COVANTA NIAGARA, L.P. SOLID WASTE MANAGEMENT FACILITY OPERATIONS & MAINTENANCE MANUAL ADMINISTRATION PLAN July 2014 TABLE OF CONTENTS (Table of Contents Contains Clickable PDF Links to the Sections) CERTIFICATION STATEMENT May 2014 OM-1 INTRODUCTION May 2014 OM-A APPLICABLE REGULATIONS March 2014 OM-2 ASH MANAGEMENT PLAN March 2014 OM-3 WASTE CONTROL PLAN July 2014 OM-4 STAFFING PLAN July 2014 OM-5 ASH SAMPLING & ANALYSIS PLAN March 2014 OM-6 OPERATIONS & FACILITY INSPECTION PLAN May 2014 OM-7 MAINTENANCE PLAN July 2014 OM-8 START-UP, SHUT-DOWN, & MALFUNCTION PROCEDURES May 2014 EMPLOYEE TRAINING PLAN May 2014 MISCELLANEOUS OPERATIONAL REQUIREMENTS May 2014 CONTINGENCY PLAN May 2014 CLOSURE PLAN May 2014 OM-9 OM-10 COVANTA Doc PE Certification Rev. No. 2 COV ANT A NIAGARA Revision Date: 5/8/1 4 O&M/ECOM Manual Reviewed Date:S/811 4 Powering Today. Protecting Tomorrow. COVANTA NIAGARA, L.P. This O&M/ECOM Manual has been prepared under the supervision and direction of the below certifying New York State registered Professional Engineer in accordance with 6NYCRR Part 3601.9(e ). All documents contained herein were prepared in conformance with the NYSDEC requirements in 6NYCRR Part 360, the ECL, the current Part 360 permit and the proposed Part 360 Permit Modification Documents and all the information contained herein is believed to be true and accurate. All engineering drawings included herewith were prepared under the supervision and direction of another certifying New York State registered Professional Engineer. ' \, "I ~· I \ J • \, Chris Schifferli, PE License 084525 Printed copies are not document controlled, refer to "S" drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1of1 0 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 INTRODUCTION The Covanta Niagara, L.P. facility, located on approximately 27 acres at 100 Energy Boulevard at 56th Street in Niagara Falls, New York, combusts solid waste in two Deutsche Babcock Anlagen (DBA) mass burn furnaces and boilers with associated turbine/generators, flue gas cleaning systems, a refuse storage and feeding system, an ash residue handling and processing system and a Rail-to-Truck Intermodal Facility (RTIF). Waste is delivered to Covanta Niagara, L.P. either by over the road truck or by rail via the operation of the RTIF. In addition, there is an alternate fuel-fired furnace/boiler, that currently combusts waste wood (e.g. pallets, construction/demolition wood, clean wood, creosote treated wood, etc.), with associated alternate fuel storage and feeding system, lime injection system for acid gas control, electrostatic precipitator, and an ash handling and processing system. The solid waste and alternate fuels are the primary fuels used in Covanta Niagara’s two solid waste-fired mass burn furnace/boilers and the alternate fuel-fired furnace/boiler, respectively, to produce high pressure steam. As the solid waste and alternate fuels are combusted in their respective furnace/boilers, the heat released is recovered via the steam produced in the boilers. The steam produced will normally be put through two extracting/condensing turbines to produce electricity and extracted steam. Some of the electricity generated (approximately 17%) is used to power equipment in the plant while the remainder is sold into the power grid. The steam that is extracted is transported to six (6) neighboring manufacturing plants for use in their processes. PURPOSE OF THE MANUAL This Operations and Maintenance manual is provided to comply with the requirements 6 NYCRR Part 360-1.14 and 360-3 and the requirements set forth in 40 CFR part 60, Subpart Ea, section 60.56a(f)(6) – “procedures for operating the MWC unit within the standards established under this subpart”. Detailed descriptions of the Covanta Niagara processes are found in the Operation Manual's Systems Description book. WASTE RECEIVING AND MANAGEMENT Rail: Delivery schedules of unit trains are established by CSXT and communicated to Covanta Niagara. Unit train deliveries will be coordinated with the control room operator to grant CSXT access to the RTIF rail sidings. Each unit train that arrives at the RTIF includes 30-36 rail cars, each carrying 4 containers for a total of 120-144 sealed intermodal containers per unit train which will be targeted to be unloaded over 36-48 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 hours. The net weight of each container is expected to be 20-22 tons. Based on this expected net weight, each unit train will deliver approximately 2,400-3,200 tons of MSW. Prior to receipt by the RTIF, residential MSW is screened and is subsequently loaded into sealed containers at the Department of Sanitation of New York (DSNY’s) North Shore and East 91st Street converted Marine Transfer Stations (MTSs). Alternate facilities are available for receipt of containerized waste from DSNY due to either an emergency or for long term capacity and is addressed by the Waste Control Plan (Section 3) of this manual. Containerized waste received by the RTIF is screened for radiation prior to transport to the tipping hall to verify radiation screening performed at the MTS to ensure only nonhazardous municipal solid waste is delivered to the Niagara RTIF. No hazardous wastes will be transported to the RTIF. The Covanta Niagara EfW Facility will not accept any hazardous wastes, either by rail or truck. Radio Frequency Identification (RFID) technology is utilized to track container movements and elapsed time from NYC to Niagara. Passive RFID technology captures data entering and leaving the facility to assist in the management of containers. After delivery of the railcars loaded with full containers, the RTIF Superintendent/Lead Operator will review the RFID container data log, ensure that each container is in good working order and discern any odors. Any discrepancies need to be immediately noted and reported to the Rail Transportation Manager. The CSXT Bill of Lading is crosschecked with the RTIF schedule for receipt of containers. Any discrepancies are immediately noted and immediately reported to the Rail Transportation Manager. Intermodal containers will be offloaded from the railcars via a dedicated container handler (Reach Stacker) designed specifically for intermodal container transfer operations. Full intermodal containers will be lifted from the railcars and then loaded by the container handler onto a yard tractor with tipping chassis. These tipping chassis will be specifically designed for the transportation of intermodal containers. The yard tractor units, with the full intermodal containers, will then proceed to the RTIF scale, or in the event of an RTIF scale outage, to the EfW Facility scale. At the scale house, the container identification is verified and container is scanned for radiation after passing over the scale, the tractor trailer units with the full intermodal containers will be directed to the tipping floor to be unloaded. In the event that full intermodal containers require the application of heat in order to allow the municipal solid waste to be discharged, then the RTIF Superintedent will direct the tractor driver to enter the thaw shed. The yard tractor units loaded with the full intermodal container will remain inside the thaw shed for a time sufficient to allow the Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 outermost portion of municipal solid waste to de-ice and release from the interior walls of the intermodal containers. The yard tractor units loaded with full intermodal containers will then proceed to the EfW Facility tipping hall to discharge the municipal solid waste. OVER THE ROAD TRUCKS: Over the road trucks (i.e., front and rear end loaders, rolloffs, transfer trailers, dump trailers, van trailers, flat bed trailers, tank trailers, etc.) hauling solid waste enter the facility grounds through a monitored entry gate off 56th street and proceed to the scalehouse via Energy Boulevard where they are weighed on computerized scales for record keeping and billing purposes. At the scalehouse, the load is identified. The hauler/generator must have a contract with Covanta Niagara and be in the scalehouse computer system, otherwise the load will be refused entry. If the generator/hauler is the scalehouse computer system, this indicates that there is a contract in place, that the waste type has been reviewed for suitability for acceptance and that the generator has been informed as to what wastes are acceptable and what wastes are not acceptable. As reflected in the facility's Waste Control Plan (Section 1) no hazardous waste, radioactive waste, or regulated medical waste are accepted. All solid waste unloading (with the exception of the tank trailers of liquid waste for the liquid injection system), storage and handling are done inside buildings. Trucks with acceptable loads proceed to either the tipping hall or the liquid waste unloading (secondary containment) area. Inside the tipping floor, the transfer trailers and dump trailers are normally backed up and unloaded directly into the large concrete refuse bunker. The refuse bunker is designed to provide three to four days of storage capacity. This storage capacity allows the facility to handle short term waste flow fluctuations. The smaller waste delivery trucks (i.e. packers and rolloffs) are unloaded on the tipping floor and then a payloader is used to push these loads into the refuse bunker. Van trailers containing pallets of various wastes: drums (liquids and solids), super sacks of powder and boxes of consumer packaged products, are unloaded by forklift using a portable unloading dock. After the pallets of boxes are unloaded, they are normally pushed (by the payloader) directly into the refuse bunker. Pallets of fiber drums and super sacks containing powders are temporarily stored on the tipping floor (either the south or north ends) and then put into the refuse bunker, one or two pallets at a time, so that they can be picked up by the grapple crane and put directly into the furnace hopper without breaking the container and creating a dust cloud. Most pallets of drums (steel, plastic or fiber) and totes (plastic or mild steel) with liquids or solids are temporarily stored in the drum storage area at the north end of the tipping floor until the containers can be processed through the Komar shredder. After discharging their loads, the trucks leave the tipping floor. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 A Komar shredder (approved by the NYSDEC in October 2002) was installed on the tipping floor to process drums (steel, plastic and fiber) and tote containers (mild steel and plastic). The drums and totes can contain liquids, solids or semisolids. The drums and totes are put into the shredder where an auger pushes the containers against a shear plate which results in the container being torn apart. As the container gets torn apart, the auger pushes the contents, as well as, pieces of the container out the discharge chute and onto the solid waste in the refuse bunker. The refuse bunker is completely enclosed and contains two full-span, overhead traveling cranes. Grapples on the cranes are used to pick up the solid waste and put it into the furnaces feed hoppers. The solid waste then slides by gravity into the refuse chute, where it acts as an airlock to impede entry of air from the feeding system into the furnace. A ram feeder pushes the solid waste from the bottom of the refuse chute onto the boiler's uppermost roller grate. The feeder then retracts, ready to feed more solid waste onto the grate. The rate at which solid waste is fed onto the grate depends on the demand for steam, the heating value of the solid waste being fed, its moisture content, and several other factors. The feed rate is altered by changing the cycle time of the ram feeder. When a change in the feed rate is made, corresponding adjustments to roller speeds and primary and secondary air flows are made to maintain combustion control. Primary air distribution to individual rollers is controlled to ensure burnout of the waste. Each crane is operated from a common air-conditioned pulpit, and each is able to satisfy the fuel requirements for each of the two furnaces. Bulk liquid wastes arrive at the facility in tank trailers (nominal size – 5,000 gallons). Most of those tank trailers are staged in a concrete secondary containment dike on the north side of the DBA boiler building and then the liquid is pumped from the trailer, through a strainer and into a storage tank. Occasionally a tank trailer is taken to the tipping floor and the liquid then sprayed from the tanker onto the solid waste in the refuse bunker. A liquid waste injection system (approved by the NYSDEC in March 2003) is used to inject the liquid waste directly into the combustion zone of the DBA boilers. Six permanent storage tanks were installed in 2011 inside a concrete secondary containment dike. The tanks have a total storage capacity of 300,000 gallons. From the tanker the liquid waste flows through a strainer (to remove solids that would plug the injection nozzles), then into a pump, through a grinder and then into one of the storage tanks. From the storage tank the liquid waste directly (through spray nozzles) into the combustion zone of the DBA boilers. The direct injection liquids are the only wastes that are not put into the refuse bunker prior to being put into the furnace. The facility effectively controls odors; all refuse handling occurs in the enclosed tipping hall and refuse bunker areas which are maintained under a slight negative air pressure. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 Primary air for the furnace is drawn from the tipping hall and refuse bunker so that solid waste odors, as well as truck exhaust fumes are swept into the furnace and combusted. The liquid waste storage tanks are vented into the primary air ducts for each of the two DBA boilers - thus there is slight negative pressure on the storage tanks and any air venting from the tanks is burned in the boilers. COMBUSTION PROCESS The Deutsche Babcock Anlagen (DBA) Duesseldorf Roller Grate system technology, developed in Germany and used throughout the world, is used at the Covanta Niagara facility. Proper combustion of solid waste is based on three fundamentals: time, temperature, and turbulence. The Duesseldorf Roller Grate consists of six rotating rollers each approximately 5 feet in diameter and made of ductile iron bars that extend the full width (approximately 22 feet) of the furnace. The roller grates are installed on a 20% incline from the first to sixth grate. Each roller is independently driven through a gear box that enables its rotational speed to be varied from about 0.6 to 12 revolutions per hour. The solid waste tumbles and mixes as it travels over the roller grates. The furnace walls are constructed of steel tube panels of membrane construction. Water flows in the tubes and heat from the combustion of the solid waste is transferred through the tubes into the water, and steam is produced. Primary air for combustion is blown into each of the roller grates, and spaces between the bars allows the combustion air to penetrate the solid waste. As each roller rotates forward, the solid waste slowly moves toward the next lower roller. Between each of the rollers a transition piece causes the solid waste to tumble and roll, an action that exposes previously unburned solid waste to the fire and air in the furnace. The Duesseldorf Roller Grate system is designed in this manner to allow a through burnout of solid waste. While on the first roller and at least part of the second roller, the solid waste is dried by the hot combustion gases produced from the solid waste combustion on the lower roller grates. The dried solid waste ignites as it crosses the second roller, and burns thoroughly as it travels across the third and fourth rollers; occasionally, wet or low heat content waste may continue to combust on the fifth roller grate as well. The burnout is completed as the bottom ash passes over the sixth roller and ultimately falls off into the water-impounded bottom ash extractor trough below. The hot combustion gases from the combusted solid waste flow upward from the lower furnace through the upper furnace, heating the water in the wall tubes. The combustion gases then pass through the screen tube section and then through several passes Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 containing the superheater and economizer sections. In the upper sections of the boiler, urea is injected through a series of nozzles for nitrogen oxides control. The urea reacts with the nitrogen oxides to form nitrogen. After the economizer section, the combustion gases flow into the boilers’ air pollution control system’s acid gas scrubber. Steam is generated in the wall and screen tubes and flows through riser tubes into the steam drum. In the steam drum, water and steam are separated. The water is returned to the lower headers of the wall tubes, while the steam is piped through the boiler’s superheater tubes to increase the steam’s temperature. Steam leaves the superheater and enters the main steam header and is transported to the facility’s two turbine/ generators to produce electricity. Each boiler is equipped with two ignition burners and two auxiliary burners that can fire natural gas. The burners are operated at the following times to facilitate the combustion process. Furnace start-up prior to introduction of solid waste; Furnace shut-down after solid waste feed has been discontinued until burnout of the solid waste in the furnace has occurred; and Other times as needed to ensure the combustion gases are subject to high temperature residence time. Basic Combustion Theory Applicable to a Municipal Waste Combustion (MWC) Unit The following description is provided in accordance with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (2) - description of basic combustion theory applicable to MWC units. The proper combustion of solid waste is based on three fundamentals: time, temperature, and turbulence. The DBA boilers grates and furnace systems are designed and constructed to obtain complete combustion of solid waste, a highly variable fuel. The combustion of any fuel requires a theoretical (stoichiometric) amount of oxygen which is usually supplied from ambient air. In practical applications, because of the incomplete mixing of the fuel and air, this stoichiometric amount of air is not enough to complete the combustion of all