HomeMy WebLinkAbout- Inspection - 285 HOLT ROAD 11/10/2021 //K�
Wheelabrator DECEIVED
NORTH ANDOVER
TOWN 0ZM D PAC�1 Cv`a IvT R
MFA
October 19, 2021
Mr. Mark Fairbrother
MassDEP-Northeast Regional Office
205E Lowell Street
Wilmington, Massachusetts 01887
RE: 3`d Quarter 2021 Third Party Inspection Report
Dear Mr. Fairbrother:
Attached is the 3`d quarter 2021 Third Party Inspection Report for the Wheelabrator North Andover
facility. The inspection was conducted by Brown and Caldwell on September 23, 2021.
1 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
this system, or those persons directly responsible for gathering information, the information is
submitted, to the best of my knowledge and belief true, accurate and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
Please feel free to contact me if you have any questions or comments on this report.
Sincerely,
Erik Lueders
Plant Manager
Cc: North Andover BOH
WST 1730.2021.10.19
285 Holt Road I North Andover,MA 01845 1 tel 978.688.9011 1 fax 978.794.8058 www.wtienergy.com
Ll
Massachusetts Department of Environmental Protection Important:When completing
Bureau of Waste Prevention / Solid Waste Management this form on a computer,use
only the Tab key to move your
Third-Party Inspection Report—310 CMR 19.018(8) cursor-not the Return key.
Operation& Maintenance
IV, I
Instructions
Use this form to record and report the results of a Third-Party Operation and Maintenance MassDEP Use Only
Inspection conducted pursuant to 310 CMR 19.018. Be sure to obtain the most recent version Rec'd Date:
of this form. All applicable sections of the submitted form must be completed to be accepted by
MassDEP.
Pursuant to 310 CMR 19.018(8)(a),the third-party inspector and facility owner/operator must sign FMF#:
this Third-Party Inspection Report form and submit the completed report to the appropriate RO#:
MassDEP regional office and one copy of each completed report to the board of health of the
municipality in which the facility is located. Reviewer:
In the event that this inspection report contains a recommendation for corrective action(s),the Comments:
owner/operator shall also submit the information required by 310 CMR 19.018(8)(c)2.
Forms and instructions are available online:
http://www.mass.goy/eea/agencies/massdep/recycle/approvals/solid-waste-applications-and-forms.html#8
Note: This form does not identify all of the requirements applicable to each solid waste
management facility;other requirements and/or policies may apply to the operation, maintenance
and monitoring for each facility.
I. Facility Information
Facility Type(check one):
❑Transfer Station/Handling Facility ❑ C&D Waste Processor or C&D Waste Transfer Station ® Municipal Waste Combustor
❑Active Landfill ❑ Closed Landfill ❑ Other:
Specify jV R
Facility: 100 RS�u�N�
Wheelabrator North Andover, Inc. Spa�SNpEPP
Facility Name
North Andover MA 01845
City/Town State ZIP Code
978-688-9011 Ext. 212 172782 132771
Telephone Number Regulated Object Account Number FMF Number
Operator:
Wheelabrator North Andover, Inc.
Operator Name(Doing Business As/Company Name)
978-688-9011 Ext. 212 elueders@win-waste.com
Telephone Number Email Address
285 Holt Road
Mailing Address
North Andover MA 01845
City/Town State ZIP Code
Permittee:
Wheelabrator North Andover, Inc.
Permittee Name(Entity Identified on Facility Permit)
285 Holt Road
Mailing Address
North Andover MA 01845
City/Town State ZIP Code
Responsible Official for the Facility:
Erik Lueders elueders@win-waste.com
Responsible Official Name(Individual) Responsible Official Email Address
Wheelabrator North Andover, Inc. 978-688-9011 Ext. 212
Responsible Official Company Name Responsible Official Telephone Number
Third-Party Inspection Report(0&M)—Rev.12/4/14 Page 1 of 9
LlMassachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation& Maintenance
II. Third-Party Inspector
Julie Kotowski Brown and Caldwell
Third-Party Inspector Name Company Name
SW48-0000056 06/12/2023
MassDEP Third-Party Inspector Identification Number MassDEP Third-Party Inspector Expiration Date(MM/DD/YYYY)
508-819-1437 jotowski@brwncald.com
Telephone Number Email Address
1 Tech Drive, Suite 310
Mailing Address
Andover MA 01810
City/Town State ZIP Code
Construction and Demolition Waste(C&D Waste)Processing Facility or C&D Waste Transfer Station Only:
Identify the qualified individual that conducted the observation of incoming waste loads and collection of samples of suspect asbestos-
containing materials during the inspection [pursuant to 310 CMR 19.018(6)(f)]. If the entire inspection was conducted by the third-party
inspector listed above, then check the box and enter only the Asbestos Inspector Certification Number.
