DEP Public Hearing on Harrisburg Incinerator

DEP Public Hearing on Harrisburg Incinerator
Tuesday, September 25th, 7 pm
Community Life Bldg, 1119 Cameron St, Harrisburg

How to Comment at the Hearing	General Requirements
Definitions	Operating Requirements
Testing Requirements	Conditional Requirements
Monitoring Requirements	Recordkeeping and Reporting

The Harrisburg Incincerator is one of the largest sources of DIOXIN in the US, and its emissions have been found to impact as far away as the Artic Circle! The DEP is allowing their permit to continue operations. The plan approval seems to indicate that the incinerator could be allowed to operate until 2003 whether or not it passes the dioxin tests.

The fact that DEP is allowing this even if the incinerator fails its stack tests is unconscionable. We need to call them on this.

Below is the Notice of Intent to Issue a Plan Approval that ran in the PA Bulletin on Sat., 8/18. You will be able to submit comments until September 25th, at a minimum.

This is our official opportunity to say the Incinerator should not be operating, that it is an environmental disaster (which is amply demonstrated by its (non)-compliance history and high dioxin levels) and that we demand shutdown based on the recent stack test failure.

If possible, when you send in comments to the DEP, please also send a copy to the community organizers.

PUBLIC HEARINGS

Southcentral Region: Air Quality Program, 909 Elmerton Avenue, Harrisburg, PA 17110;
Contact: Leif Ericson, Program Manager, (717) 705-4702.

22-05007:The Harrisburg Authority (1670 South 19th Street, Harrisburg, PA 17104) for modification and operation of the Harrisburg Materials, Energy, Recycling and Recovery Facility in the City of Harrisburg, Dauphin County.

Plan Approval No. 22-05007 authorizes physical modifications that will limit the capacity of each of the two existing combustor units to less than 250 tons per day of municipal waste. The plan approval will include conditions for shakedown and testing of the de-rated combustors.

The plan approval will include the following conditions for operating and testing of the de-rated combustors as well as monitoring of their performance and record keeping:

Conditions

General Requirements

The Harrisburg Materials, Energy, Recycling and Recovery Facility is to be modified in accordance with the plans submitted with the application (as herein approved).

This plan approval authorizes temporary operation of the sources covered by this Plan Approval provided the following conditions are met:

The Department must receive written notice from The Harrisburg Authority of the completion of construction and The Harrisburg Authority's intent to commence operation at least 5 working days prior to the completion of construction. The notice must state when construction will be completed and when The Harrisburg Authority expects to commence operation (progress reports, and the like)
Operation is authorized only to facilitate the start-up and shakedown of sources and air cleaning devices, to permit operations pending the issuance of an Operating Permit or to permit the evaluation of the sources for compliance with all applicable regulations and requirements.
This condition authorizes temporary operation of the sources for a period of 180 days from the date of commencement of operation, provided the Department receives notice from The Harrisburg Authority under subpart a.
The Harrisburg Authority may request an extension if compliance with all applicable regulations and Plan Approval requirements has not been established. The extension request shall be submitted in writing at least 15 days prior to the end of this period of temporary operation and shall provide a description of the compliance status of the sources, a detailed schedule for establishing compliance and the reasons compliance has not been established.
The notice submitted by The Harrisburg Authority under subpart a., prior to the expiration of this Plan Approval, shall modify the plan approval expiration date. The new plan approval expiration date shall be 180 days from the date of the commencement of operation.

The HMERRF is subject to portions of 40 CFR Part 60, Subpart Cb--Emission Guidelines for Municipal Waste Combustors and portions of the related Subpart Eb--Standards of Performance for Large Municipal Waste Combustors. Copies of all requests, reports, applications, submittals and other communications shall be forwarded to both the Department and EPA.