the fuel. In order to complete the process and have no unburned solid waste passing through the furnace, an extra amount of combustion air is supplied above the stoichiometric amount. This extra air is called “excess air” and will vary depending on the type of fuel being burned, but for solid waste will typically range from 60 to 100% of the stoichiometric amount. As stated above, the DBA furnace’s Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 primary air fan pulls the combustion air from the solid waste bunker and tipping floor area and directs it into the furnace through the roller grates. As the solid waste burns on the rollers, its volume decreases. An adequate bed depth of solid material on the surface of the rollers is maintained by adjusting relative rotational speeds of the rollers. This bed of solid waste protects the grate bars from intense heat in the furnace and provides a bed of combustible material deep enough to make good contact with the primary air. The ability to independently adjust the rate at which the solid waste passes across succeeding rollers in the grate as well as the quantity of air flowing through the individual roller grates contributes to proper burnout and a steady fire. In the DBA "parallel flow" design that is used at Covanta Niagara, the flue gas generated during the combustion of fuel over the initial rollers is forced to flow parallel to the remaining rollers. This increases the turbulence and the time that the flue gas spends in the primary combustion zone. After leaving this zone, secondary air is injected into the flue gas stream. Once again, further turbulence is created and the additional air promotes the completion of combustion of any unburned organic compounds and carbon monoxide remaining in the flue gas. By maintaining the proper primary and secondary air flow, a constant feed of solid waste into the furnace, and proper solid waste/ ash depth on the roller grates, a furnace temperature adequate for good combustion can be maintained. In summary the DBA furnace design incorporates the basic requirements of good combustion by: lengthening the time for combustion ( the time the solid waste is in the furnace) using slowly rotating roller grates, by directing the combustion gases generated from the solid waste on the first sets of roller grates over the remaining roller grates, and adding secondary air after the initial combustion zone in order to complete the combustion of volatiles in the flue gas. maintaining sufficient temperature - typically 1800 to 2300 F in the primary combustion zone. creating a turbulent combustion zone through the combination of primary air injection from the roller grates, forcing the flue gas initially generated to turn back and mix with the combustion gases generated on the last roller grates, and finally injecting secondary air into the furnace. Procedure to Maintain Proper Combustion Air Supply Levels The following description is provided in accordance with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (5) - procedures for maintaining proper combustion air supply levels. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 As described above, air in excess of the stoichiometric quantity needed to combust the solid waste is supplied to the DBA furnace. The air enters the furnace as primary air through the roller grates and as secondary air through nozzles located above the grates. The flue gas oxygen concentration and carbon monoxide concentration are monitored in the boiler’s final flue gas pass, after all combustion has been completed. In addition the operating conditions of the primary and secondary air fans are monitored. Plant operators, in particular the control room operators (CRO) who actually run the DBA furnace/ boilers are trained and are aware of the requirements for proper combustion, and the relationship between oxygen and carbon monoxide concentrations. The typical range for flue gas oxygen concentration is 5 to 7 % with a carbon monoxide concentration of less than 100 ppm corrected to seven (7) percent oxygen. Each unit has a dedicated continuous emission monitoring system (CEMS). The CEMS data acquisition system will collect and tabulate all the monitors outputs and will alarm in the control room if a parameter, such as flue gas oxygen concentration, is out of the proper range. The CROs monitor various parameters and make adjustments in the controls, as necessary, to maintain proper combustion air levels and overall good combustion of the solid waste. ASH RESIDUE HANDLING The solid waste combustion process results in two ash residue streams: the heavy residue from the roller grates - bottom ash, and the lighter residues from the pollution control system - flyash and scrubber salts. As the solid waste completes the burning process on the roller grates, bottom ash falls through ash chutes into the water filled ash extractor tank, entering below the water line. The water cools the ash and also serves as a seal to prevent air leakage into the furnace. A hydraulic ram extractor, submerged below the water level pushes the ash up an inclined chute (to allow free moisture to drain back into the tank) and onto one of two vibratory slipstick conveyors. The vibratory slipstick conveyors, common to both furnaces, transport the ash the width of the boiler building, and discharge it onto belt conveyors that transport the ash to the ash processing building. The belt conveyor is located inside an enclosed gallery. AIR POLLUTION CONTROL SYSTEM In addition to providing a general description of the air pollution control equipment, this description is provided in accordance with 40 CFR Part 60, Subpart Ea section 60.56a (f) (8) - procedures for minimizing the particulate matter carryover. In the air pollution control system, the light flyash residue that is entrained in the flue gas during the combustion process as well as the acid gases produced during the combustion process are removed. After leaving the boiler, the flue gas passes through Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 a flue gas cleaning system which consists of a dry scrubber followed by a reverse air baghouse. In the scrubber, a lime slurry is injected into the flue gas stream using rotary atomizers (which create a very fine mist.) When the mist contacts the flue gas, the water evaporates which cools the flue gas while the lime particles react with the hydrochloric acid, sulfur dioxide, hydrofluoric acid, etc. removing those pollutants as calcium salts. The water content of the lime slurry can be adjusted to control the temperature of the flue gas existing the scrubber while the lime content of the slurry can be varied to achieve the required sulfur dioxide removal. Activated carbon, for mercury control, is injected into the flue gas duct between the scrubber and the baghouse. Exiting the scrubber, the flue gas flows through duct work into an eight module reverse air, fabric filter baghouse. In the flue gas duct just upstream of the baghouse activated carbon, for mercury control, is injected. In the baghouse the fine particulate flyash, scrubber salts and activated carbon are removed. The reverse air baghouse has a lower air-to-cloth ratio (more cloth for filtering the flue gas) than the typical pulse jet baghouse and significantly lower emissions are expected. The baghouse will utilize woven fiberglass bags with an acid resistant finish. The flow of flue gas is upward and from inside to the outside of bags. When accumulated on the inside of the bags, flyash scrubber salts /unreacted lime and activated carbon create an additional filtering substrate to provide additional removal of unreacted acid gases, as well as very efficient removal of particulates, metals, mercury and trace organics. Each module is equipped with isolation dampers that allows the bag cleaning cycle to cascade from module to module. During the cleaning cycles, the reverse air fan gently blows air in the reverse direction from the flue gas flow and dislodges some of the flyash/ scrubber salts built up on the inside of the bags. The dislodged ash is collected in the baghouse ash hoppers, and then transported in sealed conveyors to the ash processing building where it is wetted with water in a plugmill to prevent fugitive dust emissions, and then discharged onto the loadout belt with the bottom ash for loadout into trucks for transport to the landfill. The fabric filter baghouse is designed to limit particulate emissions from each boiler to 0.01 grains per dry standard cubic foot corrected to 7% oxygen. From the baghouse the flue gas is pulled into the induced draft (ID) fan and then discharged out the stack. The flue gas continuous emission monitoring system is located in the flue gas duct after the baghouse upstream of the ID fan. CONTINUOUS EMISSION MONITORING SYSTEM In addition to providing a general description of the facility's continuous emission monitoring system (CEMS), this description is provided to comply with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (11) - procedures for monitoring MWC unit emissions. Each of the two DBA combustion units is equipped with a dedicated CEMS to measure various constituents of the flue gas exiting each boiler and each pollution control system. Each CEM system includes both extractive and in situ components. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 The extraction system component uses a dilution probe for sample handling and is an integrated system purchased from Enviroplan, Inc. It includes sample probe, sample transport, analyzers, and support hardware. The data acquisition, storage, calculations, and reporting is done by a system purchased from Trace Environmental Systems, Incorporated. Components of the Trace system will also control the sequencing of the automatic calibration feature of the CEMS. Most of the components of the extractive system and the data reporting system are in the CEMS shelter which is located at grade, between the two DBA boiler trains, beneath the scrubbers. Flue gas components measured by analyzers located in the CEMS shelter are: Sulfur Dioxide (SO2), nitrogen oxides (NOX), carbon monoxide (CO), and carbon dioxide (CO2). An extraction dilution probe is located in the flue gas duct just upstream (boiler outlet) of the acid gas scrubber. SO2 and CO2 are analyzed in the flue gas from this sampling point. After the scrubber and baghouse a second extraction dilution probe is located in the flue gas duct just upstream of the ID fan. SO2, NOx, CO and CO2 are measured in the flue gas from this sampling point. Flue gas oxygen (O2) concentration (measured for boiler control purposes only), opacity, furnace temperature, and scrubber outlet temperature are also measured by insitu devices. Measurement signals from in-situ analyzers are transmitted to the data acquisition system (DAS) that is housed in the CEMS shelter. The O2 analyzers are located in the flue gas duct adjacent to the extraction systems' dilution probes, while the opacity analyzers are located in each flue gas duct upstream of the inlet to the ID fan. The furnace temperature thermocouples are installed at the top of the section of the boiler's first pass, two on each side. The scrubber outlet instrumentation is installed in the scrubber outlet duct. Measurement data from the in situ analyzers are transmitted to the Trace system housed in the CEMS shelter. Flow monitors have now been installed in the flue gas duct at the ID fan to measure the flue gas flow rate for each of the DBA boilers. The signal from each flow monitor is transmitted to the DAS and is used in calculating the mass emissions – CO2. The data reporting system is integrated with emissions measurement equipment to digitize, record, and present CEM data. The system also controls the calibration and sample system automation. The system continuously acquires data values and status information from pollutant and process measurements, computes emission, forms averages, detects alarms, provides emission summary reports in hard copy, and allows for easy preparation of regulatory reports. The Trace computer system also receives the analog values from the analyzers and calculates three different averages, forms calibration results and performs data validity checking. The data recording system consists of a personal computer (PC) running Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 Trace’s software. It features menu selections for most data entries. It can detect alarm conditions based upon status inputs. The software can calculate such things as: Emissions on a lb/hr basis, Removal efficiency, Combustion efficiency, Boiler operating days, Excess emission alarms, and Analog alarms in bar chart or strip chart display. Data are collected in monthly data files located in the computer's hard disk drive. The Trace system produces a variety or reports, including data, calibration, and alarm logs. Daily and monthly summary data reports are also available on demand. The Trace system is also helpful in supporting daily quality assurance activities. Routine reports and other procedures can be executed with a single command. The alarm workstation is located in main control room. This PC provides the control room operator with a real-time display of current data, trends and alarm conditions. Alarms will be configured to detect emission exceedances. Normally the operator will receive a warning alarm that a parameter is nearing a permit limit. This alarm will allow the operator time to react and take actions to prevent the excursion. Any permit limit, such as hourly, daily averages, may be checked. FERROUS/NON-FERROUS METAL RECOVERY The DBA facility will recover both ferrous and nonferrous metals from the bottom ash residue and recycle those metals. At this time there are no components in the flyash stream that can be economically recovered. The ferrous/nonferrous metal recovery processes are located in the ash processing building. As discussed previously, the bottom ash is transported from the boilers’ ash extractors to the ash processing building by vibratory conveyors and belt conveyors. In the ash processing building the bottom ash residue is discharged onto a finger sizer to separate bulky items greater than 6 inch size from the ash (less than 6 inch size). The bulky items are conveyed over a drum magnet to recover the ferrous metal, while the undersized ash is conveyed under a second drum magnet to remove the smaller ferrous metals. Both ferrous metal streams from the magnets discharge into a common pile for subsequent loadout and transport to a scrap mill. After the drum magnet, the bulky material not pulled out by the magnet is discharged into a truck for subsequent transport back to the refuse bunker or, if necessary, transport to a landfill, while the remainder of the undersized ash is conveyed to a set of Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 vibratory screens where material greater than 3/8 inch is separated and conveyed over an eddy current system to remove nonferrous metals. The less than 3/8 inch ash that goes through the screen is conveyed to a second eddy current system in order to remove the smaller nonferrous metals. The remaining ash from both eddy current systems is discharged on to conveyor belts, mixed with flyash/scrubber salt and loaded out in trucks for transport to the landfill. RECORDKEEPING AND REPORTING REQUIREMENTS FOR SOLID WASTE FIRED BOILERS This description is provided to comply with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (12) – reporting and recordkeeping procedures. The following information must be recorded in computer readable format and on paper: all 6-minute average opacity levels all 1-hour average sulfur dioxide emission rate s at the outlet of the acid gas control device ( inlet as well if compliance is to be based on percent reduction) all 1-hour nitrogen oxides emission rates all 1-hour carbon monoxide emission rates all 1-hour steam load measurements all 1-hour particulate matter control device inlet temperatures The following average rates must be computed and recorded: All 24-hour daily geometric average sulfur dioxide emission rates (percent reduction , if used) All 24-hour daily arithmetic average nitrogen oxides emission rates All 4-hour block arithmetic average carbon monoxide All 4-hour block arithmetic average steam load levels All 4-hour block arithmetic average particulate matter control device inlet temperatures The following information must be identified: Operating days when any of the average emission rates (percent reduction, if applicable) or operating parameters, specified above, or the 6-minute opacity average exceeds the applicable limit. Also include the reasons for the exceedance and a description of the corrective actions taken. Operating days for which the minimum number of hours of sulfur dioxide or nitrogen oxides emissions or operational data (carbon monoxide, steam load, particulate matter control device temperature) have not been obtained. Also Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 12 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 include the reasons for the exceedance and a description of the corrective actions taken. Times when sulfur dioxide or nitrogen oxides emission or operational data (carbon monoxide, steam load, particulate matter control device temperature) have been excluded from the calculation of average emission rates or parameters and the reasons for excluding data. The results of the daily sulfur dioxide, nitrogen oxides and carbon monoxide CEMS drift tests and the accuracy assessment must be recorded. The results of all annual performance tests conducted to determine compliance with particulate matter, dioxin/furan and hydrogen chloride limits must be recorded. Also for all the dioxin/furan tests, the maximum demonstrated steam load and maximum demonstrated particulate matter control device temperature must be recorded. Semiannually, compliance reports for sulfur dioxide, nitrogen oxide, carbon monoxide, steam load and particulate matter control device temperature must be submitted to EPA and NYSDEC. The report must include: dates, 24-hour block data, 4-hour block data, identification of days when the minimum number of hours was not obtained, identification of times when data was excluded and results of the CEMS daily calibration drift check (only days when drift was excessive). Note Niagara submits this report on a quarterly basis – “Excess Emissions Report”. Semiannually, a report must be submitted for any pollutant or parameter that does not comply with the specified limits. Note Niagara submits this report on a quarterly basis – “Excess Emissions Report”. The annual compliance stack test report must be submitted to the EPA and NYSDEC. ALTERNATE FUELED-FIRED FURNACE/BOILER PROCESS The alternate fuels (i.e. waste wood) are received into the facility and weighed through the scalehouse in the same manner as the solid waste. Waste wood is received either as whole / semi whole pieces (unprocessed) or already shredded. After being weighed in, the trucks with the unprocessed waste wood then proceed to “C” building storage area. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 13 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 On an “as needed basis” the waste wood that is shredded on site is transported from the storage pile to the “C” building storage area. The shredded wood is unloaded and then pushed up into a pile using a bulldozer. “C” building has storage capacity for several thousand tons of alternate fuels. In this storage area, parascrews on either side of an A-frame traverse, under the piled alternate fuels, the length of the building and push the fuel onto a transport system, consisting of two parallel conveyor belt systems (each has three belts in series), that transport the fuel to a surge bin at the top of alternate fuels furnace/boiler. From each surge bin, which can store approximately 20 minutes of alternate fuels at normal boiler feed rates, screws on the bottom of each bin push the fuel down chutes into the furnace. Combustion Process As the alternate fuels enter the furnace, air swept distributor spouts at the bottom of the chutes help propel the alternate fuels into the furnace; the less dense particles burn in suspension and the denser material falls to and burns on the grates. The alternate fuel-fired furnace grate system, rotograte stokers, consists of four parallel trains of traveling grates each carried on two chains which are driven from the rear of the furnace toward the front by a drive and sprocket assembly. Primary air would be introduced below the grates providing the air required for combustion of the alternate fuels on the grate. Holes in the bars allow the proper distribution of primary air to the unburned fuel on the grates. By the time the grate traverses the bottom of the furnace, the combustion process of the alternate fuels on the grate is completed. The ash which remains drops off the grate, through the ash chutes. The siftings ash which falls through he grates passes through the sifting hopper into the same quench tank. Secondary air admitted above the grate would provide additional air for turbulence and combustion of the suspended material as well as the volatile gases from partially combusted material from the grate. The rate at which alternate fuels would be fed to the grate would depend on the demand for steam, the healing value of the fuel being fed, its moisture content, and several other factors. Changes in the feed rate would result in corresponding adjustments to grate speed and air flow to maintain combustion control. Air distribution to the grates and secondary air nozzles would be controlled to ensure burnout of the alternate fuels. Auxiliary burners would be operated as necessary at the following times: (1) furnace start-up prior to introduction of alternate fuels; (2) furnace shut-down; Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 14 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM (3) Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 During periods of malfunction. Air Pollution Control To control acid gases (sulfur dioxide and hydrochloric acid) hydrated lime is injected directly into the furnace. Urea is also injected into the furnace in order to control nitrogen oxide emissions. In addition activated carbon is injected into the flue gas at the outlet of the economizer in order to control trace organic compounds. The calcium salts of the acid gases and the activated carbon, as well as, the flyash produced during the combustion process are removed in the electrostatic precipitator on collector plates. Periodically, the collector plates are rapped and the flyash falls down into the flyash hoppers and into sealed drag chain conveyors which transport the flyash to an ash silo. Ash Residue Handling and Disposal In the bottom ash quench tank, a drag chain pulls the bottom ash out of the tank and discharges it into the ash hopper. When the ash hopper is full, it is taken to the tipping floor and dumped into the DBA refuse bunker. This ash is then processed through the DBA furnaces. From the ash silo, the flyash goes through a rotary feeder into a pugmill where the flyash is wetted to prevent dusting. From the pugmill the wetted flyash drops into the ash truck that transports the ash to the landfill. Continuous Emission Monitoring System – Alternate Fuel Fired Furnace/Boiler The alternate fuel -fired furnace/boiler system is equipped with a dedicated CEMS. The CEMS sampling system is an extractive type, located in the stack, and the monitors include carbon monoxide, sulfur dioxide, nitrogen oxides, and oxygen. In addition, there is an in situ stack flue gas opacity monitor. A Trace Environmental System data acquisition system (DAS) is integrated with the emissions measurement equipment to digitize, record, present CEM data. The system also controls the daily calibration checks, and sampling systems purges and sampling. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 15 of 29 Doc OM-1 Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Major Modifications to the Introduction March 2009 The “Recordkeeping and Reporting” section on page 12 was revised to reflect the type of data that is recorded in the computer March 2011 The “Continuous Emission Monitoring System” section on page 8 was revised to include the DBA boilers’ new flue gas flow monitors. March 2012 The “Solid Waste Receiving, Storage and Handling” section, on page 3, was revised to reflect the changes made to the liquid waste storage tanks and pumping system. Appendix 1 was added Combustion Unit - Basic Combustion Theory Applicable to a Municipal Waste April 2013 The “ferrous / nonferrous metal recovery” was modified to reflect the new nonferrous process for recovering the less than 3/8 inch metal. March 2014 The system description for the RTIF was added. Wood staging area text was removed as that area is no longer used. May 2014 Minor QA/QC updates. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 16 of 29 Doc OM-1 Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM APPENDIX 1 COMBUSTION THEORY Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 17 of 29 Doc OM-1 Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Basic Combustion Theory Applicable to a Municipal Waste Combustor Unit THE FUEL - Municipal Solid Waste (MSW) Combustion is a process in which fuel combines rapidly with oxygen to produce heat and product gases. Figure 1 illustrates the process. Fuel Flue Gas Carbon, Hydrogen, Oxygen Nitrogen Carbon Dioxide Water Combustion Air Nitrogen Oxygen Heat The fuel is municipal waste, which contains a mixture of paper, plastics, wood, yard waste, food, textiles, and various other materials. The combustible part of these materials consists primarily of carbon and hydrogen. Most of these materials also contain oxygen. MSW is composed of volatile fractions - which burn as a gas, and fixed carbon - which burns as a solid. Most of the materials in MSW are mixtures of many different chemical compounds. For example, wood contains thousands of different chemical substances. However, most of the important combustion reactions can be understood by just considering a few of the major compounds in the waste stream. By far, the most important elements involved in MSW combustion are C – Carbon H – Hydrogen Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 18 of 29 Doc OM-1 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 O – Oxygen These elements are combined in many different compounds which are termed hydrocarbons, because they contain large amounts of hydrogen and carbon. These hydrocarbons are the primary sources of energy in the fuel. When carbon or hydrogen reacts with oxygen, the reaction is called exothermic, meaning that heat is produced by the reaction. Two primary reactions occur during combustion of any hydrocarbon fuel: carbon combines chemically with oxygen to produce carbon dioxide and heat C + O2 CO2 + heat hydrogen combines with oxygen to produce water vapor and heat. 4H + O2 2H2O + heat The carbon dioxide and water vapor leave the furnace as flue gas. In addition to carbon, oxygen, and hydrogen, MSW contains a number of other elements including Chlorine and Sulfur Much of the chlorine combines with hydrogen to produce hydrogen chloride, a highly reactive chemical which becomes hydrochloric acid when combined with water. 