IW
Emission Rate, lb(MMBTU
I
264)ot-04
900-M2
56.7
23.83
30.67
30.11
1&71
20.22
19.84
7.820
0.028
2.254
0.947
1.219
1.197
1.341
1.725
1.693
0.311
I-lOE43
2
254)d-04
1164-1413
60.6
25.60
32-65
32-00
16.87
21.52
21.09
8.333
0.029
1.532
0.647
0.825
0.809
0.916
1.168
I.M
0.211
7.41E-04
3
25-OcW
1467-1708
OM
20.29
34.16
33.57
iT.33
22.51
22.12
8.637
0.031
1.481
0.623
0.809
0.795
0.882
11.45
1.125
0.205
7.27E-04
Average
59.9
25.24
32.49
31.89
16.64
21.41
21.02
ISM
0.020
1,756
0.739
0.951
0.034
1.046
1.346
1.321
8.55E-04
COM(Ony: Whadabrator North Andow
SOUMO.' Unit No. 2 Outlet
Job ID- "32
Train Type: EPA Method SMA
.11W �� M, VOW. . ., . . 'M� MMft
NO(W AVWWO EWLUDO Mwdiftdnm'rmft
Hydrogen Chlorlde
Ammonia
Catch VK mg
Corlr-. Mg/dwn
COM. MOMSCM 07% 02
Conc- nVklscm 012% CO2
cw-. ppmw
Corw� Rxmod 07% 02
Conc.. wmvd @12% CO2
Emission Rale. bRv
Emission Rate, b?AMBTU
Catch Wt, mg
Conc., mgIdscm
Conc- mgtdscrn 07% 02
COM- mgfdscm 012% CO2
Com-,, pMW
Co-, ppffTvd @7% 02
Cone., wmvd @12% CO2
Frnission:ftate, IW
Emission Rate, lb(MMBTU
I
264)ot-04
900-M2
56.7
23.83
30.67
30.11
1&71
20.22
19.84
7.820
0.028
2.254
0.947
1.219
1.197
1.341
1.725
1.693
0.311
I-lOE43
2
254)d-04
1164-1413
60.6
25.60
32-65
32-00
16.87
21.52
21.09
8.333
0.029
1.532
0.647
0.825
0.809
0.916
1.168
I.M
0.211
7.41E-04
3
25-OcW
1467-1708
OM
20.29
34.16
33.57
iT.33
22.51
22.12
8.637
0.031
1.481
0.623
0.809
0.795
0.882
11.45
1.125
0.205
7.27E-04
Average
59.9
25.24
32.49
31.89
16.64
21.41
21.02
ISM
0.020
1,756
0.739
0.951
0.034
1.046
1.346
1.321
8.55E-04
AIR QUALITY MODELING
ANALY�IS OF THE WHFF1 ARRATnR
NORTH ANDOVER FACILITY
M
M USING THE
1:]
OCTOBER 2004 PERFORMANCE
CERTIFICATION TEST DATA
Prepared for -
Wheelabrator North Andover, Inc.
C3
1=1 285 Holt Road
Im
North Andover, MA 01845
EPSILONASSOCIATES INC.
Engineers C3 Environmental Consultants
Prepared by:
M
Epsilon Associates, Inc.
M
C3
150 Main Street
Maynard, MA 01754
March 31, 2005
EPSILONASSOCIATES INC.
Engineers C3 Environmental Consultants
AIR QUALITY MODELING
ANALYSIS OF THE WHEELABRATOR
NORTH ANDOVER FACILITY
USING THE
OCTOBER 2004 PERFORMANCE
CERTIFICATION TEST DATA
Prepared for. -
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845
Prepared by:
Epsilon Associates, Inc.
150 Main Street
Maynard, MA 01754
March 31, 2005
u
TABLE OF CONTENTS
1.0
INTRODUCTION
2.0
SOURCE DESCRIPTION
3.0
METEOROLOGICAL DATA
4.0
MODELING ANALYSIS
5.0
RESULTS
REFERENCES
APPENDIX
I ]HendricklprojectslnandovetiOctO4lrep 1004.doc Page i
PAGE
1
2
3
4
6
Table of contents
I
I
I
E,
I
C,
I
I
1.0 INTRODUCTION
Wheelabrator North Andover (WNA) (formerly Massachusetts REFUSETECH Inc.) has
retained Epsilon Associates Inc. of Maynard, Massachusetts to perform an air quality analysis
for the municipal waste combustor facility in North Andover.
The air quality dispersion modeling is in response to Policy 91-001 of the Massachusetts
Department of Environmental Protection (DEP) that was adopted by the DEP to provide
guidance on the air quality impact analyses required for municipal waste combustors subject
to 21H Section 5C of the Massachusetts General Laws and 3.10 CMR 7.08. The 21H
legislation requires the operators of municipal waste combustors to test for dioxins and
furans in MWC emissions and ash every nine months. Wheelabrator also performs
additional stack testing for other pollutants that Massachusetts currently regulates, as agreed
to with the DEP regional office. In addition to the stack testing, dispersion modeling is
performed with the stack parameters measured during the testing to assess the air quality
impacts from the facility.
The modeling analysis is conducted in accordance with the methodologies described in the
revised modeling protocol (Hendrick, 2004). This report summarizes the air quality
dispersion modeling analysis for the North Andover facility. The stack parameters from the
October 2004 stack tests are modeled with a unit emission rate of 1 g/s. The model results
are then scaled by the pollutant emission rates determined by the October 2004 stack testing
to assess ambient impacts.
I V-IendrickorojectslnandovellOdO4lrep 1004.doc Page 1 Introduction
H
2.0 SOURCE DESCRIPTION
The WNA facility is located in North Andover, Massachusetts at UTM coordinates 326.293
krn east and 4732.393 km north (zone 19). These coordinates were identified through field
measurements using global positioning system (GPS) equipment. The coordinates obtained
from the GPS were then overlaid onto an orthographic image to validate their accuracy.
Figure 1 shows the WNA facility location on a USGS topographic map.
The base elevation of the facility is 66 feet (20.1 m) above mean sea level. The products of
combustion from each municipal waste combustor are emitted through individual flues of
one dual flue stack, the top of which is 230 feet (70.1 m) above ground level. Each
individual flue has an inside exit diameter of 7 feet (2.1 m). The stack diameter used in the
modeling is an effective diameter, that is the diameter of an effective stack that is equal in
area to the area of the two flues combined, (i.e., (square root of 2) * 2.1 m = 3.02 m). Based
on the October 2004 dioxin stack tests the Unit 1 flue had an average air flow rate of
161,100 ACFM and an average temperature of 301.51F. The Unit 2 flue had an average
flow rate of 158,067 ACFM and an average temperature of 303.71F. For modeling purposes,
that yields a stack gas exit velocity of 21.03 m/s and an average exit temperature of 423.5 0 K.
Table I summarizes the flue gas parameters from the stack test. The October 2004
PCDD\PCDF stack test parameters are presented in the appendix, along with the emission
rates for all of the pollutants.
Application of the Good Engineering Practice (GEP) formula to the facility structures
indicates a maximum GEP stack height for the facility of 307.5 ft (93.73 m). The main boiler
bui6ng is found to be the controlling structure with the structure's height of 123 ft (37.49 m)
being the critical dimension. Since the WNA'stack is 230 feet (70.1 m) in height (below GEP
height), building downwash effects were modeled in the ISCST3 dispersion modeling
analysis.
When conducting a dispersion modeling analysis, one needs to determine whether the land -
use pattern in the environs of the plant is urban or rural for modeling purposes. As described
in the revised modeling protocol, greater than 50% of the area within 3 km of the North
Andover Facility is rural for modeling purposes. . Therefore, rural dispersion coefficients are
used in the modeling analyses.
A closed landfill, wooded areas, and light to heavy industrial facilities characterize the
immediate vicinity of the site. Within 5 km of the site, elevations range from sea level to
greater than 108 m. The closest point at which the terrain height exceeds the facility stack
top elevation (90.2 m) is 2.25 km to the south-southeast at Osgood Hil L
DI IHendnckorojectslnandoveriOcIO41rep 1004.doc Page 2 . Source Description
I
3.0 METEOROLOGICAL DATA
Five years of surface meteorological data (1991-1995) collected by the National Weather
Service (NWS) at Boston's Logan International Airport have been acquired from the National
Climatic Data Center (NCDC) or the EPA SCRAM Bulletin Board and are used in the refined
modeling analysis. Logan Airport is located approximately 39 km to the south-southeast of
the facility site.
The historical five-year period, 1991-1995, of hourly meteorological data has not been
updated to reflect more recent data collection because National Weather Service offices
became automated after 1995. The observer at the stations was removed when the
automation process went into effect. A key observed parameter (total opaque sky cover) that
is necessary for stability class determination for dispersion modeling is no longer available
from the automated stations. Therefore, the period 1991-1995 is the most recent data set
with the appropriate parameters for use in dispersion modeling analyses.
The hourly surface observations include wind direction, wind speed, temperature, cloud
cover, and ceiling height. The surface data were combined with concurrent mixing height
data from NWS upper -air observations made in Portland and Gray, Maine. In September of
1994, the upper air station at Portland ceased operation and observations were resumed at
Gray, ME. Gray is approximately 20 miles north-northeast of Portland. The Portland surface
temperature -was used to initialize the soundings for all of the five years. These observation
sites were chosen because they are the closest stations to the project site that collect the
necessary meteorological data of the required quality for modeling studies.
P
11
I
I
R
nI lHendricktorojectsinandoverlOcto4LL-p 1004.doc Page 3 Meteorological Data
P
0 4.0 MODELING ANALYSIS
This refined air quality modeling analysis using the October 2004 stack test data follows the
revised modeling protocol that was submitted to DEP in July 2004.
The ISCST3 model (Version 02035) is a steady-state Gaussian plume model that can be used
to assess pollutant concentrations from a wide variety of industrial sources. It accounts for
plume rise as a function of downwind distance and can apply terrain adjustments to the
plume. ISCST3 also incorporates the COMPLEX I screening model algorithms for receptors
above stack top, i.e., complex terrain (receptor elevation above the plume height) and
intermediate terrain (receptor elevation between the release height and plume height). For
intermediate terrain receptors the model treats the receptor as both simple terrain and
complex terrain and retains the higher predicted concentration for that receptor for that hour.
A network of receptors was selected for the ISCST3 refined analysis of the facility to ensure
that the highest calculated concentrations will be captured by the mathematical modeling. A
discrete polar grid with thirty-seven concentric ring distances, centered on the stack and
combined with 36 radials at ten -degree intervals (i.e., 101, 201, ... 3601) was developed for
the modeling analysis. The refined modeling receptors were placed at the following
downwind distances: 100, 200, 300, 400, 500, 600, 700, 800, 900, 1000, 1100, 1200,
1300, 1400, 1500, 1600, 1700, 1800, 1900, 2000, 2200, 2400, 2600, 2800, 3000, 3200,
3400, 3600, 3800, 4000, 4500, 5000, 6000, 7000, 8000, 9000, and 10000 meters from the
stack. United States Geological Survey (USGS) 1:25,000 scale topographic maps were used
to hand-pick the receptor elevations. The closed landfill to the south of the facility is not
depicted on the USGS maps, therefore receptor elevations for the landfill area were obtained
from landfill site plans provided by the Massachusetts DEP. The highest terrain elevation in
each sector (defined as the area extending from one interval ring to the next downwind ring
bounded by the area extending halfway to each of the adjacent radials) was used to represent
the elevation for each receptor. In addition, discrete receptors were located along the
fenceline of the WNA facility. The polar grid receptors that lie inside the fenceline were
removed for the modeling analysis, so that offsite impacts are assessed. A total of 1322
receptors were modeled with ISCST3. The elevations assigned to each receptor in the
discrete polar grid are presented in Table 2 and the fenceline receptor locations and
elevations are presented in Table 3.
During the October 2004 stack tests both Unit 1 and Unit 2 were sampled. The refined
modeling was performed using a single stack with parameters derived from each flue. The
regulatory options of the ISCST3 model were used in the modeling analysis. The EPA
recommended options for plume rise, buoyancy induced dispersion, vertical potential
temperature gradients, treatment of calms, wind profile exponents, and enhanced dispersion
coefficients were selected. One non -default model option, HE>Zl, was also invoked to limit
the plume centerline height (HE) to be less than or equal to the mixing height (ZI). This is
important in situations when the receptor elevation is below the stack base elevation. Rural
I lHendrlckorojecisinandoveriOctO4lrt-p 1004.doc Page 4 ModelingAnalysis
E
11
I
0
11
N
11
E,
dispersion coefficients were used in the modeling analysis. The October 2004 stack test data
along with five years (1991-1995) of hourly meteorological data were used in the refined
modeling analysis. A unit emission rate of 1 g/s was used in the modeling to predict
normalized concentrations.
I V-IendrickorojectsinandovellOctO4 Irep 1004.doc Page 5 ModelingAnalysis
I
0 5.0 RESULTS
The highest normalized concentrations for several averaging periods for each of the five
years modeled are presented in Table 4. The overall highest normalized concentration for
each averaging period is summarized in the rightmost column of Table 4. The 24-hour and
annual average normalized concentrations were used to calculate the ambient air quality
impacts associated with the operations at the WNA facility.
The October 2004 PCDD/PCDF stack test data are presented in the Appendix. The October
2004 stack test data were used to calculate a dioxin emission rate using DEP's October 1991
Toxic Equivalency Factors. These emission rate calculations for Unit I and Unit 2 are
presented in the Appendix.
Annual average and 24-hour average ambient concentrations have been calculated using the
October 2004 stack test emissions data for trace metals, ammonia, hydrogen chloride and
dioxins. The predicted modeled concentrations for each pollutant are presented in the
Table 5. The modeled impacts for each pollutant are below the respective Massachusetts
DEP annual average AALs and the 24-hour average TELs.
I Wendrickorvjea� lnandoverlOdNlrep 1004. doc Page 6 Results
mPSILONASSOCIATES INC.
66Engineers 0 Environmental Consultants
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TABLE 1
Stack Parameters for the WNA Facility
Unit 1 Unit 2
Stack base elev. (m) 20.1
Stack height (m) 70.1
Stack diameter (m)
per flue
2.1 2.1
equivalent diameter
3.02
Air flow rate (ACFM)
161,100 1 158,067
Exit velocity (m/s)
21.03
Exit temp (F)
301.5 1 303.7
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Average Exit temp (K)
423.5
Building height (
37.49
Max. building width (m)
76.88
Stack location
UTM-E (km)
326.293
UTM-N (km)
4732.393
Note: Unit 1 and Unit 2 parameters from the Method 23 testing performed in October 2004.
I WendricklprojectslnandoveflOctO4 imp 1004.doc Page 8
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0)
N
N
N
0
0
W
N
N
N
'It
N
'It
N
-
N
0
M
M
M
N
4*
N
'IT
N
It
0
M
"t
N
r-
N
M
M
CD
M
N
1-
"T
0
LO
co
r-
w
-
0
0
0
0)
(D
LO
C14
P. -
en
04
0)
0)
cn
04
04
U)
Ul
W
"T
rl-
0
0
M
M
M
M
LO
Ict
-
0
-
U')
n
't
0
M
-
N
r-
N
M
M
co
M
N
"T
1-
U')
LO
0
00
0
(D
(0
C14
It
CN
'IT
(D
(D
U)
'IT
00
�T
0
LO
0)
cn
0)
't
'IT
Nr
r-
0
CD
0
0
m
m
(D
N
'IT
n
LO
I--
zT
M
U')
't
0
N
N
r--
0
0
-
N
to
M
M
M
M
M
M
I
M
I
M
M
Itt
lzr
N
N
M
U)
(D
rl-
tl-
LO
(D
(D
LO
�t
'IT
(0
r -
0
a
LO
04
N
0
It
r-
r-
M
M
M
0
r-
0
0
0
0
M
M
1,-
0
(D
0
t
r-
M
0
0
a
0
w
m
(o
N
C)
Go
C4
-
-
N
N
N
M
M
M
M
N
M
M
M
M
M
M
N
M
M
lq-
0
n
CD
0
W
0
(D
It
(D
0
r -
0
00
00
LO
04
0)
0
rl-
t-
m
m
m
0
0
0
0
[1-
r-
I-
rl-
r-
1-
0
M
M
M
M
0
0
1-
1-
0
0
M
0
04
N
00
00
OD
N
0
M
M
v
W
It
0
M
114*
N
N
V
M
V
M
Iq
N
't
M
M
-t
N
0
t
N
r-
0)
(0
(D
(D
It
U-)
U)
0
Ln
N
N
N
N
M
M
N
-
-
-
-
-
-
V
0
qzr
0
N
N
N
N
N
N
M
r.-
V
0
M
M
0
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
coc000000000000000000OOOOOCC)OCOOCOOOO
0000000000000000000000000000000C)CO000
in
0
-
C'4
m
v
000
r-
V-
T-
V-
V-
T--
V-
V-
M
M
M
M
M
V
v
Ln
%ID
co
M
0
It'.§
TABLE 3
FENCELINE RECEPTOR LOCATIONS AND ELEVATIONS
Receptor
Number
x
(M)
y
(M)
Elevation
(M)
1
-157.1
145.9
9.
2
-105.0
136.6
9.
3
-57.6
126.7
9.
4
-9.2
114.0
9.
5
39.3
101.5
12.
6
88.1
90.3
12.
7
136.8
79.0
9.
8
147.7
51.4
12.
9
147.5
3.6
15.
10
113.7
-26.4
21.
11
76.9
-60.2
24.
12
36.0
-91.2
24.
13
-13.1
-101.7
27.
14
-63.0
-99.0
24.
15
-110.2
-96.0
24.
16 1
-160.1
-90.9
24.
17
-163.0
-50.3
24.
18
-158.0
-4.4
21.
19
-157.7
45.6
18.
20
-157.4
95.6
12.
21
-157.2
135.6
9.
DI IHendrickiprojects[nandoverlOctO4lrL-p 1004.doc Page 12
(A
z
0
LLJ
0
ui
N
0
z
0
z
v;
D
W)
z
0
LU
co z
LU
u
z
0
u
u
LLJ
z
LL
LLI
ad
t"
E
E
3
t
V—
m
LM
c"
E
co
00
6
N Ln
Ln rn
co
N
LM
m
-
�.o 7:
Ln
0
f, _j_-
Ln
N
M
-"C
N N
00
0-)
Ln
C)
Ln
Ln
ro
rn
CN
co co
ko ro M
co N rn
Ln
I
0
co -C
C%4
Ln C'�
en rn CN
C14 N
ko Ln
N
L6
Ln
C4
Cj d
C5 d
0
rn
— CN
Ln
Ln
co
rn CO M
co 00 N
co
0)
6
0 -C 00
0 �: 6
N
0-6
00 -C
1,,
Ln
Ln
4000
N
rn
C)
0
rn
rn
Ln
Ln
0
co
M
Ln
M
rn
rn
00
00 00
-C
Ln 1.0
,T
m
N CN
�o wt
co
00 cq rq
m
C>
0
rq N C)
00
00
en
M M d
Ln
t,
0) M
o
en
CN
%6
rn M
CN
c;
Ln
CL
m
m
0
0
C
<
c
0
(3)
0
a
.2
E
w
u
c
Ln
c
c
0
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0
c C
0 0
E
0
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ce
TABLE 5
MAXIMUM ISCST3 (02035) AMBIENT CONCENTRATIONS
Pollutant
October 2004
Emission Rates
Unit 1 Unit 2
(lb/hr) (lb/hr)
ISCST3
Total (Units 1&2)
Modeled Concentrations
24 -Hour AnnualA
(jig/M3) (Ug/M3)
Ammonia (NH3)
2.34E-01
2.42E-01
1.09E-01
6.27E-03
Cadmium (Cd)
1.84E-04
2.1 3E-04
9.1 OE -05
5.23E-06
Lead (Pb)
4.96E-03
9.29E-03
3.27E-03
1.88E-04
Mercury (Hg)
7.24E-03
4.05E-03
2.59E-03
1.49E-04
Hydrogen Chloride (HCl)
7.999
8.264
3.73E+00
2.14E-01
(pgIM3)
PCDD/PCDF
(MA Toxic Equiv.)
8.77E-1 0
5.08E-09
N/A
6.2 3 E-04
' Assumes 90% Availability (based on five year average: 1996-2000)
I IHendrick0rojectsinandoverlOctO4lrep 1004. doc Page 14 References
REFERENCES
DEECO, 2004: Stationaty Source Sampling Report - Wheelabrator North Andover, Reference No.04-
2136, Test Dates: October 2004. DEECO, Cary, NC.
Hendrick, E., 2004: Air Quality Modeling Protocol for Emissions from Wheelabrator Notth Andover
Inc, Epsilon Associates. Inc. Maynard, MA.