All correspondence to the Department and EPA shall be addressed to:

Leif Ericson Air Quality Program Manager
Southcentral Regional Office
909 Elmerton Avenue
Harrisburg, PA 17110

Director
Air Protection Division
U.S. EPA Region III
1650 Arch Street
Philadelphia, PA
19103-2029

Within 120 days after the date of this approval, the permittee shall submit a Title V operating permit application to the Department in accordance with 25 Pa.Code Chapter 127, Subchapters F and G.

The permittee shall cease operation of the waste combustor units no later than midnight June 18, 2003, unless otherwise approved by the Department and retrofitted with all necessary emissions control equipment capable of meeting all of the applicable requirements of 40 CFR 60 Subpart Cb.

Definitions
The following definitions apply to the provisions of this plan approval:
Four-Hour Block: refers to the arithmetic average of four consecutive hourly averages measured over the 4-hour time periods from 12 a.m. to 4 a.m.; 4 a.m. to 8 a.m.; 8 a.m. to 12 p.m.; 12 p.m. to 4 p.m.; 4 p.m. to 8 p.m.; and 8 p.m. to 12 a.m..
24-Hour Block: refers to the 24 hour period rolling arithmetic averaging period calculated from the 6 preceding 4-hour block averaging periods.
245 TPD Steam Limit: refers to the 54,189 lbs/hour of steam which is the steam flow calculated by the applicant as corresponding to 245 tons per day waste feed rate averaged over any 24-hour block for each waste combustor unit as verified by testing.
250 TPD Steam Limit: refers to the 55,295 lbs/hour of steam which is the steam flow calculated by the applicant as corresponding to 250 tons per day waste feed rate averaged over any 4-hour block for each waste combustor unit as verified by testing.
Monitoring Equipment: refers to all equipment and instrumentation necessary to determine process variables including, without limitation, devices to measure steam flow, temperatures, carbon monoxide (CO) and oxygen levels, fan amperage, computer systems, electronics and other parameters.
Startup commences with the introduction of municipal waste into the empty combustor unit.
Shutdown commences with the cessation of charging of the combustor with municipal waste for the express purpose of shutting down the combustor unit.
Steam interlock system refers to technology that automatically stops waste charging to the combustors when the monitored steam flow exceeds the values corresponding to the waste feed limits previously specified.
Programmable logic control system is the electronic hardware and computer software elements integral to the steam interlock system.

Operating Requirements
The municipal waste combustor units shall be operated and maintained in accordance with good air pollution prevention practices or control practices.
The permittee shall install, maintain and operate equipment and instrumentation necessary to determine process variables and to demonstrate compliance with the provisions of this plan approval or subsequent operating permits.
The Department shall control access to the facility's programmable logic control system. The permittee shall provide justification and notify the Department in writing at least 24 hours in advance of any requested access to the system.
Any modification of the steam interlock control program requires the written approval of both the Department and the EPA. All requests for modifications shall be submitted in writing with justification to both agencies.
The facility director, operations supervisor and all shift supervisors shall obtain and keep current either an ASME provisional or operator certification.
Neither waste combustor unit shall be operated without an individual bearing either an ASME provisional or operator certification on-site.
Neither combustor shall be operated in excess of the 245 TPD steam limit as defined in Condition 7.
Neither combustor shall be operated in excess of the 250 TPD steam limit as defined in Condition 7.

