HomeMy WebLinkAbout2004-12-08 Independent Air Qualtiy Review of Proposed MRI Emissions-Control Upgrade 1 f
Town of Noah Andover , t%ORTF,
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COMMUNITY DEVELOPMENT AND SERVICES
30 School Street
W1I LIAM J. SCOTT North Andover, Massachusetts 0 18 45 Ssacwustit�y
Director
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April 23, 199$ ;I'i rm
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Mr. David H. Minott, C.C.M.
Vice, President
Alternative Resources, Inc.
9 Pond Lane
Concord, MA 01742
Re: Air Quality Consulting Service
Dear Mr. Minott;
I am pleased to inform you that the Review Committee has selected your firm for
the Air Quality Consulting Service for the Town of North Andover . Your
proposal was accepted with the fee indicated.
In this regard, I would request that you forward a contract to my office so that we
may begin.
Please contact me at 978-688-9533, should you have any questions.
Sincerely,
Wi li J. Sco
Community DeAlopmentervices Director
Cc: Robert J. Halpin, Town Manager
Kenneth Kimmell, Esq.
Board of Health
Planning Board
BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTII 688-9540 PLANNING 688-9535
Alternative Resour. ,'s, Inc. Corporate Headquarters
9 Pond Lane
, Concord, MA 01742
�,�,�,`'�. ,,�� Tel (978) 371-2054
" t`,o; Fax (978) 371-7269
ODAni
May 1 , 1998
1152
Mr. William J. Scott
Office of Community Development
Town of North Andover
Town Hall Annex
30 School Street
North Andover, MA 01845
Re: Consulting Agreement — Air Quality Consulting Services
Dear Mr. Scott;
Alternative Resources, Inc. (ARI) is very pleased to have been selected to provide Air
Quality Consulting Services in response to the Town's RFQ dated March 12, 1998. ARI
is prepared to commence work immediately upon authorization by the Town. On ARI's
part, we require nothing beyond the simple Consulting Agreement, attached. Kindly
have the appropriate Town official execute both copies of the attached Consulting
Agreement, and return one signed copy to me at ARI.
I look forward to meeting you and to working with the Planning Board.
Very truly yours,
David H. Minott, C.C.M,
Vice President
DHMlsae
Mid-Ailantic Office Midwest Office
Stroudsburg, PA Dayton, OH
Consultants In Environmental Resource Management (717) 424-9932 (937) 275-2295
i
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� 11
CONSULTING AGREEMENT
AIR QUALITY CONSULTING & SERVICES
Alternative Resources, Inc. (ARI) hereby agrees to provide its services to the Town of
North Andover, and the Town of North Andover hereby authorizes ARI to provide such
services, in accordance with the terms and conditions enumerated in ARI's Cost
Proposal for Air Quality Review (March 25, 1998), Incorporated here by reference. As a
specific condition, ARI shall not expend in total more than $25,000, without the prior,
written permission of the Town of North Andover. The Town of North Andover and ARI
execute this Consulting Agreement, by their respective, authorized signatures below:
TOWN OF NORTH ANDOVER ALTERNATIVE RESOURCES, INC. (ARI)
Authorized Signature Authorized Signature
Title Title
Date Date
Alternative Resources,Inc.
'Town of North Andover t NORTH
O' , CEOF ��O`����o ray WOOL
COMMUNITY DEVELOPMENT AND SERVICES
30 School Street
North Andover,Massachusetts 01845 �4SsacHuS�{�y
WILLIAM J. SCOTT
Director
May 5, 1998
Mr. Mathew P. Killeen
Director,Environmental Permitting
wheelabrator Environmental Systems, Inc.
4 Liberty Lane West
Hampton,NH 03842
Re: MR1 Retrofit Site Plan Review/Special Permit
Dear Mr. Killeen,
1 am writing to inform you that the Town has chosen Alternative Resources, Inc. (ARI) to
provide air quality consulting services to the Planning Board for the proposed MRI Retrofit, In
order for them to commence their review of the proposal, you must submit the $50,000 project
review fee to the Town. Although ARI's contract will not exceed $25,000 the Planning Board
will need the services of a storm water management consultant, traffic consultant and legal
consultant. Therefore the full $50,000 outlined in the fee regulations will be required. Any
money remaining in the account at the completion of the project will be returned to you.
I have enclosed a copy of the RFQ, that lists the scope of services the consultant must provide. I
have also enclosed the forms that must accompany the project review fee to establish the escrow
account.
If you have any questions please do not hesitate to contact me at (978) 688-9535.
Very truly yours,
Kathleen Bradley y Colwell
Town Planner
cc. Planning Board
Board of Health
W. Scott,Director CD&S
k Halpin,Town Manager
K. Kimmel, Esq.
CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 698.9535
i
Massachusetts REi FUSETVCjq Inc.
A WMX 1'rdmiogies Company Phone 978.688.9411
285 HOU Road Fax 978.794.8453
Nurih Andover.MA 01845
F+ACSZIWLE
FROM: .i A_� No. of Pages (iudutlu cover
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PROJECT REVIEW FEE
�VIPOSIT MONEY - �-
NORTH NDOVER PLANNINGBOA
_-, 199�
North.Andover, Massaohtisetts
AGREEMENT is made this date between the Town of North Andover and Massachusetts
REFUSETECI-I, INC., hereinafter with his or its executors, devisees, adrninistrators, heirs,
successors and assigns, referred to as the "Applicant' of. 285 Holt Road, North Andover, MA
with business address of 285 Holt Road, North Andover, MA and/or, for individual residence
address of NIA to fund project review for the .Air Emissions
Control Project as shown on a plan entitled Putt to Arxornpany an,application for Site Plan.
Review, prepared by EMCON, dated May 15, 1998, owned by Massachusetts Up-USF..TECH,�-
It�c., with business address of 285 Holt Road Sort , A idovqr,..Maasachu_ and/or, for
individual residence address of.--- N/A for land located at
Road:
��
KNOW ALL MEN by these presents that the Applicant hereby binds and obligates
himself, to the Town of North Andover, a Massachusetts municipal corporation., acting through
its Planting Board, in the sum of$50,000.00 dollars, and has secured this obligatiotl by depositing
with the Treasurer of the Town of North Andover a deposit of money in the above sum to be
deposited in an interests-bearing account as designated by the Town Treasurer in the name of the
Town, The deposit of tYtoney is to be used to unsure the performance by the Applicant of all
covenants, conditions, agreement, terms and provisions contained in the fallowing:
1. Application for Approval of Definitive Plan(Form C), dated N/A
2. The Subdivision Control Law and the Planning Board's Mules and lteguiations governing
the subdivision of land dated N/A
3. Conditions included in the Certificate of Approval issued by the Planning Board and dated
NIA
4, The Definitive flan as qualified by the Certificate of Approval.
5. Other document(s)specifying construction or installation to be completed, n.arnely
N/A -
1
?n 'a 1Q 'ON YHa QQ)1Qb1 n :GT MAU €P-91-IRLI
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6, The de Date money is to be used for the purposes specified in the letter to Mr. Matthew
Kille , irector, EnvirontnWal Pernxitfing, WiteeiabUtOr L�tivironmentai Systems Inc-'by
Kathie Bradley Colwell, 'i'own Planner, Town of North Andover dated May 5, 1998 a
copy of which is attached hereto and incorporated by reference herein ("Project Review
Fee"), Any uatised money and the interest accrued on the deposit of money, unless siad
interest is used to complete such project review, shall be returned to the Applicant at the
time the decision is made on the application.
The Town of North Andover, acting by and through its Planning Board, hereby agrees to accept
the aforesaid deposit'of money in the amount specified in this agreement to be used as a Project
Review Pee as specified herein. Any amendments to this agreement and/or to the aforesaid
security shall not be effective unless agreed upon in writing by the parties to this agreement.
TN WITNESS"WHEREOV we have hereunto set our bards and seals on this date.
Signature of Planning Board Chair or Date
Town.Planner, as authorized by vote of
Planning Board
Signature of Applicant or its Date
Authorized Agent
Social Security it or Taxpayer I.D.
M:ltiwdaS;a�lynch�664
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COMMONWEALTH OF MASSACIWSETTS
ss
Theta personally, appeared - as
the Applicant or hishts authorized agent and acknowledged the foregoing instrument to be his or
her free act and deed and thin Free act and deed of the Applicant, before me.
Notary Public
My Com;nission Expires:
5
COMMONWEALTH OF MASSACHUSETTS
ss , 19_
Then personally appeared as
the Planning Board Chair or his/her authorized agent and acknowledged the foregoing instrument
to be hWher fi;ee act and deed and the free act and deed of the Applicant (?) [ is this correct),
before me.
Notary Public
My Commission Expires:
3
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Alteinatiiye Resources, C. Corporate Headquarters
9 Pond Lang:
Concord, MA 01742
Tel (978) 371-2054
Fox (978) 371-7259
7) Ani
August 14, 1998
P 1186
Mr. Robert J. Halpin
Town Manager -
� V F
Town of North Andover m� , y
Town Hall
120 Main Street
North Andover, Massachusetts 01845
Re: Work Scope for MRI Compliance Monitoring
Dear Mr. Halpin;
In response to a request from members of the Planning Board, Alternative Resources,
Inc. (ARI) has prepared this scope of work for conducting independent monitoring, on
behalf of the Town, of MRI's air quality compliance performance. The independent
monitoring effort would entail real-time emissions checks, on-site inspections, and review
of compliance reports submitted by MR! to DEP.
Developing the details of a monitoring plan (e.g., the specific frequency of on-site
inspections) will require additional, joint planning between ARI and Town officials, and
should also consider input: from interested citizens. A preliminary listing of the elements
of a monitoring plan is provided here, however:
• Regular spot checks (via real-time computer access) of MRI's continuous
monitoring data for evidence of emissions compliance violations, or excessive
monitoring equipment downtime.
• Periodic unannounced and announced inspections of MRI's facility as relate to air
quality compliance. The purposes of such inspections would be to:
Witness the stack emission tests, especially for dioxin and mercury.
Inspect for violations of ash-dusting restrictions as could result from ash
handling, storage, and truck-loading operations (including ash tracking on
tires).
Inspect on-site operating records for the combustors and emission control
equipment to diagnose the reasons for any recent emissions-compliance
violations and to ensure that, if adverse operating conditions had developed
at any time, combustion units were promptly shut down in accordance with
Town-imposed permit conditions.
Mid-Atlantic Office Midwest Office
Stroudsburg, PA Dayton, OH
Consultants In Environmental Resource Management (717) 424-9932 (937) 275-2295
f I
f
Mr. Robert J. Halpin August 14, 1998
P1186 Page 2
�- Confirm that supervisory personnel have the formal Operator Certification
required by DEP and US EPA.
-- Determine the completeness of the Operations Manual required by DEP
and US EPA, and the adequacy of the required operator training program.
• Detailed review of the formal emissions compliance reports and air quality
modeling reports that MRI must submit periodically to DEP (9-month, quarterly).
The focus would be on review for compliance violations, the duration of such
violations, the causes of the violations, and any excessive monitoring equipment
downtime,
• Review any Notices of Violations (NOV) or Consent Orders issued to MR[; explain
the implications in each case to Town officials; monitor resolution of the NOV or
Consent Order issues.
• Review the completeness of the Emission Control Plan that MRI must submit to
DEP providing details of the upgrade project (late 1998).
• Review MRI's protocol for optimizing the emissions control for mercury (DEP's
new regulations require such optimization).
• Participate on DEP's advisory committee (summer/fail 1998) for materials
separation planning and for public reporting of compliance data, if requested to do
so by the Town and by DEP.
Many elements of the monitoring plan can be implemented now; other elements would
be implemented following the upgrade.
An annual budget of $40,000 would be an adequate upper limit for funding the planned
compliance monitoring.
Kindly contact me should you have any questions on this work scope.
Very truly yours,
David H. Minott, C.C,M.
Vice President
DHMlsae
cc: Richard Rowan, Planning Board
Gayton Osgood, Board of Health
Alternative Resources,Inc.
INDEPENDENT AIR QUALITY REVIEW
of
PROPOSED MRI
EMISSIONS-CONTROL UPGRADE
Prepared for:
Town of North Andover
Planning Board and
Board of Health
I
Prepared by;
1
* A111
Alternative Resources, Inc,
9 Pond Lane
Concord, Massachusetts 01742
(978) 371-2054 July, 1998
i
Alternative Resources, Inc. Corporate Headquarters
9 Pond Lane
Concord, MA 01742
Tel (978) 371-2054
Fax (978) 371-7269 j
* Ani
July 24, 1998
1152
Mr. Robert Halpin
Town Manager's Office
North Andover Town Hall i
120 Main Street
North Andover, MA 01845
Re: Final Report - MRI Upgrade
Dear Mr. Halpin:
Enclosed are ten copies of the report prepared by Alternative Resources, Inc., (ARI)
entitled, "Independent Air Quality Review of Proposed MRI Emissions Control Upgrade."
One unbound copy is also enclosed, to facilitate your making additional copies, should
the need arise. Copies have also been distributed directly under separate cover to other
.parties, as listed below.
ARI is very pleased to have been of service to the Planning Board and the Board of
Health.
Very truly yours,
David H. Minott, C.C.M.