I lHendrickorojects Inandoved0ct04 Irep 1004.doc Page 15 References
APPENDIX
Wheelabrator North Andover Stack Test Results
October 2004 Stationary Source Sampling Report, DEECO Inc., Cary, NC
Source Parameters for Modeling:
• PCDD/PCDF Flue Gas Parameters Summary, Unit #1
• PCDD/PCDF Flue Gas Parameters Summary, Unit #2
Emission Rates for Modeling:
• Three Run Average PCDD/PCDFs MA DEP Toxic Equivalencies Emissions, Unit #1
• Unit 1 Outlet: -Metals and Mercury Test Results
• Unit 1 Outlet: Hydrogen Chloride and Ammonia Test Results
• Three Run Average PCDD/PCDFs MA DEP Toxic Equivalencies Emissions, Unit #2
• Unit 2 Outlet: Metals and Mercury Test Results
• Unit 2 Outlet: Hydrogen Chloride and Ammonia Test Results
Company, Wheelabrator Worth Andover
Sourow. Unit No. I Outlet
Job ID: 04-21136
TralnType: EPAMethod23
Initial Meter Volume, 113
Final Meter Volume, fl:3
Intra -Port Leak Check Volume, ft3
Total Sample Volume, d
DGM Calibration Factor
Average DGM Temp, F
Average DGM delta H, "H20
Barometric Pressure, "Hg
Corrected Sample Vol,dscf
Corrected Sample Vol,dscm
Oxygen, %
Carbon Dioxide, %
NitroW,.%
Stack Gas Excess Air, %
Total MoIsWre Catch Weight grams
Stack.Gas Moisture, %
Stack Gas Dry Molecular Weight lbfibmole
Stack Gas Wet Molecular Weight lbfibmole
Average Stack Ternp, F
Stack Static (Guage) Pressure, "H20
Stack Gas ActualPressure, "Hg
Average Sqn delta P
Pilot Tube Coefficient
Stack Gas Velocity, ftfsecond
Nozzle Inside Diameter, inches
Total Sample rime, min
l8okinetic Rate,, %
Stack Dimensions
Stack Area, sq ft
-Stack Gas Flow Ratej acfm
-Stack Gas Flow Rate, acmm
Stack Gas Flow Rate, dscfm
Stack Gas Flow Rate, dscmm
1
2
3
1 U26104
1 Qr26104
10/27/04
735-1219
1255-1710
725-1140
Average
38.300
192.700
366 * 155
191.602
365.778
533.874
0.w
0.243
0.114
152.359
172.835
167.605
164.266
1.006
1.006
1.006
1.006
.59.5
67.6
63.1
63.4
1.49
1.67
1.57
1 ' 58
30.03
30.03
30.06
30;04
156-861
175-288
171.574
167-408
4.442
4.964
4�M
4.755
8.8
8.9
8.7
8 ' 8
10.6
10.5
10.8
10.6
80.6
80.6
80.5
80.6
70.5
71.9
69.3
70A
1004.7
1125.3
1118.5
1082.8
.23.2
23.2
23.5
.-23.3
30.05
30.04
30.076
30.05
27.25
27.24
27.24
27.24
299.1
302.6
302.8
301.5
-10.00
_10._00
-10.00
-10.00
29.29
29.29
29.32
29.30
0.570
0.595
0.590
0.585
0.84
0.84
0.84
0.84
39:92
41.17
41.41
41.03
0.311
0.311
0.311
240
240
240
240
106.2
104.2
103.5
124 x 76 in.
124 x 76 In.
124 x 76 in.
65.44
65.44
65.44
65.44
156,700
IKOOO
162,600
161,100
4,437
4,644
A604
4,562
82,000
85,400
84ACO
83,933
2,322
Z418
. 2j390
2j377
I
I
I
E,
I
I
I
I
Company: Wmelabrator North Andover
Source: Unit No. 2 Outlet
Job -11): 04-2136
Train Type. EPA WOW 23
Initial Meter Volume, f13
Final Meter Volume, ft3
Intra-Poit Leak Check Volume, ft3
Total Sample Volume, d
DGM Calibration Factor
Average DGM Temp, F
Average DGM deft H, "H20
Barometric Pressure, *Hg
Convcted Sample VolAsd
Corrected Sample -VolAscm
Oxygen, %
Carbon Dioxide, %
-N&oW, %
Stack Gas Excess Air, %
Total Moisture Catch Welght, grams
Stack Gas Allolftire, %
Stack Gas Dry-Malecular Welot, JMbrnole
Stack Gas Wet Molecular Weight, lbfibmole
Average Stack Temp, F
Stack Static (Guage) Pressure, "H20
Stack.Gas Actual Pressure, "Hg
Average W deft P
Pitot Tube Coefficient
Stack Gas VOlocifyj ftfsecond
Nozzle Inside Diameter, inches
Total Sample'nme, min
lsokinetic Rate,-%
Stack Dimensions
:Stw*.Area, sq ft
Stack Gas FlowlRate, acftn
-Stack Gas Flow Rate, acmm
Stack Gaeflow Rate, dadm
Stack Gas Flow Rele, dsomm
1
2
4
1 OW/04
1 W27/04
IW28/04
728-1138
1159-1609
1150-1601
Average
226-M
399.602
713.767
399.210
571.616
880.717
OA09
U00
0.000
172 '539
172.114
166.950
170.534
0297
0.997
0.997
0.997
73.8
84,.6
79.5
79.3
1.50
1.46
1.39
1.46
30.06
30.06
30.23
30.12
171.W7
167.671
165.079
168.086
4.857
4.748
4.475
4.7,60
9.9
10.1
10.0
110.0
9.5
9.5
9.4
.9.5
80.6
80.4
80.6
80.5
87.0
90.8
88.7
88.8
890.7
871.4
MA
866.2
19we
19.7
� 19.3
19.5
29.92
29.92
29.904
29.91
.27.68
.27.57
.27.61
27.59
304.0
303.2
303.8
303.7
-9.20
-9.20
-9.20
-9.20
29.38
29.38
29.55
2944
0.589
0.578
0.567
0.578
0.84
0.84
0.84
0.84
41.07
40.29
39.40
40.25
0.311
0.311
0.311
240
.240
. 240
240
100A
100.5
100.2
100.5
124 x 76 In.
124 x 76 In.
124 x 76 in.
65.44
65,44
65.44
65.44
161*,=
iW,=
154,700
158JW
4.568
4,480
4,381
4,476
.88,000
Km
85,200
86,500
2,492
2,444
2,413
2,460
---- a --- No -,:!V:!
ilipwill th th I
; ; —:A 15
ci r.: ld --44 N 4 dl -,WW
1-02HOW 141111.11.11111
�i r�: fd Nt ;- 'M 1� - C4 w v F�
NNt !w % z a
doMll !8MOAH"amp
ci .1
a 0 0 0 0 — e e gel e e
9 6- T Z�, S 2 llig"09;8 s2c�-111;9 %9�
N 4 C4 wi " 46 6 . . . . . .. . . �� � �R . . .
--mov- cli C4 w 14.0
"I Sol
dN Mdddd d d ;;a oz.
dA d, a 0'a
fit
4XI
Hilt ppill 1111, 1
I I ic-"I -4 1111 Wiliffilml 16
e t: r
h& 10 th
FS
�i 64 C4
cis
Hplipri
Ha
c4 .6 .6 A .6
i 14 4 4 -d
4 ad A.4 z �z
C4 4
NNt !w % z a
doMll !8MOAH"amp
ci .1
a 0 0 0 0 — e e gel e e
9 6- T Z�, S 2 llig"09;8 s2c�-111;9 %9�
N 4 C4 wi " 46 6 . . . . . .. . . �� � �R . . .
--mov- cli C4 w 14.0
"I Sol
dN Mdddd d d ;;a oz.
dA d, a 0'a
fit
4XI
Hilt ppill 1111, 1
I I ic-"I -4 1111 Wiliffilml 16
3
C=nMW: WhftUbrOW NWO Andftw
37.0
284)d-04
2B-OCI-04
15.08
Scuirce. Unit NIL I Oudst
111194338
Aver"e
1.96
1.82
Job -10. 04-2136
0.011
01771
0.561
0 ' 940
0.932
Tndn Type: EPA now n
0.40E-04
9.3212-04
6.09E-04
2.SM-04
2.51E-04
'KW d0dw vahm below I I ", bdb
8.45E-07
8.37E.07
&OIE-07
NOW AV-PfiWCUA)WMav-*Wr&wWmuft
1
2
274)d-04
27-Od-04
1025-1241
1326-1551
CsdmKjM Total Catch YK ug
ND(
0.2
148
Com. uofdwm
ND(
0.080
0.881
COM. LIONSM 67% 02
NO(
0.004
0.802
Carr-, M~ 07% 02
ND(
9.37E.05
8.0211-04
Emissim Rate. bft
ND(
265E45
2-27E-04
BnbSW Rate, lb/MMffTU
ND(
8.42E.W
7.2DE-07
Lead Total Catch Wt, ug
1.0
37.4
Cone., uofdscm
0.398
15.15
Conc.. LaIdsom @7% 02
0.469
17.85
Com., mgIdscm @7% 02
4.69E-04
0.0118
Emls� Ftabe� ROY
1.32E-04
5.06E-03
Emission Rate, bWMBTU
4.21E-07
1.60E-05
memuly Total Catch VK ug
32-6
26.6
CDnr- LqWscm
12.97
10.78
Com. ugfdscm @7% 02
16.28
IZ70
COnC.. nVAlscm 4D7% 02
0.016
0.013
Enftdan P^ W
4.32E-03
3.60E-03
EpAidDn Pade, bWMBM
1.37E-05
1.14E-05
3
5
37.0
284)d-04
2B-OCI-04
15.08
734-1010
111194338
Aver"e
1.96
1.82
1.37
0.011
01771
0.561
0 ' 940
0.932
0.669
0.40E-04
9.3212-04
6.09E-04
2.SM-04
2.51E-04
U415-04
8.45E-07
8.37E.07
&OIE-07
85.0
24.6
37.0
34.33
10.42
15.08
40.78
12.59
17.92
0.041
0.013
0.018
0.011
3.39E-03
AIME-03
3.66E-05
1. 1 3E-05
1.61E-05
106.6
SDA
54.0
43.01
21.35
2203
51.10
2rL&O
2822
0.051
0.026
0.026
0.014
6.94E-03
T24M
4-99E-05
7-32E-05
2 -WE -W
CoffWaw. Whealabrator North Andover
Source. unkNo.loutist
Job 11): 044136
Train Type: EPA Method UM
-MW duKtH Vdan bdw detwOm koft
Aloft* Amage EXMDES Nbn-dMdnuulmsuft
Hydrogen Chloride
Ammonia
Catch VVL mg
Corte-, mgfdscrn
Corte., mg/ds= @7% 02
Cow, mg/dscm Q 12% CO2
Corr-, ppnwd
Conc., ppmvd 07% 02
Conc., ppmvd 012% CO2
Errfs" Rate, ItVhr
Errdssion Rate, b(MMBTU
Catch VVI. mg
Conc., mgldscm
Conc., mg/cIscm @7% 02
Cone., mg/cIscm @12% CO2
Conc., ppmvd
Corte.. ppmVd @7% 02
Corr-, ppmvd 012% CO2
Efftssion Rate, b/hr
EMLRSIM Rate. MWBTU
1
27-W-04
1258-1525
56.7
23.88
27.90
27.66
15.74
18.39
18.16
7.568
0.025
0.933
0.393
0.459
0.453
0.556
0.650
0.642
0.125
4.12E-04
2
28 -Oct -D4
734-1018
63.8
27.21
32.05
31.39
17.93
21.12
20.69
8.581
0.029
2.166
0.924
LOBB
1.086
1.307
1.540
1M8
0.291
9.7TE-04
3
28-W-04
M9-1338
57.4
24.25
29.67
28.53
15.98
19.49
18.80
7.848
0.027
2.101
0.888
1.082
1.044
1.256
1.531
1.478
0.287
9.72E-04
Average
59.3
25.11
29.84
29A6
16.55
19.66
19.22
T9w
0.027
1.733
0.735
0.876
0.855
1.040
1.240
1209
0.234
7.87E-04
10-Him1h; co ------------
d.� 44 -4 W
06 doo
T:
1-H I 1� I ;: :H "
all 0:::::: 0:: 0 T! F 0::F09 �:F:: 0 -_ v a v
H, t I ch &b A L4 Lb i , 0
�! ;; cc! t 4 0
fig
F, -;M; a
11PHIM111i W _11!
_W J Sd . 4 - n id
I 'S 02 S �6� 2 2 2 1 Sh 2 11 Si 18h tt� I ! S 2 2
C4 w
d3d.'dd4ddd; dd dddilit"did 119; NO!
4dd 9 d ddd d id
lidd F4 Iff
d Fd Vd d doo dddd- 14 ow! d
Hit Pq 'M
P. 4
2
3
4
70.8
26-Od-04
CmMbMr WhnbbraW NOM Andow
27-OCNK
.28.18
11843-11256
SOWCO: UPA ft 2 Oudst
728-040
Averap
4.02
Job Uk 4"138
1.7B
IIAIS
1.W2
0.2117
Tralb Type: EPA lkl� 29
04647
2.036
0263
0.915
" V*MbdciwdMsdlon boo
2.04E-03
3S3E-04
MISE -04
NOW Av&sp 0=00 Nvn4kIW nm' ream
-6.20E-04
9.40E -W
2 -ME -04
IAEM
28-W-04
8.22607
7.44E-07
736-1006
Caftlum Total Catch YK Log
ND(
02
Cono., ugfdecm
NX
0.078
Own, ugfdsorn.@7% 02
Kq
0.1101)
Corka., R*ib= 07% 02
W.
9.99E.05
EmWon Pala, Mw.
ND(
.2.5"
Sr&mgon Rate. bMMBTU
NX
S.gMm
LOW Total Catch Wt, ug
2.1
Com, ugfdsm
0.815
Cam, uqfdscrn @7% 02
1.040
Corr-, mgIdscrn @7% 02
1.05F-03
Em"lon Rats, b1hr
2.69E-04
Emission Rate, lb/MMBTU
9.42E-07
Mora" ToW Catch Wt. ug
43.9
ODrr-.,Lgfdg=
17.04
Cow-, u9fdoom @7% 02
Ocno., mgfdwm @7% 02
211M
Am
Emb" Rat% Wr
6.82E-03
Emission PAM� bUMSTU
1.97E-05
Li
2
3
4
70.8
26-Od-04
28-W-04
27-OCNK
.28.18
11843-11256
1347 -IOU
728-040
Averap
4.02
.0.71
1.7B
IIAIS
1.W2
0.2117
0.718
04647
2.036
0263
0.915
.0.820
2.04E-03
3S3E-04
MISE -04
-6.20E-04
9.40E -W
2 -ME -04
IAEM
3.2K-07
8.22607
7.44E-07
MA
28.1
109.4
70.8
56.43
11.36
44.41
.28.18
72.63
14.35
56.25
36.07
0.073
0.014
0.056
0.036
1.8611-02
3,72E-03
1.46E-02
92DE-03
6.52E-05
12DE-05
5.OSE-05
3.24E-05
24.0
.25.2
27.9
31.0
9.445
11.40
11.25
1228
IZ16
114.40
W11
-0.012
OD14
0.016
&IOE-W
&74E-03
&73E-03
4VSE-W
I.OGE-05
1.20E-05
.12DE-05
IME -05
COMPOW: Whodabralor North Andover
soures: unituo.2oullet
Job VP "22
Thdn Type. EPA 1101hod MM
-IW' � V*k=" -0 11 ' I", loft
Abft AVWW@ OUR= MM14bbeimns m&ft
Hydrogen Chloride
Catch VK nV
Conc.. nighlow
COMM, ftVft= @7% 02
Cone., ffWdson @12% CO2
Conc., pMW
Cw� pMW @7% 02
Conc.. wnvd @12% CO2
EmWslon Rate. bhr
EvnlWon Rate, bUMBTU
Catch Wt, mg
Conc., mghiscrn
Conc.. m9ldsm 07% 02
Co--, m9/dscm 012% CO2
Cone., ppmyd
Conc., ppffwd @7% 02
Conr., ppfftwd 1@ 12% CO2
Ernissiori-Rate, b1hr
EmhWm Rate, IUWBTU
I
26-Od-04
QWII12
56.7
23.83
30.67
30.11
M71
20.22
19.84
7.820
0.028
2.254
0.947
1219
1.197
1.341
1.726
1.693
0.311
I.IDE-03
2
26,OcW
1154-1413
6D.6
26.60
32.65
32.00
16.87
21.52
21,09
8,333
0.029
1.532
0.647
0.825
0.8w
0.916
1.168
1.145
0.211
7.41 E-04
3
26 -Oct -04
1457-1706
(IM
26.20
34.16
33.57
17.33
22.51
22.12
8.637
0.031
1.481
0.623
0.809
0.795
0.882
1.145
1.126
0.205
7-rM-04
Average
59.9
2524
32.49
3149
I&S4
21.41
21.02
0.020
1.756
0.739
0.951
0.934
1.046
1.346
1.321
8-sME-04
AWheelabrator North Andover Inc.
A Waste Management Company
285 Holt Road
North Andover, MA 01845
(978) 688-9011
(978) 794-8058 Fax
April 4, 2005
Director, Air Compliance Programs
EPA New England
1 Congress Street (Mail Code: SEA)
Boston, MA 02114-2023
ATTN: Air Compliance Clerk
RE: MASS FIRING RATE REPORT
Dear Sir or Madam:
L.J
OFFICE Of i UV4N MANAGEN
This letter serves as notice that Wheelabrator North Andover Inc. did not exceed its
mass -firing rate for the period January 1, 2005 through March 31, 2005.
Sincerely,
Scott T. Emerson
Plant Manager
cc: File
MA DEP
North Andover Town Manager (2)
North Andover Board of Health
Wheelabrator -Hampton
a
V490
W"TE Moid"EMEW
A.L. Wheelabrator North Andover Inc.
WA Waste Management Company
i85 Holt Road
North Andover, MA 01845
1978) 688-9011
1978) 794-8058 Fax
May 3, 2007
Town of North Andover
Board of Health
1600 Osgood Street
Building 20, Suite 2-36
North Andover, MA 01845
Dear Sir/Madam:
177,
MAY 10 20p
TO W N 0 F N 0 R T'HANDUv1.,SR
HEALTH DEPART'V'TEINT
Enclosed are the tonnage receipts at'--�Whee�labrat�or-No�rt --A—,nd—over-1ffc—.-f0)r the calendar
month April 2007.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
information, the information submitted is to the best of my knowledge and belief true, accurate
and complete.
If you should have any questions, please contact me at 978/688-9011.
Very truly yours,
Jul ' M. Maccini
Plant Controller
cc: file
4.1.14
s/monthlyreportsnoandover
I
WVRIJ'�QD
WASTE AAAALAGEMENT
AvL
SUMMARY OF TOTAL REFUSE RECEIVED
Total WIVI Private
Contract INTER P -H Hauler Grand
Date Communities COMPANY Spot Subtotal Total
01 -Apr
0.00
0.00
0.00
0.00
0.00
02 -Apr
1,146.21
621.15
290.96
912.11
2,058.32
03 -Apr
1,072.22
597.30
357.00
954.30
2,026.52
04 -Apr
1,093.75
558.71
247.68
806.39
1,900.14
05 -Apr
910.90
487.83
399.04
886.87
1,797.77
06 -Apr
696.87
517.19
399.11
916.30
1,613.17
07 -Apr
58.70
66.17
50.53
116.70
175.40
08 -Apr
0.00
0.00
0.00
0.00
0.00
09 -Apr
1,098.26
523.42
256.37
779.79
1,878.05
1 O -Apr
846.98
534.24
262.20
796.44
1,643.42
11 -Apr
967.16
571.49
302.77
874.26
1,841.42
12 -Apr
941.96
582.36
334.81
917.17
1,859.13
13 -Apr
794.33
684.63
273.88
958.51
1,752.84
14 -Apr
47.85
34.29
62.69
96.98
144.83
15 -Apr
0.00
0.00
0.00
0.00
0.00
16 -Apr
54.03
821.53
221.48
1,043.01
1,097.04
17 -Apr
1,190.92
630.24
339.93
970.17
2,161.09
18 -Apr
1,052.86
770.77
372.98
1,143.75
2,196.61
19 -Apr
1,153.43
601.14
323.69
924.83
2,078.26
20 -Apr
1,037.78
469.93
352.92
822.85
1,860.63
21 -Apr
773.56
51.17
119.43
170.60
944.16
22 -Apr
0.00
0.00
0.00
0.00
0.00
23 -Apr
1,173.70
435.76
382.09
817.85
1,991.55
24 -Apr
1,032.17
446.14
350.16
796.30
1,828.47
25 -Apr
1,224.74
580.47
315.27
895.74
2,120.48
26 -Apr
999.85
401.48
347.72
749.20
1,749.05
27 -Apr
718.18
437.61
339.65
777.26
1,495.44
28 -Apr
58.29
46.14
99.04
145.18
203.47
29 -Apr
0.00
0.00
0.00
0.00
0.00
30 -Apr
1,170.64
415.95
391.20
807.15
1,977.79
WEEK #1
4978.65
2848.35
1744.32
4592.67
9571.32
WEEK #2
4696.54
2930.43
1492.72
4423.15
9119.69
WEEK#3
5262.58
3344.78
1730.43
5075.21
10337.79
WEEK#4
5206.93
2347.60
1833.93
4181.53
9388.46
CALENDAR
MONTH
21,315.34 11,887.11 7,192.60 19,079.71 40,395.05
FISCAL
MONTH
20,144.70 11,471.16 6,801.40 18,272.56 38,417.26
Commonwealth of M SSC-19husetts NRECEIVED
City/ I wn T OCT 16 2006
System Pu .. m 1. pingvRecord TOWN OF NORTH ANDOVER
Form 4 LT U'
L!!HEA HDEPARTMENT
A. Facility Infonation, L C4 Qq 4
System Owner:_ J 610 -1 1
Address: Telephone Number
B. Pumping Record
1. Date of Pumping C� 1716- b
atDe 2. Quantity Pumped: Gallons
3. Type of system: Cesspool(s) CSeptiC Tank Tight Tank Grease Trap
Other (describe):
4. Effluent Tee Filter present? Yes No
5. Condition of System:
6. System Pump'e,d,By:
Name
Company: Rooterman 12 East Dracut Rd. Methuen, MA 01844
7. Location where contents were disposed:
Signature of Hauler y �v UUUVUV\1
Signature of Receiving Facility
If yes, was it cleaned? Yes No
Vehicle License Number
Date
AL WheelabratorNotfh Andover Inc.