2Cl + H2 2HCl Sulfur combines with oxygen to form sulfur dioxide, which dissolves in water to form sulfuric acid. S + O2 SO2 Alkaline metals These materials - which include sodium, potassium, calcium, and magnesium - are present in many waste materials including wood and wood products. They occasionally show up in a pure form. They are highly reactive and combine readily with oxygen to form solid particles, but also with chlorine to Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 19 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 form salts which melt or vaporize in the high temperature combustion regions. These salts can also exist as corrosive liquids on boiler tube surfaces. In pure form, they are extremely combustible, easily ignited, and can react with water or steam to produce hydrogen. Heavy metals These elements, such as lead, zinc, and cadmium, are present in a variety of materials including electronic equipment, paints, and tires. These metals react with chlorine to form metallic salts which are corrosive to boiler tubes. In addition to the materials described above, trash also contains some things that don’t burn, such as water, glass, metal, and dirt. These materials absorb heat from the burning refuse and are known as heat sinks. Water is the most important of these materials for two reasons: 1. There can be a lot of water in waste. MSW is typically about 15% water, but after a lot of rain that value can be much higher, and 2. Water absorbs a lot of energy as it heats up and turns to steam. When a pound of water and a pound of metal enter the furnace in the fuel, the water takes with it about 30 times as much heat as the metal when it leaves the boiler. THE STAGES OF COMBUSTION FOR MSW Most fuels are relatively pure materials, and burn in a consistent and repeatable manner. Unlike these fuels, MSW is a mixture of many different materials and each of these affects the overall combustion process. Some important aspects of MSW combustion are: 1. 2. 3. Moisture content and fuel drying Volatile content and devolatization Fixed carbon combustion, or burnout MSW combustion involves all the mechanisms described above, and occurs in several stages, with the duration of each stage depending on the particular fuel. These stages include: Heating and drying. The fuel must be heated and dried before it can burn. The heat is supplied by the active combustion of nearby fuel, and in some cases by preheated primary combustion air. Clearly, fuels with higher water content require more energy to dry. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 20 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 Devolatization. As the fuel heats up, it begins to break down chemically. During this process the volatile fraction of the waste is released into the gas stream. These volatile materials include the hydrogen and some of the carbon contained in the fuel. They are emitted as heat vaporizes the lighter compounds, and breaks apart the chemical bonds within heavier hydrocarbon molecules to release combustible gases. The gases evolved from the waste include a wide range of light hydrocarbons, including methane, ethane, and numerous other compounds. Ignition. The light, flammable gases evolved from the heating waste move into the primary air streaming through the bed, and are ignited when they reach sufficient temperature or contact an existing flame. Burnout. The remaining char burns slowly in the bed as the surface is exposed to oxygen in the primary air. Different components of the waste stream behave differently. For example, most light plastics such as ethylene are completely volatile, so that the entire combustion process occurs in the gas stream above the bed and no char or ash is left behind. Other materials such as wood have a high percentage of both volatile materials and char, meaning that significant combustion occurs both above and within the bed. THE COMBUSTION PROCESS Burning MSW is more complicated than burning traditional fuels for several reasons, which will be described shortly. For combustion to take place, there are three requirements: Fuel - a combustible material Heat, or a source of ignition Oxygen, typically provided by air If any one of the three is removed, the combustion process stops. The three requirements for combustion are often illustrated using the well-known combustion triangle Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 21 of 29 Doc OM-1 Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Heat Oxygen Fuel Changing any component of the combustion triangle can have an effect on one or both of the other components. For example, adjusting the fuel OR oxygen (air) side of the combustion triangle will affect the heat produced. It’s important to not only know what is needed for combustion to take place, but also how they interact. Providing sufficient air, heat, and fuel will allow combustion to take place. However, the operator must ensure that combustion is proper and environmentally compliant as well. Three things help ensure proper combustion: Time, Temperature, and Turbulence – often described as the “three T’s”. These factors work together, to ensure that combustion is complete: Time: All chemical reactions take time to occur. Enough time must pass to allow the chemical reactions to complete. Temperature: Chemical reactions proceed faster at higher temperatures, therefore the temperature must be hot enough to ensure their completion. Turbulence: Fuel and air must be well-mixed to ensure that all the fuel is burned. How can the operator use and adjust the 3 T’s to aid in burning MSW? By looking at each on a basic level, relating to the primary and secondary combustion: Time: Give the solid fuel enough time in the primary combustion zone. The more retention, the better chance the surface area of the fuel will be exposed to oxygen. If the fuel moves through the primary combustion zone too quickly, the Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 22 of 29 Doc OM-1 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 likelihood of incomplete combustion increases. In the secondary zone, residence time is primarily established by the boiler design. Temperature: The fire must be hot – not only to sustain its own combustion, but to aid in the drying out and ignition of new fuel, and to ensure that all reactions are completed in the furnace volume above the grate. Turbulence: Turbulence is needed on the primary combustion level to properly mix and agitate the fuel, continually exposing the surface area to oxygen. On the secondary combustion level, proper secondary air penetration is needed to promote better mixing for the chemical reactions to complete. Much like the three sides of the combustion triangle, the 3 T’s also interact. For example, if the turbulence is insufficient, it would be difficult to adjust the time and temperature to compensate. A good operator not only understands the individual elements of the Combustion Triangle and the “3 T’s”, but also understands collectively how each piece affects and interacts with the others. COMBUSTION AIR A good combustion process requires that the fuel interact closely with the oxygen at a molecular level. Because of the nature of MSW, it is very difficult to ensure this fuel-toair contact, and it is also very difficult to achieve good air/fuel mixing. The air delivered to the furnace doesn’t readily mix with the fuel, as it would in a gas- or oil-fired boiler. Referring again to the combustion triangle, to burn MSW we control the “heat” part of the triangle (the output) by adjusting the “air” and “fuel” (the inputs): HEAT AIR FUEL Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 23 of 29 Doc OM-1 Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Excess Air The amount of air supplied to the combustion process is critical. For any amount of fuel, the amount of air required for complete combustion, with no fuel or oxygen left over is call the theoretical air rate. This would be 0% excess air. Combustion normally occurs with excess air, meaning more air is supplied than is chemically necessary to burn all of the fuel. Thus, oxygen is left over in the flue gas. If a combustion process has insufficient air to completely burn the fuel, there would be fuel left in the flue gas stream, in the form of CO, soot (carbon particles), and hydrocarbons. The next figure illustrates an important point regarding air and fuel: The flame temperature depends on the air ratio. With insufficient air there is not enough oxygen to burn all the fuel and this limits the temperature. With excess air heat is carried away by the surplus air, cooling the flame. At the stoichiometric point, the maximum flame temperature is reached because there is exactly enough air to burn all the fuel without any excess. Again, this is the theoretical air rate, or 0% excess air. Stoichiometric Combustion Flame Temperature Maximum temperature occurs when there is Temperature Temperature is is limited limited because because there is not energy is used enough air to to heat up burn all the Insufficient Theoretical Excess Air Air Air Air Flow Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 24 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 The figure above again illustrates the interactions of different sides of the combustion triangle – in this case, air affecting heat. MSW combustion always utilizes excess air. Clearly, the diverse nature of MSW presents an extreme challenge in mixing all of the combustible materials with the oxygen. We must add extra air to compensate for this inability