❑Same as above. Provide Asbestos Certification Number ► MA Dept.of Labor Standards Asbestos Inspector Certification Number
Asbestos Inspector Name Company Name
Telephone Number Email Address
Mailing Address
City/Town State ZIP Code
III. Inspection Details
A. FREQUENCY
Indicate the scheduled inspection frequency for this facility as required by 310 CMR 19.018(6)(b),or a more frequent schedule set forth
in the Facility Permit/Other Approval:
❑ Bi-Monthly ® Quarterly ❑ Semi-Annual ❑ Annual ❑ Biennial
❑ Other(include permit/approval type and date of issuance):
B. DATE,TIME&PERSONNEL
Inspection Date(MM/DD/YYYY): 09/23/2021
Inspection Start Time: 1:00 ❑AM ® PM
Facility Representatives in Attendance During Inspection: Kevin Beauregard
C. CONDITIONS
Air Temperature: Approximately 80 degrees F. Wind Direction(direction from which the wind is blowing):
Weather: ❑ Clear ❑ Partly Cloudy ® Cloudy ❑NW ❑N ❑NE
® Dry ❑ Rain ❑ Snow
❑w Wind ❑E
Wind Speed: ❑ Calm ❑ Breeze ® Moderate ❑ Strong ❑SW ❑S ®SE
Third-Party Inspection Report(0&M) Page 2 of 9
LlMassachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
LIM Operation& Maintenance
IV. Pre-Inspection Preparation
A. FACILITY-SPECIFIC O&M REQUIREMENTS
During each third-party inspection,the third-party inspector shall examine and evaluate the facility's solid waste activities,equipment,
operations, practices, procedures,and records relevant to the type of third-party inspection being conducted in order to determine the
facility's compliance with all applicable requirements as set forth in 310 CMR 19.018(6)(a)1.
Therefore, pursuant to 310 CMR 19.018(6)(a)1, prior to conducting a third-party facility operation and maintenance
inspection,the third-party inspector shall,without limitation, complete all of the following:
® Review and become familiar with the regulations set forth at 310 CMR 19.000—Massachusetts Solid Waste Regulations.
® Identify, review and become familiar with all solid waste permits, plans, approvals,and orders(or other enforcement documents
issued to the facility by the Department), and the solid waste requirements applicable to the operation and maintenance of the
facility.
Relevant requirements may include,without limitation,specific practices and procedures for the operation, maintenance and
monitoring of the facility,waste acceptance/storage limits,and other requirements related to the facility's solid waste activities.
Without limitation,these facility-specific requirements may be contained in the Facility Permit,Authorization to Construct,
Authorization to Operate, Operation and Maintenance Plan, Closure/Post-Closure Plans and Approvals, Facility Modification
Approvals, Beneficial Use Determinations,Administrative Consent Orders, and other determinations,authorizations or
enforcement actions issued by the Department.
1,Julie Kotowski, have identified, reviewed and understand all of the aforementioned requirements that are No. JEK
applicable to this facility and the following are my observations and recommendations related to the Inspector Initials
facility-specific requirements.
B. SOLID WASTE PERMITS, PLANS,APPROVALS&ORDERS
List all relevant solid waste permits, plans, approvals,orders or other enforcement actions issued to the facility by the Department that
contain specific practices, procedures and other requirements still in effect for the operation, maintenance and monitoring or
closure/post-closure of the facility. Where applicable, provide the plan or issue date for each item. For enforcement actions, include
the document number, effective date,and status of implementation by the facility.
Discussion:
Permit Modification Approval -Class II Recycling Program Renewal,August 27, 2018
Waste Ban Compliance Plan,June 19, 2014
Operations and Maintenance Plan, February 2015
Revised Permit and Authorization to Operate,June 30, 2015
Third-Party Inspection Report(0&M) Page 3 of 9
' Massachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation& Maintenance
V. Performance Standards
Examine and evaluate the facility's solid waste activities,equipment, operations, practices, procedures and records relevant to the type
of solid waste facility.