A Waste Management Company
t_25�H_oltRoad
"North -And6v_erW 01845
078) 688-9011
(978) 794-8058 Fax
May 21, 2007
Susan Sawyer
North Andover Board of Health
1600 Osgood Street
Building 20, Suite 2-36
North Andover, MA 01845
Dear Susan:
MAY 2 2 2ov
TOWN OF tqCp,
_IHIIEAITH
Due to an unforeseeable circumstance in the units we will be re -testing the
quarterly stack test to the following days
Date(s) Unit Test Parameter(s)
Week of June 4, 2007 Unit 1 & 2 PCDD/PCDF
Thank you for your co-operation.
Please call me if you have any questions.
Sinc��ely,
Pete/ J. Marrinan
Environmental, Health and
Safety Compliance Director
Copy: File
Dana Buske —Tech Environmental
2007-4-16 NAnd.doc
6
w1vae
WASTE MANAGEMENT
Alm—Wheelabrator Notth Andover Inc.
A Waste Management Company
285 Holt Road
North Andover, MA 01845
(978) 688-9011
(978) 794-8058 Fax
October 24, 2007
Town of North Andover
Board ofHealth
1600 Osgood Street
Building 20, Suite 2-36
North Andover, MA 0 1845
Dear Sir/Madam:
REC.'s'S"" E 0
OCT 2 9 2007
TOWN OF NORTH APDOVER
HEALTH DEPARTiOENT
Enclosed are the tonnage receipts at Wheelabrator North Andover Inc. for the calendar month
September 2007.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering information,
the information submitted is to the best of my knowledge and belief true, accurate and complete.
If you should have any questions, please contact me at 978/688-9011.
Very truly yours,
Ju* M. Maccini
Plant Controller
cc: file
4.1.14
s/monthlyreportsnoandover
N
W%Una
WASTE MANAGEMENT
SUMMARY OF TOTAL REFUSE RECEIVED
Total WIVI Private
Contract INTER P -H Hauler Grand
Date Communities COMPANY Spot Subtotal Total
26 -Aug
17.35
(17.35)
(0.01)
(17.36)
(0.01)
27 -Aug
1,159.12
282.22
299.62
581.84
1,740.96
28 -Aug
842.17
232.76
262.34
495.10
1,337.27
29 -Aug
1,063.26
317.31
1644.91
574.83
1,638.09
30 -Aug
1,066.59
325.91
378.15
704.06
1,770.65
31 -Aug
786.87
406.89
416.25
823.14
1,610.01
01 -Sep
40.18
41.27
66.77
108.04
148.22
02 -Sep
0.00
0.00
0.00
0.00
0.00
03 -Sep
0.00
246.87
15.81
262.68
262.68
04 -Sep
1,223.07
268.08
437.88
705.96
1,929.03
05 -Sep
1,090.98
255.88
368.95
624.83
1,715.81
06 -Sep
1,422.08
294.15
350.85
645.00
2,067.08
07 -Sep
11181.93
335.49
388.45
723.94
1,905.87
08 -Sep
703.91
71.42
114.71
186.13
890.04
09 -Sep
0.00
0.00
0.00
0.00
0.00
1 O -Sep
1,041.13
329.27
430.16
759.43
1,800.56
11 -Sep
825.16
203.80
292.69
496.49
1,321.65
12 -Sep
1,132.21
387.23
386.64
773.87
1,906.08
13 -Sep
934.15
276.98
450.60
727.58
1,661.73
14 -Sep
637.42
318.70
398.00
716.70
1,354.12
15 -Sep
50.37
19.29
62.21
81.50
131.87
16 -Sep
13.61
0.00
(13.61)
(13.61)
0.00
17 -Sep
1,109.28
254.34
361.20
615.54
1,724.82
18 -Sep
931.74
135.69
317.94
453.63
1,385.37
19 -Sep
1,196.11
198.26
332.12
530.38
1,726.49
20 -Sep
992.92
192.34
320.28
512.62
1,505.54
21 -Sep
750.73
232.16
267.69
499.85
1,250.58
22 -Sep
50.70
7.08
59.29
66.37
117.07
23 -Sep
2.15
0.00
(2.15)
(2.15)
0.00
24 -Sep
1,072.81
187.75
259.44
447.19
1,520.00
25 -Sep
910.79
217.85
264.43
482.28
1,393.07
26 -Sep
1,113.97
243.48
242.30
485.78
1,599.75
27 -Sep
1,007.30
151.49
351.13
502.62
1,509.92
28 -Sep
726.28
241.07
341.23
582.30
1,308.58
29 -Sep
37.34
3.67
68.89
72.56
109.90
30 -Sep
0.00
0.00
0.00
0.00
0.00
WEEK #1
4975.54
1589.01
1680.64
3269.65
8245.19
WEEK #2
5621.97
1471.89
1676.65
3148.54
8770.51
WEEK #3
4620.44
1535.27
2020.30
3555.57
8176.01
WEEK#4
5045.09
1019.87
1644.91
2664.78
7709.87
WEEK #5
CALENDAR ]=20,198..'�2
5,113.61
6,933.90
12,047.51
32,245.83
MONTH
FISCAL
25,133.68
6,661.35
8,547.77
15,209.12
40,342.80
MONTH
11
COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF WASTE PREVENTION
PUBLIC NOTICE
Notice is hereby given that the Department of Environmental Protection, acting in accordance with the provisions of M.G.L.
Chapter 111, Section 142A through 142E, will offer for public comment the following Draft Emission Control Plan Approval
issued pursuant to 3 10 CMR 7.08(2), and the following Streamlined Draft Operating Permit issued pursuant to 3 10 CMR 7.00:
A � -4;, ('
The Draft Emission Control Plan Approval and Streamlined Draft Operating Permit are for:
FACILITY NAMES: Wheelabrator North Andover, Inc.
APPLICANTS: Scott T. Emerson
ADDRESSES: c285�-H6lFRb-ad7North Andover, MA 0 1845
TRANSMITTAL NOS.: 20169 (Emission Control Plan Approval)
96402 (Operating Permit)
A6
AUG 2 7 2007
TOWN OF NORTH ANDOVER
HEALTH DEPARTMENT
The Draft Emission Control Plan Approval is being re -issued in accordance with 310 CMR 7.08(2)0)7. The purpose of 310
CMR 7.08(2) is to provide emission limitations for the control of certain designated pollutants emitted from Municipal Waste
Combustors (MWCs), in accordance with the requirements contained in Sections I I I (d) and 129 of the Clean Air Act. 3 10 CMR
7.08(2) establishes requirements for the following: Operating Practices (Carbon Monoxide [CO], Flue Gas Temperature, Load
Level), Metals (Mercury [Hg], Lead [Pb], Cadmium [Cd]), Particulate Matter (PM), Opacity, Organics (Dioxins/Furans), Acid
Gases (Sulfur Dioxide [S021, Hydrogen Chloride [HCII), Nitrogen Oxides [NO.], Fugitive Ash Emissions. The Draft Emission
Control Plan Approval is being re -issued to include an ammonia (NIJ.-4) (�mission limit in the Emission Control,. lF.P. Appr-s�. al
previously issued on June 9, 1999.
The Draft Operating Permit is being re -issued in accordance with 310 CMR 7.00: Appendix C(6). The purpose of the Draft
Operating Permit is to codify all of the facility's applicable requirements under the state and federal Clean Air Act, including
monitoring, record keeping requirements, and emission limitations into a renewable Operating Permit. This action is required by
the U.S. Environmental Protection Agency (USEPA) as stated in its final rule approving the Department's Operating Permit
program (Federal Register Vol. 61, No. 95 Wednesday May 15, 1996). The Department re -issued the Draft Operating Permit to
allow public comment on the Streamlined Draft Operating Permit. The Streamlined Draft Operating Permit streamlines all of the
applica ble requirements by listing in bold the most stringent requirements, which ensures compliance with all subsumed
emissions limits, record keeping, reporting, and monitoring requirements previously detailed in the Operating Permit issued on
December 22, 2004. The facility is subject to all applicable requirements contained in the Operating Permit, as well as, all existing
regulations and Approvals subsumed in the Draft Operating Permit. On May 10, 2006, EPA deleted the requirement for large
MWCs to comply with 40 CFR Part 60, Subpart E. Therefore, the Department amended the Draft Operating Permit to delete all
references to applicable requirements under 40 CFR Part 60, Subpart E.
The public comment period will extend until September 21, 2007. Under the provisions of M.G.L. Chapter 30A and 3 10 CMR
7.08(2)0)7., after the close of the public comment period, the Department will modify the Emission Control Plan. Under the
provisions of M.G.L. Chapter 30A and 3 10 CMR 7.00: Appendix C(6)(f), a public hearing on the Draft Operating Permit may be
requested by any person who submits a written request to the Regional Office, stating the nature of the issues to be raised at a
public hearing. Based on the written request, the Department will determine if a public hearing will be held and a 30 -day written
notice will be given. The duration of the public comment period shall automatically extend to the close of the public hearing as
provided for at 3 10 CMR 7.00: Appendix C(6)(g).
Comments may be presented in writing until 5:00 PM on September 21, 2007. Please submit three copies of any written
testimony. Written testimony shall be submitted to the:
Department of Environmental Protection
Metropolitan Boston/Northeast Regional Office
205B Lowell Street, Wilmington, Massachusetts 01887
ATTENTION: James E. Belsky, Permit Chief, Bureau of Waste Prevention
Copies of the Draft Emission Control Plan Approval, Draft Operating Permit, and background information, including the
facility's Streamlining Demonstration will be available for inspection at the Regional Office listed above by calling Cosmo
Buttaro at (978) 694-3281.
By Order of the Department
Arleen O'Donnell
Commissioner
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY &. ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
NORTHEAST REGIONAL OFFICE
UV �
205B Lowell Street, Wilmington, MA 01887 9 (978) 694-3200
DEVAL L. PATRICK
Governor IAN A. BOWLES
Secretary
TIMOTHY P. MURRAY
Lieutenant Governor AUG 2 2 2007 ARLEEN O'DONNELL
Commissioner
Mr. Scott T. Emerson RE:
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845 F-R-EC-EMVE-D--�
Dear Mr. Emerson:
AUG 2 7 2007
TOWN OF NORTH ANDOVER
HEALTH DEPARTMENT
NORTH ANDOVER - Metropolitan
Boston/Northeast Region
3 10 CMR 7. 00: Appendix C
Application No. MBR-95-OPP-0 12
Transmittal No. 96402
Draft Operating Permit
� I The Department of Environmental Protection ("MassDEP") has determined that the
revisions to the Operating Pen -nit Application for the Wheelabrator North Andover, Inc. facility
located at 285 Holt Road in North Afidover are administratively and technically complete afid
hereby re -issues the enclosed Draft Operating Permit for the subject facility.
This Draft Operating Permit is being re -issued in accordance with 310 CMR 7.00:
Appendix C of the Air Pollution Control Regulations ("the Regulations"), as adopted pursuant to
M.G. L. c. I 11, §§ 142 A through E inclusive.
MassDEP has reviewed and approved your Streamlining Demonstration, and has
determined that the Draft Operating Permit contains streamlined requirements that are the most
stringent requirements applicable to your facility. The Draft Operating Permit includes the
streamlined emission limits/standards shown in bold face type, monitoring, record keeping, and
reporting requirements, which subsume all applicable requirements that are at least as stringent
or less stringent than the streamlined requirements. The citations to the subsumed requirements
are listed under the Applicable Regulation and/or Approval Number column. Your facility is
subject to all applicable requirements contained in this Operating Permit, as well as, all existing
regulations and Approvals subsumed in this Draft Operating Permit.
On May 10, 2006, EPA deleted the requirement for large MWCs to comply with 40 CFR
Part 60, Subpart E. Therefore, MassDEP amended the Draft Operating Permit to delete all
references to applicable requirements. under 40 CF.R Part 60, Subpart E.
Public notice of this Draft Operating Permit will be published by MassDEP in accordance
with the requirements of 3 10 CMR 7.00: Appendix C. As such, the public comment period shall
end on September 21, 2007. During that period, a public hearing may be requested pursuant to
This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service - 1-800-298-2207.
. http://www.mass.gov/dep - Fax (978) 694-3499
ID Printed on Recycled Paper
Wheelabrator North Andover, Inc.
Transmittal No. 96402 — Draft Air Quality Operating Permit
Page 2 of 2
3 10 CMR 7.00: Appendix C(6)(f). You shall be notified under a separate letter if a public hearing
has been requested.
Please review the entire Draft Operating Permit carefully. It lists the applicable Federal
and State Air Pollution Control Requirements and what is required of the facility in order for it to
be considered in compliance with such applicable requirements. It also includes requirements
that were promulgated or approved by the USEPA through rule making at the time of issuance
but have future effective compliance dates.
Should you have any questions concerning this Draft Operating Permit, please contact
Cosmo Buttaro at (978) 694-3281.
Cosmo Buttaro
Environmental Engineer
Sincerely,
JoKes 13�.�elsky
Regional Permit Chief
Bureau of Waste Prevention
cc: Town Hall, 120 Main Street, North Andover, MA 0 1845
Board of Health, 120 Main, Street, North Andover, MA 0 1845
Fire Headquarters, 124 Main Street, North Andover, MA 0 1845
Merrimack Valley Planning Commission, 160 Main Street, Haverhill, MA 0 183 0
United States Environmental Protection Agency (USEPA) — New England Regional Office,
One Congress Street, Suite 1100 (CAP), Boston, Massachusetts 02114-2023,
Attn: Manager — Air Permits Program
USEPA (E -Copy): Ida McDonnell
Affected States (E -Copy): D. McVay/RI - DEM, G. Rose & R. Pirolli/CT - DEP,
D. ElliottfVT — DEC, T. Moore/NH - DES, M. Cone/ME — DEP,
R. J. Stanto/NY — DEC, R. Langbein/NJ —DEP
MassDEP/Regions (E -Copy): Karen Regas, Yi Tian, Marilyn Levenson, John Winkler,
Thomas Cusson, Maria L'Annunziata, Craig Goff
MassDEP/NERO: Thomas Parks (E -Copy & Hard Copy), James Belsky (E -Copy),
Ed Braczyk (E-Copy)j Mary Persky (Hard Copy), Cosmo Buttaro (Hard Copy)
I
DEVAL L. PATRICK
Governor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY &, ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
NORTHEAST REGIONAL OFFICE
205B Lowell Street, Wilmington, MA 01887 e (978) 694-3200
IAN A. BOWLES
Secretary
TIMOTHY P. MURRAY ARLEEN O'DONNELL
Lieutenant Governor Comrnissioner
DRAFT AIR QUALITY OPERATING PERMIT
Issued by the Massachusetts Department of Environmental Protection
("MassDEP'l) pursuant to its authority under M.G.L. c. 111, §142B
and §142D, 310 CMR 7.00 et seq., and in accordance with the
provisions of 310 CMR 7.00:.Appendix C.
ISSUED TO ["the Permitteell]:
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845
FACILITY LOCATION:
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA 01845
NATURE OF BUSINESS:
Municipal Waste Combustor .
INFORMATION RELIED UPON:
Application No. MER-95-OPP-012
Transmittal No. 96402
FACILITY IDENTIFYING NUMBERS:
SSEIS ID No. 1210261
FMF FAC No. 132771
FMF RO No. 162861
STANDARD INDUSTRIAL CODE:
(SIC): 4953
RESPONSIBLE OFFICIAL: FACILITY CONTACT PERSON:
Name: Scott T. Emerson Name: Scott T. Emerson
Title: Plant Manager Title: Plant Manager
Phone: 978-688-9011
This Operating Permit shall expire on
For the Department of Environmental Protection, Bureau of Waste
Prevention
Richard Chalpin Date
Regional Director
This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service - 1-800-298-2207.
http: / /www. mass. gov/dep . Fax (978) 694-3499
0 Printed on Recycled Paper
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 2 of 28
TABLE OF CONTENTS
SPECIAL CONDITIONS FOR OPERATING PERMIT ................. 3
1 .
PERMITTED ACTIVITIES 3
2.
EMISSION UNIT IDENTIFICATION ................................................................
4
3.
EXEMPT ACTIVITIES
23
4.
APPLICABLE REQUIREMENTS ....................................................................................
5
A.
EMISSION LIMITS AND RESTRICTIONS
5
B.
COMPLIANCE DEMONSTRATION
7
C.
GENERAL APPLICA13LE REQUIREMENTS ..........................................................................................
16
D.
REQUIREMENTS NOT CURRENTLY APPLICABLE ............................................................................
16
5 .
SPECIAL TERMS AND CONDITIONS .......................................................... 16
6 .
ALTERNATIVE OPERATING SCENARIOS ....................................................
21
7.
EMISSIONS TRADING ...................................................................................................... 21
8
COMPLIANCE SCHEDULE ................................................................................................
21
GENERAL CONDITIONS FOR OPERATING
PERMIT ............... 22
9.
FEES ...................................................................................................................................................... 22
10.
COMPLIANCE CERTIFICATION ................................................................................
22
11.
NONCOMPLIANCE .......................................................................................................................
23
12.
PERMIT SHIELD ....................................................................................................................
23
13.
ENFORCEMENT ....................................................... a .......................................................................
23
14.
PERMIT TERM ...........................................................................................................................
24
15.
PERMIT RENEWAL .................................................................................................................
24
16.
REOPENING FOR CAUSE ............................................................................................
24
17.
DUTY TO PROVIDE INFORMATION ..............................................................
24
18.
DUTY TO SUPPLEMENT ................................................................................................
24
19.
TRANSFER OF OWNERSHIP OR OPERATION ....................................
25
20.
PROPERTY RIGHTS ............................................................................................................. 25
21.
INSPECTION AND ENTRY ..........................................................................................
25
22.
PERMIT AVAILABILITY ................................................................................................
25
23.
SEVERABILITY CLAUSE ................................................................................................
25
24.
EMERGENCY CONDITIONS ............................................................................................
26
25.
PERMIT DEVIATION ..........................................................................................................
26
26.
OPERATIONAL FLEXIBILITY ..................................................................................
27
27.
MODIFICATIONS .......................................................................................................................
27
APPEAL CONDITIONS FOR OPERATING PERMIT ................... 28
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 3 of 28
SPECIAL CONDITIONS FOR OPERATING PERMIT
1. PERMITTED ACTIVITIES
In accordance with the provisions of 310 CMR 7.00: Appendix C and
applicable rules and regulations, the Permittee is authorized to operate
air emission units as shown in Table 1 and exempt and insignificant
activities as described in 310 CMR 7. 00: Appendix C (5) (h) and (i) . The
units described in Table 1 are subject to the terms and conditions shown in
Sections 4, 5, and G and to other terms and conditions as specified in this
Permit. Emissions from the exempt activities shall he included in the total
facility emissions for the emission -based portion of the fee calculation
described in 310 CMR 4.00 and this Permit.
MassDEP has reviewed and �pproved ' the Permittee's streamlining
demonstration, and has determined that the Operating Permit contains
streamlined requirements that are the most stringent requirements applicable
to the Permittee. Table 3 includes the streamlined emission limits/standards
shown in hold face type, which subsume all applicable requirements that are
at least as stringent or less stringent than the streamlined requirements.
The citations to the subsumed requirements are listed under the Applicable
Regulation and/or Approval Number column of Table 3.
The -.Permittee is suiDject to all applicabie require-mt-nts contained In ��his
Operating Permit, as well as, all existing r'egulations and Approvals
subsumed in this operating Permit. For the subsumed applicable requirements,
the Permit Shield granted in General Condition 12 shall be in effect, and
compliance with the streamlined requirements are deemed to also be in
compliance with the subsumed requirements.
DESCRIPTION OF FACILITY AND OPERATIONS
The Wheelabrator North Andover, Inc.. facility is comprised of a municipal
waste combustor (MWC) plant located at 285 Holt' Road in North Andover,
Massachusetts. The MWC plant consists of two identical incinerators/water
wall boilers (EU1 and EU2), each capable of combusting greater than 250 tons
per day of municipal solid waste (MSW) . Each boiler is designed to generate
173,000 pounds per hour of steam that is delivered to a turbine generator
capable of producing 40 Megawatts (MW) output of electricity for sale and
distribution to the New England power grid system. Each boiler is equipped
with two auxiliary burners that burn natural gas during start-up, shutdown,
and malfunction periods. Each MWC train is equipped with air pollution
control equipment consisting of: 1) a Selective Non -Catalytic Reduction
(SNCR) system for reduction of nitrogen oxides, 2) an activated carbon
injection system for control of mercury, 3) a spray dry absorber (SDA)
system with lime slurry injection for the control of acid gases, and 4) a
fabric filter/bag house for the control of particulate and other pollutants.
Fly ash from the MWC plant is conveyed to and conditioned by an ash handling
system (EU3) prior to being transported by dump trucks to an off-site ash
landfill. The MWC plant and ash handling system is subject to 310 CMR 7.08.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 4 of 28
2. EMISSION UNIT IDENTIFICATION
The following emission units (Table 1) are subject to and regulated by this
Operating Permit:
Table, 1: i�
0 .0 N -I T�
::DESCRIPTION!;
EEMIS ON
i EU,, C ITY,
ud:
0 LLUTION;ZONTROL., E:,
EUI
Mass 'Burn
288.4 MMBTU/rir heat input
Two (2) Naturai uas eired
Incinerator/Water Wall
173,000 lbs/hr of steam @
Low NO. 4 0 MMBTU/hr
Boiler
612 psig/750 Degrees F
Auxiliary Burners [ABI
(PCD 1)
Seiective Non-CataiYE-1—c
Reduction with Urea
Injection [SNCRI (PCD 2)
Powdered Activated Carbon
Injection System [PACII
(PCD 3)
Two-Fiuid Nozzle Spray
Drier Absorber with Lime
Slurry Injection [SDAI
(PCD 4)
u se Jet, 8 Mocluie, Size
1.6,15 IA,'. Fabric
Filter [FF1 (PCD 5)
E U
Mass Burn
288.4 MMBTU/hr He input
rwo (2) Naturai Gas Fired
Incinerator/Water Wall
173,000 lbs/hr of steam @
Low NO. 4 0 MMBTU/hr AB
Boiler
612 psig/750 Degrees F
(PCD 6)
SNCH (PUL)
PACi (PCJ 8)
SDA (PUD -9)
1�' (PCL) lu)
EU3
Ash Conveying Systems
2U,000 ACI�'M @
Water injected Centritugai
and Buildings and
68 Degrees F
Scrubber, Tri -Mer Corp.