Vice President
I
DHM:gat
I
Copies Enclosed Sent Under Separate Cover
—
Planning Board Mr. Kimmell, Bernstein, Cushner & Kimmell, P.C.
(6 copies plus 1 unbound) Ms. Kulash, People for the Environment
Board of Health (3 copies) Mr. Meagher, People for the Environment
Town Manager (1 copy) Mr. Worster, NESWC
Mr. Healy, Goodwin, Proctor & Hoar, LLP
I E
Mid-Allantie Office Midwest j
Stroudsburg, PA Dayton,
Consultants In Environmental Resource Management (717) 424-9932 (937) 2�
INDEPENDENT AIR QUALITY REVIEW
of
PROPOSED MRI
EMISSIONS-CONTROL UPGRADE
Prepared for,
Town of North Andover
Planning Board and
Board of Health
Prepared by;
Alternative Resources, Inc,
9 Pond lane
Concord, Massachusetts 01742 July, 1998
(978) 371-2054
' I
Table of Contents
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
2.0 APPROACH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
3.0 SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.1 Overall Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.2 Key Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.3 Recommended Permit Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6
4.0 PERFORMANCE OF FABRIC FILTERS VERSUS
ELECTROSTATIC PRECIPITATORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
6.0 ABILITY TO MEET NEW EMISSION LIMITS . . . . . . . . . . . . . . . . . . . . . . . 5-1
5.1 Technical Likelihood of Meeting New Emissions Limits . . . . . . . . . . . 5-1
5.2 Qualifications of MRI Operational Staff 5-5
6.0 ASH-DUST MITIGATION AND ASH TOXICITY . . . . . . . . . . . . . . . . . . . . . . 6-1
6.1 Ash-Dust Control Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.2 Ash Characteristics, Before Versus After Upgrade . . . . . . . . . . . . . . . 6-2
6.3 Ash Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3
7.0 HEALTH RISKS FROM STACK EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . 7-1
7.1 Projected Future Health Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
7.1.1 Air Quality Impact Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
7.1.2 Projected Impacts Compared with Ambient Standards . . . . . . . 7-1
7.1.3 Projected Health Risks for
Hazardous Air Pollutants Following MRI Upgrade . . . . . . . . . . 7-2
7.2 Health Risks from Total Exposure to
MRI Facility Emissions, Past and Present . . . . . . . . . . . . . . . . . . . . 7-8
7.2.1 Dioxin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-8
7.2.2 Mercury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 7-12
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Table of Contents [Continued)
7.3 Cumulative Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-13
7.3.1 DEP Study of Cumulative Risk . . . . . . . . . . . . . . . . . . . . . . . . 7-13
7.3.2 Epidemiological Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-14
7.3.3 Accumulated Levels of Mercury in Fish . . . . . . . . . . . . . . . . . . 7-15
8.0 MRl COMPLIANCE HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1
8.1 Compliance Assessments by DEP and CDM 8-1
8.2 Notice of Violation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2
8.3 Conclusions Regarding Compliance History . . . . . . . . . . . . . . . . . . . . 8-3
9.0 COMPLIANCE WITH ZONING BYLAW . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1
10.0 RECOMMENDED PERMIT CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . 10-1
List of Tables
Table 5.1-1: Applicable Emission Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2
Table 7.1-1: Projected Change in Maximum Impacts of Criteria
Air Pollutants, Pre-Upgrade versus Post-Upgrade 7-3
Table 7.1-2: Comparison of Maximum Air Pollutant Impacts after
Upgrade with Ambient Standards . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4
Table 7.2-1: Past Exposure to MR[ Dioxin Emissions . . . . . . . . . . . . . . . . . . . . . . 7-9
Table 7.2-2: Total Dioxin Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-11
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1.0 INTRODUCTION
The Planning Board of the Town of North Andover has before it an Application for Site
Plan Review submitted by Massachusetts Refusetech, Inc. (MRI), the operator of a
regional waste-to-energy facility located in North Andover. MRl operates the facility
under contract to the 23 communities served by the facility, those communities
comprising collectively the North East Solid Waste Committee (NESWC). MRI proposes
in its Application to upgrade the current air-pollutant emission controls at the facility in
order to reduce emissions from the existing combustion process, and to reduce the
potential for ash dusting during ash handling activities. The emissions control upgrade is
required by new Emissions Guidelines that US EPA issued in 1995 (40 CFR 60,
Subpart (Cb) and by corresponding new regulations which Massachusetts DEP will issue
imminently in 1998 (310 CMR 7.08). By law, the emissions control upgrade must be
completed and operating by December 19, 2000.
The Planning Board and the Board of Health of the Town of North Andover have
retained Alternative Resources, Inc. (ARI), to perform an independent review of certain
regulatory, control-equipment, and environmental-impact aspects of the upgrade
proposed for the MRI facility. This report presents findings and recommendations that
result from ARl's independent review.
1
E
2.0 APPROACH
As requested by the Town, ARI has focused its independent air-quality review of MRI's
proposed emissions control upgrade on the following aspects:
• The relative performance of control equipment alternatives -- a fabric filter
versus an electrostatic precipitator.
• The ability to meet the new US EPA and DEP emissions limits, considering
both the proposed upgrade technology and also the qualifications of MRI
personnel to operate it.
• The ability to comply with environmental provisions of the Town's Zoning
Bylaw.
• Health risks from stack emissions — past, current, and future risks.
• The control of ash-dust emissions and the issue of ash toxicity.
ARI has also developed recommendations for specific permit conditions for the Town to
impose, should the Planning Board decide to approve MRI's application for a Site Plan
Approval. ARI's recommended permit conditions have two, key objectives:
• Ensuring public access to emissions monitoring data in "real time."
• Ensuring prompt shut-down of a combustion unit for malfunctions relating to
emissions control.
In preparing this report, ARI in most cases, has used the term "municipal waste
combustor facility" (MWC facility), the terminology for waste-to-energy plants used by
US EPA.
In performing its independent review, ARI conducted an inspection of the MRI facility;
reviewed MRI's permit application and supporting materials; reviewed relevant material
supplied by others, including by concerned citizens; conducted literature reviews;
reviewed applicable new US EPA and DEP regulations in detail; and reviewed extensive
information regarding MRl's compliance record. ARI also attended several public
meetings held by the Board of Health and had extensive fact-finding contact with
numerous cognizant parties, including Town officials, representatives of People for the
Environment, MRI technical staff, MRI consultants, NESWC and its consultant, and DEP
officials.
2-1
3.0 SUMMARY
The Planning Board.and the Board of Health of the Town of North Andover have
retained Alternative Resources, Inc. (ARI) to perform an independent air-quality review of
the emissions control upgrade which MRI proposes for the waste-to-energy facility that
MRI operates in North Andover, under contract to NESWC. ARI's independent review
has addressed certain regulatory, control-equipment, and environmental-impact aspects
of the proposed upgrade.
The upgrade, required by new, US EPA Emissions Guidelines and by corresponding,
new (pending) DEP regulations, must be fully operational by law no later than December
19, 2000. Currently at the MRI facility, control of stack emissions is accomplished with
an electrostatic precipitator (ESP) and with dry-sorbent injection of lime. These devices
would be replaced in the upgrade with:
• Fabric filters (control particulate matter, heavy metals, acid gases, and
dioxin)
• A powdered, activated-carbon injection system (provides enhanced control
of mercury and dioxin)
• Selective Non-Catalytic Reduction — SNCR (controls nitrogen oxides)
Auxiliary gas burners would be added to maintain adequate combustion temperature
during periods of facility start-up and shut-down. Continuous monitoring systems (CEM)
now in operation for nitrogen oxides, sulfur dioxide, carbon monoxide, and opacity would
be improved. In addition, the upgrade would include new measures to reduce the
potential for ash dusting ("fugitive" emissions) in relation to ash handling and load-out
activities. Most notably, those measures would include full enclosure of all ash
conveyance, storage, and load-out operations.
To provide context for ARI's findings listed below, the air pollutants of concern for the
upgrade under US EPA Emission Guidelines and DEP regulations are identified here:
Pollutants Having Formal Air Quality Standards
Particulate Matter
Sulfur Dioxide (SO2)
Nitrogen Oxides (NO)
Carbon Monoxide (CO)
Environmentally-Persistent Organic Compounds
Dioxins/Furans (DEP toxic equivalents)
Polychlorinated Biphenols (PCB)
3-1
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Heavy Metals Acid Gases
Mercury (Hg) Hydrogen Chloride (HCI)
Lead (Pb) Hydrogen Fluoride (HF)
Cadmium (Cd) Sulfuric Acid (H2SO4)
Antimony (Sb)
Arsenic (As) Other
Beryllium (Be)
Capper (Cu) Ammonia (NH.)
Total Chromium (Cr)
Hexavalent Chromium (Cr VI)
Nickel (Ni)
Selenium (Se)
Vanadium (V)
Below, ARI presents the overall conclusions of its independent review, and a summary
listing of key findings. ARI then summarizes the recommendations it makes for Town-
imposed permit conditions.
3.1 Overall Conclusions
The upgrade of the MRI facility would result in a reduction of air pollutant emissions from
the stack, notably of those pollutants of most concern for public health — dioxin, and
metals such as mercury. The upgrade would also significantly reduce the potential for
ash dusting ("fugitive emissions") to result from ash-handling operations. ARI finds that
the upgrade would comply with applicable regulations — US EPA's new Emissions
Guidelines, DEP's proposed regulations that implement those Guidelines, as well as the
Town's Zoning Bylaw.
The fabric-filter control device proposed by MRI would be the better environmental
performer versus the alternative — upgrading the existing electrostatic percipitator (ESP).
ARI concludes that the upgraded MRI facility would meet all emissions limits imposed by
US EPA's new Emission Guidelines. DEP has just set the strictest emission limit for
mercury in the nation. ARI determined that the probability is good that the upgraded
facFi[[ y would meet this new, unprecedented limit. ARI believes the small uncertainty in
this regard is warranted by the environmental benefit of the strict, new mercury limit.
ARI finds MRI's plant operators to be well-trained and to be formally certified as being
competent to operate the facility following the upgrade. Also relevant is that MRI's
record of compliance with permit conditions in the past has been good.
ARI finds that the health-based Guideline limits set by DEP for assessing health risks
incorporate very large margins of safety. ARI determined that, following the upgrade,
emissions impacts from the MRI facility would comply with DEP's Guideline limits.
Further, ARI finds that peoples' total exposure to MRI's emissions -- past, plus future
exposures — would pose no significant risk of adverse health effects. Also, ARI found no
credible evidence that significant health risks have resulted or would result in the future,
3-2
as a consequence of peoples' cumulative exposure to emissions from MRI and other
local combustion facilities. Conversely, there was a limited amount of scientific evidence
available specifically to the contrary, indicating no link between local waste-combustion
facilities and adverse health effects.
High mercury levels in fish pose a serious health threat. Existing waste combustion
facilities are the largest, known source of mercury in the State. It is simply not known,
however, what contribution the MRI facility has made to mercury levels present in locally-
caught fish, versus other important contributors — historic discharges from textile mills
and wastewater plants, as well as major contributors from out-of-State. The emission
levels from the MRI facility, both before and following upgrade, are shown to be safe, as
judged by the facility's emissions impact levels compared with DEP's health-based
Guideline limits.
With the upgrade, MR[ proposes to fully enclose all ash handling, storage, and truck
load-out operations, and to formalize its procedures for cleaning of ash from truck tires.
ARI concludes that these measures would dramatically reduce the potential for ash
dusting (fugitive emissions) and for tire-tracking of ash. ARI believes these control
measures will enable compliance with the stringent restriction on visible emission of ash
dust that US EPA is imposing.
Finally, ARI has developed and recommends a number of specific permit conditions for
the Town to impose, should it choose to approve MRI's site plan application. The goals
of the permit conditions are:
• To ensure public access to emissions compliance data in real time, to
enable independent, public verification of compliance status day-to-day.
• To clearly define the right of the Town to conduct both unannounced and
scheduled inspections of MRI's operations and records, as related to air
quality compliance.
• To ensure that the charging of waste to a combustion unit ceases promptly,
should an emissions-related malfunction occur.
3.2 Key Findings
9. Performance of Fabric Filters Versus Electrostatic Precipitator
• For the upgrade, MRI could either improve its existing electrostatic
precipitators or replace them with new fabric filters. MRI has proposed
fabric filters for the upgrade. While both fabric filters and electrostatic
precipitators provide high removal efficiencies, the fabric filter is more
consistent in ensuring highest removal of fine particulate matter, heavy
metals and dioxin. ARI concludes that fabric filters are the better performer
for the MRI upgrade project.
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1
I
2. Ability to Meet New Emissions Limits
• ARI concludes that the upgraded MRI facility can meet all emission limits
imposed by US EPA's Emission Guidelines. ARI bases this conclusion on
the results of US EPA's analysis of the emissions performance of similarly-
equipped plants nationally, and on the basis of ARI's own review of
historical emissions-test data from several Wheelabrator plants that operate
with emissions controls similar to those proposed by MRI.