Using the tables below, identify all areas evaluated by the inspector during the inspection by checking the box in the first column.
Describe all deviations noted during the inspection in the third column. Provide recommendations for corrective action to return to
compliance with the applicable performance standard in the fourth column.
Facility Type Performance Standards
Transfer Station/Handling Facility Complete Section A.
(Including C&D Facility) If C&D Handling/Processing Facility,then also complete Section B.
Municipal Waste Combustor Complete Section A.
Active Landfill Complete Sections C. and F.
If active ash landfill,then also complete Section D.
Closed Landfill Complete Sections E. and F.
A. TRANSFER STATION, HANDLING FACILITY,OR MUNICIPAL WASTE COMBUSTOR(INCLUDING C&D FACILITY)
Comments/Observations and
Evaluated Performance Standard Deviation(s) Recommended Corrective
Action(s)
19.205(1)
® Storm Water Controls. Good.
® 19.205(2) Good
Equipment.
19.205(3)
® Weighing Facilities. Good
19.207(1)
® General. Discuss in Section VI. Discuss in Section VI.
19.207(2)
® Good
Supervision of Operation.
19.207(3)
® Access to Facilities. Good
® 19.207(4) Good
Security.
19.207(5)
® Posting of Handling Facility. Good
19.207(6)
® Unloading of Refuse. Managed effectively
19.207(7)
® Special Wastes. None observed
19.207(8)
® Banned/Restricted Wastes. Managed effectively
19.207(9)
® Hazardous Waste. None observed
19.207(10)
Household Hazardous Waste Not applicable
and Waste Oil Collections.
19.207(11)
® Bulky Waste. Container present for bulky waste
storage.
19.207(12)
® Liquid Wastes. None observed
Third-Party Inspection Report(0&M) Page 4 of 9
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation& Maintenance
Comments/Observations and
Evaluated Performance Standard Deviation(s) Recommended Corrective
Action(s)
® 19.207(13) None observed
Bird Hazards.
19.207(14)
® Dust Control. No dust conditions observed outside of
tipping floor.
19.207(15)
® Vector Control. No vector conditions observed
19.207(16)
® Control of Wind-blown Litter. No litter conditions observed
19.207(17)
® Staffing.
Adequate
19.207(18)
® Employee Facilities. Good
19.207(19)
® Accident Prevention/Safety. Good
19.207(20)
® Fire Protection. Good
19.207(21)
® Recycling Operations. Managed effectively
19.207(22)
® Records for Operational and Good
Plan Execution.
19.207(23)
® Screening and/or Fencing. Good
19.207(24)
® O None observed
Open Burning.
19.207(25)
® In compliance
Inspections.
19.207(26)
® End-of-Life Mercury-added None observed
Products.
Third-Party Inspection Report(O&M) Page 5 of 9
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report—310 CMR 19.018(8)
Operation & Maintenance
VI. Inspection Observations
A. FACILITY CONDITION AND OPERATIONS
Examine and evaluate the facility condition and operations as observed during the inspection, including the following:
® Describe any evidence of the following conditions observed at the time of the inspection:
• Unpermitted discharges to air,water, land or other natural resources of the Commonwealth;and
• Dust,odors, litter, and/or other nuisance conditions.
® Document and discuss all deviations from any specific requirements for the facility that are not addressed in the previous section
(Section V.—Performance Standards), including without limitation,the requirements set forth in the facility's operation and
maintenance plan,orders or other enforcement documents,and other solid waste permits,approvals, and authorizations issued to
the facility by MassDEP.
® List the types and estimated quantities of all waste and materials stored at the facility at the time of the inspection.
® Provide a narrative that describes the overall status of the general condition,operation and performance of the facility as
observed at the time of the inspection.
Attach photographs taken during the inspection that depict the general condition and operation of the facility. At a minimum, include
photographs,as applicable,of the waste unloading(tipping)area,waste storage areas, recyclable material storage and,for transfer
stations, the waste reloading activity.
Discussion: Facility operations appeared to be well organized at the time of inspection. Access to the facility is
provided via the gate located at the main entrance from Holt Road south of the Administration building.