Enclosures of Ash
W-200 model H (PCD 11)
Conveying Systems
Ash Conveyors, buliaings
and Enclosures
+ Table 1 Key:
EU# = Emission Unit Number
PCD = Pollution Control Device
F = Fahrenheit
MMBTU/hr = million British thermal units per hour
@ = at
lbs/hr = pounds per hour
psig = pounds per square inch gauge
ACFM = Actual Cubic Feet per Minute
NO. = oxides of nitrogen
3. EXEMPT ACTIVITIES
The following are considered exempt activities in accordance with the
criteria contained in 310 CMR 7.00: Appendix C(5)(h):
... ........
i1ne iist ot current exempt activities is contained Tn_ tifte Uperating Permit Appilcation
and shall be updated by the Permittee to reflect changes at the facility over the Permit
term. An up-to-date copy of exempt activities list shall be kept on-site at the facility
and a copy shall be submitted to MassDEP's Regional Office. Emissions from these
activities shall be reported on the annual emissions statement pursuant to 310 CMR 7.12.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page S of 28
4. APPLICABLE REQUIREMENTS
-1
EU2
A. EMISSION LIMITS AND RESTRICTIONS
The Permittee is subject to the emission limits/restrictions as contained in
Table 3 below:
I < 110-. of maximurr
— —1 1. — �,J k�j 4
jemonstrated load
-----CT—
MBR -98 -ECP -005
< 0.020 mg/ciscm a—F-7767727—
(based on steam
Pb
< 0.440 mg/ctscm at 76 0,
flow), calculated
HUI
S 2-9 ppm--Fy– volume at 7�6 U2--d—ry
in 4 -hour block
arithmetic
basis or 95% reduction by weight
averages,
or volume, whichever is less
measured during
stringent.
11)3-oxin/Furan
< 30 ng/cIscm at 7;=2 ---
the most recent
dioxin/furan
PM
< X/ mg/dscm at' 1-, U2 (1)
.31U CMR Y.U8(2) (t)7 -
test
in which
MER -98 -ECP -005
compliance is
achieved (3)
EPA PSD Permit
No. 029-121 MA16 (5)
PM Control Device
Inlet
MBR -82 -INC -004
Temperature:
< l7o� (300F)
MBR -91 -INC -004
su,
< 29 ppm by volume at 7�, 02 dry
1�asis or 75% reduction by weight
JlU CMR '/.U8(2)
ii-bove maximum
demonstrated PM
or volume, whichever is less
MBR -98 -ECP -005
control device
stringent
inlet
temperature,
(24-hour geometric mean)
EPA PSD Permit
calculated in 4 -
No. 029-121 MA16 (6)
hour block
arithmetic
MBR -82 -INC -004
averages,
measured during
MBR -91 -INC -004
< 69 ppm by volume at 7% 0, dry
basis at combustor outlet
310 CMR
7.08(2)(fll.a.i.
the most recent
dioxin/furan
compliance test
(4 -hour block average)
. in which
MBR -98 -ECP -005
compliance is
achieved (3)
EPA PSD Permit
No. 029-121 MAlG (7)
Feed Rate or
Firing Rate
MBR -82 -INC -004
66.96 tons/houx
Of MSW (4)
MBR -91 -INC -004
�S 2U5 ppm by volume at 71, 02 dry'
JIU CMR 7--U9TTTTrT3--
basis
(24-hour daily arithmetic average)
MBR -98 -ECP -005
EPA PSD Permit
No. 029-121 MAlG (8)
MBR -82 -INC -004
MBR -91 -INC -004
310 CMR 7.19(9)(a)
Hg
< .08U mg/dscm at 7!� 0. (durTng
i I U (2MR 7 . 0 8 (2) (g) 2.
any single quarterly compliance
test)
M13R-98-ECP-005
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 6 of 28
. . . . . . . . . .
q:
4: :.q:
a''
E
RESTRICTI.ON/:,
POLLU TAN
'Xf
"..EMISSIOX]FLI 1:T/STANDAR �10 1. H_
a
PLICAB LE
OPERkilk
F.
TICES;:;!.
..AP'PR6.VAL NUMBER
P'ul'
OCL lit -1 CLIj I-WU V t__
Hg
S 0.028 mg/dscm at 7 0, (based on
310 CMR 1. 08 �2) (Z)2.
EU2
average of 4 quarterly compliance
tests per rolling 12 months)
MBR -98 -ECP -005
< ppm by voiume at 7�s 02 dry
MBR-98-ECP-U0b
basis (9)
(State Only
Requirement)
H2SOI
< 0.02 ib/MMB'iU ----F7A-7SD
PeFm_17__
No. 029-121 MA16
MDR -82 -INC -004
�misslons < J mil
3 hour period (2)
MBR -91 -INC -004
MBR -98 -ECP -005
Table 3 Notes:
�'L t . --z' i,-- "Speci.,.11 Terms And
Refer tr, Sr - n -a)
2 Refer to Section 5.b), "Special Terms And Conditions".
3 Refer to Section 5.c), "Special Terms And Conditions".
4 Refer to Section 5.i), "Special Terms And Conditions".
5 The EPA PSD Permit No. 029-121 MA16, Approval MDR -82 -INC -004-, and Approval
MBR -91 -INC -004 PM limit of 0.05 gr/dscf at 121-o CO21 which is approximately
equivalent to 114.3 mg/dscm at 7%.02, is less restrictive than the listed
Table 3 limit, 27 mg/dscm at 7�oo 0 2 (310 CMR 7. 08 (2) (f) 2. ) .
6 The EPA PSD Permit No. 029-121 MA16, Approval MBR -82 -INC -004, and Approval
MER -91 -INC -004 S02 limit of 0.27 lb/MMBTU, which is approximately
equivalent to 113 ppm by volume at 7-. 0, dry basis, is less restrictive
than the listed Table 3 limit, 29 ppm by volume at 71 02 dry basis (310 CMR
7.08(2) (f)2.).
7 The EPA PSD Permit No. 029-121 MA16, Approval MBR -82 -INC -004, and Approval
MBR -91 -INC -004 CO limit of 0.07 lb/MMBTU, which is approximately equivalent
to 69 ppm by volume at 7-. 02 dry basis, is as restrictive as the listed
Table 3 limit, 69 ppm by volume at 7-. 02 dry basis (310 CMR
7.08(2)(fll.a.i.).
8 The 3 10 CMR 7.19 (9) (a) NO. limit, 0. 6 lb/MMBTU (calendar day average) , or
the EPA PSD Permit No. 029-121 MA16, Approval MBR -82 -INC -004, and Approval
MBR -91 -INC -004 NO. limit of 0.6 lb/MMBTU (24-hour daily arithmetic
average) , which is approximately equivalent to 349 ppm by volume at 7o�o 02
dry basis, is less restrictive than the listed Table 3 limit, 205 ppm by
volume at 71 0, dry basis (24-hour daily arithmetic, average) (310 CMR
7.08 (2) (f) 3.)
9 Refer to Section 5.d), "Special Terms and Conditions".
10 Emission limits /standards in Table 3 and under 310 CMR 7.08 apply at all
times except during periods of start -up, shutdown or malfunction as def ined
in 40 CFR Part 60, Subpart Eb, 60.58b, as amended.
+ Table 3 Key:
EU# = Emission Unit.Number
mg/dscm = milligram per dry standard cubic meter
ng/dscm = nanogram per dry standard cubic meter
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 7 of 28
pp:m = parts per million
lb/MMBTU pounds per million British Thermal Units
gr/dscf grains per dry standard cubic foot
g/dscm gram per dry standard cubic meter
MSW = Municipal Solid Waste
Cd = Cadmium
Pb = Lead
HC1 = Hydrogen Chloride
Dioxin/Furan = tetra - through octa - chlorinated dibenzo -p-dioxins
and dibenzofurans
PM Particulate Matter
SO, Sulfur Dioxide
CO Carbon Monoxide
NOx Nitrogen Oxides
Hg Mercury
NH3 Ammonia
H2SO4 = Sulfuric Acid Mist
02 = Oxygen
CO2 = Carbon Dioxide
% = percent
oC = Degrees Centigrade
oF = Degrees Fahrenheit
.� = less than or equal to
NA Not Applicable
B. COMPLIANCE DEMONSTRATION
The Permittee is subject to the monitoring/testing, record keeping, and
reporting requirements as contained in Tables 4, 5, and 6 below and 310 CMR
7.00 Appendix C(9) and (10), as well as the applicable requirements
contained in Table 3:
� . -�, -i--- -Y - --- , . - �- I k�') , - - - - - - 1,r ---J--.Y --- --
provisions of 40 CFR 60.S8b, "Compliance and Performance Testing", as
amended, the provisions of which are hereby incorporated by reference.
Compliance with the applicable requirements as set forth in 310 CMR
7.08(2)(f) and Section 4 of this Operating Permit, shall be determined
in accordance with 40 CFR 60.58b, except as provided under 310 CMR
7.08(2)(g)l., 2., 3., 4., S., and 6., and as specified within this
loperating Permit. I
wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality operating Permit
Page 8 of 28
Tap p::�:�.;
EU#1'. W:
, � It, 4, �� ,
0 ITORI NG./T4qT,�T�U-RYOUTREMENTS.:;.::
.. . . I I.: i
EUT, EU2-
2. The taciiity shaii conduct compiiance tests tor dioxin/turan emissions
according to one of the schedules specified below,,as required by 310 CMR
7.08(2)(g)l.a. and b.:
a. The facility shall conduct compliance testing for dioxin/furan
emissions on all municipal waste combustor unit(s) on a nine month basis,
or
b. For municipal waste combustor unit(s) where all compliance tests for
all unit(s) over a 27 month period indicate that dioxin/furan emissions
are less than or equal to 7 nanograms per dry standard cubic meter total
mass (ng/dscm) , corrected to 7 percent oxygen, the facility may elect to
conduct compliance tests for one unit every nine months.
At a minimum, a compliance test for dioxin/furan emissions shall be
conducted every nine months following the previous compliance test for
one unit at the municipal waste combustor plant. Every nine months a
different unit at the municipal waste combustor plant shall be tested,
and the units at the plant shall be tested in sequence.
The facility may continue to conduct compliance testing on only one unit
per nine month basis so lorg as the dioxin/furan emissions remain less
than or equa7 to 7 ngl'd�cm ;��, 7oi
If any nine month compliance test indicates dioxin/furan emissions
greater than the specified limit, compliance tests shall thereafter be
conducted on all units at the plant every nine months until and unless
all nine month compliance tests for all units at the plant over a 27
month period indicate dioxin/furan emissions less than or equal to the 7
ng/dscm @ 7i; 02-
3. in accordance with 310 CMR V.08k2)(g)l.d., tor� municipa-L waste
combustor units where carbon injection (or equivalent) is used to comply
,�ith the dioxin/furan emission limits specified in 310 CMR 7.08(2) (f)2.
or the dioxin/furan emission limit specified in 310 CMR 7.08(2) (g)1.b,
the facility shall measure and calculate the carbon (or equivalent) usage
rate following the procedures specified in 40 CFR 60.58b(m), as amended.
4. in accordance with 310 CMR 7.08(2) (g)2., compiiance testin r Hg
shall be conducted on all municipal waste combustor unit(s) on a
quarterly basis. Compliance with the emissions limit specified in 310 CMR
7.08(2)(f) 2. shall be based on the average of four quarterly compliance
tests per rolling twelve months but shall not exceed 0.080 mg/dscm in any
quarterly test.
If compliance with the Hg emission limit has been achieved in each
quarter for eight consecutive quarters, the.fac-ility may elect to perform
compliance testing on a nine month basis. Any,municipal waste combustor
unit(s) that cannot achieve compliance with the emission limitation 1
310 CMR 7.08(2) (f)2. during the nine month c - ompliance test shall resume
I
quarterly compliance testing as specified above.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 9 of 28
At
79R -4di,#EQUIREMENT �:J
Ui, V, U 4
5. in accordance with _310 UMR /.U15k2) g) j. , tor municipal waste combustor
nit(s) which employ a carbon injection (or equivalent) Hg emission
control system, the facility shall conduct optimization tests. These
tests will determine the optimum feed rate for the Hg emissions control
apparatus by determining the carbon (or equivalent) feed rate at which
the emissions of Hg are equal to or less than the applicable limit at 310
CMR 7.08(2)(f)2. The optimization test shall be conducted as follows:
a. The optimization tests shall be performed after a change in carbon (or
equivalent), upon request by MassDEP, upon request by the facility, or
annually if required under 310 CMR 7.08(2)(g)4.
. If there are identical municipal waste combustor units at the
municipal waste combustor plant, then optimization tests may be performed
on one unit, and the resulting parameters applied.to the other unit(s),
which is identical to that unit at that plant.
c. Within 30 calendar days of the conclusion of any optimization t est,
the facility shall submit to MassDEP for approval a proposed optimized�
carbon (or equivalent) feed rate that minimizes Hg emissions. An
approvable feed rate is the feed rate such that a higher feed rate
achieves insignificant addit ' ional reductions.. in. INg emissions compared to
of c_�rhon �or -equiva:ent) ad,7EF.-. T11e s:�tr'Don (or equivaleri,,:)
eed rate approved by MassDEP shall be used to operate the carbon
l.'-he
njection (or equivalent) Hg control system until the next optimization
ti�est is performed and the feed rate approved.
b. in accordance with 310 CMR /.08(2) (g)6., tHe faciiity shaTIT-7-o-n-duct
compliance testing every nine months for each municipal waste combustor
unit. Compliance testing for dioxin/furan and Hg shall be conducted as
specified in 310 CMR 7.08(2)(g)l. and 2.
in accordance with Approval MBR -iNC-004, eacft unit shaii be
equipped with an approved smoke density indicator, alarm and recorder
that is pr�perly installed, maintained, and continuously . operated. The
use of COMS operated in accordance with 310 CMR 7.08(2) shall be deemed
compliance with this requirement.
8. in accordance with Approval MbH-_98-ECP-U05, the tacii1ty snaii conduct
compliance testing for NH, every nine months for each municipal waste
combustor unit. Said testing shall be conducted in accordan e with a test
cdays
protocol, which has been submitted to MassDEP at least Go prior tc
the anticipated date of testing, and approved by MassDEP prior to
testing. Compliance with the NH, emission limit/standard shall be based
upon a minimum of 3 compliance te�st runs on each MWC unit per compliance
test, measured at the Spray Drier Absorber inlet or Fabric Filter
outlet, using EPA Test Method 26A or other test method approved by
MassDEP. (State only Requirement)
-9.
In accordance with 310 CMR 7.08(2) (g)5.a. (turther ciaritied in—a
letter dated October 1, 1998 from MassDEP's Business Compli �nce
ivision) , Continuous Emissions Monitoring Systems (CEMS) which monitor
NO�, SO,, and operating practices parameters (e.g., CO, unit load and PM
control device inlet temperature) -shall obtain at a minimum valid
continuous emissions monitoring system data for 7526 of the operating
hours per - day (18 hours per day) for 75-oo of the days per month (23
days/month for a 30 day month) that a municipal waste combustor unit is
combusting solid waste continuously (24 hours/day) and valid CEMS data
must be obtained for 90*-. of the hours per quarter that the municipal
aste combustor unit is combustinig municipal solid waste.
lu.
in accordance with 310 UMH '/. 08 (2) (g) 5.b. , UU CEMS instaiied a
operated
in accordance with Performance Specification 4 of 40 CFR Part
60,
Appendix 3, will satisfy the requirements in 310 CMR 7. 08 (2) (g) , EPA
PSD
Permit No. 029-121 MA16, Approval MBR791-INC-004, and �,pproval MBR-
-82
-INC -004. I
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 10 of 28
�.j ... . ......
ONITOR q�TESTIN.G 41.
EQIJIREMENTS::z�,�
Lui, r, U z
L
11. The nine month compliance demonstration tor the opacity iimit�
required under 310 CMR 7. 08 (2) (g) (6) may be conducted using either datjja
L
from the continuous opacity monitoring system (COMS) or the procedures in
40 CFR Part 60, Appendix A, Method 9 as provided for under 4 0 CFR
60.58h(c)(6) and 40 CFR 60.11(e)(6).
_L2. in accordance with EPA PSL) Permit No. 02-9-121 MA16, EPA Conse
Agreement and Order Docket No. CAA -1-99-0017, and consistent with
Approval MBR -82 -INC -004, monitor the feed rate or firing rate of MSW
(See Section 5.(i) "Special Terms And Conditions").
EU3
13. AS required --by 310 UMR 7. U8 (2) (g) and Approval MBH -98 - EUP-UU5, the
facility shall comply with the provisions of 40 CFR 60.58b, "Compliance
and Performance Testing", as amended, the provisions of which are hereby
incorporated by reference. Compliance with the fugitive ash requirements
as set f orth in 3 10 CMR 7. 0 8 (2) (f ) 5 and Sect ion 4 of thi s Operat ing
Permit, shall be determined in accordance with 40 CFR 60.58b. Fugitive
ash emissions shall be tested every nine months in accordance with 310
CMR 7.08(2)(g) requirements.
Faclilty-wide
14. in accordance with 310 CMR '1.13(l), any person owning, leasing,
operating or controlling a facility for which MassDEP has determined
that stack testing is necessary to ascertain compliance with MassDEP's
regulations or design approval provisos shall cause such stack testing:
(a) to be %onducted by a person knowledgeaLle in stack
(b) to be conducted in accordance with procedures contained in a test
protocol which has been approved by MassDEP, and
(c) to be conducted in the presence of a representative of MassDEP when
such is deemed necessary.
.1b.
Yursuant to MassDEP's authority througii 310 CMK ./.UU: Appendix
C(9)(b)2., conduct any other,testing or testing methodology if and when
requested by MassDEP,or EPA.
16. Monitor operations such that intormation may be compiled tor thE
annual preparation of a Source Regi stration/Emis s ion Statement Form as
required by 310 CMR 7.12.
IF: . ..... .
rr,
bl
J�Y]�Q KEE.P1NG.:REOUiKEMENTS!,..::
EU1, EU2 1. in accordance with 310 CMR 7.08(2) (h)9., the results ot all nine month
compliance tests conducted to determine compliance with the PM, opacity,
Cd, Pb, Hq, dioxin/furan, HC1, and fugitive ash emission limits shall be
recorded along with supporting calculations and submitted to MasSDEP
within 90 days after the test. In addition, in accordance with Approval
rBR -98 -ECP -005, the results of the quarterly Hg compliance tests shall
also be recorded and submitted to MassDEP within 30 days after the test.
Furthermore, in accordance with Approval MBR -98 -ECP -005, the results of
3Lll nine month compliance tests conducted to determine compliance with
-he NH3 emission limit shall be recorded along with supporting
::alculations and submitted to MassDEP within 90 days after the test.
(State Only Requirement)
�. L)uring all cLioxin/turan compliance tests, the maximum ciemonsurar-ea
nunicipal waste combustor load and maximum PM control device temperature
iverages (for each PM control device) shall be recorded along with
;upporting calculations,.as required by 310 CMR 7.08(2)(h)10.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 11 of 28
-7
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D:. KEEPING
F-EQ9R E VIRE
!, ..c: : -.- ., .1. .4; .—IF ','4 Y
IUTI V, U z
3. As required by =--CM7 /.08(2)(h)4., municipai waste combustor unit(s)
that apply carbon (or equivalent) for Hg or dioxin/furan control, shall
maintain the following records:
a. The average carbon (or equivalent) mass feed rate (in lbs/hr)
estimated as required under 40 CFR 60.58b (m) (1) (i) , as amended, during
all compliance tests,:with supporting calculations.
The average carbon (or equivalent) mass feed rate (in lbs/hr)
estimated for each hour of operation as required under 40 CFR
60.58b(m)(1)(ii), as amended, during the initial dioxin/furan performance
test and all subsequent nine month compliance tests, with supporting
calculations.
C. The average carbon (or equivalent) mass feed rate (in lbs/hr)
estimated for each. hour of operation as required under 40 CFR
60.58b(m)(3)(ii), as amended, with supporting calculations.
d. The total carbon (or equivalent) usage for each calendar quarter
stimated as specified under 40 CFR 60.58b(m) (3), as amended, with
Supporting calculations.
'The carbon- or equ.-J-,.7a-,ent- `1-�ection syeiccm ---peraL.Lng par��.--;e'-er data
e L / 111 - L -
for the parameter(s) . that are the primary indicator(s) of carbon (or
equivalent) feed rate.
4. As required by 310 UMR 7. 08 (2) (h) 13., tor municipa-L waste 'combustor
units that apply carbon (or equivalent) for Hg or dioxin/furan control:
a. Identification of the calendar dates when the average carbon (or
equivalent) mass feed rates recorded under 310 CMR 7..08(2) (h)4.c. were
less than either 'of the hourly carbon feed rates estimated 'during
compliance tests for Hg or dioxin/furan emissions and recorded under 310
CMR 7. 0 8 (2) (h) 4. a. or b. respectively, with reasons f or such f eed
rates and a description of corrective actions taken.
b. Identification of the calendar dates when the carbon injection (or
equivalent) system operating parameter(s) that are the primary
indicator(s) of carbon mass feed rate (or equivalent) recorded under 310
CMR 7.08(2)(h) 4. e., are below the level(s) estimated during the
compliance tests as specified in 40, CFR 60.58b(m)(1)(i) and
60.58b(m)(1)(ii), as amended, with reasons for such occurrences and a
description of corrective actions taken. 11
wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 12 of 28
�,Tapxei� �b,
�CQRD; Kl�j�.P INT M
MENTS
IRE
nul, r'uz b. in accordance with 310 CMR 7.08(2)(n)2., the iaciiity shaii record the
emission concentrations and parameters measured using continuous
emissions monitoring systems. The measurements specified below shall be
recorded and shall be available for submittal to MassDEP or for onsite
review by an inspector:
a. All 6 -minute block averages of opacity levels as specified under 40
CFR 60.58b(c), as amended, including the highest level measured.
