HomeMy WebLinkAbout2001 Correspondence SPR Town of North Andover %4°avN
Office of the Planning Department
Community Development and Services Division
27 Charles Street
pOAFTco r�~�
North Andover, Massachitsetts 01845 GHUS
Heidi Griffin Telephone (978)688-9535
Planning Director Fax (978)688-9542
MEMORANDUM
TO: Mark H. Rees, Town Manager
FROM: Heidi Griffin, Town Planne
CC: North Andover Planning Board
RE: Compliance with MRI Decision
DATE: August 13, 2001
Since our site visit with MRI is being held tomorrow night, I have reviewed the decision
for annual compliance for MRI.
I am Unsure if you have ever received a copy of the Planning Board decision, so I am
enclosing it for your files. The decision mentions that multiple items are to be supplied
to the Town Manager annually each year and I am writing this memorandum to
determine if they have provided you with all that is required.
In particular, these items are as follows:
Item Id: Requires that MRI send to Contract Haulers reminders of the designated
route and provide copies of such reminders to the Town Manager.
Item Ie: Requires that AM provide written warnings to the Contract Haulers who
violate the route restriction, with copies to the Town Manager. I don't believe anyone
has violated the route to the best of my knowledge, but you may have copies that are
contrary to this belief.
Item I Requires that MRI send reminders to NESWC relative to the route restrictions
and send copies of such reminders to the Town Manager,
Item 2c: Requires that NMI send compliance reports to regulatory agencies and copies
of these to the Town Manager. I have evidence in my file this has been completed
recently.
BOARD OF APPEALS 688-9541 BUIL131\'G 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLATNINTI1V6 688-9535
Item 4c: Requires that MRI notify the Town Manager with copies of an accident or
violation notice to required regulatory agency. I don't believe any accidents/violations
have occurred.
Item 5d: Requires that MRI pay to the town the lump sum of $25,000 annually on or
before January 2 each year. I have asked the Finance Director to confirm this year's
payment has been made.
Item 5e: Requires that AM provide a bond in the amount of$50,000 to be utilized for
emergency services at the facility while in operation and notify the Town Manager upon
posting of the bond. I have a letter in the file that MRI has notified you of their bond
posting and I have the original bond in my department, which requires additional
paperwork and will be formalized at the September 4 2001 Planning Board Meeting.
I am particularly interested if items Id, I and I have been provided to your office. If
you could kindly apprise me of this I would greatly appreciate it. I am also providing
you with a copy of a chart I update annually to review MRI's compliance.
Thanking you in advance for your cooperation.
1
SITE PLAN APPROVAL/SPECIAL PERMIT
MASSACHUSETTS RE,FUSETECH,INC.
EMISSIONS CONTROL PROJECT
Background
The Planning Board hereby approves with conditions the Special Permit/Site Plan Review
for the construction of emissions control equipment ("the Project") at the existing,solid waste
incinerator located off of Holt Road and owned and operated by Massachusetts Refusctech,Inc.
{"N1RI"). The locus of this incinerator is 285 Holt Road, Assessors Map 34,Lot 21. The land is
owned by the Commonwealth of Massachusetts, and has been leased to MR1.
MM applied for a Special Permit/Site Plan Approval on or about May 15, 1998. The
project involves the installation of air pollution control equipment required by the Clean Air Act
and the regulations promulgated thereunder. MRI proposes to replace the existing electrostatic
pfecipitator and dry sorbent injections systems with new equipment consisting of spray dryer
absorbers, fabric filters, a selective non-catalytic reduction system, a powdered activated carbon
injection system, and natural gas-fired auxiliary burners. The project also involves enclosing the
existing ash storage shed to better control potential fugitive emissions from the ash pile.
The Planning Board held a duly noticed public hearing on the project on June 16th, 1998,
and continued that hearing to August 4t', 1998. The Planning Board closed the public hearing on
August e,- and voted on the application on August 18, 1998. In addition to hearing testimony
from MW and its consultants and members from the public, the Planning Board also received
independent expert analyses from the following individuals; 1)David Minott of Alternative
Resources, Inc., who presented a written report and oral testimony regarding air emissions from
the facility and potential public health impacts; 2) Stephen Ambrose, who presented a written
report and oral testimony regarding noise impacts; and 3).Paul Hajec of Hajec Associates, who
presented a written,report and oral testimony regarding traffic impacts. While this application
was pending before the Planning Board, the North Andover Board of Health also held three
public meetings to hear testimony on the potential health effects of the facility. At the conclusion
of these public meetings, the Board of Health voted unanimously to inform the Planning Board
that on the basis of its review,the facility would not cause adverse public health effects. The
chairman of the Board of Health sent a letter to the Planning Board so indicating.