• ARI concludes that the upgraded MRI facility can meet all emissions limits
imposed by DEP's proposed new regulations; however, the certainty in this
regard is not as great in the case of DEP's proposed mercury limit. DEP
has proposed an emission limit for mercury that is much more stringent
than US EPA's new Emission Guidelines; in fact, DEP's limit is now the
strictest in the country. Based on the limited but favorable test data from
Wheelabrator facilities equipped as MRI will be with enhanced mercury
control, and the continuing general decline of mercury levels in municipal
solid waste, ARI concludes that the probability is good that the MRI facility
can meet DEP's strict limit for mercury. As no one has been required yet
nationally to meet a mercury limit this strict, it will require a period of
operational experience in the future to determine if MRI or any other
Massachusetts facility can meet the limit, not just most of the time, but
always. ARI concludes that the environmental benefit of this strict, new
mercury limit is worth the small uncertainty in this regard,
• To meet US EPA's and DEP's new emissions limits, the MRI facility must
not only have top emissions control equipment, that equipment must also
be operated effectively. ARI finds the key operational personnel at the MRI
facility to be well-trained and experienced. This conclusion is based on
ARI's inspection of the control room operations, on ARI's inspection of
MRI's on-site operator training program, and importantly, on the fact that
senior operational personnel have already earned Operator Certification, a
future requirement of US EPA's new Emission Guidelines.
3. Compliance with Zoning Bylaw
• The Town's Zoning Bylaw at Section 8.3 (6)(a)(ii) states that:
"The proposed development must not present a demonstrable,
adverse impact on the surrounding area, resulting from
excessive noise, dust, smoke or vibration which are higher
than levels now experienced from uses permitted in the
surrounding area."
The MRI facility represents a "use permitted by right" under the Zoning Bylaws. The
proposed development (the upgrade project) would result in a reduction in the emissions
of a number of air pollutants, no change in the emissions of the other air pollutants, and
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I
improved control of dust from ash-handling operations. The upgrade project would not
entail any new, significant sources of noise or vibration. Because emissions would be
lower, not higher than levels now experienced, and because noise and vibration levels
would not noticeably change compared with existing levels, ARI concludes that the MRI
facility upgrade project complies with Section 8.3(6)(a)(il).
4. Health Risks from Stack Emissions
• With the upgrade, emissions from the MRI facility will go down significantly
for those pollutants of greatest concern — dioxin, mercury and other heavy
metals, and acid gases.
MRI consultants applied air quality models to project maximum air quality
impacts in the community (NO,, SO2, CO, particulate matter) following the
upgrade of the MRI facility. ARI found that standard modeling techniques
were used, and thus, the modeling results are reliable. The modeled
impacts, when added to background air quality levels, yielded projected
total air-quality concentrations. Projected total air-quality levels were well
within ambient standards. Thus, the upgrade project is shown to comply
with ambient standards set by US EPA and DEP to protect public health.
• For emissions of hazardous air pollutants from the MRI facility after
upgrade, the maximum impacts were projected by means of air quality
modeling. The hazardous air pollutants assessed included acid gases
(e.g., hydrochloric acid, sulfuric acid), heavy metals (e.g., mercury, lead,
cadmium), and organic compounds (notably, dioxins and furans). The
modeled maximum impacts for all hazardous air pollutants following the
facility upgrade were projected to be below DEP's health-based Guideline
limits. ARI again found that standard modeling techniques were used, and
that the results are reliable.
• Judging from the disparate opinions of the various health-science experts
presenting at the recent Board of Health public meetings, the toxicity of
pollutants such as mercury and dioxin is controversial. Nonetheless, ARI
believes it has been well demonstrated that DEP's Guideline limits for
mercury, dioxin, and other hazardous air pollutants have been
conservatively set; that is, the Guideline limits were set to protect public
health with a very large margin of safety. Accordingly, air quality impacts
shown to be below the DEP Guideline limits, and to a point, above the
Guideline limits, do not pose a significant health risk. Because maximum
impacts of hazardous air pollutants emitted from the upgraded MRI facility
are shown to be below the DEP Guideline limits, and because DEP
developed those limits very conservatively, ARI concludes that the
upgraded MRI facility would not cause adverse health effects.
• ARl requested that MRI have its health-science consultants prepare a risk
assessment for people's total exposure to MRI emissions; that is, for
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peoples' total exposure from the time the facility opened in 1985 to the time
up to 30 years into the future when it would close. ARI suggested the
assessment focus on dioxin, the pollutant of most concern for long-term
exposure, Results showed that:
Modeled, maximum dioxin impacts in the past (pre-upgrade) ranged
from slightly below to slightly above DEP's Guideline limit. Impacts
at those levels do not pose a significant health risk.
— Modeled maximum dioxin impacts in the future (post upgrade), as
well as the impacts for total exposure — past plus future — were
below the DEP Guideline limit. This indicates impact levels that pose
no significant health risk.
ARI concludes that maximum impacts resulting from dioxin emissions —
past plus future emissions — from the MRI facility will not result in total
exposure levels in the community which would cause adverse health
effects.
• MRI's health-science consultants also assessed peoples' total exposure to
mercury emissions from the MRI facility. The maximum, modeled annual
impacts for mercury — both past and future — were shown to be well below
DEP's Guideline limit for mercury. Accordingly, ARI concludes that
people's total exposure — past and future -- to mercury emissions from the
MRI facility will not result in adverse health effects.
• DEP has undertaken a modeling study to assess the cumulative impacts in
the Merrimack Valley due to existing and future emissions from MRI and
the three other waste combustion facilities in the area. DEP's findings
project no significant future health risks as a consequence of cumulative
exposure to the emissions of four waste combustion facilities operating in
the Merrimack Valley (including MRI). The future impact levels presume
implementation of DEP's proposed, new emission-control regulations.
DEP's study of cumulative risks resulting from existing emission levels from
those four facilities is still in progress.
• Limited epidemiological studies have been performed in the North Andover
area for cancer and for asthma, one study was performed by the
Massachusetts Department of Public Health, and two by a university
professor on behalf of Wheelabrator. These limited studies show no link
between those diseases and emissions from waste combustion facilities in
the area.
• High mercury levels in fish caught in Massachusetts waters, including local
waters, is a serious health threat. Clearly, DEP's recent decision to adopt
the nation's strictest mercury emission limit for municipal waste combustors
underscores DEP's commitment to action. This was justified because
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existing municipal waste combustors are the largest, known, manmade
source of mercury emissions in the State. Mercury present in fish caught
locally comes from many sources, however, besides the MRI facility — past
discharges from textile mills, current wastewater treatment plant discharges,
and major out-of-state sources. The relative contributions of these sources,
however, is simply not known. Noteworthy in this regard is that the
proposed upgrade would significantly reduce mercury emissions from the
facility; i.e., by at [east 85%.
5. Ash-Dust Control and Ash Toxicity
• At present, ash from the MR[ facility is trucked out of Town for disposal;
that practice would not change with the upgrade.
• Regarding control of ash dusting, portions of the ash handling, storage, and
load-out system are partially open to the air at present. This creates an
existing potential for fugitive emissions of ash dust to the air. With the
upgrade, all ash conveyance, handling, storage and load-out systems would
be totally enclosed. Ventilation air from the enclosed, ash-storage and
load-out building would be cleaned with a wet scrubber. That building
would also be equipped with a tire-wash system, to prevent ash tracking by
truck tires. ARI concludes that these measures would dramatically reduce
the opportunity for fugitive emissions of ash to occur. ARI judges that
these control measures would enable MRI to meet the provisions of US
EPA's new Emission Guidelines that stringently restrict fugitive emissions of
ash dust to the air.
• The ash characteristics are not expected to change significantly following
the upgrade of the facility. The amount of ash produced will increase about
ten percent by weight, because of the addition of residue from the
proposed, new scrubbers. Regarding composition, an increase in the small
concentrations of mercury present in the ash should be anticipated,
because mercury removed from the flue gas as a result of the upgrade
would end up in the ash. Based on a review of experience at similarly-
equipped plants, ARl expects that ash produced by the upgraded facility
would pass US EPA's metals-leaching test, as it does at present.
Accordingly, the facility's ash would be classified as a nonhazardous
material.
• Regarding the toxicity of ash, the key issue is the potential over the years
for heavy metals present in ash to leach from an ash landfill into the
environment. The relatively soluble metals, lead and cadmium, are of most
concern. While uncertainty remains in this regard for the long term, ARI
believes there is substantial evidence that metals will not leach from the
ash in significant amounts. First, ash virtually always passes US EPA's
leaching test, indicating the ash is nonhazardous. Second, an ash-
treatment additive used widely today appears to be very effective in making
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the metals present in the ash very resistive to leaching. Third, a decade of
leachate testing at actual ash landfills shows very low metals levels in real
leachate. Finally, reports of apparently-high levels of lead in leachate from
the ash landfill serving Wheelabrator's facility in Claremont, New
Hampshire, were investigated by State and US EPA officials. Those
officials determined that the high lead level appeared in only one leachate
sample, and that the high level "resulted from flawed sample collection."
• Regarding ash, it is ARI's overall conclusion that ash. produced by the MRI
facility after the upgrade will test to be nonhazardous by US EPA's metals-
leaching test. When disposed in an ash landfill, the ash is extremely
unlikely to produce leachate that contains metals in hazardous quantities,
based on over a decade of experience of leachate testing at ash landfills.
6. MRI Compliance Record
• MR1's record of compliance with formal permit requirements is good. MRI
has been in compliance with all current permit limits historically, except for
sulfur dioxide. Violations of permit limits for sulfur dioxide in the early years
ceased with the installation of additional emissions controls in 1992.
US EPA issued a Notice of Violation to MRI in November, 1997, over which
US EPA and MRI are currently negotiating. The substantive matters cited
in the Notice do not appear to connote any implications for public health,
and primarily involve procedural reporting violations.
3.3 Recommended Permit Conditions
In the event that the Planning Board approves MRI's application for a Site Plan Approval,
ARI has developed a set of specific permit conditions that the Board may wish to
impose. The goals of those suggested permit conditions are:
• To ensure public access to emissions compliance data in real time, to
enable independent, public verification of compliance status day-to-day.
• To clearly define the right of the Town to conduct both unannounced and
scheduled inspections of MRI's operations and records, as related to air
quality compliance.
ARI has also developed specific permit conditions that would require prompt cessation of
waste charging to a combustor unit, in the event of an emissions-related malfunction.
Waste charging would cease if:
• The stack exhaust fan fails.
• There is inadequate combustion efficiency (low temperature)
• The fabric filter falls.
• The scrubber fails.
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4.0 PERFORMANCE OF FABRIC FILTERS VERSUS ELECTROSTATIC
PRECIPITATORS
Particulate matter emitted by MWC facilities consists principally of fly ash plus residue
(salts and unreacted-lime reagent) from the acid gas scrubbing system.
US EPA and Massachusetts DEP focus their regulation of particulate matter on fine
particles, because it is particles of respirable size (submicron to 10-micron diameter) that
create the greatest health risks from inhalation. For MWC facilities in particular, heavy
metals (e.g., lead, cadmium, mercury) as well as dioxin present in the exhaust gas
concentrate preferentially on the fine, respirable-size particles. Thus, effective control of
fine particulate matter emitted from MWC facilities is essential.
Fabric filters (also known as baghouses) and electrostatic precipitators (ESPs) are the
most widely used devices worldwide for controlling emissions of particulate matter from
MWC facilities. This is because these devices have proven over the years to be the
most effective.and reliable in reducing particulate emissions from MWC facilities. While
both devices do remove particulate matter with very high efficiency, the fabric filter has
the performance "edge," as is further discussed below.
A fabric filter works much like a sophisticated vacuum cleaner. With fabric filters, the
flue gas is drawn through filter material, and particulate matter present in the gas is
sieved out. As flue gas flows through the fabric filter, particulate matter builds up on the
surface of the filter material to form a "cake." The cake greatly augments the filtering
capacity over that of the filter material alone. As a consequence, fabric filters achieve a
very high removal efficiency on a consistent basis, including specifically for fine,
respirable-size particulate matter. Fabric filters are "forgiving," providing very high
removal efficiency over a wide range of particle sizes and inlet loadings, and over
varying ash compositions and flue gas flow rates.
In the air pollution control train, the fabric filter is preceded by a scrubber for acid gas
control and by activated-carbon injection for greater consistency of mercury and dioxin
removal. Unreacted lime reagent from the scrubber, as well as carbon particles from the
carbon injection process, become part of the cake buildup on the fabric filter. When the
flue gas passes through the filter cake containing lime and carbon, this results in
enhanced control of acid gases, mercury, and dioxin.
A disadvantage of fabric filters versus ESPs is that fabric filters require a substantially
greater, ongoing commitment to preventative maintenance. Otherwise, the fabric filters
can malfunction due to clogging or filter-material failures, resulting in emissions
excursions.
With an ESP, particulate matter is removed via electrostatic attraction. That is,
particulate matter in flue gas passing through the ESP is given an electric charge by
means of a high-voltage electric field. The charged particles are attracted to collector
plates within the ESP that are charged oppositely. The particles then stick to the plates
electrostatically and are collected.