Testing Requirements
The permittee shall conduct stack emission testing on each waste combustor unit according to the schedule specified in Paragraph 11 of the January 9, 2001, Consent Order and Agreement between the Department and the City.
The previous testing is required under the January 9, 2001, Consent Order and Agreement to determine the dioxin/furan, particulate matter, carbon monoxide, lead, cadmium, mercury and nitrogen oxides emissions and inlet temperatures for each electrostatic precipitator control device. All testing shall be conducted in accordance with 40 CFR Part 60, Appendix A and 25 Pa.Code Chapter 139 as follows:
1. Each unit being tested shall be operated at 80% to 100% of the 245 TPD steam limits using waste representative of the waste normally fired, without any segregation or separation
2. Dioxin/furan--EPA Method 23
3. PM--EPA Method 5
4. Visible emissions--EPA Method 9
5. Carbon monoxide--EPA Method 10, 10A or 10B
6. Cadmium, lead and mercury--EPA Method 29
7. Nitrogen oxides--EPA Method 7E
Each IBW/Martin municipal waste combustor is subject to a maximum NOx emission limit of 300 ppm, dry volume, corrected to 7% oxygen. NOx emissions shall be verified annually by stack testing as previously defined.
At least 45 days prior to each stack test, the permittee shall submit a test protocol to the Department and EPA.
The permittee shall notify the Department and EPA at least 7 days prior to each test.
The following operating information shall be submitted for each test period:
1. Municipal solid waste feed rate in tons per hour
2. Boiler steam flow in pounds per hour, temperature in degrees Fahrenheit and pressure in pounds per square inch gage
3. Boiler oxygen value in percent
4. Boiler furnace temperature in degrees Fahrenheit
5. ESP inlet (economizer outlet) temperature in degrees Fahrenheit
6. Boiler carbon monoxide value at ESP outlet in ppmv @ 7% oxygen
7. Forced draft fan and overfire air fan amperage and discharge pressures in amps and inches water column
The permittee shall submit a summary of the emission test results for dioxin/furan, particulate matter, visible emissions, lead, cadmium, mercury, nitrogen oxides and carbon monoxide to the Department and EPA within 45 days of completion of each stack test.
The permittee shall submit a complete test report, including all information described in Conditions Nos. 17 and 21 to the Department and EPA within 60 days of completion of each stack test.
The permittee shall comply with all applicable performance and testing procedures and monitoring requirements set forth in 40 CFR 60.38(b) of Subpart Cb and 40 CFR 60.58b(c), (d), (g) and (i)(6) and (7) or other equipment methods approved by the Department. The provisions of 40 CFR 60.58b(c)(8)-(11) and 60.58b(g)(5) and (6) and 60.58d(2)(v) are not applicable procedures for purposes of this plan approval.

Conditional Requirements

If stack test results indicate that dioxin/furan emissions from either combustor unit have exceeded 1,500 ng/dscm during any test, the permittee shall institute the following measures:

conduct a bimonthly stack test of the units which exceeded 1,500 ng/dscm according to the Testing Requirements section of this permit until a time the permittee can demonstrate dioxin/furan concentrations of 1,500 ng/dscm or less for two consecutive bimonthly stack tests

conduct monthly inspections and repairs of these areas for the associated boilers

(1)sifting valves	(6)vibration pan seal and doors
(2)front boiler door panels	(7)air pre-heater seals
(3)boiler inspection ports	(8)ESP seals
(4)quench basins	(9)expansion joints
(5)MSW feed chutes	(10)boiler/stoker connection seals

The bimonthly stack testing is in addition to testing referenced in Condition No. 16.

If stack test results indicate that dioxin/furan emissions from either combustor unit have exceeded 1,500 ng/dscm during any test, the Department specifically and expressly reserves the right to require additional measures with respect to dioxin/furan emissions. These measures include, without limitation, the right to deny, suspend or revoke any approval or permit and the right to order cessation of the units.
Subsequent to the first dioxin/furan test required by this permit, the ESP inlet (economizer outlet) temperature for each unit shall not exceed by 30 degrees Fahrenheit the highest 4-hour block arithmetic average flue gas temperature measured at the ESP inlet during 4 consecutive hours of each stack test required under Condition No. 18 and demonstrating compliance with the applicable dioxin/furan limit of 1,500 ng/dscm at 7% oxygen, total mass. Until the ESP inlet (economizer outlet) temperature is established during testing, the temperature limit is 600 degrees Fahrenheit.
In the event the ESP inlet (economizer outlet) temperature exceeds the previous limits, the permittee shall slow the waste feed to reduce the temperature below the applicable limit and shall implement the procedures in the revised Operational and Maintenance Manual.
In the event the ESP inlet (economizer outlet) temperature does not drop below the previous limit after any two 4-Hour Blocks, which occur in a 24 hour period, the permittee shall immediately cease feeding waste, begin visual inspection of the baffle walls and conduct the following:
1. Check the flue gas pressure drop across the economizer against values recorded previously at similar loads when the economizer outlet temperature remained below the previous limits; in the event of an increase in pressure drop of more than 1/2 inch in water gage, thoroughly clean the economizer section.
2. Compare the difference between furnace temperature and economizer inlet temperature to levels recorded previously at similar loads when the economizer outlet temperature remained below the limit in this paragraph. Routinely inspect the refractory baffle wall and the metal division wall during off-line cleaning to assure that they are still intact and conduct off-line cleaning.
If the ESP temperature data is unavailable and cannot be restored within 4 hours, the permittee will cease feeding waste to the combustor units until the ESP inlet temperature is restored, unless the permittee takes manual temperatures, takes the economizer inlet temperature and repairs the system within 24 hours or the next business day.