Findin s
The Planning Board has evaluated the application with respect to all relevant review
criteria and design guidelines set forth in Section 8.3.6 of the Zoning Bylaw and the special permit
criteria set forth in Section 10.3 of the Zoning Bylaw. On the basis of this extensive review, the
Planning Board makes the following findings as required by the North Andover Zoning Bylaw§§
8.3 and 10.3.
e
I
i
1. The site is an appropriate location for the project. The site is within the Industrial
2 zone, and resource recovery facilities are allowed as of right in that district. In addition,the
facility has been operating at this site since the mid-1980's.
2. Provided that MRI complies with all conditions to this approval, the Project will
not cause any adverse effects on the neighborhood. The visual impacts are minimal, as the new
structures are lower than existing structures, and will be placed within the existing developed
footprint of the facility. The noise impacts can be controlled to acceptable levels with proper
design and engineering. Most importantly,the MRI facility will emit significantly lower
concentrations of pollutants as a result of the Project.
3. There will be no nuisance or serious hazard to vehicles or pedestrians, The Project
will cause a minimal increase in truck traffic on Route 125 and Holt Road, and these minimal
impacts will be more than mitigated by conditions imposed on this permit.
4, MRI's plans provide for adequate and appropriate facilities for the proper
operation of the facility. As noted, this is an existing facility, and the existing infrastructure is
adequate and appropriate. To the extent the Project imposes additional demands upon
infrastructure,MRI has appropriately addressed these additional demands in its application.
5. The Project is in harmony with the general purpose and intent of the Bylaw. As
noted, this type of use is allowed as of right in the Industrial District. Also, the Project will result
in lower emissions of pollutants, thereby providing a healthier and safer environment for the
residents of North Andover, compared to existing conditions.
6. MRI has submitted all information required by Section 8.3.5 of the Zoning Bylaw.
7. The Planning Board further finds that the Project should satisfy all relevant review
criteria and design requirements set forth in section 8.3 of the Bylaw.
8. The Planning Board finds that conditions are required in order to ensure full
compliance with Sections 8.3 and 10.3 of the Bylaw. The Planning Board hereby grants an
approval to MRI subject to the following conditions.
Special Conditions
1) Truck Routes/Traffic
a) On April 12, 1982, the North Andover Board of Selectmen requested that the Department
of Environmental Quality Engineering (DEQE) impose a condition in the site assignment
for the MRI facility that would allow the Board of Selectmen to designate a route for the
facility. On Mayl 1, 1982,the DEQE issued a site assignment containing this condition.
On February 11, 1985,the Board of Selectmen voted to designate a route for the facility.
Copies of documents reflecting the above are attached hereto. The term"designated
2
P
i
route" as used below means the route that the Selectmen designated in February 1985 as
may be amended over time. (Modified by vote of the Planning Board, December 15, 1998)
b) Commencing upon the date of filing this decision with the Town Clerk,MRI shall assist in
ensuring compliance with the Designated Route by placing language in all new contracts
with MRI, and in all renewals of existing contracts between MRI, and municipal solid
waste haulers, ash haulers, and metals haulers (collectively referred to as"NM Contract
Haulers")requiring such haulers to use the Designated Route, and any applicable truck
route regulations that may be issued by the Board of Health. This condition will apply to
all contracts that MRI enters into directly with the haulers. To the extent that equivalent
provisions do not already exist in the existing contracts,MRI will use its best efforts to
incorporate the above requirements in the existing contracts by January 31, 1999. The
term best efforts includc8, but is not limited to, sending to such haulers a copy of this
decision and a written request that the contract be amended to incorporate the above
requirements. A copy of any such written request shall be copied to the Town Manager,
and MRI shall follow up the written request with additional efforts should the Town
Manager request it.