Waste vehicles were observed entering through the main entrance gate and weighing in at the scale house. On the
tipping floor, a loader operator was directing waste vehicles where to deposit loads of municipal solid waste and
non-recyclables. After the waste vehicles unloaded their waste and exited the tipping floor the front-end loader was
used to manage the waste on the tipping floor and push the waste into the waste pit. The loader operator
segregates waste ban materials including white goods and cathode ray tubes(CRTs)to designated holding areas for
recycling. Two roll-off containers are located on the tipping floor for bulky waste and for employee and facility
waste. In addition, a small container for CRTs is located on the tipping floor.There is a designated holding area for
CFC-containing devices, and bunkers for bulk metals,ferrous and non-ferrous metals.
At the time of inspection,the employee waste roll-off container was 3/4 full and the bulky waste roll-off container
was 1/2 full. The small container for CRTs was empty. Approximately 800 cubic yards of waste was being held on
the tipping floor. Ash handling was being conducted within the ash handling building. According to the facility
operator, street sweeping of the facility roads is conducted on a daily basis, and more frequently as necessary.
Third-Party Inspection Report(0&M) Page 6 of 9
LlMassachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation& Maintenance
B. RECORD REVIEW
Examine and evaluate the facility's record-keeping. Without limitation,document the status of the facility's compliance with,and any
deviations from, the record-keeping required by 310 MCR 19.000;the facility's operation and maintenance plan;orders or other
enforcement documents issued to the facility;and other solid waste permits,approvals,determinations and authorizations issued to the
facility by the Department, including the following:
® Discuss the evaluation of the Facility's"daily log"such as, daily tonnage records.
® List and discuss any special incidents that have occurred since the previous inspection such as exceedances of the facility's
permitted waste acceptance limits, nature and outcome of complaints reported to the facility operator(including the identity of the
complainant, if known),fires,emergencies,or other disruptions to the routine operation of the facility.
Discussion:
The facility appeared to be operating in compliance with operation and maintenance requirements, current permits,
waste ban compliance plan, and authorization to operate. Incoming waste is weighed at the scale house prior to
delivery to the tipping floor. The tons per day limitation was not exceeded during the period of May 1, 2021 through
August 31, 2021.
Waste ban inspections are being conducted in accordance with the facility's waste ban compliance plan. A minimum
of 20 comprehensive waste load inspections were performed each month, and routine monitoring of every load was
carried out.
One scheduled outage and ten unscheduled outages occurred since the last inspection. During these outages,
repairs and cleaning were conducted. No unanticipated disruptions to the facility occurred as a result of these
outages.
Third-Party Inspection Report(0&M) Page 7 of 9
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation& Maintenance
VII. Summary and Recommendations
Pursuant to 310 CMR 19.018(6)(a)4.,where a third-party inspector observes that the operation or maintenance of the facility deviates
from the aforementioned applicable requirements, he or she shall document all such deviations and recommend corrective actions for
the facility to take to return to compliance.
A. INSPECTION RESULTS
Based on the examinations and evaluations conducted in Sections V.and VI., please summarize the inspection results by checking one
of the following determinations:
® No deviations from the applicable performance standards or additional requirements listed at 310 CMR 19.018(6)
were identified during this inspection.
If no deviations were identified during the inspection, check this box and proceed to Section VII.B.
❑ Deviations from the applicable performance standards or additional requirements listed at 310 CMR 19.018(6)were
identified during this inspection and are discussed further in this report.
If deviations were identified during the inspection,check this box and ensure that each deviation and the recommended
corrective actions are discussed in the applicable section(s)below.
B. STATUS OF PREVIOUS RECOMMENDATIONS FOR CORRECTIVE ACTION
If a previous inspection report identified deviations with recommendations for corrective action, please describe the action(s)taken
since the last inspection to return the facility to compliance with the applicable requirements.
Discussion: None
C. RECOMMENDATIONS FOR CORRECTIVE ACTION
Based on the results of this inspection, please list all deviations noted during the inspection and provide recommendations for corrective
action to return to compliance with the applicable requirement.
Recommendations: None
D. ADDITIONAL COMMENTS
Comments: None
Vill. Additional Information Checklist
Attach the following additional information, as applicable,to complete the inspection report.'
® Attach photographs taken during the inspection that depict the general condition and operation of the facility,as required in
Section VI.A.