All 1 -hour block averages of S02 emission concentrations as specified
under 40 CFR 60.58b(e), as amended.
c. All 1 -hour block averages of NO, emission concentrations as specified
under 40 CFR 60.58b(h), as amended.
d. All 1 -hour block averages of CO emission concentrations, municipal
waste combustor unit load measurements, and PM control device inlet
temperatures as specified under 40 CFR 60.S8b(i), as amended.
e. All 24-hour daily geometric averages of So, emission concentrations
and all 24-hour daily geometric averages of percent reductions in S02
emissions as anplicable, as specified under 40 CFR 60.58b(e), as amended,l
:4.uu"ud'i1g the LU7-
i� L L _4hest recorde�d�
f. All 24-hour daily arithmetic averages of No. emission concentrations
as specified under 40 CFR 60.58b(h), as amended, including the highest
level recorded.
g. All 4 -hour block averages of CO emission concentrations, as
applicable, as apecified under 40 CFR 60.58b(i), as amended, -including
the highest level recorded. '
h. All 4 -hour block arithmetic averag6s of municipal waste combustor unit
load levels (steam flow) and PM control device inlet temperatures as
specified under 40 CFR GO.58b(i), as amended, including the highest levelll
— � —I— -- -.Y --, , % � / X - , I . , -- .- - -�- - - - Y - , — - - - - - - - - —
lendar dates when any of the average emissions concentrations o
rcent reductions, or operating parameters recorded under 310 CM
08(2)(h)L, exceed the applicable limits, with detailed specifi
asons for such exceedances and a description of corrective action
. As requirea ny .3ju um?, /.ubk2) kn)b., une zaciiizy snai-L recora zn
alendar dates and time periods for which the minimum number of hours o
ny of the data specified below have not been obtained including reason
or not obtaining sufficient data and a description of corrective action
So, emissions data,
No. emissions data,
CO emissions data,
Municipal waste combustor unit load data,
PM control device inlet temperature data.
. As required by 3io UMH /. U8 �2) (n) 6. , tne raciiir-y sna-L-L recora eac
ccurrence that SO, emissions data, No. emissions data, or operationa
ata (e.g. CO. emissions, unit load, and PM control device inle
emperature) have been excluded from the calculation of average emissio
oncentrations or parameters, along with detailed and specific reason
or excluding the data.
. As required by .310 CMR 7. 08 (2) kh)'/. , the taciiity shali recor
esults of daily drift tests and quarterly accuracy determinations fo
0,, NO., and CO continuous emission monitoring systems, as required unde
0 CFR, Part 60, Appendix F, Procedure 1.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 13 of 28
F
2UT Itluz
10. As required by 3 10 CMR 7. 0 8 (2) (h) 8. the taciiity shaii maintain
records of each occurrence of a start-up, shut -down or malfunction that
results in an exceedance of the limits defined in Table 3, including
the specific reasons for each occurrence, date, time, and unit
involved. Average emissions concentrations or percent reductions, or
operating parameters recorded under 3 10 CMR 7. 0 8 (2) (h) 2. , shall be
recorded during start-up, shut -down or malfunction that results in an
exceedance of the limits defined in Table 3.
Ii. in accordance with 310 UMR /.U8(2)(h)ll., the taclilty shaiI—m—a—l-n—Ealn
records showing the names of the municipal waste combustor chief facility
operator, shift supervisors, and control room operators who are certified
by ASME (Operator Certification and Provisional Certification), including
the dates of initial and renewal certifications and documentation of
current certification.
The facility shall also maintain records showing the names of the
nunicipal waste combustor chief facility operator, shift supervisors, and
control room operators who have completed the EPA municipal waste
combustor operator training course if required.
12. In accordance with 310 CMR /.08(2)(h)12., the taciiity snaii maintain
records showing the names of the persons who have completed a review of
the operating manual as required by 310 --MR 7 08�2)(flrd_ incluOing the
date' of - 'the ini4 iai're.View und ann---al �evieWS.
ij, in accordance wiETT7_71T_= 7.08 (2) (ft) 1., the taciiity shaiI_ma1`HTa-1n
the calendar date of each record required above.
14. in accordance with EPA PSD Permit No. 029-121 MA16, EPA Consent
Agreement and Order Docket. No. CAA -1-99-0017, and consistent with
Approval MER -82 -INC -004, the facility shall maintain records of the
feed rate or firing rate of MSW (See Section 5. (i) "Special Terms And
Conditions").
EW
1b. in accordance with 310 MR 7.08(2) (H)9. and Approvai MER-98-Eup-00b,
maintain records of the results of all nine month compliance tests
conducted to determine compliance with the fugitive ash emission limit,
along with supporting calculations.
Faclilty-wiTe-16.
Pursuant to Massl)EP's authority through 310 CMR Tuu: Appendix
C(9)(b)2., maintain the test results of any other testing or tes�ing
methodology required by MassDEP or EPA.
17. Maintain records tor tile annuai preparation ot a source
Registration/Emission Statement Form as required by 310 CMR 7.12.
18. Keep copies ot Source Registration/Emission Statement Forms
submitted annually to.MassDEP as required per 310 CMR 7.12(3)(b).
1-4. in accordance with 310 CM? 7.08(-2) (h) and 310 UMR 7.00: Appendix
C(10)(b), maintain records of all monitoring data and supporting
information required by this Operating Permit on site for five (5)
years from the date of the monitoring sample, measurement, report or
initial Operating Permit Application. Said records shall be made
available to MassDEP personnel upon request.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 14 of 28
EU#
'E 'j- . .....
EU1, EU2 I As required by 3 1 L) UMH 7. 08 (2) (i) , the tacii1ty sftaii submit an annuai
report of the information specified in 310 CMR 7.08(2) (i)l., as
applicable. The facility which elects to follow the compliance testing
schedule specified in 310 CMR 7.08(2)(g)l.b., shall follow the procedures
specified in 310 CMR 7.08(2) (i)l. for reporting the selection of this
schedule.
Annual Reporting Requirements The information specified in a. througi
g. below shall be reported:
a. 310 CMR 7.08(2) (h)2.a., e. through h. for the highest emission levelE
recorded.
b. 310 CMR 7.08(2)(h)4.a. and h.
c. 310 CMR 7.08(2)(h)S. - 6.
d. 310 CMR 7. 08 (2) (h) B. - 10.
e. Summary of a. through d. for the previous year.
f. The performance evaluation of the continuous emission monitorinc
system using the applicable performance specifications in Appendix B oi
40 CFR, Part 60.
. A notification of intent to begin the reduced dioxin/furan complianCE
testing schedule specified in 310 CMR 7.08(2)(g)l.b. during the followinc
calendar year.
—TTTa-7'-1—n-c=u =-, -7F,-E
2. The taclilty shai sUbm-17 repor
information specified in 310 CMR 7.08(2) (i)2. for any recorded pollutant
or parameter that does not comply with the emission limits as set fortl
in 310 CMR 7.08(2).
Semi -Annual Reporting Requirements The information specified in a.
through e. below shall be reported:
. 310 CMR 7.08(2) (h)2.a., e. through h. for each date recorded in 31
MR 7. 08,(2) (h) 3.
310 CMR 7. 0 8 (2) (h) 3.
310 CMR 7. 0 8 (2) (h) 4. c.
310 CMR 7.08(2)(h) 9. 3
310 CMR 7.08(2)(h)13.
AS required by 310 CMR /.08(2)(i), in meeting the reportiH
equirements of 310 CMR 7.08 (2) (i) 1. and 310 CMR 7.08(2)(i)2., th
acility shall report the information in a format determined by MassDE
hat is designed to be understandable and informative to the public. Th
nformation shall be submitted in written format and electronic format.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 15 of 28
Table 6 Notes:
I In accordance with 310 CMR 7. 08 (2) (i) 1. , annual reports shall be submitted
to this office no later than February,15 of each year following the calendar
E U#:'
7,
4. in accordance With Approvai MBR-82-iNC-UU4, tne taciiity shaii submit
to MassDEP, CEMS Excess Emission and Monitoring System Performance
reports on a quarterly basis for opacity, SO,, NO., and CO. Such reports
shall include:
a. the date and time of commencement and completion of each period of
excess emissions and the magnitude of the excess emissions for each hour;
and,
identification of the suspected reason for the excess emissions and
any corrective action'taken; and,
c. the date and time that any CEMS stopped collecting valid data and when
it started to. collect valid data again, except for zero and span checks
(report only invalid one hour data averages); and,
d., the nature and date of system repairs.
In the event none of the above items have occurred, such information
shall be stated -in the report.
Peportable excess emiss.i-ons shall be defined as emisslons -'in excess of
emissiL;n, I -11,aits/standOl-ds defined -Ln 'Table 3. 1-wie fac1lity may use
the reporting format' required by 310 CMR 7.08 or some other format
determined by MassDEP that is designed to be understandable and
informative to the public.
The report for each calendar quarter shall be submitted by the thirtieth
(30th) day of April, July, October, and January covering the previous
calendar periods of January through March., April through June, July
through September, and October throug h December, respectively.
b. In accordance . with EPA PSD Permit No. 029-121 MA16, EPA . consent
Agreement and Order Docket No. CAA -1-99-0011, and consistent with
Approval MBR -82 -INC -004, the facility shall submit to MassDEP on a
quarterly basis a report containing either a listing of each occasion
when the maximum allowed feed rate or firing rate of MSW was exceeded,
or a statement that the allowed firing rate was not exceeded. The report
for each calendar quarter shall be submitted by the thirtieth (30th) day
of April, July, October, and January covering the previous calendar
periods of January through March, April through June, July through
September, and October through December, respectively. These quarterly
reports may be submitted concurrently with the quarterly reports required
as per Table 6, Item 4.
-A—pp-endix
Faciiity-Wi-ae
6. Pursuant to MassDEPI—s authority through 310 UMR '/.—Uu:
C (9) (b) 2. , submit the test results of any other testing or testing
nethodology required by MassDEP or EPA.
7. Submit a Source Registration/ Emission Statement Form to Mass= —on an
annual basis as required by 310 CMR 7.12.
8. Submit by January 3U and Juiy 30 for the previous six months
respectively, a summary of all monitoring data and related supporting
inf ormation to MassD EP as required by 310 CMR 7. 00: Appendix C (10) (c) .
9. Submit Annuai Compilance report to MassDEP and EPA by January 30 o
each year and as required by General Condition 10.
10. Promptly report E—o-M-a-ssDEP aii instances ot deviations tr-offi`--P-e—rm77
requirements by telephone or fax, within three days of discovery of such
deviation, as provided in 310 CMR 7. 00: Appendix C (10) (f) . (See General
Condition 25).
11. Aii required reports must be certitieU by a responsibie otticiai as
provided in 3 10 CMR 7. 0 0: Appe ndix C (10) (h) . i
Table 6 Notes:
I In accordance with 310 CMR 7. 08 (2) (i) 1. , annual reports shall be submitted
to this office no later than February,15 of each year following the calendar
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 16 of 28
year in which the data was collected.
2 Semiannual reports shall be submitted according to the schedule specified:
(1) If data reported in accordance with 310 CMR 7. 08 (2) (i) 2 were collected
during the first calendar half, then the report shall be submitted on or
before August 1 following the first calendar half; (2) If data reported in
310 CMR 7.08(2)(i)2 were collected during the second calendar half, then the
report shall be submitted on or before February 15 following the second
calendar half.
These semiannual reports submitted as per 310 CMR 7.08(2) W2. can meet the
intent of the semiannual reports required under 310 CMR 7.00 Appendix
C(10)(c) provided they meet the requirements of General Condition 10.b. That
is, the semiannual reports shall be submitted by January 30 and July 30 to
MassDEP and contain the information as specified in General Condition 10.b.
and 310 CMR 7.08(2)(i)2.
3 Include only the reports that document emission levels that were above the
applicable requirements and the corrective actions taken.
C. GENERAL APPLICABLE REQUIREMENTS
The Permittee shall comply with all generally applicable requirements
contained -in. 3 10 CMR 7. n n. Ft_ sea and. 310 CMR a, 00. et. seq., when subject.
D. REQUIREMENTS NOT CURRENTLY APPLICABLE
The Permittee is currently not subject to the following requirements:
5. SPECIAL TERMS AND CONDITIONS
The Permittee is subject to the following special provisions that are not
contained in Tables 3, 4, 5, and 6:
a) In accordance with 310 CMR 7.08 (1) (g) , no person shall cause, suf f er,
allow, or permit emissions from any incinerator of any particles that
have a dimension greater than 100 microns. (State Only Requirement)
b) No person subject to 310 CMR 7.08(2) shall cause, suffer, allow or
permit the discharge into the atmosphere of any visible emissions of
combustion ash from an ash conveying system (including transfer
points) in excess of 5 percent of the observation period (nine minutes
per three hour period) . This emission limit does not cover visible
emissions discharged inside buildings or enclosures of ash conveying
systems; however the emission limit does apply to visible emissions
discharged to the atmosphere from buildings or enclosures of ash
conveying systems. This subsection does not apply during maintenance
and repair of ash conveying systems. Maintenance and repair of the ash
conveying systems must be done in accordance with best management
practices.
c) No person subject to 310 CMR 7.08(2) shall:
1. cause, suffer, allow or permit a municipal waste combustor unit
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 17 of 28
to operate at a load level (based on steam f low) greater than
110 percent of the maximum demonstrated municipal waste
combustor unit load calculated in 4 -hour block arithmetic
averages, measured during the most recent dioxin/furan
compliance test in which compliance is achieved; and
2. cause, suffer, allow or permit a municipal waste combustor unit
to operate at a temperature, measured at the PM control device
inlet, exceeding 17oC (30oF) above the maximum demonstrated PM
control device temperature, calculated in 4 -hour block
arithmetic averages, measured during the most recent
dioxin/furan compliance test in which compliance is achieved.
During any nine month dioxin/furan compliance test and the 2
weeks preceding each nine month dioxin/furan compliance test,
municipal waste combustor unit load limit and PM control device
temperature limitations are not applicable.
Municipal waste combustor unit load limit and PM control device
temperature limitations may be waived, if prior approval is
granted by MassDEP, for the purposes -of evaluating system
performance, testing new technology or control technologies,
diagnostic testing, or related activities for the purpose of
improving facility performance provided that there is an
.4m air pollution, or advancing the
in contr(---'7
state-bf-thZ-art for controiling facility emissions.
Emission limits apply at all times except during periods of
start-up, -shutdown or malfunction as defined in 40 CFR Part
60.58b, as amended.
d) In accordance with Approval MBR -98 -ECP -005, based on the current NO.
limit of 205 ppm by. vo ' lume at 7*-. 0, dry basis, NH, emisoions from
each MWC unit shall he limited to 10 ppm by volume at 7*-. 02 dry
basis. Compliance with the NH, emission limit/standard shall be based
on a minimum of 3 compliance test runs on each MWC unit per
compliance test, measured at the Spray Drier Absorber inlet or
Fabric Filter outlet, using EPA Test Method 26A or other test method
.approved by MassDEP. (State Only Requirement)
e) In accordance with Approval MBR -98 -ECP -005, the facility shall not
combust sewage sludge in any of the municipal waste combustor units.
f) In accordance with 310 CMR 7.08(2)(f)G. and 40 CFR Part 60, Subpart Eb
- Section 60.54b, the facility shall implement the following municipal
waste combustor operator training and certification requirements:
1. The facility shall have each chief facility operator and shift
supervisor obtain and maintain an Operator Certificate issued
by the American Society of Mechanical Engineers (ASME).
The facility shall not allow the municipal waste combustor unit
to be operated at any time unless one of the following persons
is on duty: A chief facility operator or a shift supervisor who
has obtained an Operator Certificate. (A Provisional
Certificate is acceptable provided the supervisor is scheduled
to obtain an Operator Certificate in accordance with 310 CMR
7.08 (2) (f) . A provisionally certified operator who is newly
promoted or recently transferred to a chief facility operator
or a shift supervisor position may perform the duties of the
certified chief facility operator or certified shift supervisor
without notice to, or approval by, MassDEP or EPA for up to six
(6) months before taking the ASME certification exam.) . If one
of the persons listed above must leave the municipal waste
combustor plant during his or her operating shift, a
provisionally certified control room operator who is onsite at
the municipal waste combustor plant may fulfill these
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 18 of 28
requirements subject to 40 CFR Part 60, Subpart Eb - Section
60. 54b.
when the certified chief facility operator or certified shift
supervisor is off site for twelve (12) hours or less, and no
certified operator is onsite, the provisionally certified
control room operator may perform those duties without notice
to, or approval by, MassDEP or EPA.
when the certified chief facility operator or certified shift
supervisor is off site for more than twelve (12) hours, but for
two (2) weeks or less, and no certified operator is onsite, the
provisionally certified control room operator may perform those
duties without notice' to, or approval by, MassDEP or EPA.
However, the facility owner or operator shall record the period
when the certified chief facility operator or certified shift
supervisor are off site and include that information in the
annual report as specified under 40 CFR Part 60, Subpart Eb -
Section 60.59b(g)(5) and 310 CMR 7.08(2)(i)l..
When the certified chief facility operator or certified shift
supervisor is off site for more than two weeks, and no other
certified operator is onsite, the provisionally certified
control room operator may perform those duties without approval
by MassDEP or EPA... However, the facility must take the
�o.,,iow,jag two actions:
i. MassDEP and EPA must be notified in writing. In the
notice, the reasons that caused the absence and the
actions being taken to ensure that a certified chief
facility operator or certified shift supervisor is on
site as expeditiously as practicable must be included.
ii. A . written status report and corrective action summaxy
must be submitted 'to MassDEP and EPA every four weeks
following the initial notification. The facility shall
include in each status sumftiary a demonstration that a
good faith effort has been made and continues to be made
to ensure that a certified chief facility operator or
certified shift supervisor is on site. If MassDEP or EPA
provides notice that the status report or corrective
action summary is disapproved, the MWC unit may continue
operation for ninety (90) days, but then must cease
operation. If corrective actions are taken in the ninety
(90) day period such that MassDEP or EPA withdraws the
disapproval, MWC unit operation may continue.
3. The facility shall have all chief facility operators, shift
supervisors, and control room operators complete the National
Technical Information Service - "EPA Municipal Waste Combustor
Operating Course".
4. The facility shall establish a training program to review the
operating manual with each person who has responsibilities
affecting the operation of an affected municipal waste
combustor unit, including, but not limited to, chief facility
operators, shift supervisors, control room operators, ash
handlers, maintenance personnel, and crane/load handlers. Each
person specified above shall undergo initial training no later
than the date prior to the day the _ person assumes
responsibilities affecting municipal waste combustor unit
operation and annually thereafter. The site-specific operating
manual shall be updated on a yearly basis and shall address at
a minimum the following:
i. A summary of all applicabfe requirements in this
regulation;
ii. Basic combustion theory applicable to a municipal waste
combustor unit;
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 19 of 28
iii. Procedures for receiving, handling, and feeding municipal
solid waste;
iv. Municipal waste combustor unit startup, shutdown, and
malfunction procedures;
V. Procedures for maintaining proper combustion air supply
levels;
vi. Procedures for operating the municipal waste combustor
unit within the requirements established under this
regulation;
vii. Procedures for responding to periodic upset or off -
specification conditions;
viii. Procedures for minimizing PM carryover;
ix. Procedures for handling ash;
X., Procedures for monitoring municipal waste combustor unit
emissions;
xi. Reporting and record keeping procedures.
5. The facility shall, upon request from MassDEP or EPA, make
available all the operating manuals and records of training for
inspection.
g) In accordance with 310 CMR 7.08(2) (j)5. and Approval MBR -98 -ECP -005,
additional requirements may be included in an Emission Control Plan
Approval if MassDEP determines that the emissions from a municipal
waste combustor plant unit (s) alone or cumulat ivel-�,, with other
-a - -.�-piantlsuni�,s` cause, or ccntrihuto- Lo a
..F.-ianicipal waste corrLb :tur
condition of air pollution or a violation of any other regulation.
Such requirements would not be federally enforceable and would be
subject to State enforcement only. These requirements could include
but are not limited to emissions limits on air contaminants, and
additional stack testing or emission monitoring requirements.
MassDEP may modify the Emissi.on Control Plan at any time if MassDEP
determines that a municipal waste combustor plant I s unit (s) alone or
cumulatively with other municipal waste combustor plant I s unit (s)
cau�e or contribute to a condition of air pollutioii or a violation of
any other regulation.
Cumulative Impact: MassDEP has assess ed the cumulative impact of other
municipal waste combustors within the vicinity of the municipal waste
combustor facility. The analyses indicated that the subject municipal
waste combustor facility would not alone or cumulatively with any
other municipal waste combustor facility cause or contribute to a
condition.of air pollution.
h) In accordance with 310 CMR 7.08(2) (a) and Approval MBR -98 -ECP -005, no
person shall allow, or permit the construction, substantial
reconstruction, alteration or operation of a municipal waste combustor
unit on a site which -has not received a site assignment in accordance
with M.G.L. c.111, s.150A. (State only Requirement)
i) in accordance with Approval MBR -82 -INC -004, the facility's maximum
feed rate or firing rate shall not exceed 66.96 tons of Municipal
Solid Waste (MSW) per hour. The facility shall determine compliance
with the facility's maximum feed rate or firing rate by monitoring
and recording the firing rate using the method set out in Attachment
A of the EPA Consent Agreement and Order Docket No. CAA -1-99-0017,
and as specified below.