c) Deleted. (Vote of Planning Board December 15, 1998)
d) Within thirty days of the date of filing of this decision with the Town Clerk, and at least
annually thereafter, and whenever requested by the Town Manager,MRI shall send to
MRI Contract Haulers reminders of the Designated Route with a reminder that failure to
comply with the route restrictions may result in revocation of the contract or suspension
of tipping privileges. MRI shall promptly send copies of such reminders to the Town
Manager.
c) Within five days of learning of a violation of the above route restriction, MRI shall provide
written warnings to any MRI Contract Hauler that MRI determines has violated the route
restriction notifying the hauler that failure to comply with the route restrictions may result
in revocation of the contract or suspension of tipping privileges. AM shall promptly send
copies of such warnings to the Town Manager.
f) Within thirty days of the date of filing of this decision with the Town Clerk, and at least
annually and whenever requested by the Town Manager, MRI shall send reminders of the
route restrictions to NESWC with a request that NESWC advise its member communities
about the route restrictions. MRI shall promptly send copies of such reminders to the
Town Manager.
g) MRI shall propose and fund the installation of truck turn warning signage along Route
125 northbound,just prior to the Route 125/Holt Road intersection, subject to approval
and implementation by the Massachusetts Highway Department.
3
{ {f p
\ E
h) MRI shad propose and fund center and shoulder-line painting along Holt Road between
Route 125 and the MRI facility, subject to approval and implementation by the North
Andover Department of Public Works.
i) MRI shall propose and fund installation of a YIELD sign for right turns from Holt Road
onto Route 125 southbound, subject to approval and implementation by the Massachusetts
Highway Department and the North Andover Department of Public Works.
j) MRI shall apply for approvals of the Massachusetts Highway Department and the North
Andover Department of Public Works no later than October 31, 1998, and shall make
best efforts to ensure that the condition g, h and i are implemented no later than March 1,
1999.'
2) Air Quality Monitoring and Access to Data and. Records
a) Public Access to Compliance Data in Real Time. Prior to operation of the Project, MRI
shall arrange for public access to Plant data by establishing an Internet website aecgssible
using common web browser software such as Netscape or Microsoft Explorer. Data
from MRI's database computer shall be downloaded to the website for the purpose of
providing public access to continuous emissions and operational operating data, suitably
time-averaged for compliance demonstration as defined by DEP and US EPA permit
conditions, regulations and guidelines. Public access in this regard shall be unrestricted as
to who may access the data, and as to time of day or day of the week. MRI shall provide
the data to the website continuously throughout each day on a basis as near to a real time
as is reasonably practical, but not more than twelve hours following the end of the data
time-averaging period required for compliance demonstration. MR1 shall install a
computer, modem telephone line, and modem in the Town's library to facilitate ready
public access to the data.
'The Planning Board recognizes that there is case law to the effect that a local board may not
impose conditions that require the approval of other agencies, such as the Massachusetts Highway
Department. Should a court determine that Conditions g,h, i and j are invalid on that basis, it is
the Planning Board's intent that those conditions be deemed severable from the remainder of this
decision. The annulment of those conditions would not affect the Planning Board's ultimate
determination that the Project meets the criteria in the bylaw, including traffic-related criteria.
4
i
b) The specific continuous monitoring data to be made publicly available is as follows;
i) Most Recent Cam liance Data: The latest monitored emissions and operating levels,
compared with permit limits(graphical format), specifically:
l Sulfur Dioxide, 24-hour average geometric mean concentration and the removal
efficiency
(2) Nitrogen Oxides, 24-hour daily arithmetic average concentration
(3) Opacity, 6-minute average percentage values, daily summary
(4) Carbon Monoxide,4-hour block arithmetic average
(5) Flue Gas Temperature at the fabric filter inlet, 4-hour block arithmetic average
(6) Mercury,Dioxin, and any other parameter that is tested but not subject to
continuous emissions monitoring data, the latest test results. MW shall test
quarterly for dioxin. The Planning Board reserves the right to amend this
condition and allow less frequent testing if the test results during the first year of
operation reveal levels of dioxin substantially below the permitted limits.
H) Summaries of Historical Compliance with Ap&cable Limit :
(1) For each continuously monitored parameter above, an historical compliance
summary shall be provided that includes, at a minimum, the prior week's data and
the last six months' data. The format, graphical or tabular, shall clearly convey the
number, dates, and magnitudes of any exceedances of applicable limits.