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ESPs are proven for over two decades to provide high collection efficiency of particulate
matter emitted by MWC facilities. The ESP presently in use at the MRI facility has
always complied with the existing permit emission limit of 0.05 grains of particulate
matter emitted per cubic foot of flue gas (0.05 grldscf @ 12% CO2). This emission limit
was considered strict when issued by DEP. By comparison, the new US EPA Emission
Guidelines and DEP draft regulations impose a stricter limit of 0.27 mg/dscm — about
0.012 grldscf. US EPA has determined that both fabric filters and ESPs operating at
existing MWC facilities can achieve this new, stricter performance level in removing total
particulate matter. A relevant advantage of ESPs over fabric filters is that ESPs achieve
high removal efficiency of total particulate, with lower maintenance requirements than
with fabric filters. The main disadvantage of ESPs is that the collection efficiency varies
with particle size, with ash characteristics such as electrical resistivity, and with the flue
gas flow rate. Most notably, an ESP's collection efficiency decreases for very fine
(submicron) particles; i.e., the size range of particles in which heavy metals and dioxin
tend to concentrate. In addition, the ESP does not afford a final "polishing" step of
control for acid gases, mercury, and dioxin, as does the cake buildup of a fabric filter.
In summary, both fabric filters and ESPs are capable of high removal efficiencies of
particulate matter emitted by MWC facilities. This is evidenced, for example, by the fact
that US EPA in its new Emissions Guidelines for existing MWC facilities has set the
same, strict emission limit (27 ngldscm @ 7% 02) on emissions of total particulate
matter from existing MWC facilities, irrespective of whether a fabric filter or an ESP is
used. Fabric filters, however, more consistently achieve high removal efficiencies over
varying ash and flue gas conditions. Most importantly, fabric filters consistently remove
the very fine, respirable-size particles that are associated with emissions of heavy metals
and dioxins. For dioxin in particular, this fact is reflected by US EPA's Emission
Guidelines. While EPA has set the same emission limit for fabric filters and ESPs for
removal of total particulate, it has set a slightly more stringent limit on dioxin emissions
for fabric filters (30 ngldscm total mass emission) than for ESPs (60 ngldscm). Besides
the more consistent filtering capability of fabric filters, unreacted lime and carbon present
in the filter cake provide a final "polishing" step of control for acid gases, mercury and
dioxin.
In conclusion, while both fabric filters and ESPs provide high removal efficiencies, the
fabric filter is more consistent in ensuring highest removal of fine particulate matter,
heavy metals and dioxin. Fabric filters are the better performer for the MRI upgrade
project.
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5.0 ABILITY TO MEET NEW EMISSION LIMITS
In this section, ARI addresses the likelihood that MRI's upgrade will achieve compliance
with the stricter emission limits being imposed by US EPA and DEP. ARI makes this
assessment based on review of the tested performance of plants elsewhere with similar
control equipment, and also on review of the qualifications of the MRI facility operating
staff.
5.1 Technical Likelihood of Meeting New Emissions Limits
The MRI facility upgrade will add new equipment to further reduce air pollutant
emissions. A system comprised of a spray-dry absorber (SDA), which is a scrubber that
uses lime as a reagent, plus a fabric filter (FF), also known as a baghouse, will be
installed on each of the two waste combustion units. The SDAIFF system will further
reduce emissions of particulate matter, acid gases (S02, HCI, HF, H2SO4), heavy metals
(Pb, Hg, Cd), and dioxins and furans. Powdered activated carbon will be injected into
the SDA to enhance the removal of mercury and dioxin. A Selective Non-Catalytic
Reduction (SNCR) system will be added to each combustion train which injects urea into
the combustor in order to further control emissions of nitrogen oxides (NOJ, Auxiliary
burners, fueled with natural gas, will be added to each combustion unit in order to
maintain adequate combustion temperature during periods of facility start-up and shut-
down. This reduces the likelihood of emissions excursions during those periods. Finally,
facilities for handling the combustion ash will be improved to prevent visible dusting
("fugitive" emissions) of ash during ash handling and load-out operations.
The MRI facility currently has emission limits for particulate matter, S021 NOx, CO, and
H2SO4. The limits for particulate, S02 and NO,, become more stringent under US EPA's
new Emission Guidelines and DEP's corresponding, new regulations. New, additional
limits are also added for HCI, heavy metals (Pb, Cd, H,), and dioxins. Both the existing
and the new emission limits, plus the required bases for demonstrating compliance, are
summarized in Table 5.1-1.
ARI has analyzed the likelihood that the upgraded MRI facility would meet the new
emissions limits being imposed through US EPA's new Emissions Guidelines, and DEP's
new regulations. First in this regard, ARI notes that US EPA's Emission Guideline limits
have been determined by that agency to represent Maximum Available Control
Technology (MACT). US EPA defines the MACT "floor" as an emission level at least as
stringent as that demonstrated by the top-performing 12 percent of existing MWC units
nationally. EPA set its emissions limits at the MACT floor, except for dioxin, mercury,
and cadmium, for which more stringent limits were set as MACT. US EPA's MACT
determinations were based on an extensive analysis by US EPA of the emissions
performance of nearly all large MWC facilities operating nationally. US EPA determined
that existing large MWC facilities, if equipped with the types of emissions controls MRI
proposes, will meet the Emission Guideline limits. Based on US EPA's MACT
determination, ARI expects that emissions from the upgraded MRI facility would comply
with US EPA's Emission Guideline limits for all pollutants.
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Table 5.1-1
APPLICABLE EMISSION LIMITS
Existing DEP Emission New US EPA/DEP Compliance
Pollutant Limit Emission Limit Demonstration'
27 mg/dscm @ 7%02 Stack Test
Particulate Matter (Average of 3 runs)
(PM) 0.05 grldscf (-0.012 grldscf
@ 12%CO2 @ 7%02)
Opacity — 10% Continuous Monitoring,
6-minute average
29 ppmdv @ 7%02 or 75% Continuous Monitoring,
Sulfur Dioxide(S02) reduction,whichever is less 24-hour geometric mean
stringent
0.27lb/MMBtu (-0.181b/MMBtu)
Carbon Monoxide 0,07lb/MMBtu' 100 ppmdv @ 7%02 Continuous Monitoring,
(CO) (-0.10 Ib/MMBtu) 4-hour average
Nitrogen Oxides 205 ppmdv @ 7%02 Continuous Monitoring,
(NOx) 24-hour arithmetic average
0.6 ib/MMBIu (-0.34 lb/MMBtu)
Sulfuric Acid Stack Test
ASO,) 0.02 Ib/MMBtu' No EPA limit (Average of 3 runs)
Hydrogen Chloride 29 ppmdv @ 7%02 or 95% Stack Test
(HCI) reduction,whichever Is less (Average of 3 runs)
stringent
Lead(Pb) 0.44 mgldscm @ 7%02 Stack Test
(Average of 3 runs)
Cadmium(Cd) MRt Proposed Limit Stack Test
0,02 mgldscm @ 7%02 (Average of 3 runs)
US EPAIDEP Limit
0.04 mg/dscm @ 7%02
US EPA Limit:
0.080 mg/dscm @ 7%02,
Mercury(Hg) or 85%Reduction
DEP Limit: Stack Test
0.028 mgldscm @ 7%02 (Average of 3 runs)
Dioxins/Furans — 30 ng/dscm(Total Mass) Stack Test
@ 7%02 (Average of 3 runs)
Fugitive Emission — Visible emissions<5%of the Visual Observation Test(Average
from Ash Handling observation period of 3, 1-hour observations)
1. DEP's limit applies because It Is more stringent than US EPA's limit.
2. Limits apply at al€times,except during periods of start-up,shut-down,or malfunction,per US EPA regulations(40 CFR Part
60.58b)and proposed DEP regulations(310 CMR 7.08).
3. Compliance Details:
DEP requires stack tests be conducted every 9 months,except for mercury.
• DEP requires compliance with the mercury limit, based on the annual average of four quarterly tests.
US EPA and DEP require annual demonstration of compliance with the fugitive ash emissions limit.
US EPA and DEP require continuous emissions monitors to be operational at least 90%of the hours of each quarter
during which the facility operates(Le., is combusting waste).
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ARi also reviewed emissions test data from Wheelabrator MWC facilities equipped with
emission controls that are the same as those planned for the MRI facility upgrade. In
this regard, ARI focussed on the tested emissions of pollutants of particular concern for
the MRI facility:
• Mercury (Hg), because of its toxicity and because DEP has set an emission
limit stricter than US EPA's, in fact, the strictest limit in the nation.
• Lead (Pb) and cadmium (Cd), because of their toxicity
• Dioxin, because of its toxicity
• Hydrochloric acid (HCI) and sulfuric acid (H2SO4), because existing MRI
emissions of these acid gases result in modeled air quality impacts that
exceed DEP's health-based Guideline limits.
Mercury
DEP will impose a mercury emission limit of 0.028 ,mgldscm @ 7% 02, which is more
stringent than US EPA's new limit of 0.080 mgldscm, or 85% removal. In fact, DEP's
limit is now the most stringent nationally. DEP believes its strict, new limit is achievable
because of the improved emissions controls now available, and importantly, because the
level of mercury present in municipal solid waste continues to decline steadily.
Wheelabrator operates two of its MWC facilities with activated-carbon injection, the
means planned for the MRI upgrade to achieve enhanced mercury removal. Those
facilities are the Falls Township facility in Pennsylvania and the Gloucester County
facility in New Jersey. The Falls facility has the longer experience record with carbon
injection for mercury control -- since 1994.
ARI reviewed summarized results of mercury compliance testing at Falls for 1994
through 1997. The data show that the Falls facility complied with the new US EPA limit
at all times. Regarding DEP's strict, new limit (0.028 mgldscm), the Falls facility's
emission rate in 1995 (0.054 mgldscm) would not comply. Its 1996 emissions were just
over at 0.034 mgldscm; and its 1997 emissions complied with DEP's limit. The trend of
actual mercury emissions at Falls has been downward with time. A more limited record
of emissions test data (1996, 1997) is available from the Gloucester County facility.
Emissions tested during both years would comply with DEP's limit.
The limited, available test data are very encouraging, indicating a good probability that
DEP's strict limit for mercury emissions can be met. Further operating experience will be
needed, however, before one can know with confidence whether DEP's limit can be met
all of the time, or just most of the time.
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Lead Pb and Cadmium Cd
US EPA and DEP will limit emissions of lead and cadmium to 0.44 mgldscm and 0.02
mg/sdcm @ 7% 02, respectively. The MRI facility upgrade will add a spray-dry absorber
(scrubber) and fabric filter system to improve collection of heavy metals, For lead and
cadmium, a five-year record was reviewed of emissions test data from Wheelabrator
facilities equipped with scrubber/fabric filter systems. Test data for lead are available
from seven facilities (Gloucester County, New Jersey; North Broward County and South
Broward County, Florida; Falls Township, Pennsylvania; Spokane, Washington; Lisbon,
Connecticut; and Saugus, Massachusetts). For cadmium, test data are available from
six facilities (Gloucester County, New Jersey; North Broward County and South Broward
County, Florida; Falls Township, Pennsylvania; Spokane, Washington; and Saugus,
Massachusetts). All tested values over the five years of test data meet the new limits
for lead and cadmium. This broad record of compliance leads ARI to conclude that the
upgraded MRI facility will meet the new emission limits for lead and cadmium.
Dioxin
The new U.S. EPA and DEP limit for dioxin emissions (total mass) is 30 pglm3 @ 7% 02.
The Falls Township facility, with carbon injection, is equipped for enhanced dioxin control
the same as would be the MRI facility. A four-year record of dioxin emissions tests
(1994-1997) at the Falls facility indicates compliance with the new dioxin limit in each
year. Based on US EPA's MACT determination and on Wheelabrator's four-year record
of dioxin compliance at its Falls facility, ARI believes that the upgraded ARI facility will
meet the new dioxin limit.
Hydrochloric Acid (H9I1
The new US EPA and DEP emission limit for HCI is 29 ppmdv @ 7% 02, or 95% control,
whichever is less stringent. The MRI facility upgrade will add a spray-dry absorber
(scrubber) and fabric filter system to improve control of HCI emissions. For NCI, a five-
year summary (1991-1994) of emissions test data was reviewed from seven
Wheelabrator plants equipped with scrubber/fabric-filter systems (Falls Township,
Pennsylvania; Saugus, Massachusetts; North Broward County and South Brown County,
Florida; Gloucester County, New Jersey; Spokane, Washington; and Lisbon,
Connecticut). For six of the seven facilities, all test data over the five years of testing
showed compliance with US EPA's new emission limit. One of six facilities showed
some test results that exceed US EPA's new limit by a small margin. That plant,
however, was subject to a permit limit (50 ppmdv, or 90% removal) that is less stringent
than US EPA's new limit. That plant's scrubber system was being operated to meet the
less-stringent limit.
To summarize, emissions test data from six Wheelabrator facilities, equipped and
operated for HCI gas control as would the upgraded MRI facility, show tested HCl
emissions over a lengthy period (5 years) that are all below the new HCI limit.
Accordingly, ARI concludes that the updated MRI facility will comply with the new US
EPA and DEP emission limit for HCI.
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Sulfuric Acid MA041
MRI is subject to an existing DEP emissions limit for H2SO4 of 0.02 Ib/MMBtu, This limit
will remain in the future. The MRI facility upgrade will add a scrub berlfabric-filter system
for improved control of H2SO4 emissions. ARI reviewed a five-year summary of
emissions test data from five Wheelabrator plants equipped with scrubber/fabric-filter
systems (Saugus, Massachusetts; North Broward County and South Broward County,
Florida; Gloucester County, New Jersey; and Lisbon, Connecticut). There was a total of
45 years of annual test data over all of the combustion units at the five plants. For 44 of
the 45 years of data, emissions were at levels that comply with DEP's emission limit for
H2SO4. Results for only one year exceeded DEP's limit, and only by a small amount.