Total MSW feed rate (tons/hr) shall be continuously monitored by
continuously monitoring and recording total boiler steam flow
(Klb/hr) in accordance with the following procedure :
A 30 -day rolling average boiler evaporation rate KJb - Ste�a will
(Ton - MSW)
be calculated daily in accordance with the following equation:
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 20 of 28
30 Day Rolling Evaporation Rate ( Klb - Steam) — 30 Day Steam Total (Klb)
'�Ton-MSW) 30 Day MSW Processed (Tons)
The 30 -day rolling average evaporation rate will be calculated based
on 30 -day rolling total facility steam production (Klbs) and
concurrent 30 -day rolling total facility MSW processed (Tons).
Thirty -day rolling average total boiler steam flow (Klbs) will be
calculated from boiler steam flow totalizers. Thirty -day rolling
average facility MSW processed total (tons) will be calculated as
follows:
Day 1 Inventory (Tons) Day 30' Inventory (Tons) + 30 Day Scale
House Receipts (Tons) = Total MSW Processed (Tons)
A new total steam flow surrogate limit (Klb/hr) will be determined
daily based on the 66.96 tons/hour MSW feed rate limit using the 30 -
day rolling average evaporation rate. This surrogate total steam
flow limit (Klb/hr) will be used to ensure the maximum hourly
charging rate (tons/hr) is not exceeded.
Surro,yate.Steam Limit Klbs = 66.96 Tons x Evaporation Rate Klb - Steam
Hour- Hour i on - MSW
The 30 -day rolling facility steam flow total (Klb), total MSW
Klb — Steam
processed (tons), evaporation rate � Ton — MSV , and surrogate
steam f low limit (Klb/hr) must be c ' alculated daily and recorded.
These records must be maintained on site for five years pursuant to
310 CMR 7.00: Appendix C(10)(b) and be available for inspection.
Steam flow meters will be calibrated annually in accordance with
requirements under 40 CFR 60.58b(i)(6). Calibration records will be
maintained on site for five years pursuant to 310 CMR 7.00: Appendix
C(10)(b) and be available for inspection.
j) Consistent with Approval MBR -82 -INC -004, the facility shall provide
sampling ports for particulate emissions testing downstream of the
Fabric Filters/Baghouses, and permanent test platforms and access
ladders when such testing is to occur at an elevated point on the
stack.
k) In accordance with EPA PSD Permit No. 029-121 MA16, the facility
shall comply with all applicable state and federal air pollution
control regulations. Specifically, the various notification,
testing, monitoring, and record keeping provisions of 40 CFR Part
60, Subpart A are applicable to the facility.
1) In accordance with Approval MBR -98 -ECP -005, Approval MBR -96 -IND -027,
and Approval MBR -82 -INC -004 should any nuisance condition(s) occur
as a result of the operation of this facility, then appropriate
steps shall immediately be taken by the facility to abate said
nuisance condition(s).
m) In accordance with Approval MBR -98 -ECP -005 and 310 CMR 7.08(2),
following performance tests for Dioxin\Furan or Mercury emissions,
the facility shall operate with carbon mass feed rate that equals or
exceeds the average that was determined during the performance test.
Compliance with this minimum feed rate will he based on carbon mass
feed rate 8 -hour block averages, in pounds per hour (lbs/hr).
n) Per data as supplied through the Permittee's Operating Permit
Application (MBR-95-OPP-012, Transmittal No. 96402), EU1 and EU2
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Transmittal No. 96402 Draft Air Quality Operating Permit
Page 21 of 28
shall continue to emit products of combustion through two (2)
separate flues (Flue 1 and 2, respectively) contained in an existing
stack, each flue having the following parameters:
Flue 1
Flue Height 230 feet
Flue Exit Diameter 7 feet
Flue Material Steel
Flue 2
Flue Height 230 feet
Flue Exit Diameter 7 feet
Flue Material Steel
0) The Permittee is subject to, and has stated in their operating
Permit Application (MBR-95-OPP-012, Transmittal No. 96402), that
they are in compliance with the requirements of 40 CFR Part 82:
Protection of Stratospheric ozone. These requirements are applicable
to this facility and EPA.enforces these requirements.
6. ALTERNATIVE OPERATING SCENARIOS
The Permittee did not request alternative operating scenarios in its
C111�4' ?F-"rmit Application -
7. EMISSIONS TRADING
(a) Intra -facility emissions trading
.The Permittee did not request intra -facility enlissions trading in its
Operating Permit Application.
Pursuant to 310 CMR 7.00: Appendix C(7)(b), emissions trades, provid6d
for in this Permit, may be implemented provided the Permittee notifies
The United States Environmental Protection Agency (EPA) and MassDEP at
least fifteen (15) days in advance of the proposed changes and the
Permittee provides the information required in 310 CMR 7.00: Appendix
C(7)(b)3.
Any intra -facility change that does not qualify pursuant to 310 CMR
7.00: Appendix C(7) (b)2. is required to be submitted to MassDEP
pursuant to 310 CMR T.00: Appendix B.
(h) Inter -facility emissions trading
The Permittee did not request inter -facility emissions trading in its
Operating Permit Application.
All increases in emissions due to emissions trading, must be
authorized under the applicable requirements of 310 CMR 7.00:
Appendix 3 (the "Emissions Trading Program") and 42 U.S.C. §7401 et
seq. (the "Act"), and provided for in this Permit.
8. COMPLIANCE SCHEDULE
The Permittee has indicated that the facility is in compliance and shall
remain in compliance with the applicable requirements contained in Sections
4 and- 5. In addition, the Permittee shall comply with any applicable
requirements that become effective during the Permit term.
wheelabrator North Andover, Inc.
Transmittal No. 9G402 - Draft Air Quality Operating Permit
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GENERAL CONDITIONS FOR OPERATING PERMIT
9. FEES
The Permittee has paid the Permit Application processing fee and shall pay
the annual compliance fee in accordance with the fee schedule pursuant to
310 CMR 4.00.
10. COMPLIANCE CERTIFICATION
All documents submitted to MassDEP shall contain certification by the
responsible official of truth, accuracy, and completeness. Such
certification shall be in compliance with 310 CMR 7.01(2) and contain the
following language:
"I certify that I have personally examined the foregoing and am familiar
with the information contained in this document and all attachments and
that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the information is true,
accurate, and complete. I am aware that there are significant penalties for
submitting false information, including possible fines and,impris.onment."
Mass�)ZP has made available to the Permittee via MassDEP's web site,
http: //www. mass. gov/dep/air/approvals/aqf orms. htm#op , an "Operating Permit
Reporting Kit". The "Operating Permit Reporting Kit" contains instructions,
and the Annual Compliance Report and Certification and the Semi -Annual
Monitoring Summary Report and Certification.
a. Annual Compliance Report and Certificatio n
The Responsible official shall certify,.annually for the calendar year, that
the facility is in compliance with the requirements of this Permit. The
report shall be postmarked or delivered by January 30 to MassDEP and to the
Regional Administrator, United States Environmental Protection Agency - New
England Region. The report shall be submitted in compliance with the
submission requirements below.
The compliance certification and report shall describe:
i. the terms and conditions of the Permit that are the basis of the
certification;
ii. the current compliance status and whether compliance was continuous
or intermittent during the reporting period;
iii. the methods used for determining compliance, including a description
of the monitoring, record keeping, and reporting requirements and
test methods; and
iv. any additional information required by MassDEP to determine the
compliance status of the source.
b. Semi -Annual Monitoring Summary Report and Certification
The Responsible official shall certify, semi -annually on the calendar year,
that the facility is in compliance with the requirements of this Permit.
The report shall be postmarked or delivered by January 30 and July 30 to
MassDEP. The report shall be submitted in compliance with the submission
requirements bel ow.
The compliance certification and report shall describe:
i. the terms and conditions of the Permit that are the basis of the
certification;
ii. the current compliance status during the reporting period;
iii. the methods used for determining compliance, including a description
of the monitoring, record keeping, and reporting requirements and test
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 23 of 28
methods;
iv. whether there were any deviations during the reporting period;
V. if there are any outstanding deviations at the time of reporting, and
the Corrective Action Plan to remedy said deviation;
vi. whether deviations in the reporting period were previously reported;
vii. if there are any outstanding deviations at the time of reporting, the
proposed date of return to compliance;
viii. if the deviations in the reporting period have returned to compliance
and date of such return to compliance; and
ix. any additional information required by MassDEP to determine the
compliance status of the source.
11. NONCOMPLIANCE
Any noncompliance with i Permit condition constitutes a violation of 310
CMR 7.00: Appendix C and the Clean Air Act, and is grounds for enforcement
action, for Permit termination or revocation, or for denial of an operating
Permit Renewal Application by MassDEP and/or EPA. Noncompliance may also be
grounds for assessment of administrative or civil penalties under M.G.L.
-c.21A, §16 and 310 CMR 5.00; and civil penalties under M.G.L. c.111, §142A
and 142B. This Permit does not relieve the Permittee from the obligation to
comply with any other provisions of 310 CMR 7.00 or the Clean Air Act, or
to obtain any other necessary authorizations from other governmental
with all ot-her applicable Fec2era.l, State, or Local
agencies, or to-corr.pl-,.
rules and regulations, not addres sed in this Permit.
12. PERMIT SHIELD
(a) This facility has a Permit shield provided that it operates in
compliance with the terms and conditions of this Permit. Compliance with the
terms and conditions of this Permit shall be deemed compliance with all
applicable requirements specifically identified in Sections 4, 5, 6, and 7
for the emission units as described in the Permittee's Application and' as
identified in this Permit.
where there is a conflict between the terms and conditions of this Permit
and any earlier Approval or Permit, the terms and conditions of this Permit
control.
(b) MassDEP has determined that the Permittee is not currently subject to
the requirements listed in Section 4, Part D., Table 7.
(c) Nothing in this Permit shall alter or affect the following:
i. the liability of the source for any violation of applicable
requirements prior to or at the time of Permit issuance.
ii. the applicable requirements of the Acid Rain Program, consistent with
42 U.S.C. §7401, §408(a); or
iii. the ability of EPA to obtain information under 42 U.S.C. §7401, §114
or §303 of the Clean Air Act.
13. ENFORCEMENT
The following regulations found at 310 CMR 7.02(8)(h) Table 6 for wood fuel,
7.02(8) (i) , 7.04(9),� 7.05(8), 7.09% (odor), 7.10 (noise) , 7.18(l) (b) , 7.21,
7.22, and any condition(s) designated as "state only" are not federally
enforceable because they are not required under the Clean Air Act or under
any of its applicable requirements. These regulations and conditions are not
enforceable by the EPA. Citizens may seek equitable or declaratory relief to
enforce these regulations and conditions pursuant to Massachusetts General
Law Chapter 214, Section 7A.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 24 of 28
All other terms and conditions contained in this Permit, including any
provisions designed to limit a facility's potential to emit, are enforceable
by MassDEP, EPA, and citizens as defined under the Clean Air Act.
A Permittee shall not claim as a defense in an enforcement action that it
would have been necessary to halt or reduce the permitted activity in order
to maintain com-oliance with the conditions of this Permit.
14. PERMIT TERM
This Permit shall expire on the date specified on the cover page of this
Permit, which shall not be later than the date five (5) years after issuance
of this Permit.
Permit expiration terminates the Permittee's right to operate the facility's
emission units, control equipment or associated equipment covered by this
Permit, unless a timely and complete Renewal Application is submitted at
least 6 months before the expiration date.
15. PERMIT RENEWAL
Upon MassDEP.Is receipt, of a complete—and timely Application for renewal,
.,,I- * , - .., --::y4may con-,: . Lnue-L'Z) operatc - ��uhj to final action' by MassDEP on
�,, a s. ", i,- a c i.
the Renewal Application.
In the event MassDEP has not taken f inal action on the operating Permit
Renewal Application prior to this Permit's expiration date, this Permit
shall remain in effect until MassDEP takes final action on the Renewal
Application, provided that a timely and complete Renewal Application has
been submitted in accordance witb 310 CMR 7.00: Appendix C(13).
16. REOPENING FOR CAUSE
This Permit may be modified, revoked, reopened, and reissued, or terminated
for cause by MassDEP and/or EPA. The responsible official of the facility
may request that MassDEP terminate the facility's operating Permit for
cause. MassDEP will reopen and amend this Permit in accordance with the
conditions and procedures under 310 CMR 7.00: Appendix C(14).
The filing of a request by the Permittee for an Operating Permit revision,
revocation and reissuance, or termination, or a notification of a planned
change or anticipated noncompliance does not stay any Operating Permit
condition.
17. DUTY TO PROVIDE INFORMATION
Upon MassDEP's written request, the Permittee shall furnish, within a
reasonable time, any information necessary for determining whether cause
exists for modifying, revoking and reissuing, or terminating the Permit, or
to determine compliance with the Permit. Upon request, the Permittee shall
furnish to MassDEP copies of records that the Permittee is required to
retain by this Permit.
18. DUTY TO SUPPLEMENT
The Permittee, upon becoming aware that any relevant facts were omitted or
that incorrect information was submitted in the Permit Application, shall
promptly submit such supplementary facts or corrected information. The
Permittee shall also provide additional information as necessary to address
any requirements that become applicable to the facility after the date a
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 25 of 28
complete Renewal Application was submitted but prior to release of a Draft
Permit.
The Permittee shall promptly, on discovery, report to MassDEP a material
error or omission in any records, reports, plans, or other documents
previously provided to MassDEP.
19. TRANSFER OF OWNERSHIP OR OPERATION
This Permit is not transferable by the Permittee unless done in accordance
with 3 10 CMR 7. 00: Appendix C (8) (a) . A change in ownership or operation
control is considered an Administrative Permit Amendment if no other change
in the Permit is necessaryand provided that a written agreement containing
a specific date for transfer of Permit responsibility, coverage and
liability between current and new Permittee, has been submitted to MassDEP.
20. PROPERTY RIGHTS
This Permit does not convey any property rights of any sort, or any
exclusive privilege. I
I:X��PECTI'ON- AND ENtRY
Upon presentation of credentials and other documents as may be required by
law, the Permittee shall allow authorized representatives of MassDEP and EPA
to perform the following, as per 310 CMR 7.00: Appendix C(3)(g)12.:
(a) enter upon the Permittee's premises where an Operating Permit source
activity is located or emissions- related activity is conducted, or where
records must be kept under the conditions of this Permit;
(b) have access to and copy, at reasonable times, any records that must be
kept under the conditions of this Permit;
(c) inspect at reasonable times any facilities, equipment (including
monitoring and control equipment) , practices, or operations regulated or
required under this Permit; and
(d) sample or monitor at reasonable times any substances or parameters for
the purpose of assuring compliance with the Operating Permit or applicable
requirements.
22. PERMIT AVAILABILITY
The Permittee shall have available at the facility, at all times, a copy of
the materials listed under 310 CMR 7.00: Appendix C(10)(e) and shall provide
a copy of the Permit, including any amendments or attachments thereto, upon
request by MassDEP or EPA.
23. SEVERABILITY CLAUSE
The provisions of this Permit are severable, and if any provision of this
Permit, or the. application of any provision of this Permit to any
circumstances is held invalid, the application of such provision to other
circumstances, and the remainder of this Permit, shall not be affected
thereby.
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Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 26 of 28
24. EMERGENCY CONDITIONS
The Permittee shall be shielded from enforcement action brought for
noncompliance with technology based' emission limit'ations specified in this
Permit as a result of an emergenCY2. In order to use emergency as an
affirmative defense to an action brought for noncompliance, the Permittee
shall demonstrate the affirmative defense through properly signed,
contemporaneous operating logs, or'other relevant evidence that:
(a) an emergency occurred and.that the Permittee can identify the cause(s)
of the emergency;
(b) the permitted facility was at the time being properly operated;
(c) during the period of the emergency, the Permittee took all reasonable
steps as expeditiously as possible, to minimize levels of emissions that
exceeded the emissions standards, or other requirements in this Permit; and
(d) the Permittee submitted notice of the emergency to MassDEP within two
(2) business days of the time when emission limitations were exceeded due to
the emergency. This notice must contain a description of the emergency, any
steps taken to mitigate emission, and corrective actions.taken.
If an emergency episode requires immediate notification to the Bureau of
p/Emezgen-y Response, immediate not'-ficaticn r�o �the
Was! -,-L. Site Cif�a=
app:L3f;ziate parties should be made as requLred by law.
25. PERMIT DEVIATION
Deviations are instances where any Permit condition is violated and not
rf-�ported as an emergency pursuant to Section 24 of this Permit. Reporting a
Permit deviation is not an affirmative defense for action brought for
noncompliance. Any reporting requirements listed in Table 6 of this
Operating Permit shall supercede the following deviation reporting
requirements, if applicable.
The Permittee shall report to MassDEP's Regional Bureau of Waste Prevention
the following deviations from Permit requirements, by telephone or fax,
within three (3) days of discovery of such deviation:
Unpermitted pollutant releases, excess emissions or opacity exceedances
measured directly by CEMS/COMS, by EPA reference methods or by other
credible evidence, which are ten percent (10%-) or more above the
emission limit.
Exceedances of parameter limits established by your Operating Permit or
other Approvals, where the parameter limit is identified by the Permit
or Approval as surrogate for an emission limit.
I Technology based emission limits are those established on the basis of emission
reductions achievable with various control measures or process changes (e.g., a
new source performance standard) rather than those established to attain health
based air quality standards.
2 An "emergency" means any situation arising from sudden and reasonably
unforeseeable events beyond the control of the source, including acts of God,
which situation would require immediate corrective action to restore normal
operation, and that causes the source to exceed a technology based limitation
under the Permit, due to unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to the extent caused by
improperly designed equipment, lack of preventative maintenance, careless or
improper operations, operator error or decision to keep operating despite
knowledge of any of these things.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 27 of 28
Exceedances of Permit operational limitations directly correlated to
excess emissions.
Failure to capture valid emissions or opacity monitoring data or to
maintain monitoring equipment as required by statutes, regulations, your
Operating Permit, or other Approvals.
Failure to perform QA/QC measures as required by your Operating Permit or
other Approvals for instruments that directly monitor compliance.
For all other deviations, three (3) day notification is waived and is
satisfied by the documentation required in the subsequent Semi -Annual
Monitoring Summary and Certification. Instructions and forms for reporting
deviations are found in the Massachusetts Department of Environmental
Protection Bureau of Waste Prevention Air Operating Permit Reporting Kit,
which is available via MassDEP's web site,
http://www.mass.gov/dep/air/approvals/aqforms.htm#op ' . This report shall
include the deviation, including those attributable to upset conditions as
defined in the Permit, the probable cause of such deviations, and the
corrective actions or preventative measures taken.
Deviations that were reported by telephone or fax within three (3) days of
discovery, said deviations * shall also be submitted in writing via the
Operating Permit Deviation Report to the Regional Bureau of Waste
Prevention within ten (10) days of discovery. For deviations that do not
rec
1.1-ree- (1).., day verbal- notif i cation- - f c1iow -i�.n reporting requi rement
are satisfied ty the documentation required in the aforementioned Semi -
Annual Monitoring Summary and Certification.
26. OPERATIONAL FLEXIBILITY
The Permittee is allowed to make changes at the facility consistent with 42
U. S. C. §7401, §502 (b) (10) not specif ically prohibited by the Permit and in
compliance with all applicable requirements provided the Permittee gives the
EPA and MassDEP written notice fifteen (15) days prior- to said change�;
notification is not required for exempt activities listed at 310 CMR 7.00:
Appendix C(5)(h) and (i). The notice shall comply with the requirements
stated at 310 CMR 7.00: Appendix C(7)(a) and will be appended to the
facility's Permit. The Permit shield allowed for at 310 CMR 7-00: Appendix
C(12) shall not apply to these changes.
27. MODIFICATIONS
(a) Administrative Amendments - The Permittee may make changes at the
facility which are considered administrative amendments pursuant to 310 CMR
7.00: Appendix C(8)(a)l.,: provided they comply with the requirements
established at 310 CMR 7_00:1 Appendix C(8)(b).
(b) Minor Modifications - The Permittee may make changes at the facility
which are considered minor modifications pursuant to 310 CMR 7.00: Appendix
C (8) (a) 2. provided they comply with the requirements established at 310 CMR
7.00: Appendix C(8)(d).
(c) Significant� Modifications - The Permittee may make changes at the
facility.which are considered significant modification's pursuant to 310 CMR
7.00: Appendix C(8)(a)3., provided they comply with the requirements
established at 310 CMR 7.00: Appendix C(8)(c).
(d) No Permit revision shall be required, under any approved economic
incentives program, marketable Permits program, emission trading program and
other similar programs or processes, for changes that are provided in this
Operating Permit. A revision t * o the Permit is not required for increases in
emissions that are authorized by allowances acquired pursuant to the Acid
Rain Program under Title IV of the Clean Air Act, provided that such
increases do not require an Operating Permit revision under any other
applicable requirement.
Wheelabrator North Andover, Inc.
Transmittal No. 96402 - Draft Air Quality Operating Permit
Page 28 of 28
APPEAL CONDITIONS FOR OPERATING PERMIT
This Permit is an action of MassDEP. If you are aggrieved by this action, you may
request an adjudicatory hearing within 21 days of issuance of this Permit. In
addition, any person who participates in any public participation process required
by the Federal Clean Air Act, 42 U.S.C. §7401, §502(b)(6) or under 310 CMR 7.00:
Appendix C(G), with respect to MassDEP's final action on Operating Permits
governing air emissions, and who has standing to sue with respect to the matter
pursuant to federal constitutional law, may initiate an adjudicatory hearing
pursuant to Chapter 30A, and may obtain judicial review, pursuant to Chapter 30A,
of a final decision therein.
If an adjudicatory hearing is requested, the facility must continue to comply with
all existing federal and state applicable requirements to which the facility is
currently subject, until a final decision is issued in the. case or the appeal is
withdrawn. During this period, the Application shield shall remain in effect, and
the facility shall not be in violation of the Clean Air Act for operating without
a Permit.