(2) For mercury, dioxin, and any other parameter that is tested but not subject to
continuous emissions monitoring data,the preceding three years of test data, in a
format that clearly conveys the number, dates, and magnitudes of any exceedances
of applicable limits.
iii) Continuous Emissions Monitoring Equipment Malfunction Summaries:
(l) Summaries of time periods during which each continuous monitoring system was
malfiinctioning while the facility was operational, as"operational" is defined by
applicable regulations.
(2) Quarterly cumulative summaries of such malfunction time.
iv) Should W be required by US EPA or DEP to modify the frequency, nature, extent,
or type of sampling and reporting, Mlu shall promptly adapt the above database so
that it is consistent with any such modifications.
c) Compliance Records. Commencing at the time this decision is filed in the Town Clerk's
office, at the same time that Milt submits such reports to regulatory agencies,MRl shall
deliver to the Town Manager two copies of each periodic(e.g.,monthly, quarterly, 9-
month, annual)report required by federal, state, or local permits and/or regulations
relating to air quality.
5
1
d) Inspection of Facility Operations and Records. Commencing at the time this decision is
filed in the Town Clerk's office, the Board of Health and its Agents shall have the right to
both unannounced and scheduled inspections of any and all facility operations and
operating records generated after this decision is filed with the Town Clerk as required to
assess ongoing compliance of the facility with permit limits and conditions imposed by US
EPA, DEP, and the Town, and compliance with the applicable air quality regulations of
those entities. The right to such inspections is unrestricted in frequency,timing, or
duration, provided that such inspections are conducted in the presence of the Plant
Manager or his designated representative, in a manner that does not unnecessarily disrupt
MRI facility operations and in compliance with MRI health and safety policies and
procedures. Without limiting the foregoing, MRI shall provide fourteen days prior notice
to the Board of Health and its designated representative before conducting tests for
mercury, dioxin, and/or any other pollutant that is not tested on a continuous emissions
monitoring basis. The Board of Health and/or its designated representative shall have the
right to be present at the facility during such tests, and shall have access as may be needed
to ensure that the tests are representative of the facility's operations. The test shall be
representative of actual facility operations.
3) Solid Waste Monitoring
a) Inspection for Ash Dusting. The Board of Health and its Agents shall have the right to
periodic unannounced inspections for the purpose of determining whether ash-handling,
storage, and load-out operations comply with the US EPA and DEP requirements
restricting visible emissions,with such compliance to be determined as specified by those
agencies' regulations. Such inspections shall be conducted in the presence of the Plant
Manager or his designated representative, in a manner that does not unnecessarily disrupt
MRI facility operations and in compliance with MRI health and safety policies and
procedures.
4) Shut-Downs of Combustor Units and Other Problems
a) Shut-Down of Combustor Units. NM is required to promptly cease the charging of
municipal solid waste to a combustor unit or units if any of the following criteria is met as
to that combustor unit or units:
i) Potential for Stack Exhaust Fan Failure. The forced draft or induced draft fan ceases
to function. An interlock is required that automatically prevents the further charging
of waste to the affected combustor unit(s),until the fan resumes service.
ii) Potential for Excess Emissions from Inadequate Combustion Efficiency. On startup,
furnace gas temperature, as measured at Elevation 125'- 0" (TI &T2), less than 1600
F (which.is equivalent to 1800 F at the one-second gas residence time plane). An
interlock is required that automatically prevents the charging of waste to the affected
combustor unit(s), until the temperature criterion is met.
.6
J
l
During waste combustion, furnace gas temperature measured at Elevation 125'- 0"
drops below 1600 li for more than three hours. Operator must promptly cease the
charging of waste to the affected combustor unit(s), and cannot resume charging until
the temperature criterion is met.
iii) Potential for Excess Emissions fi•om Failure of the Fabric Filter. More than three
fabric filter modules are out-of service (isolated). Operator must promptly cease the
charging of waste to the affected combustor unit(s), and cannot resume charging until
sufficient modules are in service.
iv) Potential for Excess Emissions from Scrubber Failure. Temperature exceeds 450 F at
fabric filter inlet;i.e., following the spray-dry absorber (scrubber). An interlock is
required that automatically prevents the further charging of waste to the affected
combustor unit(s),until proper scrubber functioning is restored, as evidenced by the
temperature at the fabric filter inlet.