ARI concludes that based on this lengthy record of test data from five similarly-equipped
plants, the upgraded MRI facility will meet the DEP emission limit for H2SO4.
Overall Conclusion
In conclusion, based on US EPA's determination that MWC facilities will meet EPA's
Emission Guidelines if equipped with the types of controls MRI proposes, and based on
ARI's review of emissions test data from Wheelabrator plants so-equipped, ARI
concludes that the upgraded MRI facility can meet all of US EPA's new Emission
Guidelines. With the exception of mercury discussed below, DEP's new limits are the
same as those of US EPA.
DEP will impose an emission limit for mercury that is more stringent than US EPA's new
Emission Guidelines; in fact, DEP's limit is now the strictest in the country. Based on the
limited but favorable test data from Wheelabrator facilities equipped with enhanced
mercury control, and the continuing decline of mercury levels in municipal solid waste,
ARI concludes that the probability is good that the MRI facility can meet DEP's strict limit
for mercury. As no one has been required yet nationally to meet a mercury limit this
strict, it will require a period of operational experience in the future to determine if MRl or
any other Massachusetts facility can meet the limit, not just most of the time, but always.
ARI concludes that the environmental benefit of this strict, new mercury limit is worth the
small uncertainty in this regard.
5.2 Qualifications of MRI Operational Staff
MWC facilities are technologically sophisticated operations. It requires highly-trained and
experienced personnel to operate a MWC facility competently, and this is particularly so
for the advanced, emission control equipment of the type proposed for the MRI facility
upgrade. To meet US EPA's and DEP's new emissions limits, the MRI facility must not
only have the best emissions control equipment, that equipment must be operated
effectively.
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US EPA addressed this important issue in its new Emission Guidelines. The Guidelines
require the chief facility officer, shift supervisors, and control room operators to take EPA
or State operator training courses. The chief facility officer and shift supervisors must
obtain provisional and full Operator Certification (ASME — American Society of
Mechanical Engineers), and the control room operators are encouraged to do so. In
addition, the plant must have a site-specific training manual.
During an inspection of the MRI facility on June 8, 1998, ARI sought and reviewed
documents regarding the qualifications of the plant operators. ARI found documentation
that the chief officer, the shift supervisors, and the control room operators are currently
ASME-Certified. The current certifications are provisional, pending DEP's issuance of
full certification requirements later in 1998. ARI also inspected a computer-based,
operator training program functioning in the control room, with training records on hand.
During ARI's inspection, the operator on duty appeared to be effectively monitoring and
adjusting the combustion and emission control equipment. He also answered ARI's
questions knowledgeably.
ARI finds the key operational personnel at the MRI facility to be well-trained and
experienced. This conclusion is based on ARI's inspection of the control room
operations, on ARI's inspection of MRI's on-site operator training program, and
importantly, on the fact that senior operational personnel have earned Operator
Certification.
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6.0 ASH-DUST MITIGATION AND ASH TOXICITY
In this section, ARI evaluates the adequacy of measures proposed by MRl to minimize
potential "fugitive" emissions of ash dust that results from the handling, storage, and
load-out of ash. The regulatory concern with ash stems from the fact that the ash
contains small concentrations of heavy metals such as lead, cadmium, and mercury, as
well as trace levels of organic compounds such as dioxin. ARI also addresses whether
or not the characteristics of ash produced by the MRI facility would change as
consequence of the planned, emissions control upgrade. Finally, ARI discusses the
subject of ash toxicity.
6.1 Ash-Dust Control Measures
Currently, ash produced by the MRI facility is trucked out of North Andover for disposal
at a landfill in Peabody. This would not change with the upgrade.
Presently, portions of the ash conveyance system at the MRI facility are only partially
enclosed, and ash is stored in a three-sided, roofed structure. With portions of the ash
handling system open to the air, the potential exists currently for ash dusting ("fugitive
emissions") to occur, especially with windy conditions.
The new, US EPA Emissions Guidelines strictly limit the permissible occurrence of
visible emissions of ash dust to the air. Specifically, visible.emissions are not permitted
for more than five percent (9 minutes) of any 3-hour observation period, except when the
ash-handling system is under maintenance and repair. To meet this new limit, MRI
proposes a number of measures.
• Ash is presently moistened prior to storage and load-out, to suppress
dusting. This practice would continue after the upgrade. ARI notes that
historically, this has proven to be an effective dust-suppression measure.
• With the upgrade, the entire system for ash conveyance, conditioning,
storage, and load-out will be totally enclosed. In ARI's experience, total
enclosure is the key measure to be taken for containing ash dust, and
thereby, for minimizing fugitive emissions of ash dust.
• Ash storage and truck loading will take place within a totally enclosed
structure, served by a ventilation system. The exhaust from the ventilation
system will be vented to the atmosphere through a dust-collection scrubber.
ARI has reviewed the conceptual design for the planned scrubber. The
scrubber would be a conventional, wet venturi-type scrubber, either one or
two units, with a total design air flow of 10,000 cubic feet per minute, and a
capability to control dust emissions to less than 0.03 grains per standard
cubic foot of air, dry basis. ARI concludes that the wet scrubber would
provide effective control of dust vented from the ash storage and load-out
building. ARI also finds plausible Wheelabrator's judgement that a wet
venturi scrubber would be more reliable in this application than a "bin vent"
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bag-type filter. Such filters can be prone to clogging, as a consequence of
the ash being moist.
• Dr. Paul Connett of St. Lawrence University, commenting on behalf of
People for the Environment, noted a potential for fugitive emissions of ash
dust to occur, as a consequence of ash being tracked out of the ash
storage and load-out building on the tires of trucks. ARI.has confirmed that
MRI's plan for the upgraded ash storage building includes a truck-tire wash
system `(or other effective tire-cleaning system) to minimize the potential for
ash tracking. MRI indicates that a hand-wand.type spray washer has
found to be most effective at other Wheelabrator facilities.
ARI concludes that the upgrade would result in a dramatic reduction in the potential for
fugitive emissions of ash dust, as compared with current ash-handling practices. ARI
also believes that the planned control measures would enable the upgraded facility to
comply with the stringent restrictions on ash-dust fugitive emissions that are imposed by
US EPA`s new Emissions Guidelines. Those Guidelines restrict fugitive emissions from
the entire ash handling and load-out operation (including tire tracking).
6.2 Ash Characteristics, Before Versus After Upgrade
MRI estimates that the weight of ash generated after the upgrade would increase by
about 1 A%. This is plausible since the only significant change in this regard would result
from the addition of residue from the proposed, new scrubbers.
It is the express purpose of the upgrade to improve emissions controls, including
specifically, to remove heavy metals from the exhaust stream with greater efficiency. Of
the heavy metals, it is mercury for which the upgrade is intended to result in the greatest
improvement in capture efficiency. As the captured metals end up in the fly ash, one
might expect to see an increase in the mercury level in ash following the upgrade. ARI
has reviewed ash-composition data supplied by MRI for the Wheelabrator Saugus
facility. The data were for combined fly and bottom ash for the period 1989 to 1996.
Data were supplied for the facility pre-upgrade versus post-upgrade. A comparison
showed, not surprisingly, that the levels of mercury in the ash increased (from an
average of 1.4 mg/kg to 13 mglkg, both small concentrations). Results showed
decreases in lead and also dioxin levels in the ash after the upgrade. The decreases
appear to be attributable, at least in part, to the dilution effect of the ash amount
increasing by about 10 percent after the upgrade. It is reasonable to expect that the
composition of MRI ash after the upgrade would resemble that of Saugus ash, because
the pre-upgrade ash compositions of the two facilities are similar.
The US EPA requires ash from MWC facilities to pass a laboratory test (the "TCLP" test)
that indicates the potential for the metals in the ash to leach out into the environment.
Ash passing the test can be disposed as a nonhazardous solid waste. Ash failing the
test is regulated as a hazardous waste. The ash from the MRI facility (pre-upgrade), and
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i
the ash from Saugus, both pre-upgrade and post-upgrade, pass the leaching test. ARI
has reviewed ash leaching-test data from Wheelabrator's facility at Falls Township,
Pennsylvania. That facility is equipped the same as the MR[ facility would be after
upgrade, and the Falls facility ash passes the leaching test.
ARI concludes that, following the MRI upgrade, the only notable changes in ash
composition would be a roughly ten percent increase in the amount of ash by weight,
and an increase in the small concentration of mercury present in the ash. ARI further
concludes that the ash from the MRI facility after upgrade would pass the US EPA
metals-leaching test, and would thus be regulated as a nonhazardous waste.
6.3 Ash Toxicity
The question of environmental fate of the heavy metals present in ash has been
controversial for years. In a regulatory sense, however, US EPA has settled the matter
as described above. If the ash passes US EPA's metals leaching test, the ash is
considered nonhazardous. If it fails, it is disposed as hazardous material.
Based on years of ash leachate testing, lead and cadmium are the metals with the
highest potential to leach out. Lead, in particular, is of concern since it not only leaches
readily in an acid environment as most metals do, it also leaches readily in a highly
alkaline environment. Thus, methods used to stabilize the metals in ash by pH buffering
(e.g., by adding lime) do not always work for lead.
Wheelabrator developed and markets an ash treatment method ("WES-PHix"). With
WES-PHix treatment, phosphoric acid is added to the ash. This not only buffers the pH
of the ash, but also results in metals such as lead and cadmium forming metal
phosphate compounds. Such compounds are both low in solubility and geochemically
stable. This means that the metals in the ash treated with WES-PHix should be very
resistive to leaching, and that the leaching resistance should persist long term. The
effectiveness of WES-PHix in stabilizing lead present in ash has been demonstrated in
research by Dr. T. Taylor Eighmy of the University of New Hampshire at Durham (under
Wheelabrator funding). WES-PHix treatment of ash is now standard practice at MWC
facilities nationally. MRI states that it is used at all facilities Wheelabrator operates. ARI
is unaware of any MWC facility nationally today with ash that fails US EPA's metal-
leaching test.
While WES-PHix treatment of ash has been shown nationally to enable ash to virtually
always pass US EPA's leaching tests, a legitimate question is, what are the long-term
prospects for metals leaching after ash is disposed in an ash landfill? The research by
the University of New Hampshire indicates ash treated with WES-PHix should resist
metals leaching long term. Sampling of leachates from ash landfills nationally has been
carried out for about one decade now. Results indicate that generally, leaching has
been much lower for the lead and cadmium than predicted based on US EPA's leaching
test. The test is, therefore, conservative. The metals levels in leachate from actual ash
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i
landfills (as opposed to from laboratory leachate-testing of ash) are often near the levels
allowable by drinking water standards (see, for example, Roffman').
While there remains long-term uncertainty, a decade of field experience indicates that
leachate from ash does not contain metals at hazardous levels. In any case, leachates
produced by all ash landfills must be collected, tested, and treated, specifically to
prevent metals from entering the environment at unacceptable levels.
There is controversy over the ash from one particular Wheelabrator facility — the
Claremont, New Hampshire, facility — as pointed out by Drs. Jill Stein and Paul Connett,
on behalf of People for the Environment. There were reports that a single sample of
leachate from the ash landfill where ash from the Claremont facility is disposed,
exceeded the regulatory hazard level for lead. The commentators above viewed this as
significant, because it could mean the treatment of ash with WES-PHix is ineffective.
Both the New Hampshire and US EPA regulatory officials investigated, and in written
statements found "that the high lead level resulted from flawed sample collection
procedures." Specifically, the sample is supposed to contain leachate (liquid) only. In
reality, ash residue from the landfill was present in the leachate sample when the sample
was analyzed in the laboratory. All leachate testing since shows lead concentrations
well below hazardous levels. AR1 concludes that the high lead level measured one time
in the ash leachate resulted from faulty sampling procedures and is not valid data.
It is ARI's overall conclusion that.ash processed by the MRl facility after the upgrade will
test to .be nonhazardous by US EPA's metals leaching test, and when disposed .in an
ash landfill, is unlikely to produce leachate that contains metals in hazardous quantities.
fl M t A-eCA Walk ccy-�
COPICkyl-N O)C Oj
' Roffman, Haia, "Chemical Characteristics of Leachates from Many Municipal Waste
Combustion Ash Monofills," peer-reviewed paper presented at the 86th Annual Meeting of
Air & Waste Management Association, Denver, Colorado, June, 1993.
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{
7.0 HEALTH RISKS FROM STACK EMISSIONS
In this section, ARI summarizes available studies and expert opinions regarding health
risks associated with stack emissions from the MR] facility. While from the regulatory
standpoint, the focus is on risk levels to expect after the emission control upgrade, ARI
has also addressed the health risk levels associated with people's total exposure; i.e.,
past exposure as well as future.