Under 310 CMR 1. 01 (6) (b) , the request must state clearly and concisely the facts
which are the grounds for the request, and the relief sought. Additionally, the
request must state why the Permit is not consistent with applicable laws and
regulations.
alr,,q.- with. a-.- validl- �reck payable to The CC)Tnm=-,,ea..L_t'h of
Massachusetts in the amount of one hundred dollars ��100.00) must be mailed to:
The Commonwealth of Massachusetts
Department of Environmental Protection (MassDEP)
P.O. Box 4062
Boston, MA 02211
The request will be di�smissed if -the filing fee is not paid unless Ehe appellant
is exempt or granted a waiver as described below.
The filing fee is not required if the appellant is a city or town (or municipal
agency), county, or district of the Commonwealth of Massachusetts, or a municipal
housing authority.
MassDEP may waive the adjudicatory hearing -filing fee for a person who shows that
paying the fee will create an undue financial hardship. A person seeking a waiver
must file, together with the hearing request as provided above, an affidavit
setting forth the facts believed to support the claim of undue financial
hardship.
DEVAL L. PATRICK
Governor
TIMOTHY P. MURRAY
Lieutenant Governor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY &, ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
NORTHEAST REGIONAL OFFICE.
205B Lowell Street, Wilmington, MA 01887 * (978) 694-3200
Mr. Scott T. Emerson
Wheelabrator North Andover,
2 85 Holt Road
North Andover, MA 0 1845
Dear Mr. Emerson:
RE:
n C —.1
RECEWED
AUG 2 7 2007
TOWN OF NORTH ANDOVER
HEALTH DEPARTMENT
AUG 2 2 2007
IAN A. BOWLES
Secretary
ARLEEN ODONNELL
Commissioner
NORTH ANDOVER - Metropolitan
Boston/Northeast Region
3 10 CMR 7.08(2) - Municipal Waste Combustors
Application No. MBR -98 -ECP -005
Transmittal No. 201629
EMISSION CONTROL PLAN
DRAFT APPROVAL
The Metropolitan Boston/Northeast Regional Office (NERO) of The Department of Environmental Protection,
Bureau of Waste Prevention, ("MassDEP"), has reviewed your letter dated March 22, 2007, which includes a
proposal to modify your Municipal Waste Combustor (MWC) Emission Control Plan (ECP) Final Approval issued
by MassDEP on June 9, 1999. This ECP letter Submittal includes a, proposal to include an ammonia emission limit in
your ECP Approval, which details how emission limitations and compliance schedules for the control of certain
designated pollutants according to 3 10 CMR 7.08(2) — Municipal Waste Combustors (MWCs), will be implemented
for equipment located at the Wheelabrator North Andover, Inc. facility at 285 Holt Road in North Andover,
Massachusetts. Your submittal bears the signature of Mr. Scott T. Emerson as the designated legally responsible
official for the facility.
LEGAL AUTHORITY
On December 19, 1995, EPA adopted New Source Performance Standards (NSPS) for new MWCs (40 CFR 60 Subpart
Eb), and Emission Guidelines (EG) for existing MWCs (40 CFR 60 Subpart Cb). The United States Environmental
Protection Agency (EPA) amended the EG on October 24, 1997. The NSPS apply to facilities that commenced
construction after September 20, 1994, and the EG apply to facilities that commenced construction on or prior to
September 20, 1994. Both the NSPS and the EG apply to large MWC units, that is, those combusting greater than 250
tons per day of municipal solid waste (MSW). Because the facility was constructed prior to September 20, 1994, and
your two combustion units bum greater than 250 tons per day of MSW, your facility is subject to 40 CFR 60 Subpart Cb
"Emission Guidelines" and 310 CMR 7.08(2). In addition, MassDEP has imposed further requirements, including
materials separation requirements, a requirement for electronic filing of compliance data, cumulative impact
requirements, and lowered the emission limitation for mercury from the Federal limit of 0.090 milligrams per dry
standard cubic meter (mg/dscm.) to 0.028 mg/dscm. With the exception of the emission limitation for mercury, the
Commonwealth has adopted Emission Limits identical to the Federal EG into regulation under 310 CMR 7.08(2),
"Municipal Waste Combustors" as contained in 310 CMR 7.00 "Air Pollution Control Regulations" adopted by
MassDEP pursuant to the Massachusetts General Laws, Chapter I 11, Sections 142 A -M.
The MWC Regulation requires any person who owns, leases, operates or controls a large municipal waste combustor
unit to comply with 310 CMR 7.08(2) in its entirety. The MWC ECP was submitted in accordance with Regulation
3 10 CMR 7.08(2)0).
This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service - 1-800-298-2207.
http://www.mass.gov/dep . Fax (978) 694-3499
10 Printed on Recycled Paper
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 2 of 16
The purpose of 3 10 CMR 7.08(2) is to provide emission limitations and compliance schedules for the control of certain
designated pollutants emitted from Municipal Waste Combustors, in accordance with the requirements contained in
sections I 11 (d) and 129 of the Clean Air Act. 3 10 CMR 7.08(2) establishes requirements for the following:
Operating Practices (Carbon Monoxide (CO), Flue Gas Temperature, Load Level)
Metals (Mercury (Hg), Lead (Pb), Cadmium (Cd))
Particulate Matter (PM)
Opacity
Organics (Dioxin/Furan)
Acid Gases (Sulfur Dioxide (S02), Hydrogen Chloride (HCI))
Nitrogen Oxides (NOx)
Fugitive Ash Emissions
Applicable requirements and limitations contained in 3 10 CMR 7.08(2) shall not supersede, relax or eliminate any more
stringent conditions or requirements (e.g. emission limitation(s), testing, record keeping, reporting, or monitoring
requirements) established by regulation or contained in a facility's previously issued source specific Plan Approval(s) or
Emission Control Plan(s).
B'z��ed upon the above, ViassDEP has determined the your submittal is administrativeiy and technicaliy compie�t- anw.
that the proposed modifications are in conformance with current air pollution control engineering practices and hereby
grants Draft Approval for the proposed modifications of your MWC units, with the conditions listed below.
Wheelabrator North Andover Inc. — Emission �ontrol Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 3 of 16
EQUIPMENT DESCRIEPTION
The following emission units (Table 1) are subject to and regulated by this ECP Approval:
R
EUI
Mass Bum Incinerator/Water Wall
288.4 MMBTU/hr Heat
Two (2) Natural Gas Fired Low NO. 40
Boiler
Input
MMBTU/hr Auxiliary Burners [AB]
173,000 lbs/hr of steam @
(PCD 1)
Selective Non -Catalytic Reduction with
.612 psig/750 Degrees F
Urea Injection [SNCRI (PCD 2)
Powdered Activated Carbon Injection
System [PACII (PCD 3)
Two -Fluid Nozzle Spray Drier
Absorber with Lime Slurry Injection
[SDA1 (PCD 4)
Pulse Jet, 8 Modalle, Size 1615 TA
Model 275, Fabric Filter FFF] (PCD 5)
EU2
Mass Bum Incinerator/Water Wall
288.4 MMB;TU/hr Heat
Two (2) Natural Gas Fired Low NOc 40
Boiler
Input
MMBTU/hr AB (PCD 6)
SNCR (PCD 7)
173,000 lbs/hr of steam @
612 psig/750 Degrees F
PACI (PCD 8)
SDA (PCD 9)
FF (PCD 10)
EU3
Ash Conveying Systems and Buildings
20,000 ACFM @
Water Injected Centrifugal Scrubber,
and Enclosures of Ash Conveying
68 Degrees F
Tri -Mer Corp.
Systems
W-200 Model H (PCD 11)
Ash Conveyors, Buildings and
Enclosures
EU# = Emission Unit Number
PCD = Pollution Control Device
F = Fahrenheit
MMBTU/hr = million British thermal units per hour
@ = at
lbs/hr = pounds per hour
psig = pounds per square inch gauge
ACFM = Actual Cubic Feet per Minute
NO,, =.Oxides of Nitrogen
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MDR -98 -ECP -005
Transmittal No. 201629
Page 4 of 16
APPLICABLE REQUIREMENTS
)N ITMITS AND RESTRICTIONS
The facility is subject to the emission limits/restrictions as contained in Table 2 below:
[�i�!: .�".,'-.I`��!PPERATING;:
;��i i�l���TRACTICE
EUI,
Unit Load:
Opacity
10% (6 minute block average)
EU2
I 10% of maximum
Cd
0.020 mg/dscm at 7% 02
demonstrated load (based
Pb
0.440 mg/dscm at 7% 02
on steam flow), calculated
HCI
29 ppm by volume at 7% 02 dry. basis or 95%
in 4 -hour block arithmetic
. reduction by weight or volume, whichever is less
averages, measured
stringent.
during t1le most recent
Dioxm/Fur-.n
30 ng
,/dscm a� 7% 07
dioxin/furan compliance
PM
27 mg/dscm at 7% 02 1
test in which compliance
3
S02
29 ppm by volume at 7% 02 dry basis or 75%
is achieved
reduction by weight or volume, whichever is less
PM Control Device Inlet
Temperature:
::-�I 170C (300F) above
maximum demonstrated
PM control device inlet
temperature, calculated ir
4 -hour block arithmetic
averages, measured
during the most recent
dioxin/furan compliance
test in which compliance
is achieved'
CO ::� 69 ppm,by volume at 7% 02 dry basis at
I combustor outlet (4 -hour block aveiage) 5
'WUM Ek.,
310 CMR 7.08(2)(f)2.1
310 CMR
7.08(2)(f)Lad.
EPA PSD Permit
No. 029-121 MA16
MBR -82 -INC -004
NO,, 205 ppm. by volume at 7% 02 dry basis 3 10 CMR 7.0 8(2)(f)3.
(24-hour daily arithmetic averne)
Hg < 0.080 mg/dscm at 7% 02 (during any single 3 10 CMR 7.08(2)(g)2.
quarterly compliance test)
Hg 0.028 mg/dscm. at 7% 02 (based on average of 4 3 10 CMR 7.08(2)(f)2.
I quarterly compliance tests per rolling 12 months)
NH3 10 pprn by volume at 7% 02 dry basis 4 3 10 CMR 7.08(2)0)5.
(State Only
2
JrEU3 NA Fugitive Ash I Visible emissions:!� 9 minutes per 3 hour period 13 10 CMR 7.08(2)(Q5.
H
1 In accordance with 3 10 CMR 7.08(l)(g), no person shall cause, suffer, allow, or permit emissions
from any incinerator of any particles that have a dimension greater than 100 microns. (State Only
Requirement)
2 No person subject to 310 CMR 7.08(2) shall cause, suffer, allow or permit the discharge into the
atmosphere of any visible emissions of combustion ash from an ash conveying system (including
transfer points) in excess of 5 percent of the observation period (nine minutes per three-hour period).
I
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 5 of 16
This emission limit does not cover visible emissions discharged inside buildings or enclosures of ash
conveying systems; however the emission limit does apply to visible emissions discharged to the
atmosphere from buildings or enclosures of ash conveying systems. This subsection does not apply
during maintenance and repair of ash conveying systems. Maintenance and repair of the ash
conveying systems must be done in accordance with best management practices.
No person subject to 3 10 CMR 7.08(2) shall:
cause, suffer, allow or permit a municipal waste combustor unit to operate at a load level
(based on steam flow) greater than. I 10 percent of the maximum demonstrated municipal
waste combustor unit load calculated in 4 -hour block arithmetic averages, measured during
the most recent dioxin/furan compliance test in which compliance is achieved; and
2. cause, suffer, allow or permit a municipal waste combustor unit to operate at a temperature,
measured at the PM control device inlet, exceeding 170C (300F) above the maximum
demonstrated PM control device temperature, calculated in 4-bour block arithmetic
averages, measured during the most recent dioxin/furan compliance test in which
compliance is achieved.
During any nine-month dioxin/furan compliance test and the 2 weeks preceding each nine-
month dioxin/furan compliance test, municipal waste combustor unit load limit and PM
control device temperature limitations are not applicable.
Municipal waste combustor unit load limit and PM control device temperature limitations
may be* waived, if prior approval is granted by MassDEP, for the purpose7s of evaluating
system performance, testing new technology or control technologies, diagnostic testing, or
related activities for the purpose of improving facility performance provided that there is an
improvement in controlling air pollution, or advancing the state-of-the-art for controlling
facility emissions.
Based on the current NO,, limit of 205 ppm by volume at 7% 02 dry basis, N113 emissions from each
MWC unit shall be limited to 10 ppm by volume at 7% 02 dry basis. Compliance with the N_H3
emission limit/standard shall be based on a minimum of 3 compliance test runs on each MWC unit
per compliance test, measured at the Spray Drier Absorber inlet or Fabric Filter outlet, using EPA
Test Method 26A or other test method approved by MassDEP.
In accordance with 310 CMR 7.08(2)(e)l., applicable requirements and limitations contained in 310
CMR 7.08(2) shall not supersede, relax or eliminate any more stringent conditions or requirements
established by regulation or contained in a facility's previously issued source specific plan approval(s)
or emission control plan(s). The EPA PSD Permit No. 029-121 MA16, Approval MBR -82 -INC -004,
and Approval MBR -91 -INC -004 CO limit of 0.07 lb/MMBTU, which is approximately equivalent to
69 ppin by volume at 7% 02 dry basis, is more restrictive than the CO limit of 100 ppm by volume at
7% 02 dry basis contained in 3 10 CMR 7.08(2)(f)l.a.i..
Emission limits/standards in Table 2 and under 310 CNIR 7.08 apply at all times except during
periods of start-up, shutdown or malfunction as defined in 40 CFR Part 60, Subpart Eb, 60.58b, as
amended.
+ Table 2 Keye
EU# = Emission Unit Number
mg/dscm = milligram per dry standard cubic meter
ng/dscm = nanogram per dry standard cubic meter
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 6 of 16
ppm = parts per million
Cd = Cadmium
Pb = Lead
HCl = Hydrogen Chloride
Dioxin/Furan = tetra- through octa- chlorinated dibenzo-p-dioxins and dibenzofurans
PM = Particulate Matter
S02 = Sulfur Dioxide
CO = Carbon Monoxide
NO,, = Nitrogen Oxides
Hg = Mercury
NH3 = Ammonia
02 Oxygen
% percent
OC Degrees Centigrade
OF Degrees Fahrenheit
:!� = less than or equal to
NA = Not Applicable
Any person subject to 3 10 CMR 7.08(2) that is subject to 3 10 CMR 7.00 and 3 10 CMR 19.00 shall be in compliance
with, or on a MassDEP approved compliance schedule to meet, all provisions of 3 10 CMR 7..00 and 3 10 CMR 19-00
and any Plan Approval, order, notice of noncompliance or pen -nit issued thereunder. The facility is subject to the
monitoring/testing, record keeping, and reporting requirements as contained in Tables 3, 4 and 5 below and 3 10 CMR
7.08, as well as the applicable requirements contained in Table 2:
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 7 of 16
TaWTI+
11 �i�
kNd'�fES"ITIN G";;k:rz b��T'911��T'
EUI, EU2
2. The facility shall conduct compliance tests for dioxin/furan emissions according to one of the schedules
specified below, as required by 310 CMR 7.08(2)(g)l.a. and b.:
a. The facility shall conduct compliance testing for dioxin/furan emissions on all municipal waste
ombustor unit(s) on a nine month basis, or
b. For municipal waste combustor unit(s) where all compliance tests for all unit(s) over a 27 month period
indicate that dioxin/furan emissions are less than or equal to 7 nanograms per dry standard cubic meter
total mass (ng/dscm), corrected to 7 percent oxygen, the facility may elect to conduct compliance tests for
one unit every nine months.
At a minimum, a compliance test for dioxin/faran emissions shall be conducted every nine months
followirig the previous compliance test for one unit at the municipal waste combustor plant. Every nine
months a different unit at the municipal waste combustor plant shall be tested, and the units at the plant
1" all be tested in sequence.
The facility may continue to conduct compliance testing on only one unit per nine month basis so long as
the dioxin/faran emissions remain less than or equal to 7 ng/dscm @ 7% 02.
If any nine month compliance test indicates dioxin/furan emissions greater than the specified limit,
compliance tests shall thereafter be conducted on all units at the plant every nine months until and unless
all nine month compliance tests for all units at the plant over a 27 month period indicate dioxin/furan
emissions less than or equal to the 7 ngldscm a, 7% 02.
3. In accordance with 310 CMR, 7.08(2)(g)l.d., for municipal waste combustor units where carbon
injection (or equivalent) is used to comply with the dioxin/furan emission limits specified in 310 CNM
7.08(2)(02. or the dioxin/furan emission limit specified in 310 CMR 7.08(2)(g)l.b, the facility shall
neasure and calculate the carbon (or equivalent) usage rate following the procedures specified in 40 CFR
0.58b(m), as amended.
4. In accordance with 310 CNM 7.08(2)(g)2., compliance testing for Hg shall be conducted on all
municipal waste combustor unit(s) on a quarterly basis. Compliance with the emissions limit specified in
3 10 CMR 7.08(2)(f) 2. shall be based on the average of four quarterly compliance tests per rolling twelve
months but shall not exceed 0.080 mg/dscm in any quarterly test.
If compliance with the Hg emission limit has been achieved in each quarter for eight consecutive quarters,
the facility may elect to perforrn compliance testing on a nine-month basis. Any municipal waste
Prnbustor unit(s) that cannot achieve compliance with the emission limitation in 3 10 CNM 7.08(2)(f)2.
Iduring
the nine month compliance test shall resume quarterly compliance testing as specified above. I
Wbeelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MDR -98 -ECP -005
Transmittal No. 201629
Page 8 of 16
Tab e:
kU4
h;i;,!
-NTS� J; 2,
ORING ESTINGREQUIREME
EU I, EU2
5. In accordance with 310 CMR 7.08(2)(g)3., for municipal waste combustor unit(s) which employ a
carbon injection (or equivalent) Hg emission control system, the facility shall conduct optimization tests.
These tests will determine the optimum feed rate for the Hg emissions control apparatus by determinin. g
the carbon (or equivalent) feed rate at which the emissions of Hg are equal to or less than the applicable
limit at 3 10 CMR 7.08(2)(02. The optimization test shall be conducted as follows:
a. The optimization tests shall be performed after a change in carbon (or equivalent), upon request bYl
MassDEP, upon request by the facility, or annually if required under 3 10 CMR 7.08(2)(g)4.
b. If there are identical municipal waste combustor units at the municipal waste combustor plant, then
optimization tests may be performed on one unit, and the resulting parameters applied to the other unit(s),
which is identical to that unit at that plant.
c. Within 30 calendar days of the conclusion of any optimization test the facility shall submit to MassDEP
for approval a proposed optimized carbon (or equivalent) feed rate that minimizes Hg emissions. An
approvable feed rate is the feed rate such that a higher feed rate achieves insigni-Qcant additional reductions
in Hg emissions compared to the amount of carbon (or equivalent) added. The carbon (or equivalent) feed
rate approved by MassDEP shall be used to operate the carbon injection (or equivalent) Hg control system
until the next optimization test is performed and the feed rate approved.
6. In accordance with 310 CMR 7.08(2)(g)6., the facility shall conduct compliance testing every nm*e
months for each municipal waste combustor unit. Compliance testing for dioxin/furan and Hg shall be
conducted as specified in 3 10 CMR 7.08(2)(g)l. and 2.
7. Pursuant to MassDEP's authority through 3 10 CMR 7 .08(2)(j)5., the facility shall conduct compliance
testing for NH3 every nine months for each municipal waste combustor unit. Said testing shall be
conducted in accordance with a test protocol, which has been submitted to MassDEP at least 60 days prior
to the anticipated date of testing, and approved by MassDEP prior to testing. Compliance with the NE3
emission limit/standard shall be based upon a minimum of 3 compliance testruns on each MWC unit per
compliance test, measured at the Spray Drier Absorber inlet or Fabric Filter outlet, using EPA Test
Method 26A or other test method approved by MassDEP. (state Only Requirement)
8. In accordance with 3 10 CMR 7.08(2)(g)5.a. (ftirther clarified in a letter dated October 1, 1998 from
MassDEP's Business Compliance Division), Continuous Emissions Monitoring Systems (CEMS) which
monitor NO., S02, and operating practices parameters (e.g., CO, unit load and PM control device inlet
temperature) shall obtain at a minimum valid continuous emissions monitoring system data for 75% of the
operating hours per day (18 hours per day) for 75% of the days per month (23 days/month for a 30 day
month) that a municipal waste combustor unit is combusting solid waste continuously (24 hours/day) and
valid CEMS data must be obtained for 90% of the hours per quarter that the municipal waste combustor
unit is combusting municipal solid waste.
9. In accordance with 310 CMR 7.08(2)(g)5.b., CO CEMS installed and operated in accordance with
Performance Specification 4 of 40 CFR Part 60, Appendix B, will satisfy the requirements in 3 10 CMR
7.08(2)(g).
10. The nine month compliance demonstration for the opacity limit required under 3 10 CMR 7.08(2)(g)(6)
may be conducted using either data from the continuous opacity monitoring system (COMS) or the
procedures in 40 CFR Part 60, Appendix A, Method 9 as provided for under 40 CFR 60.58b(c)(6) and 40
1CFR
60.1 l(e)(6).
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 9 of 16
3 11. As required by 310 CMR 7.08(2)(g), the facility shall comply with the provisions of 40 CFR
60.58b, "Compliance and Performance Testing", as amended, the provisions of which are hereby
incorporated by reference. Compliance with the fugitive ash requirements as set forth in 310 CMR
7.08(2)(f)5 and the "Applicable Requirements" of this ECP, shall be determined in accordance with 40
CFR 60.58b. Fugitive ash emissions shall be tested every nine months in accordance with 310 CMR
�.08(2)(g) requirements. I
. ..... ....