Monitoring Requirements
The permittee shall provide a single dedicated dial-up modem accessible to the Department and EPA with remote access to monitor operating system parameters as follows:
1. remote access shall be operable and available to the Department and EPA until midnight on June 18, 2003
2. the system shall monitor these parameters:
  actual furnace temperature carbon monoxide
  steam flow set point oxygen
  steam flow ESP inlet temperature
  an indicator of feeder operation average steam flow
3. data shall be available on a real-time basis and a 30 day historical basis; trend charts shall indicate any exceedances of the 245 TPD and 250 TPD steam limits.
The permittee shall maintain and operate a steam interlock control system to ensure that waste charging does not exceed the applicable steam flow limit for each unit referenced in Conditions Nos. 14 and 15.

Recordkeeping and Reporting
The permittee shall report exceedances of each unit's 245 TPD-equivalent steam limit to the Department and EPA within 24 hours or the next business day. The permittee shall provide a written description of each exceedance, its cause and the corrective measures taken to the Department and EPA within 10 days.
The permittee shall observe the following procedures for exceedances of each unit's 250 TPD-equivalent steam limit:
1. immediately cease feeding waste to the units
2. report each exceedance to the Department and EPA within 24 hours or the next business day
3. provide a written description of each exceedance, its cause and the corrective measures taken to the Department and EPA within 10 days
4. not restart the unit unless the Department determines that the unit is physically limited to operating at the 250 TPD-equivalent steam limit
In addition to the records required under 25 Pa.Code � 129.95, the permittee shall maintain records of the following for each municipal waste combustor:
1. Tons of municipal waste combusted and steam produced per day
2. Hours of operation
3. Summary of maintenance performed on the combustors, control devices and monitoring devices
4. Duration of all start-ups, shutdowns and malfunctions of the combustors, control devices and monitoring devices
5. Testing, calibration, adjustments and maintenance of all continuous monitoring devices
No later than 21 days after the end of each calendar month, the permittee shall submit a report containing, but not limited to, the information referenced in Condition No. 35 to the Department.
All records required by this operating permit shall be maintained onsite for the most recent 5-year period and made available to Department representatives upon request.

Operating Permit No. 22-05007 will provide for the derated operation of the combustors and will include conditions for compliance monitoring and ongoing testing of the de-rated units. Operation of the waste combustors beyond June 18, 2003 is contingent upon compliance with the applicable requirements of 40 CFR 60, Subpart Cb--Emissions Guidelines and Compliance Times for Large Municipal Waste Combustors.

A public hearing will be held for the purpose of receiving comments on the proposed actions. The hearing will be held on September 25, 2001, at the Community Life Building, 1119 South Cameron Street, Harrisburg, PA 17103 from 7 p.m. until all scheduled comments on the proposed action are received.

Those wishing to comment are requested to contact Sandra Roderick at (717) 705-4931 at least 1 week in advance of the hearing to schedule their testimony. Commentators are requested to provide two written copies of their remarks at the time of the hearing. Oral testimony will be limited to a maximum of 10 minutes per individual. Organizations are requested to designate an individual to present testimony on behalf of the organization.