7.1 Projected Future Health Risks
7.1.1 Air Quality Impact Modeling
With its Site Plan Review Application, MRI included a modeling analysis of air
quality impacts to expect from MRI stack emissions, before and after the
emissions control upgrade is implemented. The modeling analysis entailed
application of both screening-level and refined air quality models that are DEP-
approved models. ARI reviewed the modeling approach and found it to be
consistent with accepted modeling protocol. ARI initially, however, had questions
in two areas which it pursued and resolved:
• Is meteorological data available for input to the models that is more
local than the Boston data utilized? Standard protocol requires
either one year of high-quality on-site data be used, or if not
available, five years of high-quality regional data. The consultants
who performed the air quality modeling informed ARI that one year of
local data (from Haverhill) is available, but because it is neither on-
site data nor a five-year record, it cannot be used. ARI is satisfied
that use of Boston data was consistent with required regulatory
protocol. It should also be noted that DEP has recently modeled the
cumulative impacts of the MRI facility and other combustion facilities
in the region using both the Boston and Haverhill data sets. Use of
Boston data yielded more conservative (higher) modeled impacts.
• The consultant's report of MRI's' modeling analysis did not provide
sufficient documentation that terrain elevations input to the model
had been determined with adequate resolution. Direct discussion
with the consultants, however, confirmed that an adequate approach
had been utilized; terrain elevations had been determined per
standard practice, at 100-meter lateral intervals in the vicinity of the
predicted maximum impacts.
7.1.2 Projected Impacts Compared with Ambient Standards
The facility emits pollutants for which US EPA and DEP have set ambient
standards. Air pollutants with formal standards are referred to as "criteria
pollutants." If a standard is exceeded, this means serious, adverse health effects
are to be expected. Accordingly, proposed new emissions sources, as well as
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proposed modifications of existing sources, must demonstrate compliance with the
standards. Via the modeling analyses of air quality impacts described above,
MRI performed a compliance demonstration with regard to ambient standards.
For pollutants with ambient standards, the maximum, modeled impacts resulting
from the MRI facility emitting at its maximum, permitted levels are compared in
Table 7.1-1 for existing (pre-upgrade) conditions versus future (post-upgrade)
conditions. The US EPA Emissions Guidelines will impose new stricter emission
limits for NOD S02, and PM-10, and from Table 7.1-1, maximum impacts for those
pollutants are projected to decrease. The maximum impacts for CO are predicted
to increase slightly, however. This is because maximum, permitted CO emissions
will stay the same under the upgrade (DEP's existing CO permit limit is stricter
than US EPA's new Emissions Guideline for CO), but the upgrade will result in a
cooler flue gas temperature, and less thermal "rise" of the plume.
As a point of information, the modeled locations of maximum impact are found
generally about 1,000 — 1,300 feet to the southeast and to the southwest of the
facility. The modeled locations of maximum impact were the same for both
existing and post-upgrade conditions.
Maximum modeled impacts after upgrade are compared in Table 7.1-2 with the
national ambient air quality standards. The modeled impacts, when added to
background air quality levels, yield projected total air-quality concentrations.
Projected total air-quality levels are well within ambient standards. Thus, the
upgrade project is shown to comply with ambient standards set by US EPA and
DEP to protect public health. As another point of information, the maximum
modeled impacts for existing conditions (pre-upgrade) also comply with the
ambient standards.
7.1.3 Projected Health Risks for Hazardous Air Pollutants Following MRI
Upgrade
Massachusetts DEP has developed health-based guideline limits for both short-
term "acute" exposure and long-term "chronic" exposure to hazardous air
pollutants. DEP refers to these respectively as their 24-hour average Threshold
Effects Limits (TEL) and their annual-average Allowable Ambient Limits (AAL).
These DEP Guideline limits exist for organic compounds such as dioxin, for heavy
metals (e.g., mercury, lead), for acid gases, and for other hazardous air pollutants.
It is important to recognize the difference between an air quality standard and an
air quality guideline. While both are health-based limits, they have very different
connotations. When a standard is exceeded, this means that adverse health
effects are highly likely to occur. By contrast, if impacts are below a guideline
limit, then adverse health impacts are extremely unlikely to occur. Furthermore,
impacts that exceed DEP Guidelines by a relatively small margin do not imply a
significant health risk; rather, a small exceedance means that the potential for
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Table 7.1-1
PROJECTED CHANGE IN MAXIMUM IMPACTS OF CRITERIA
AIR POLLUTANTS, PRE-UPGRADE VERSUS POST-UPGRADE
Maximum MR[ Impact
Pollutant Averaging Period Existing Future
Conditions Upgrade
NO2 Annual 3.6 2.3
S02 3-Hour 40 28
24-Hour 17 12
Annual 1.6 1.2
PM-10 24-Hour 6.4 1.5
Annual 0.6 0.2
CO 1-Hour 1.9 22 .
8-Hour 93 10
Source: "Air Quality Modeling Report," January 1998, prepared for MRI by Earth
Tech, Inc,
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Table 7.1-2
COMPARISON OF MAXIMUM AIR POLLUTANT IMPACTS
AFTER UPGRADE WITH AMBIENT STANDARDS
MRI Total (MRI +
Maximum Background background) National
Averaging Impact Concentration Concentration Ambient
Period (F,glm3) (pglm3} (/rglm3) Standard
NO2 Annual 2.3 34 36 100
S02 3-Hour 28 170 199 1300
24-Hour 12 86 98 365
Annual 1.2 18 20 80
PM-10 24-Hour 1.5 35 37 150
Annual 0.2 16 16 50
CO 1-Hour 22 22222 22246 40,000
8-Hour 10 8935 8946 10,000
Pb 3-Month 0.05' 0.01 0.06 1.5
1. The three-month lead (Pb) concentration is conservatively based on the highest
24-hour predicted concentration.
Source: "Air Quality Modeling Report, "January 1998, prepared for MRI by Earth
Tech, Inc.
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1
adverse effects cannot be ruled out, according to DEP. DEP's TEL and AAL
Guidelines are protective of public health for impacts below, and to a point, above
the Guideline limits because of the large safety margins incorporated into the
Guidelines. In developing the TEL and AAL Guidelines, DEP adopted multiple
safety margins to account for factors such as:
• continuous lifetime exposure, compared with 8-hour exposure on
which occupational standards are based
• adult/child susceptibility differences
• people at special risk
• differences in lab animal susceptibility, versus humans
• exposure via pathways, besides inhalation (e.g., ingestion)
• other uncertainties, such as database limitations.
As an example, at a presentation of its new MWC combustor rules on July 8,
1998, DEP discussed the safety factors built into its TEL and AAL Guideline limits
for hydrochloric acid (HCI). DEP's TEL and AAL Guideline limits for HCI are each
7 erg/m3. DEP noted the following about the HCI Guideline limit of 7 ,ug/m3:
• The Guideline is three times lower than US EPA's "Acceptable Level"
(20 lag/m3).
• The Guideline is less than 1% of levels shown in research not to
cause adverse effects in asthmatics (1,200 — 2,700 erg/m3).�
• The Guideline is 1,000 times lower than the US workplace limit
(7,500 erg/m3),
• The Guideline is 2,000 times lower than levels shown to cause throat
toxicity in rats (15,000 pug/m).
• The Guideline is 7,600 times lower than levels shown to cause throat
irritation in people (53,000 pg/m3).
As another example, Gail Charnley, Ph.D. (toxicology) of M.I.T., presenting on
behalf of MR[ at the Board-of-Health public meeting held June 18, 1998, illustrated
that DEP's AAL Guideline for mercury is 3,500 times more stringent than the
exposure limit used to protect workers in the United States. In a conversation
during a break at the meeting, she illustrated to ARI that DEP's AAL Guideline for
dioxin assumes dioxin toxicity factors that are five times more stringent than
factors US EPA uses, which are in turn, more conservative than factors that have
been adopted internationally.
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As a check, ARI compared DEP's Guideline concentration limits for two of the
pollutants discussed above — HCI and mercury — with guideline limits set by New
York and New Jersey. Like Massachusetts, those states also have rigorous air-
toxics regulatory programs, and have extensive experience in regulating MWC
facilities. Dioxin was not included in this comparison because the limits set by the
states are on differing technical bases, making direct intercomparison
inappropriate. The comparison for HCI and mercury follows:
ANNUAL GUIDELINES
Pollutant Mass DEP NY DEC NJ DEP
ygim, Ngf m, Ngim3
HCI 7 20 20
Mercury 0.07 0.3 0.3
24-HOUR GUIDELINES
Pollutant Mass DEP NY DEC NJ DEP
yg/m3 yg/m3 lug/m3
HCI 7 160 None
Mercury 0.14 6 None
While all three states have adopted stringent limits, Massachusetts' Guideline
limits are most conservative in the cases of HCl and mercury.
A differing opinion on the protectiveness of DEP's and US EPA's health-based
standards and guidelines was presented by Jill Stein, M.D., on the clinical staff of
Harvard Medical School; by Ted Shettler, M.D., M.P.H., on the staff of Boston
Medical Center, and with Physicians for Social Responsibility; and by James
Dickey, M.D., a private physician at Montague Internal Medicine; all presenting on
behalf of People for the Environment at the Board of Health public meeting held
July 9, 1998. These experts stated that current levels of protection by DEP and
US EPA are not adequately protective, in their opinions, for certain pollutants such
as mercury, dioxin, and fine particulate matter. It was important for both the
Board of Health and the public to hear this, as it furnished them with a fuller range
of professional opinion on the matter than had been previously presented.
The potential need, however, for tighter environmental standards and guidelines is
an issue that is usually addressed at the state, Federal, and international levels,
not on a project-specific basis. The norm is for project-specific decisions to be
based on the latest standards and guidelines issued by the state and Federal
governments to protect public health, and on consideration of any project-specific
risk assessment studies and location-specific epidemiological studies that may be
7-6
available. ARI concludes that DEP's TEL and AAL Guideline limits are
demonstrated to have been conservatively developed; that is, the Guideline limits
were set to protect public health with a large margin of safety. Accordingly, the
DEP Guideline limits provide a conservative means for judging whether or not
emissions from the MRI facility pose a significant health risk.
The maximum, modeled impacts due to emissions of hazardous air pollutants
following retrofit of the MRI facility were compared with DEP's TEL and AAL
guideline limits in MRI's Application for Site Plan Review. As noted earlier, ARI
has found that MRI's modeling consultants did use acceptable protocols in
performing the modeling analysis. The impact analysis was performed for the
following pollutants;
Environmentally-Persistent Organic Compounds
Dioxins/Furans (DEP toxic equivalents)
Polychlorinated Biphenols (PCB)
Heavy Metals Acid Gases
Mercury (Hg) Hydrogen Chloride (HCI)
Lead (Pb) - Hydrogen Fluoride (HF)
Cadmium (Cd) Sulfuric Acid (H2SO4)
Antimony (Sb)
Arsenic (As) Other
Beryllium (Be)
Copper (Cu) Ammonia (NH3)
Total Chromium (Cr)
Hexavalent Chromium (Cr VI)
Nickel (Ni)
Selenium (Se)
Vanadium (V)
The emission rates modeled were the maximum allowable under US EPA's
Emissions Guidelines for dioxin, mercury, lead, cadmium, and hydrochloric acid,
and under DEP's existing permit limit for sulfuric acid. For the remaining
pollutants not specifically limited by US EPA Emissions Guidelines or DEP permit
limits, MRI had estimated maximum expected emission rates based on statistical
analysis of actual test data from other MRI facilities equipped with emission
controls similar to those which the MRI upgrade would use.
The modeling analysis demonstrated that the maximum projected impacts for
each of the above pollutants is below DEP's TEL and AAL Guideline limits. For
cadmium (Cd), MRI determined that it needed to commit to a maximum emission
rate that is more stringent than that required by the US EPA Emission Guideline,
in order to demonstrate impacts below the DEP TEL guidelines. MRI has done
so.
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k
Because maximum impacts of hazardous air pollutants emitted from the MR]
facility are shown to be below the DEP Guideline limits, and because DEP
developed those limits very conservatively, ARI concludes that the upgraded MRI
facility would not cause adverse health effects.
7.2 Health Risks from Total Exposure to MRI Facility Emissions, Past and
Present
As noted earlier, in the regulatory setting, it is future (post-upgrade) impacts that are the
focus for analysis. When the situation involves an existing facility, however, local
citizens virtually always express concern over their total exposure to facility emissions —
past as well as future exposures. Accordingly, at the Board of Health public meeting
held June 11, 1998, ARI requested MR] to have its health-science consultants (The
Weinberg Group) assess the maximum health risks resulting from peoples' total
exposure to MRI emissions; i.e., past exposure (pre-upgrade) plus future exposure (post-
upgrade). ARI suggested that the focus be placed on pollutants for which health risks
result from long-term exposure, notably dioxin. The Weinberg Group did prepare the
study and reported it to the Board of Health on July 17, 1998. ARI has reviewed the
report and summarizes Its findings below for the two pollutants of most concern, dioxin
and mercury.
7.2.1 Dioxin
For dioxin, Weinberg estimated peoples' past exposure as follows;
• The maximum, modeled annual impact in the community was
determined, corresponding to each dioxin stack test performed every
nine months since May, 1989. Modeled impacts for years prior to
1991 were adjusted to be based on DEP's current (1991) toxicity
factors for dioxins and furans.
• The average of these maximum, annual impacts was determined,
and was used to represent peoples' level of exposure to dioxins and
furans for the 15-year period (1985-2000) preceding the facility
upgrade.
• This estimate of peoples' maximum, average exposure level in the
past was compared with DEP's AAL Guideline limit for dioxins and
furans, to assess the health risk resulting from past exposure.
ARI considers this approach appropriate for assessing the dioxin-related health
risk from past exposure.