Lime-slurry feed to the spray-dry absorber interrupted for more than four hours.
Operator must promptly cease the charging of waste to the affected combustor unit(s),
until lime-slurry feed is restored.
v) MRI shall maintain a written record on site of the occurrence (date and time) of any of
the above events, and the reason, to the extent known, for the occurrence.
b) If there is a shut down of a combustor unit(s) for the reasons set forth in Condition 4(a),
MRI shall promptly notify the Town Manager of the shut down. The term"promptly"
means if the shut down occurs during Town business hours, within three hours of the shut
down, and if the shut down occurs after Town business hours, no later than 10:00 A.M.
on the next normal business day of the town. MRI Shall also post any such notices to the
Town Manager on the database referenced in Condition 2(a).
c) Commencing at the time that this decision is filed in the Town Clerk's office, whenever
MRI is required by permit to notify a regulatory agency of an accident or violation, MRI
shall also notify the Town Manager at the same time that it notifies the regulatory agency.
MRI shall also post any such notices to the Town Manager on the database referenced in
Condition 2(a).
5) Miscellaneous
a) MR1 shall not combust sewage sludge in the combustor units.
b) Noise: Noise from the facility as upgraded by the Project shall not increase the broadband
level by more than 10dBA above the ambient levels or produce a"pure tone" condition as
set forth in DAQC Policy 90-001, the guideline for 310 CMR 7.10. In order to ensure
compliance with this condition, MR1 shall perform ambient testing prior to operation of
the Project, at Location 5 as referenced in a document entitled "Sound Level Evaluation
7
1
� t
for the Massachusetts Refusetech,Inc.Emissions Control Project,prepared by Michael D.
Theriault Associates,Inc., and consistently with the testing that was done in that report.
MRI shall then perform testing at Location 5 not later than one hundred and eighty days
from completion of on-site construction, and compare the test results to determine
compliance. MRI shall submit the test results with a report indicating whether the test
results indicate compliance with this condition. If the test results indicate non-compliance,
MRI shall devise and implement measures to ensure compliance.
c) MRI shall comply with all applicable federal and state laws,regulations, and permit
conditions governing the operations of the facility.
d) MRI shalt pay to the Town the lump sum of twenty-five thousand dollars ($25,000) on
or before January 2, 1999, in addition to any payments made under the Host Community
Agreement between MRI and the Town, for the purpose of funding air quality monitoring
activities relating to the facility. NM shall pay the lump sum of$25,000 on or before
January 2 of each year thereafter, and this obligation shall cease one year after the
termination of the operation of the entire facility.
e) MRI shall provide financial security in a form acceptable to the Board, such as a proper
bond analogous to that required under the Subdivision Control Law, G.L. c.41, §8IU, in
the amount of fifty thousand dollars($50,000) to be used by the Town for expenses
incurred by the Town should the facility be abandoned or extraordinary expenses incurred
by the Town to provide emergency services at the facility while it is in operation. The
financial security shall be renewable and reinstatable and shall be maintained on a yearly
basis, and MRI shall notify the Town Manager when the financial security is established,
and each time it is renewed.
fj Unless otherwise specified,the conditions herein shall be effective upon operation of the
emissions control project. Operation shall be defined as the date upon which MM
submits its initial performance test to DEP in accordance with the new Clean Air Act
regulations.
g) All conditions to this Special Permit/Site Plan Approval are binding upon any and all
successors, assignees, and transferees of MRI.
h) Without limiting the remedies available to the Town, violations of these conditions are
subject to fines and/or injunctive relief to the fullest extent authorized by law.
i) The air quality consultant retained by the Town shall specifically investigate and address
the extent to which MRI's continuous emissions monitoring equipment is not functioning
and report to the Planning Board based on actual data as to whether a standard stricter
than that imposed by DEP and USEPA should be imposed to address this issue. Such
stricter standards may include but are not limited to, imposing a requirement that a
combustor be shut down if a continuog emissions monitoring system fails for an excessive
amount of time, or requiring redundant continuos emissions monitoring equipment. The
8
I
j
IE
Planning Board reserves the=right to revisit this issue after receiving reports from the air
quality monitor.
j) Prior to the date of Operation,MRI shall submit to the Board an as-built plan, certified
by a professional engineer, indicating that the Project has been constructed substantially in
compliance with the plans contained in the Application for Site Plan Review.
k) The Application for Site Plan Review, dated May 15, 1998, and revised duly 7, 1998 and
the attachments thereto, shall be deemed part of this decision, and the Project shall be
constructed in accordance with those documents and plans including the following:
i) Traffic Impact Assessment prepared by R. D. Vanasse&Assoc., Inc., 10 New
England Business Center Drive, Suite 314, Andover, MA 0 18 10,prepared for
EMCON, 3 Riverside Drive, Andover, MA 01810, dated January 28, 1998,rev.