❑ For C&D Waste facilities only,attach the analytical results, as required in Section V.B.
`Note:Pursuant to 310 CMR 19.018(8), MassDEP may request additional information.
Continue to Certification Statement on Next Page ►
Third-Party Inspection Report(0&M) Page 8 of 9
LlMassachusetts Department of Environmental Protection
Bureau of Waste Prevention / Solid Waste Management
Third-Party Inspection Report-310 CMR 19.018(8)
Operation & Maintenance
IX. Certification —THIRD-PARTY INSPECTOR
"I attest under the pains and penalty of perjury that:
1. I have personally examined and am familiar with the information
contained in this submittal,including any and all documents Signature of Third-Party Inspector
accompanying this certification statement; Julie Kotowski
2. Based on my inquiry of those persons responsible for obtaining the
information,the information contained in this submittal is,to the best of Print Full Name
my knowledge,true,accurate and complete;
3. 1 have been able to conduct the third-parry inspection and prepare the Brown and Caldwell
third-party inspection report without being influenced by the facility Company Name
owner or operator and, (if I am a municipal employee)without being
influenced by my municipal employer, by any coworker or by any elected or appointed official of the municipality;and Date 10/19/2021
/2021/YYYY)
4. 1 am aware that there are significant penalties,including,but not limited
to,possible administrative and civil penalties for submitting false,
inaccurate,or incomplete information and possible fines and
imprisonment for knowingly submitting false,inaccurate,or incomplete
information."
X. Certification — FACILITY OWNER/OPERATOR
Does the facility maintain a Financial Assurance Mechanism(FAM)pursuant to 310 CMR 19.051? ❑YES ® NO
If yes: . Enter the amount of the current FAM: $
• Enter the date of the last revision of the FAM amount, pursuant to 310 CMR 19.051(6):
As a reminder,pursuant to 310 CMR 19.051(6),the estimate of the cost of closure and post-closure
maintenance must be revised every year, and every second year shall be submitted to the D rtment.
"I certify under the penalty of law: _
1. That I have personally examined and am familiar with the information Signa re�ofResp�.,.,ble Official
submitted in this third-party inspection report,including but not limited to
the statements above concerning the financial assurance mechanism in Erik Lueders
place in accordance with any facility permit and 310 CMR 19.051, and Print Full Name
all attachments and that,based on my inquiry of those individuals
immediately responsible for obtaining the information, I believe that the Plant Manager
information is true,accurate and complete.I am aware that there are Title
significant penalties both civil and criminal for submitting false
information including possible fines and imprisonment.
2. That,in the event that this inspection report contains a recommendation Date(MM/DD/YYYY)
for corrective action(s),I have completed and attached to this report a
Corrective Action Plan and Schedule',pursuant to 310 CMR Pursuant to 310 CMR 19.018(8)(c),a copy of each third-
19.018(8)(c)2." party inspection report shall be maintained at the facility in
accordance with the requirements of 310 CMR 19.000. The
'Note:The owner or operator may elect to correct deviations identified in the Third- owner and operator shall make third-party inspection reports
Party Inspection Report in a manner that is different than that recommended by the available to personnel or authorized representatives of the
Third-Party Inspector,so long as the facility is brought back into compliance with applicable requirements. Department for review at the facility upon request.
Within 30 days of the 0 Mail this completed form to the MassDEP Regional A list of municipalities and MassDEP Regional
inspection date: Office that serves the municipality in which the facility Offices is available online at:
is located.(Attention:Solid Waste Management) http://www.mass.gov/eea/agencies/massdep/about/
co nta cts/fi nd-th e-massdeg-reg i o n al-office-for-you r-
• Send one copy to the local board of health for the city-or-town.html
municipality in which the facility is located.
Third-Party Inspection Report(08M) Page 9 of 9
Photograph Log
Wheelabrator North Andover, Inc.
September 23, 2021
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Photograph 1: Entrance to facility
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Photograph 2: Entrance to tipping floor A
Page 1 of 4
Photograph Log
Wheelabrator North Andover, Inc.
September 23, 2021
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Photograph 3: Tipping floor
Photograph 4: Tipping floor
Page 2 of 4
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Photograph Log
Wheelabrator North Andover, Inc.
September 23, 2021
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Photograph 7: Scales and bunker for CFC-containing devices
Page 4 of 4