The modeled, maximum, annual impacts for dioxin, as presented by Weinberg,
are shown in Table 7.2-1. The impacts range from 0.026 to 0.056 picrograms per
cubic meter of air (pglm3). This range can be compared with DEP's current AAL
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I� '
Table 7.2-1
PAST EXPOSURE TO MRI DIOXIN EMISSIONS
Maximum Modeled Concentration
in Air, Annual Average (a'b)
Dioxin Stack Test Date
MRIIWeinberg cry CDM tdi'
(pg/m3) (pg1m3)
July 1997 0.041 0.07
October 1996 0.05 0.075
January 1996 0.024($) 0.024(e)
April 1995 0,033 0.172
July 1994 No data(O No data(Q
October 1993 0.038 0.038
January 1993 0.056 0.056
April 1992 0.035 0.035
July 1991 0.026 0.026
October 1990 0.026 0.026
February 1990 0.027 0.027
May 1989 0.031 0.031
Average Past Exposure 0.036 0.056
a. Maximum, modeled concentrations corresponding to tested dioxin emission rates.
b. Concentrations were calculated using current (1991) DBP toxic equivalency factors for
dioxin and furan isomers.
c. Source: The Weinberg Group, Inc., Paul Chrostowski, Ph.D., letter report to forth
Andover Board of Health, dated July 17, 1998.
d. Source: Personal conversation between David Minott, Alternative Resources, Inc., and
Cynthia Hibbard, Camp Dresser & McKee (CDM) on July 15, 1998.
e. Data was not used here in calculating the average past exposure, because facility was not
operating in its normal mode during the dioxin testing.
f. Dioxin stack test data for this test date was invalidated by MRI with DBP's concurrence,
because the plant was not operating in its normal mode during testing.
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Guideline for dioxin, which is 0.045 pg/m3. Historically, most of the annual
impacts have been slightly below the AAL limit, but in two cases the dioxin
impacts (corresponding to the January, 1993 and October, 1996 tests) were
slightly above. Impacts associated with a third test (February, 1990) had
exceeded DEP's old (1989) AAL limit, but not the current (1991) limit. The
average of the maximum, annual impacts over all the test data was determined by
Weinberg to be 0.036 pg/m3, as shown in Table 7.2-1. This indicates that
peoples' past exposure to the facility's dioxin emissions is slightly less than DEP's
AAL Guideline, based on Weinberg's assessment.
Note that in Table 7.2-1, a second set of dioxin impact levels is shown. These
impacts were calculated by Camp Dresser & McKee (CDM), consultants who
independently reviewed the MRI dioxin test data in detail on behalf of the NESWC
communities. For these dioxin emission tests, CDM arrived at differing modeled
impacts than did Weinberg. These differences resulted from differing judgements
between MR1 and CDM about how to account for interferences that occurred
during laboratory analysis of the test samples. DEP had concurred with the
judgements MRI had made in this regard. MRI's judgements about the emissions
are reflected in Weinberg's impact calculations presented here in Table 7.2-1.
CDM's calculations reflect a very conservative interpretation of the suspect
laboratory data. ARI finds both interpretations to be rationally based, technically;
there is not one "right" answer in this case. ARI has thus presented both sets of
data here. Using CDM's conservative impact values, ARI re-calculated the
average impact for all the test data. The average CDM concentration is 0.056
pg/m3, as shown in Table 7.2-1. While Weinberg's calculations indicate peoples'
past exposure to be just under DEP's AAL Guideline, CDM's calculations indicate
past exposure could be slightly above the Guideline. Again, ARI points out that
both sets of calculations are rationally based.
ARI concludes that based on these data, peoples' past exposure to the facility's
dioxin emissions falls somewhere from slightly below to slightly above the DEP
AAL Guideline limit. Given the conservative margin of safety DEP has built into its
AAL Guideline, ARI further concludes that people's past exposure to MRI dioxin
emissions poses no significant risk of cancer or other adverse health effects.
In Section 7.1.3 above, it was stated that modeled impacts of all hazardous air
pollutants from the facility after the upgrade would be below DEP's TEL and AAL
Guidelines. Specifically, for dioxin, peoples' future exposure level to dioxin after
the upgrade was modeled to be 0.011 pglm3, compared with the AAL Guideline of
0.045 pgim3. Given the range of estimates above for peoples' past exposure (pre-
retrofit) of 0.036 to 0.056 pg/m3, and the projected future (post-retrofit) exposure
of 0.011 pgim3, ARI has calculated peoples' total average exposure, past plus
present. These calculations are for a 35-year total exposure (15 years past, plus
20 years future) and for a 45-year total exposure (15 years past, plus 30 years
future) and are shown in Table 7.2-2.
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Table 7.2-2
TOTAL DIOXIN EXPOSURE
35 Years Total 45 Years Total
Future Exposure Future Exposure
20 Years 30 Years
(2000 - 2020) 0.011 pglm3 (2000 - 2030) 0.011 pg/m3
Past Exposure Past Exposure
15 Years 15 Years
(1985 - 2000) 0.036-0.056 pglm3 (1985-2000) 0.036-0.056 pg/m3
Total ExposureM Total Exposure(s)
35 Years 45 Years
(1985-2020) 0.022-0.030 pglm3 (1985-2030) 0.019-0.026 pglm3
DEP AAL DEP AAL
Guideline Limit 0.045 pglm3 Guideline Limit 0.045 pglm3
a. Total exposure is calculated by Alternative Resources, Inc., as the time-
weighted average of the past and future exposure levels.
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The projected total, average exposure for 35 year- and 45-year exposure periods
is about 0.02 to 0.03 pg/m3. This is slightly below the DEP AAL Guideline of
0.045 pglm3. ARI concludes, therefore, that maximum impacts resulting from
dioxin emissions — past plus future emissions -- from the MRI facility will not result
in total exposure levels in the community which would cause adverse health
effects.
During the Board of Health's public meetings, Wheelabrator's presenters
discussed a study by the independent International Ash Working Group that found
MWC facilities to be net destroyers of dioxin, based on data from Germany. They
showed that more dioxin comes into the facility with the waste than goes out with
the stack emissions and the ash.
Subsequently, Dr. Paul Connett, on behalf of People for the Environment,
furnished data published in the respected British journal, Warmer Bulletin, that
showed that MWC facilities are net producers of dioxin based on data from the
United Kingdom. ARI finds both positions to be supported by credible data. The
opposite findings of the two studies are explained by large differences from
country to country in the small amount of dioxin present in municipal solid waste
and thus in levels that enter MWC facilities. The studies showed relatively little
difference in the dioxin levels coming out of MWC facilities, Whether an MWC
facility is a net producer or destroyer of dioxin depends on how much dioxin goes
into the facilities, not on how much comes out.
While the question of whether MWC facilities are net producers or destroyers of
dioxin is interesting academically, the key issue is the dioxin level emitted to the
environment, particularly from the stack. As discussed above, ARI concludes that
dioxin emissions from the MRI facility — past and future — do not result in total
exposure levels which would cause adverse health effects.
7.2.2 Mercury
The Weinberg group also assessed peoples' total exposure, past plus future, to
mercury emissions from the MRI facility. Based on the record of past emissions
testing for mercury, the modeled maximum annual impacts in the community
historically have ranged from 0.0009 to 0.006 pglm3, with an average of
0.003 pglm3. Impacts in the past have been consistently below DEP's AAL
Guideline limit for mercury of 0.07 pglm3.
Impacts in the future are projected by MRI to decline following the emissions
control upgrade by at least 85%. The modeled, maximum annual impact
projected for mercury following the upgrade is 0.0005 pglm3, which is about one
percent of the DEP Guideline of 0.07 pglm3.
The maximum, modeled annual impacts for mercury — both past and future — are
shown to be well below DEP's AAL Guideline limit for mercury. Accordingly, ARI
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concludes that people's total exposure —:past and future — to mercury emissions
from the MRl facility will not result in adverse health effects.
7.3 Cumulative Risks
People's lifetime cumulative health risks from environmental exposure result from
exposure to pollutants emitted from sources known and unknown; local and distant;
anthropogenic (manmade) and natural; and past, present and future in time. Peoples'
cumulative risks also depend on individuals' particular susceptibilities. With all of these
factors to consider, rigorous health-risk studies are highly complex, are fraught with
substantial uncertainties, and can be exceedingly expensive to perform. The complexity
and cost for major cumulative risk studies restrict the number of such studies that even
state and Federal governments can afford to perform or sponsor. Accordingly, while
proponents of individual projects must assess the incremental risks posed by their own
projects, they are not expected to undertake rigorous cumulative-risk studies.
There is, however, a limited amount of pertinent information available about the
cumulative risks people experience who live in the North Andover area. That information
is summarized below,
7.3.1 DEP Study of Cumulative Risk
DEP is performing a limited assessment of cumulative risks posed by emissions
from the BFI medical waste incinerator, plus the MWC facilities operating in North
Andover (MRI), Haverhill and Lawrence. DEP undertook the study in conjunction
with developing its new, proposed air regulations for MWC facilities, and to
address public concerns.
DEP discussed its preliminary results at a public meeting held July 8, 1998. DEP
modeled the maximum impacts that would result from the cumulative emissions
from these four facilities and compared the impacts with DEP's AAL and TEL
Guideline limits. The impact assessment was performed for dioxin, mercury, lead
and other heavy metals (Be, Cd, Cr, CrVI, Cu, Ni, Se, Sb), and the acid gases,
hydrogen chloride (HCI) and hydrogen fluoride (HF). Impact levels were projected
(1) for the future under DEP's proposed emissions-control regulations and (2) for
existing emissions.
For the future scenario, cumulative impacts were shown by DEP to be below
DEP's Guideline limits for all pollutants except for cadmium, which exceeds the
TEL Guideline by a very small margin (36%). The small exceedance does not
imply a significant health risk. To illustrate, DEP noted that the cumulative
impacts from the five carcinogenic (cancer-related) pollutants studied (cadmium,
chromium, hexavalent chromium, beryllium, and dioxin) yielded a maximum risk of
death from cancer of about 3 chances in 1 million. DEP considers this risk level
to be very minor, well below DEP's "action level" of 10 chances in 1 million which
triggers additional risk-assessment study. It should also be noted that DEP's
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cumulative risk assessment did not take into account that MRI has committed to a
lower emission limit for cadmium that would keep its impact below DEP's
Guideline limit.
Regarding DEP's assessment of cumulative impacts due to existing emissions
from the.four facilities, results were not available in time for DEP's presentation on
July 8. DEP did note that cumulative impacts from hydrochloric acid (HCI)
currently exceed the DEP TEL Guideline by a factor of 13, largely attributable to
the MRI facility. DEP put this exceedance in perspective by stating that while the
HCI impact does exceed the Guideline, the impact level is "well below levels
where adverse effects are known to occur." "Toxicity [is] unlikely, but potential for
adverse effects cannot be ruled out."
In conclusion, .DEP has projected no.significant future health risks as a
consequence of cumulative exposure to the emissions of four waste combustion
facilities operating in the Merrimack Valley (including MRI). The future impact
levels presume implementation of DEP's proposed, new emission-control
regulations. DEP's study of cumulative .risks resulting from existing emission
levels from those four facilities is still in progress.
7.3.2 Epidemiological Studies
At the Board of Health public meeting held July 18, 1998, the Weinberg Group
presented on behalf of MRI summaries of available epidemiological studies
performed for the local area. Rosanne McTyre, Ph.D. (Epidemiology), described
three local studies: a study by the Massachusetts Department of Public Health
(DPH) regarding cancer incidence and two studies sponsored by Wheelabrator on
cancer incidence and asthma incidence, and performed by Harris Pastides, Ph.D.
(Epidemiology) of the University of Massachusetts at Amherst.
Dr. McTyre described a DPH study preformed in 1997 indicating that breast
cancer incidence in Andover was higher than the Statewide average. No other
cancer types showed an unusually-high incidence. She described a follow-up
study that DPH conducted in 1998 of breast cancer incidence in Andover. That
DPH study concluded that breast cancer cases "were not concentrated in any
pattern that would suggest golf courses and/or incinerators have played a role in
breast cancer incidence in Andover."
Dr. McTyre summarized a study performed by Dr. Pastides of cancer incidence in
the Merrimack Valley. Based on cancer incidence and mortality data for
1990-1994 from the Massachusetts Cancer Registry, the study had compared
cancer incidence in 11 communities close by and downwind from the four waste
combustion facilities in the Merrimack Valley (including MRI), with cancer
incidence Statewide. Dr. McTyre summarized results as indicating that no
significant increase in cancer incidence or mortality was observed for the
Merrimack Valley communities compared with the rest of the State for total cancer
incidence or for 24 individual types of cancer.
7-14
l
Lastly, Dr. McTyre described a study that Dr. Pastides performed regarding
preventable hospitalizations for asthma in North Andover between 1990 and 1995.
The study had analyzed incidence data from the Massachusetts Department of
Health Care, Finance and Policy on asthma hospitalization, specifically comparing
North Andover with the rest of the State. Dr. McTyre noted that the study found
that preventable hospitalization for asthma was lower in North Andover than
Statewide. She further noted that the Department of Public Health also plans a
study of respiratory illness in the North Andover area.