August 3, 1998.
ii) Air Quality Monitoring Report prepared by Earth Tech, 196 Baker Avenue, Concord,
MA 01742,prepared for Massachusetts REFUSETECH Inc., 285 Holt Road,North
Andover, MA, dated January 1998.
iii) Sound Level Evaluation prepared by Michael D. Theriault Associates, Inc., prepared
for EMCON,Inc., Andover,MA, dated January 1998, June 1998.
iv) Visual Impact Analysis prepared by Young Associates, 121 Juliand Hill Road, Greene,
NY 13778,prepared for Massachusetts REFUSETECH Inc., 285 Holt Road,North
Andover,MA, dated January 6, 1998.
v) Independent Air Quality Review of Proposed MRI Emissions-Control Upgrade,
prepared by ARI, 9 Pond Lane, Concord, MA, for Town of North Andover Planning
Board and Board of Health, dated July 1998.
vi) Noise Study Peer Review prepared by Stephen E. Ambrose,Noise Control Engineer,
4 Old Great Falls Road, Windham,ME 04062, prepared for the North Andover
Planning Board, dated July 30, 1998.
vii)Traffic Review prepared by Hajec Associates, 375 Common Street, Lawrence,MA
01840,prepared for the North Andover Planning Board, dated July 2, 1998.
viii) Plan titled: Massachusetts Refusetech Inc., 285 Holt Road,North Andover,MA
Air Emissions Control System Retrofit General Arrg't Elevation, prepared by
EMCON,Inc., Andover,MA, dated 4/15/98, last rev. 5/21/98
ix) Plan titled: Massachusetts Refusetech Inc., 285 Holt Road,North Andover, MA Plan
to Accompany Application for Site Plan Review,prepared by EMCON, Inc., Andover,
MA, dated 4/15/98, rev. 5/13/98 and 7/7/98.
9
1
e
i
x) Plan titled: Massachusetts Refusetech Inc., 285 Holt Road,North Andover,MA Lime
Preparation retrofit General Arrangement Elevation, prepared by EMCON,Inc.,
Andover, MA, dated 4/15/98,rev. 5/13/98.
Cc. Director of Public Works
Building Inspector
Health Administrator
Assessors
Conservation Administrator
Drainage Consultant
Planning Board
Police Chief
Fire Chief
Applicant
Engineer
File
MRI- Site Plan Review
10
y
Special Permit-Site Plan Review- issued August 19,1 998
Special Condition- 2(b) (i) (6)
On page 5 , lists what info we will mare available to the public via the
webpage.
(6)....."MRI shall test quarterly for dioxin. The planning board reserves
the right to amend this condition and allow less frequent testing if the
test results during the first year of operation reveal levels of dioxin
substantially below the permitted limits."
We are asl'ng that the requirements be set to match the MADEP
requirements. Currently those requirements are every nine months.
I
i
1
Stack Testing Results of Qloxinsli✓urans
ngldscm @ 7% 02
NIIWWIMWNI Unit
1 Unit 2
2004
June 6.764 0.224
Jan 5.82 0.11
2003
Oct 7.039 7,086
July 6.645 6.846
April 1.2 3.2
Jan 1.8 4.5
2002
Nov 2.889 3.383
Aug1.774 2.156
May 1.301 0.586
Feb 0.916 1.239
2001
Nov 0.816 0.967
June 1 0.359 0.362
March 0.366 0.563
Feb NIA 0.41
Limit U1 Avg. 11U2 Avg.
INI
30 2.436 2.25
DioxinlFurans Averages (3 yrs.)
3a
25
20
0 Limit
ngldscm 15 U 1 Avg.
❑LJ2 Avg.
10
A i
5
r
0
1
2001 2004 Averages
M:IFiieslr:nvlAir12004\Emission Testing Summaries