2T abi 6 4
iLi'L!::;i%li:,�,'� !F
KEEPING REWIR SN N
EUI, EU2
1. In accordance with 3 10 CMR 7.08(2)(h)9., the results of all nine month compliance tests conducted to'
determine compliance with the PM, opacity, Cd, Pb, Hg, dioxin/faran, HCl, and fugitive ash emission�
limits shall be recorded along with supporting calculations and submitted to MassDEP within 90 days after
the test. In addition, the results of the quarterly Hg compliance tests shall also be recorded and submitted
o M.assDEP within 30 days after the test.
Furthermore, pursuant to MassDEP's authority through 310 CNIR 7.08(2)(j)5., the results of all ninel
nonth compliance tests conducted to determine compliance with the NH3 emission limit shall be recorded
ong with supporting calculations and submitted to MassDEP within 90 days after the test. (State Only
Requirement)
2. During all dioxin/furan compliance tests, the maximum demonstrated municipal waste combustor load
and maximum PM control device temperature averages (for each PM control device) shall be recorded
along with supporting calculations, as required by 3 10 CNIR 7.08(2)(h)10.
3. As required by 310 CMR 7.08(2)(h)4., municipal waste combustor unit(s) that apply carbon (or
equivalent) for Hg or dioxin/furan control, shall maintain the following records:
a. The average carbon (or equivalent) mass feed rate (in lbs/hr) estimated as required under 40 CFR
60.58b(m)(1)(i), as amended, during all compliance tests, with supporting calculations.
b. The average carbon (or equivalent) mass feed rate (in lbs/hr) estimated for each hour of operation as
equired under 40 CFR 60.58b(m)(I)(ii), as amended, during the initial dioxin/furan performance test andl
all subsequent nine month compliance tests, with supporting calculations.
c. The average carbon (or equivalent) mass feed rate (in lbs/hr) estimated for each hour of operation as
required under 40 CFR 60.58b(m)(3)(ii), as amended, with supporting calculations.
d. The total carbon (or equivalent) usage for each calendar quarter estimated as specified under 40 CFR
60.58b(m)(3), as amended, with supporting calculations.
e. The carbon (or equivalent) injection system operating parameter data for the parameter(s) that are thel
primary indicator(s) of carbon (or equivalent) feed rate.
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 10 of 16
V;. F�
�a e
k66R' b. k tEPING RE
EUI, EU2
4. As required by 310 CMR 7.08(2)(h)13., for municipal waste combustor units that apply carbon (or
equivalent) for Hg or dioxin/furan control:
a. Identification of the calendar dates when the average carbon (or equivalent) mass feed rates recorded
under 310 CMR 7.08(2)(h)4.c. were less than either of the hourly carbon feed rates estimated during
compliance tests for Hg or dioxin/furan emissions and recorded under 3 10 CMR 7.08(2)(h) 4. a. or b.,
respectively, with reasons for such feed rates and a description of corrective actions taken.
b. Identification of the calen dar dates when the carbon injection (or equivalent) system operating
paraineter(s) that are the primary indicator(s) of carbon mass feed rate (or equivalent) recorded under 3 10
CMR 7.08(2)(h) 4. e., are below the level(s) estimated during the compliance tests as specified in 40 CFR
60.58b(m)(1)(i) and 60.58b(m)(1)(ii), as amended, with reasons for such occurrences and a description of
corrective actions taken.
5. In accordance with 310 CMR 7.08(2)(h)2., the facility shall record the emission concentrations and
parameters measured using continuous emissions monitoring systems. The measurements specified below
shall be recorded and shall be available for submittal to MassDEP or for onsite review by an inspector:
All 6 -minute block averages of opacity levels as specified under 40 CFR 60.58b(c), as amended,
including the highest level measured.
b. All I -hour block averages Of S02 emission concentrations as specified under 40 CFR 60.58b(e), as
amended.
c. All I -hour block averages of NO. emission concentrations as specified under 40 CFR 60.58b(h), as
amended.
d. All I -hour block averages of CO emission concentrations, municipal waste combustor unit load
measurements, and PM control device inlet temperatures as specified under 40 CFR 60.58b(i), as
amended.
e. All 24-hour daily geometric averages Of S02 emission concentrations and all 24-hour daily geometric
averages of percent reductions in S02 emissions as applicable, as specified under 40 CFR 60.58b(e), as
amended, including the highest level recorded.
f. All 24-hour daily arithmetic averages of NO. emission concentrations as specified under 40 CFR
60.58b(h), as amended, including the highest level recorded.
g. All 4 -hour block averages of CO emission concentrations, as applicable, as specified under 40 CFR
60.58b(i), as amended, including the highest level recorded.
h. All 4 -hour block arithmetic averages of municipal waste combustor unit load levels (steam flow) and
PM control device inlet temperatures as specified under 40 CFR 60.58b(i), as amended, including the
hi2hest level recorded.
6. As required by 310 CMR 7.08(2)(h)3., the facility shall record the calendar dates when any of the
average emissions concentrations or percent reductions, or operating parameters recorded under 3 10 CUR
7.08(2)(h)2., exceed the applicable limits, with detailed specific reasons for such exceedances and a
kescriotion of corrective actions taken.
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 11 of 16
77777777771
. . .... .... ....... .. . ... . . .......... .. .... . .. .. .... ...
KEEPM.1",
EU1, EU2
7. As required by 3 10 CM]�, 7.08(2)(h)5., 'the facility shall record the calendar dates and time periods for
which the minimum number pf hours of any of the data specified below have not been obtained including
reasons for not obtaining sufficient data and a description of corrective actions taken:
S02einissions data,
b. NO,, emissions data,
c. CO emissions data,
d. Municipal waste combustor unit load data,
e. PM control device inlet temperature data.
8. As required by 3 10 CMR 7.0 8(2)(h)6., the facility shall record each occurrence thatS02emissions data,
NOX emissions data, or operational data (e.g. CO emissions, unit load, and PM control device inlet
temperature) have been excluded from the calculation of average emission concentrations or parameters,
along with detailed and specific reasons for excluding the data.
9. As required by 310 CMR,7.08(2)(h)7., the facility shall record the results of daily drift tests and
quarterly accuracy determinations for S02, NO,,, and CO continuous emission monitoring systems, as
required under 40 CFR, Part 60, Appendix F, Procedure L'
10. As required by 3 10 CMRI the facility shall maintain records of each occurrence of a
start-up, shut -down or malfunction that results in an exceedance. of the limits defined in Table 2,
including the specific reasons for each occurrence, date, time, and unit involved. Average emissions
concentrations or percent reductions, or operating parameters recorded under 3 10 CUR 7.08(2)(h)2.,
shall be recorded during start-up, shut -down or malfunction that results in an exceedance of the limits
defined in Table 2.
11. In accordance with 3 10 CMR 7.08(2)(h) I L, the facility shall maintain records showing the names of
the municipal waste combustor chief facility operator, shift supervisois, and control room operators who
are certified by ASME (Operator Certification and Provisional Certification), including the dates of initial
and renewal certifications and documentation of current certification.
The facility shall also maintain records showing the names of the municipal waste combustor chief facility
operator, shift supervisors, and control room operators who have completed the EPA municipal waste
combustor ol)erator training course if required.
12. In accordance with 310 CMR 7.08(2)(h)12., the facility shall maintain records showing the names of
the persons who have completed a review of the operating manual as required by 3 10 CMR 7.08(2)(f)6.d.,
including the date of the initial review and subsequent annual reviews.
13. In accordance with 3 10 CMR 7.08(2)(h) L, the facility shall maintain the calendar date of each record
required above.
EU3
14. In accordance with 310 CMR 7.08(2)(h)9., maintain records of the results of all nine month
compliance tests conducted to determine compliance with the fugitive ash emission limit, along with
calculations.
-supporting
EU I, EU2, EU3
15. Any person subject to 3 10 CMR 7.08(2) shall maintain records of the information specified in 3 10
CMR 7.08(2)(h), as applicable, for each municipal waste combustor unit. All records shall be retained at'
the facility for at least 5 years.
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 12 of 16
fl"I,: 7 �,k 7� 7v!;
Ta'
U
. . ......... . ..
EUI, EU2
1. As required by 310 CMR 7.08(2)(i), the facility shall submit an annual report of the information
specified in 3 10 CMR 7.08(2)(i)l., as applicable. The facility which elects to follow the compliance testing
schedule specified in 310 CMR 7.08(2)(g)l.b., shall follow the procedures specified in 310 CMR
7.08(2)(i)1. for reporting the selection of this schedule.
Annual Reporting Requirements The information specified in a. through g. below shall be reported:
a. 3 10 CNIR 7.08(2)(h)2.a., e. through h. for the highest emission levels recorded.
b. 3 10 CMR 7.08(2)(h)4.a. and b.
c. 3 10 CNM 7.08(2)(h)5. — 6.
d. 3 10 CNIR 7.08(2)(h)8. — 10.
e. Summary of a. through d. for the previous year.
E The performance evaluation of the continuous emission monitoring system using the applicable
performance specifications in Appendix B of 40 CFR, Part 60.
g. A notification of intent to begin the reduced dioxin/furan compliance testinc, schedule specified in 3 10
zn
CNM 7.08(2)(g)Lb. during the following calendar year.
2. The facility shall submit a Semiannual report that includes the information specified in 310 CMR
7.08(2)(i)2. for any recorded pollutant or parameter that does not comply with the emission limits as s
forth in 3 10 CMR 7.08(2).
Semi -Annual Reporting Requirements The information specified in a. through e. below shall be
a. 310 CMR7.08(2)(h)2.a., e. throughh. for each date recorded in 310 CMR 7.08(-)(h)3.
b. 3 10 CMR 7.08(2)(h)3.
c. 3 10 CMR 7.08(2)(h)4.c.
3
d. 3 10 CMR 7.08(2)(h)9 .
e. 310 CMR7.08(2)(b)13.
3. AS requiredby 310 CMR 7.08(2)(i), in meeting the reporting requirements of 310 CMR 7.08(2)(i)l. and
3 10 CNIR 7.08(2)(i)2., the facility shall report the information in a format determined by MassDEP that is
designed to be understandable and informative to the public. The information shall be submitted in written
format and electronic format.
+ Tahle 5 Notes&
In accordance with 3 10 CMR 7.0 8(2)(i) I., annual reports shall be submitted to this Office no later
than February 15 of each year following the calendar year in which the data was collected.
Semiannual reports shall be submitted according to the schedule specified: (1) If data reported in
accordance with 3 10 CMR 7.08(2)(i)2 were collected during the first calendar half, then the report
shall be submitted on or before August I following the first calendar half-, (2) If data reported in 3 10
CNM 7.08(2)(i)2 were collected during the second calendar half, then the report shall be submitted on
or before February 15 following the second calendar half
Include only the reports that document emission levels that were above the applicable requirements
and the corrective actions taken.
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 13 of 16
SPECLAL CONDITIONS FOR ECP
a) The facility shall not combust sewage sludge in any of the municipal waste combustor units.
b) In accordance with 3 10 CMR 7.08(2)(D6. and 40 CFR Part 60, Subpart Eb — Section 60.54b, the facility shall
implement the following municipal waste combustor operator training and certification requirements:
The facility shall have each chief facility operator and shift supervisor obtain and maintain an
Operator Certificate issued by the American Society of Mechanical Engineers (ASME).
2. The facility shall not allow the municipal waste combustor unit to be operated at any time unless one
of the following persons is on duty: A chief facility operator or a shift supervisor who has obtained an
Operator Certificate. (A Provisional Certificate is acceptable provided the supervisor is scheduled to
obtain an Operator Certificate in accordance with 310 CMR 7.08(2)(1). A provisionally certified
operator who is newly promoted or recently transferred to a chief facility operator or a shift supervisor
position may perform the duties of the certified chief facility operator or certified shift supervisor
without notice to, or approval by, MassDEP or EPA for up to six (6) months before taking the ASME
certification exam.). If one of the persons listed above must leave the municipal, waste combustor
plant during his or her operating shift, a provisionally certified control room operator who is onsite at
the municipal waste combustor plant may fulfill these requirements subject to 40 CFR. Part 60,
Subpart Eb — Section 60.54b.
When the certified chief facility operator or certified shift supervisor is off site for twelve (12) hours
or less, and no certified operator is onsite, the provisionally certified control room operator may
perform those diities without notice to, or approval by, MassDEP or EPA.
When the certified chief facility operator or c6rtified shift supervisor is off site for more than twelve
(12) hours, but for two (2) weeks or less, and no certified operator is onsite, the provisionally certified
control room operator may perform those duties without notice to, or approval by, MassDEP or EPA.
However, the facility owneror operator shall record the period when the certified chief facility
operator or certified shift supervisor are off site and include that information in the annual report as
specified under 40 CFR Part 60, Subpart Eb — Section 60.59b(g)(5) and 3 10 CMR 7.08(2)(i)l..
k
When the certified chief facility operator or certified shift supervisor is off site for more than two
weeks, and no other certified operator is onsite, the provisionally certified control room operator may
perforin those duties without approval by MassDEP or EPA. However, the facility must take the
following two actions:
i. MassDEP and EPA must be notified in writing. In the notice, the reasons that caused the
absence and the actions being taken to ensure that a certified chief facility operator or
certified shift supervisor is on site as expeditiously as practicable must be included.
ii. A written status report and corrective action summary must be submitted to MassDEP and
EPA every four weeks following the initial notification. The facility shall include in each
status summary a demonstration that a good faith effort has been made and continues to be
made to ensure that a certified chief facility operator or certified shift supervisor is on site. If
MassDEP or EPA provides notice that the status report or corrective action summary is
disapproved, the MWC unit may continue operation for ninety (90) days, but then must
cease operation. If corrective actions are taken in the ninety (90) day period such that
MassDEP or EPA withdraws the disapproval, MWC unit operation may continue.
3. The facility shall have all chief facility operators, shift supervisors, and control room operators
complete the National Technical Information Service — "EPA Municipal Waste Combustor Operating
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 14 of 16
Course".
4. The facility shall establish a training program to review the operating manual with each person who
has responsibilities affecting the operation of an affected municipal waste combustor unit, including,
but not limited to, chief facility operators, shift supervisors, control room operators, ash handlers,
maintenance personnel, and crane/load handlers. Each person specified above shall undergo initial
training no later than the date prior to the day the person assumes responsibilities affecting municipal
waste combustor unit operation and annually thereafter. The site-specific operating manual shall be
updated on a yearly basis and shall address at a minimum the following:
Z�l
i. A summary of all applicable requirements in this regulation;
ii. Basic combustion theory applicable to a municipal waste combustor unit;
iii. Procedures for receiving, handling, and feeding municipal solid, waste;
iv. Municipal waste combustor unit startup, shutdown, and malfunction procedures;
V. Procedures for maintaining proper combustion air supply levels;
vi. Procedures for operating the municipal waste combustor unit within the requirements
established under this regulation;
vii. Procedures for responding to periodic upset or off -specification conditions;
viii. Procedures for minimizing PM carryover;
ix. Procedures for handling ash;
X. Procedures for monitoring municipal waste combustor unit emissions;
xi. Reporting and record keeping procedures.
The facility shall, upon request from MassDEP or EPA, make available all the operating manuals and
records of training for inspection.
c) In accordance with 3 10 CMR 7.08(2)0)5., additional requiremefits may be included in an Emission Control'
Plan Approval if MassDEP determines that the emissions from a municipal waste combustor plant's unit(s)
alone or cumulatively with other municipal waste combustor plant's unit(s) cause or contribute to a condition of
air pollution or a violation of any other regulation. Such requirements would not be federally enforceable and
would be subject to State enforcement only. These requirements could include but are not limited to emissions
limits on air contaminants, and additional stack testing or emission monitoring requirements.
MassDEP may modify the Emission Control Plan at any time if MassDEP determines that a municipal waste
combustor plant's unit(s) alone or cumulatively with other municipal waste combustor plant's unit(s) cause or
contribute to a condition of air pollution or a violation of any other regulation.
Cumulative Impact: MassDEP has assessed the cumulative impact of other municipal waste combustors within
the vicinity of the municipal waste combustor facility. The analyses indicated that the subject municipal waste
combustor facility would not alone or cumulatively with any other municipal waste combustor facility cause or
contribute to a condition of air pollution.
d) In accordance with 310 CMR 7.08(2)(a), no person shall allow, or permit the construction, substantial
reconstruction, alteration or operation of a municipal waste combustor unit on a site which has not received a
site assignment in accordance with M.G.L. c. I 11, s. I 50A. (State Only Requirement)
e) -Should any nuisance condition(s) occur as a result of the operation of this facility, then appropriate steps
shall immediately be taken by the facility to abate said nuisance condition(s).
In accordance with 3 10 CMR 7.08(2), following performance tests for Dioxin\Furan or Mercury emissions,
the facility shall operate with carbon mass feed rate that equals or exceeds the average that was determined
during the performance test. Compliance with this minimum feed rate will be based on carbon mass feed
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 15 of 16 . .
rate 8 -hour block averages, in pounds per hour (lbs/hr).
MODIFICATION TO THE ECP
In accordance with 3 10 CMR 7.08(2)0)7., if MassDEP proposes to modify a MWC planfs ECP, MassDEP shall publish
a notice of public comment in accordance with M.G.L. c. 30A detailing the proposed modification. MassDEP shall
allow for a 30 -day public comment period following the published notice. MassDEP will modify the ECP after the close
of the public comment period.
GENERAL LEGAL RESPONSEBILITY
The facility shall maintain continuous compliance at all times with the terms of this ECP. This Approval may be
suspended, modified, or revoked by MassDEP if at any time the facility is violating any applicable Regulation(s) or
conditions of this Approval.
The application material submitted and this Approval together constitute the approved ECP. Where there is a conflict
between the submitted inforination and this Approval, this Approval -shall rule.
MASSACHUS�ETTS ENVIRONMENTAL POLICY ACT
MassDEP has determined that the filing of an Environmental Notification Form (ENF) with the Secretary of
Environmental Affairs, for air quality control purposes, was not required prior to this action by MassDEP.
Notwithstanding this determination, the Massachusetts Environmental Policy Act (MEPA) and Regulation 301 CMR
11.00 Section 11.04, provide certain "Fail Safe Provisions" which allow the Secretary to require the filing of an ENF
and/or Environmental Impact Report at a later time. The facility submitted an ENF on February 2, 1998 solely because
the project could have triggered the review threshold for financing by a public agency [3 10 CMR I 1.24(4)(a) 1.). On
March 13, 1998,'the Executive Office of Environmental Aflairs issued'a Certificate h1lowing for the emission control
project to proceed without the need t ' o prepare an Environmental Impact Report. The Certificate stated, "the project will
have significant air quality benefits; other environmental impacts should prove minor; and the review of the ENF has
served adequately to disclose iinpacts/benefits and mitigation."
Please be advised that this Approval doesnot negate the responsibility of the facility to comply with this or any other
applicable federal, state, or local regulations now or in the future. Nor does this Approval imply compliance with any
applicable federal, state or local regulations now or in the future.
Should you have any questions concerning thisApproval, please contact Cosmo Buttaro by telephone at (978) 694-
3281, or in writing at the following address: Department of Environmental Protection (MassDEP), 205B Lowell
Street, Wilmington, Massachusetts 0 1887.
Cosmo Buttaro
Environmental Engineer
Sincerely,
Jag
1%�A. Belsky
A-rinit Chief
Bureau of Waste Prevention
cc: Town Hall, 120 Main Street, North Andover, MA 0 1845
Board of Health, 120 Main Street, North Andover, MA 01845
Fire Headquarters, 124 Main Street, North Andover, MA 0 1845
Merrimack ValleyPlanning Commission, 160 Main Street, Haverhill, MA 01830
United States Environmental Protection Agency — New England Regional Office, One Congress Street,
Suite 1100 (CAP), Boston, Massachusetts 02114-2023, Attn: Manager — Air Permits Program
Wheelabrator North Andover Inc. — Emission Control Plan Draft Approval
Application No. MBR -98 -ECP -005
Transmittal No. 201629
Page 16 of 16
MassDEP/Boston: Yi Tian (E -Copy), Marilyn Levenson (E -Copy)
MassDEP/NERO: Tom Parks (E -Copy & Hard Copy), Mary Persky (Hard Copy), Cosmo Buttaro (Hard Copy)
OML4 Environmental, LLC
March 19,2009
Mr. Thomas Trowbridge, DDS, MD, Chairman
North Andover Board of Health
1600 Osgood Street
Building 20; Suite 2-36
North Andover, MA 0 1845
RECEIVED
APR 0 9 2009
TOWN OF NORTH ANDOVER
HEALTH DEPARTMENT
Re: Class A- I Resnonse Action Outcome (RAO) Statement and
Immediate Resvonse Action (IRA) ComDletion ReDort — Hvdraulic Oil Release
Wheelabrator North Andover, Inc.
285 Holt Road
North Andover, MA
RTN # 3-28306
SAK Project No. 06.13.03
Dear Mr. Trowbridge:
This letter has been prepared in accordance with the public notification requirements of the
Massachusetts Contingency Plan (MCP) regulations ()'10 CMR 40.1403) notifying you that a
Class A- I Response Action Outcome (RAO) Statement has been submitted to the Massachusetts
Department of Environmental Protection (MADEP) for a release of hazardous material at 285
Holt Road in North Andover, Massachusetts. This submittal is available for public review at
MADEP's Northeast Region office at 205B Lowell Street in Wilmington, Massachusetts 01887.
If you have questions, please contact Mr. Peter Marrinan, EH&S Compliance Manager,
Wheelabrator North Andover, Inc. at (978) 688-9011 ext. 216.
Sincerely,
SAK Environmental, LLC
By:
Tracey G. Benkosky
cc: MADEP Northeast Regional Office
Peter Marrinan (Wheelabrator North Andover, Inc.)
P.O. Box 234 * North Andover, MA 01845 * phone: 978 688 7804 * fax: 978.688 7801 * www.sakenvironmental.com