In conclusion, limited epidemiological studies have been performed in the North
Andover area for cancer and for asthma. These limited studies show no link
between those diseases and emissions from the MRI facility.
7.3.3 Accumulated Levels of Mercury in Irish
At the Board of Health public meeting held July 9, 1998, Jill Stein, M.D.,
presenting on behalf of People for the Environment, addressed the implications for
public health of the existing, high levels of mercury in fish. She provided an
informative discussion of how mercury present in the environment bioaccumulates
in nature via the food chain, and explained why the currently-high levels of
mercury present in many fish species — including in waters local to North Andover
— present a dangerous risk to the fetuses of pregnant women.
Dr. Stein also stated that most of the mercury ("the preponderance") found in fish
caught locally to North Andover is from the MRI facility. She supported the
statement with the fact that the MRI facility, according DEP's Mercury Report, is
currently the largest known source of mercury in the area. Dr. Stein, however, did
not support her conclusion with a conventional assessment of the transport and
environmental fate of the mercury MRI emits. Such studies assess how mercury
emitted from a stack disperses in the air, falls onto the land via "dry deposition"
(settling) and via "wet deposition" (rainout), and how the deposited mercury
washes via stormwater runoff into the local surface waters. Without such a study,
we simply do not know specifically what portion of the mercury emitted by MRI
ends up in local waters.
In addition, attributing the preponderance of mercury found in locally-caught fish to
MRI emissions improperly ignores other mercury contributors. The DEP Mercury
Report indicates that:
• 59% of the mercury deposited in Massachusetts comes from existing
sources that are out-of-State
• There are numerous other in-State sources at present, such as
wastewater treatment plants that discharge mercury directly to
surface waters, including the Merrimack River
7-15
• Historically, substantial amounts of mercury were discharged to the
Merrimack River by textile mills and other industries
All of these mercury sources, including MRI, make some contribution to the
mercury levels present in locally-caught fish. The relative contributions of these
sources, however, is simply not known. The MRI facility, after upgrade, would
reduce its contribution by at feast 85%.
In conclusion, Dr. Stein's stated concerns over the high mercury levels present in
local fish, and the serious threat to public health such high levels of mercury pose,
should be taken seriously. Clearly, DEP's very recent decision to adopt the
nation's strictest mercury emission limit for MWC facilities underscores DEP's
commitment to action. Dr. Stein's statement, however, that the preponderance of
the mercury present in local fish came from the MRI facility has not been
adequately supported.
7-16
8.0 MR1 COMPLIANCE HISTORY
Relevant to MRI's ability to meet US EPA's and DEP's new emissions limits following the
emissions control upgrade, is MRI's past record of environmental compliance. ARI has
reviewed available information regarding compliance history, including assessments
made by DEP and by the consulting firm of Camp Dresser & McKee. ARI also reviewed
a Notice of Violation recently issued by US EPA.
8.1 Compliance Assessments by DEP and CDM
In 1996, Camp Dresser & McKee (CDM), on behalf of the NESWC communities,
conducted a detailed review of MRI's compliance history. In performing the study, CDM
reviewed MRI's permits, emissions limits, continuous emissions monitoring (CEM) data,
stack test reports, air quality modeling reports, and compliance-related correspondence,
notices, and agreements on file at DEP's offices.
CDM found MRI's compliance history to be as follows, as of 1996:
• In 1996, the facility was in compliance with all permit requirements.
• Stack tests showed emissions to exceed the permit limit for sulfur dioxide in
the earlier years of operation. Following a DEP Notice of Non-Compliance
in 1991, dry lime-injection scrubbing, installed in 1992, rectified the
problem. Emissions tested since have complied with the permit limit.
• Tested emissions of all other pollutants with permit limits have always been
in compliance.
• Stack testing reports had been prepared and submitted to DEP in a timely
manner.
• The Continuous Emissions Monitoring (CEM) data for sulfur dioxide,
nitrogen oxides, and carbon monoxide shows the facility emits below its
permit levels more than 99 percent of the time monitored. Brief excursions
occur, on the order of minutes, for unusual operating conditions. These
excursions are not permit violations, because currently, stack test results,
not CEM data, are used to determine compliance.
• Air quality modeling shows maximum air quality impacts for tested
hydrochloric acid (HCI) emissions have always exceeded DEP's health-
based guideline. This is not a permit violation. CDM noted that HCl
impacts should be below the guideline with an acid gas scrubber being
added during the proposed upgrade.
• Modeling shows maximum air quality impacts for tested dioxin emissions
over the years have tended to be close to DEP's health-based guideline,
either just over or just under. Following a DEP Administrative Order in
8-1
1990, MRI conducted cleaning of grit from its electrostatic precipitators
(ESP). This appeared to lower dioxin emissions. There was one high
result since, about four times over the guideline, in 1995.
• Modeling shows maximum air quality impacts for tested emissions of
mercury, lead, and cadmium have always been under DEP's guidelines.
In summary, CDM determined that the MR[ facility presently (as of 1996) complies with
all current permit limits and, with one exception, has always been in compliance in the
past. Sulfur dioxide emissions had exceeded permit limits early on. An emission control
upgrade in 1992 remedied this violation, and sulfur dioxide emissions have complied with
permit limits since. Modeled impacts based on tested emissions of hydrochloric acid
have historically always exceeded DEP's health-based guidelines, and dioxin
occasionally has exceeded. CDM noted that these exceedances are not permit
violations, however, and noted that the planned upgrade project would likely cure the
exceedances.
ARI contacted DEP in July of 1998 to discuss MRI's compliance status from 1996 (when
CDM's assessment was completed) until the present. The cognizant DEP official noted
specifically that DEP considers the MRI facility to have been continuously in compliance
with all permit requirements and applicable regulations from 1996 to present.
Based on the representations of DEP and CDM, ARI concludes that MRI's record of
compliance with permit conditions and with applicable regulations has been good,
overall.
8.2 Notice of Violation
US EPA inspected the MRI facility in April, 1997, and issued a Notice of Violation (NOV)
in November of 1997. In the NOV, US EPA cites as violations of the facility's Federal air
permit a failure to operate control equipment and a failure to monitor the rate at which
municipal solid waste is charged to the combustor. The NOV also cites failures to report
emissions data, excess emissions, and excess monitor downtime, as violations of the
facility's Federal and DEP air permits.
ARI has found that the principals involved with the NOV (MRI, US EPA, and DEP) are in
negotiations to resolve the NOV, and are reluctant to discuss the NOV with other parties,
including ARI. Thus, ARI is privy to only limited information about the import of the
various citations included in the NOV. Based on information on hand, ARI has the
following observations about the NOV:
• The cited failure in 1997 of MRI to provide continuous monitoring data to
DEP on a quarterly basis appears to be a legitimate citation. MR[ had
supplied an annual summary of the data, not quarterly summaries.
8-2
• The citation for failure to operate the secondary sorbent injection system
appears to be insupportable. That system was brought on site with DEP's
approval as an experimental system. There is no DEP permit condition
requiring use of the secondary sorbent injection system, thus, it does not
appear that MRI is in violation.
• The citations for excess emissions based on continuous monitoring data
appear to be based on a questionable interpretation by US EPA of
applicable DEP permit requirements. As a legal matter, the existing DEP
permit requires emissions compliance to be determined based on periodic
stack testing, not on the basis of continuous monitoring data. These
citations, therefore, may be found to be insupportable.
• For other citations relating to failure to monitor the solid waste charging rate
and relating to excessive downtime for the continuous monitors, ARI has
little background information regarding the basis for the citations, and
makes no comment.
In summary, resolution of the NOV is a matter under active negotiation between the US
EPA and MRI. Based on information ARI can independently confirm, it appears that the
most serious citations -- failure to operate an emission control system, and causing
excess emissions — appear to be without adequate foundation. Other citations, for which
ARI has no basis for informed comment, relate to procedural issues; e.g., data reporting.
Based on ARI's review of the NOV and its knowledge of existing permit requirements,
ARI concludes that the NOV citations do not connote conditions that would create any
increase in health risks.
8.3 Conclusions Regarding Compliance History
MRI's record of compliance with formal permit requirements is good. MRI has been in
compliance with all current permit limits historically, except for sulfur dioxide. Violations
of permit limits for sulfur dioxide in the early years ceased with the installation of
additional emission controls in 1992. US EPA issued a Notice of Violation to MRI in
November, 1997, over which US EPA and MRI are currently negotiating. The matters
cited in the Notice do not appear to connote conditions that would create any increase in
health risks. The substantive matters appear to relate to procedural reporting
requirements,
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8-3
9.0 COMPLIANCE WITH ZONING BYLAW
The Town's Zoning Bylaw at Section 8,3(6)(a)(ii) states that:
"The proposed development must not present a demonstrable, adverse
impact on the surrounding area, resulting from excessive noise, dust,
smoke, or vibration which are higher than levels now experienced from
uses permitted in the surrounding area."
The MRI facility represents a "use permitted by right" under the Zoning Bylaws, The
proposed development (the upgrade project) would result in a reduction in the emissions
of a number of air pollutants, no change in the emissions of the other air pollutants, and
improved control of dust from ash-handling operations. The upgrade project would not
entail any new, significant sources of noise or vibration. Because emissions would be
lower, not higher than levels now experienced, and because noise and vibration levels
would not noticeably change compared with existing levels, the MRI facility upgrade
project complies with Section 8.3(6)(a)(li).
9-1
i
E
• Historical Compliance Summaries
-- For each continuously monitored parameter above, an historical
compliance summary (examples: prior week's data, or the last six
months' data). The format, graphical or tabular, shall clearly convey
the number, dates, and magnitudes of any exceedances of
applicable limits.
• Eguipment Malfunction Summaries
Summaries of time periods during which each continuous monitoring
system was malfunctioning while the facility was operational, as
"operational" is defined by applicable regulations.
-- Quarterly cumulative summaries of such malfunction time.
The Board of Health can amend the above listing to be consistent with future
changes .in DEP or US. EPA continuous monitoring requirements The Board. of
Health and MRI may amend the listing at any time by mutual written consent.
2. 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.
3. Compliance Records
No later than five business days following their submission to the regulatory agency by
MR[, MR[ must 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.
4. Inspection of Facility Operations and Records
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, as
required to assess 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.
10-2
10.0 RECOMMENDED PERMIT CONDITIONS
Should the Planning Board approve MRl's application for a Site Plan Approval, ARI
recommend that a number of specific permit conditions be imposed by the Town to
ensure that the facility complies with applicable emission limits, air quality standards, and
guidelines. In addition, permit conditions are recommended to require that charging of
municipal solid waste to a combustor unit cease should a failure occur in the operation of
the combustion equipment or air pollution control equipment. ARI also recommends
permit conditions to enable inspection of facility operations and of compliance records in
general, and inspections for ash dusting.
ARl's recommended permit conditions are as follows:
1. Public Access to Compliance Data in Real Time
MR] shall arrange for public access, via telephone modem, to MRI's database computer
for the purpose of public acquisition of continuous emissions and operational monitoring
data, suitably time-averaged for compliance demonstration as defined by applicable DEP
and US EPA permit conditions, regulations, and guidelines. Public access in this regard
shall be unrestricted as to whom may access the data, and ,as to time of day or day of
week. MRI shall make the data publicly available via modem access on as near to a
real-time basis as reasonably practicable. Under normal operating conditions, this
means that the data shall be publicly accessible no more than twelve hours following the
end of the data time-averaging period required for compliance demonstration. Upon
request by the Town, MRI shall install a computer, modem telephone line, and modem in
the Town's library to facilitate ready public access to the data.
The specific continuous monitoring data to be made publicly available is as follows:
Most Recent Compliance Data
The latest monitored emissions and operating levels, compared with permit
limits (graphical format), specifically:
— Sulfur Dioxide, 24-hour average geometric mean concentration and
the removal efficiency
-- Nitrogen Oxides, 24-hour daily arithmetic average concentration
— Opacity, 6-minute average percentage values, daily summary
— Carbon Monoxide, 4-hour block arithmetic average
Flue Gas Temperature at the fabric filter inlet, 4-hour block arithmetic
average
10-1
5, Prompt Shut-Down of Combustor Unit for Malfunctions
MRI is required to promptly cease the charging of municipal solid waste to the combustor
unit if any of the following criteria is met as to that combustor unit;
• 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, until the fan resumes service.
• Potential for Excess Emissions from Inadequate Combustion Efficiency
— On start-up, furnace gas temperature, as measured at
Elevation 125' — 0" (T1 & 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, until the temperature criterion is met.
During waste combustion, furnace gas temperature measured at
Elevation 125' —0" drops below 1,600"F for more than three hours.
Operator must promptly cease the charging of waste to the affected
combustor unit, and cannot resume charging until the temperature
criterion is met.
• Potential for Excess Emissions from Failure of the Fabric Filter
More than three fabric filter modules are out-of-service (isolated).
Operator must immediately cease the charging of waste to the
affected combustor unit, and cannot resume charging until sufficient
modules are in service.
• Potential for Excess Emissions from Scrubber Failure
— Temperature exceeds 450OF 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, until proper scrubber functioning is restored, as
evidenced by the temperature at the fabric filter inlet.
10-3
i
Lime-slurry feed to the spray-dry absorber interrupted for more than
four hours. Operator must immediately cease the charging of waste
to the affected combustor unit, until lime-slurry feed is restored.
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.
Aran
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