to obtain “the perfect mix”. However, simply adding additional air to ensure that all of the combustible materials are adequately exposed to oxygen is generally not sufficient. The above figure illustrates this as well. Combusting fuel with just a small amount of excess air results in extremely high temperatures. These temperatures would be above the melting point of many materials in the bed, which results in excessive furnace slag and bed clinkering. This is also an illustration of how air can be a heat sink. Unlike moisture or noncombustible materials in the fuel, this is a heat sink that the operator can control. Air is a mixture of many different gases, but is mostly nitrogen and oxygen. Combustion requires oxygen, which is about 21% of the air. The rest of the air is not part of the combustion process, but merely passes through the furnace and carries heat away as it leaves. This excess combustion air is that heat sink. The excess air rate can also affect emissions rates for carbon monoxide (CO) and nitrogen oxides (NOx). Carbon monoxide (CO) is a toxic pollutant known as a product of incomplete combustion because it is a partially oxidized form of carbon. This compound is produced under two conditions: In a fuel-rich combustion zone where there is not enough oxygen to combine with all the carbon (sometimes referred to as hot CO) In a low temperature area where the combustion temperature is too low to complete the chemical reactions (sometimes referred to as cold CO). NOx (a general description for two similar compounds – NO and NO2) is an oxidized form of nitrogen, which contributes to acid rain and ground-level ozone. It is formed when nitrogen combines with oxygen at high temperatures in the combustion process. Depending on the primary source of the nitrogen, it is described as either Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 25 of 29 Doc OM-1 Revision Date: 5/8/14 Review Date: 5/8/14 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Fuel NOx, in which the primary source of the nitrogen is the fuel itself, especially at certain times of the year. Green wastes such as grass clippings, Christmas trees, and yard waste are high in nitrogen. Thermal NOx, in which the primary source of nitrogen is the combustion air. Relative Emissions Rate The following figure illustrates the impact of temperature and excess air rate on emissions of CO and NOx. The NOx emissions in a Municipal Waste Combustor generally don’t vary as much with temperature as this graph illustrates, because virtually all NOx formed in a waste combustion process is fuel NO x. This is because temperatures are generally not high enough to produce significant amounts of thermal NOx. CO is high because there is not enough oxygen to completely burn the fuel NOx is high because of the high combustion temperature CO is high because the excess air cools the flame and stops combustion before it is complete CO NOx NOx is low because the temperature is low Insufficient Air CO is low because enough air is supplied to completely burn the fuel, but without excessive cooling Theoretical Air NOx is low because the temperature is low Excess Air Air Flow Combustion air is typically provided in two forms: primary air and secondary air. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 26 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 Primary Combustion Air Proper flow and distribution of Primary Combustion Air is critical to maintaining boiler load, firebox temperatures, emissions, and complete combustion. Primary air is supplied below the fuel bed, and passes through the burning fuel. The distribution of this air below the bed is very important to the combustion process. Depending on the combustion technology being used, the operator may be able to adjust the primary air distribution, while in other cases it is established during startup or tuning of the boiler. As the fuel goes through the combustion stages, it also moves along the grate from the feeding area to the ash discharge area. With some technologies the motion of the refuse bed is very uniform, with fuel fed at one end, and moved steadily toward the discharge end. With most technologies, however, the bed does not move through distinctive stages because either the new fuel gets distributed over a wide area of the bed, or grate motion causes continuous mixing of new fuel with material that has been in the bed for some time. In all cases, however, there is a general trend for newer fuel to be near one end of the bed and burned out ash to be at the other end. With this distribution of the combustion stages, the goal is to match the primary combustion air to the combustion process occurring in each region. The amount of air in each zone affects the combustion rate and gas velocity. Velocity, in turn, affects particulate carryover from the bed. Primary Air Flow in the Combustion Regions. Combustion within the primary combustion regions can generally be described as follows. Note that there is no clear line between regions, but instead a continuous transition from drying to combustion to burnout. Furthermore, the transitions between zones vary depending on fuel conditions and combustion settings. Drying region. Within this region, the fuel is heated and dried to drive out moisture. With high moisture content fuels, this region may be very apparent when looking at the grate, with little combustion taking place. With very dry fuels, it may be difficult to even detect, as the fuel begins burning almost immediately upon entering the furnace. If moisture is low or airflow is too high, the fuel will quickly ignite and burn intensely, quickly releasing much of its heat within a very small volume. This leads to excessive slagging of the furnace and may damage the stoker and feeding equipment. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 27 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 If the airflow is too low, or moisture very high, the fuel will not adequately dry out, preventing ignition. This situation may ultimately require manual intervention to agitate and expose air to the fuel. Eventually the fuel will ignite, but combustion intensity may be extremely high when this finally occurs. Main Combustion Zone. In this region, the volatile fraction of the fuel is driven into the gas stream where it rapidly burns, using up the available oxygen. Gases leaving this region of the bed have little to no oxygen, and very high contents of combustible gases, including light hydrocarbons and CO. Excessive airflow will cause rapid combustion within a small region, leading to excessive temperatures. It is also likely to cause thin refuse beds, which leads to high flue gas velocities and increased particulate carryover. Insufficient airflow will not allow complete combustion within the region, causing long fires, high unburned content in the ash, and increased likelihood of ash discharger pluggage. Burnout Zone. Primary combustion is slow in this zone, as the fixed carbon burns off. Most of the combustion is complete well before the solids leave the grate, but sufficient air must be provided to ensure that any remaining carbon is completely burned. Thus, the gases leaving this region are relatively high in oxygen content. Excessive airflow will cool the fire in this zone, causing high CO levels. Insufficient airflow will not allow the combustion to complete, resulting in high unburned content in the ash and may lead to ash discharger pluggage. Proper primary air flow and distribution is achieved by taking many things into consideration, including but not limited to: CO and NOx emissions Combustion/furnace temperatures Appearance of the fuel bed ( thick or thin, lumpy or uneven) Appearance of the fire (bright or dull, proper fire line) Unburned combustibles Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 28 of 29 Doc OM-1 COVANTA NIAGARA O&M Manual/ECOM Rev. No. 8 Revision Date: 5/8/14 Review Date: 5/8/14 Secondary Combustion Air Proper Secondary Air flow, or Overfire Air flow, is critical for emissions and control of the fire. As noted earlier, gases coming from the combusting refuse bed are highly stratified: Gases leaving the drying zone are very high in moisture content, and may contain high levels of oxygen and low levels of combustible gases - particularly with wetter fuels. Gases leaving the main combustion zone form a reducing environment with virtually no oxygen and very high concentrations of combustible gases. All available oxygen has been consumed in the primary combustion process, Gases leaving the burnout zone are high in oxygen. Secondary air creates a very turbulent mixing zone to thoroughly mix together these stratified streams leaving the refuse bed. It also provides additional oxygen to ensure that all combustible gases released by the fuel are completely burned before leaving the furnace. In order to be effective, secondary air must be introduced to the furnace at a high velocity. This gives the air enough momentum to penetrate deeply into the furnace, ensuring that the reacting gases are thoroughly mixed. By completing combustion of these rising gases, the overfire helps control flame tip height, which can reduce corrosion rates in the boiler. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 29 of 29 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual SECTION A COVANTA NIAGARA, L.P. NIAGARA RESOURCE RECOVERY FACILITY APPLICABLE REGULATIONS MUNICIPAL SOLID WASTE COMBUSTION UNITS Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual SECTION A COVANTA NIAGARA APPLICABLE REGULATIONS A.1 EMISSION STANDARDS AND GUIDELINES A.1.1 DBA UNITS A.1.2 NEW SOURCE PERFORMANCE STANDARDS A.1.3 EFW BOILER #1 / EFW BOILER #2 A.1.4 MISCELLANEOUS PERMITS A. 1.5 MAJOR REVISIONS TO SECTION A Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 11 Doc OM-A COVANTA NIAGARA O&M/ECOM Manual A.1 Rev. No. 4 Revision Date: 3/3/14 EMISSION STANDARDS AND GUIDELINES The U.S. EPA has established emission standards (regulations, codified as 40 CFR 60, Subpart Ea, as well as guidelines, codified at 40 CFR 60, Subpart Cb – Maximum Achievable Control Technology (MACT) requirements) that are applicable to sources combusting municipal solid waste and nonhazardous industrial waste (NHIW). The NYSDEC has taken the MACT guidelines and incorporated those guidelines into a State Implementation Plan (SIP). U.S. EPA has approved New York’s SIP. The emission standards applicable to the DBA furnace/boilers at the Covanta Niagara facility are presented below. This description is provided in accordance with 40 CFR Part 60, Subpart Cb Section 60.56a (f) (1) - pursuant to the Clean Air Act Amendments of 1977 and 1990. All federal emission standards and NYSDEC requirements are consolidated in the Title V Air permit and the Solid Waste Facility Part 360 permit. In Section 111 of the Clear Air Act Amendments of 1977 (PL 05-11), the U.S. EPA Administrator was directed to publish a list of stationary sources that may reasonably be anticipated to endanger public health or welfare and to publish proposed regulations which establish federal standards of performance for new sources within each category. The standards of performance are to reflect the degree of emission control achievable by the application of the best technological system of continuous emission reduction that has been adequately demonstrated. The Administrator must review and revise the standards, if appropriate, every four years. NSPS for various source categories are published at Title 40 Part 60 of the Code of Federal Regulations (40 CFR 60). A.1.1. DBA UNITS The New Source Performance Standards (NSPS) for new, modified and reconstructed municipal waste combustors (MWC) were promulgated in the Federal Register, dated February 11, 1991 under Subpart Ea. The intent of this NSPS was to require new MWCs constructed before September 20, 1994 to control emissions to the level achievable by applying the best demonstrated system of continuous emission reduction, considering costs, non air quality health and environmental impacts and energy requirements. The Subpart Ea NSPS are summarized in Table A-1. The U.S. EPA subsequently promulgated revised rules to address specific emission limits for lead, cadmium and mercury, as well as updating requirements to comply with MACT requirements. These rules were promulgated on December 19, 1995. Subpart Eb was for new construction and is not applicable to the Niagara facility. Subpart Cb provided emission guidelines for existing facilities and is applicable to the DBA Units. At the time of promulgation, Subpart Ca was removed and reserved and thus does not apply to the facility. The applicable requirements of Subpart Cb to the Niagara Facility are summarized in Table A-2. New York incorporated the Subpart Cb emission (MACT) guidelines into the state SIP. The Niagara facility complies with these MACT guidelines at this time. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual Note: The nitrogen oxide and mercury limits established for the Covanta Niagara facility are more stringent compared to the standards and guidelines shown in Table A - 1 and A - 2. Covanta Niagara’s limits are: Nitrogen Oxide 150 ppmc 24-hour block average Mercury 28 ug/dscm or 85% removal no specific averaging period A.1.2 NEW SOURCE PERFORMANCE STANDARDS Each DBA unit is equipped with two ignition burners and two auxiliary burners that are capable of firing either natural gas or low sulfur distillate fuel oil. The total heat input rate for these four burners is approximately 260 MMBtu/hr. However, these units are not subject to NSPS regulations under either Subparts Da or Db. Subparts Da and Db are applicable to steam generating units which combust fuel to produce steam or heat water. The ignition and auxiliary burners will be operated as necessary to comply with the temperature and time requirements of the Niagara facility’s NYSDEC permit and are not considered steam generating units. A.1.3 EFW #1 BOILER / EFW #2 BOILER EFW Boilers #1 and #2 are designated as very large boilers per 6 NYCRR 227-2; the presumptive NOx RACT limits are contained in 6 NYCRR 227-2.4(a). The current and future presumptive NOx RACT limits for EFW #1 Boiler and EFW #2 Boiler, as provided in 6 NYCRR 227-2.4(a), are summarized in Table A-3. Phase II NOX RACT for EFW #1 Boiler and EFW #2 Boiler were established by NYSDEC following review of a NOX RACT Plan submittal. The applicable NOx limitations are summarized in Table A-4. EFW Boiler #1 is a Gas 1 boiler subject to the Major Source Boiler MACT Rule, (40 CFR Part 63, Subpart DDDDD). There are no numerical emission standards; however, a one-time energy assessment and annual tune-ups must be completed. EFW Boiler #2 is an existing Energy Recovery Unit which will be subject to the Commercial and Industrial Solid Waste Incinerator (CISWI) MACT Guidelines (40 CFR 60, Subpart DDDD) as long as it burns any solid waste. Solid waste approved for combustion by the NYSDEC as alternative fuels in this unit includes creosote treated wood and construction & demolition sourced wood that has not been documented to meet EPA’s Non Hazardous Secondary Materials rule legitimacy criteria. The final compliance date will be either three years after EPA’s approval of the SIP or FIP implementing the guidelines, or February 7, 2018, whichever is earlier. At this time it is expected that the final Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 11 Doc OM-A COVANTA NIAGARA O&M/ECOM Manual Rev. No. 4 Revision Date: 3/3/14 compliance date will be February 7, 2018. Applicable emission standards are summarized in Table A-5. A.1.4 MISCELLANEOUS PERMITS The Covanta Niagara facility also operates under several other permits. They are as follows: Solid Waste Facility Permit Covanta Niagara operates under Solid Waste Management, Article 27, Title 7, Permit No. 9-291100113/00023, for the delivery, unloading, processing, and combustion of solid waste. Other operating parameters in this permit include: emergency reporting, approved waste, unacceptable waste, approved design capacity, refuse storage, unscheduled shutdowns, sampling notification, ash loading, waste disposal, and reporting requirements. Wastewater Discharge Permit Discharge Permit No. 32 from the City of Niagara Falls allows the plant to discharge facility storm and wastewater, stormwater in a controlled manner from the RTIF site, and RTIF wash waters into the city’s sanitary sewer system for subsequent treatment at the publicly owned wastewater treatment plant. The permit has various sampling and analyses requirements that the plant complies with. State Pollutant Discharge Elimination System (SPDES) Permit Discharge Permit No. NY 0106259 permits the discharge of stormwater runoff to the Niagara River. The permit has various sampling and analyses requirements that the plant complies with. Petroleum Bulk Storage Registration Certificate Above ground storage tanks that contain gasoline, diesel fuel, and No. 1 fuel oil are registered under certificate number 9-221279. Hazardous Substance Bulk Storage Registration Certificate Tanks (above ground) containing sulfuric acid, sodium hydroxide (caustic), sodium hypochlorite, and several boiler feed water chemicals are registered under certificate number 9-000239. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 11 Doc OM-A COVANTA NIAGARA O&M/ECOM Manual A.1.5 Rev. No. 4 Revision Date: 3/3/14 MAJOR REVISIONS TO SECTION A November 2005 Name change to Covanta from American Ref-Fuel January 2008 Section A.1.3 and Table A-3 added. March 2011 Section A.1.3 modified to reflect that the EPA has issued new regulations that apply to EFW boiler No. 2. November 2013 Reference to 40 CFR 60, Subpart Ea has been changed to Cb. March 2014 NOX RACT requirements applicable to EFW #1 and EFW #2 Boilers was added. Update to include Solid Waste Facility Permit requirements and Discharge Permit #32 to accommodate the Rail Transfer Intermodal Facility was included. Major Source Boiler MACT requirements for EFW Boiler #1 were added and CISWI MACT requirements for EFW Boiler #2 were amended. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual TABLE A-1 INITIAL USEPA EMISSION STANDARDS APPLICABLE TO THE DBA UNITS AT THE COVANTA NIAGARA FACILITY NSPS SUBPART EA REGULATED POLLUTANT BY CATEGORY MWC ACID GASES SULFUR DIOXIDE (SO2) HYDROGEN CHLORIDE (HCL) MWC M ETALS PARTICULATE MATTER (PM) OPACITY MWC ORGANICS DIOXINS/FURANS CARBON MONOXIDE (CO) NITROGEN OXIDES (NOX) ALL MWC EMISSIONS GOOD COMBUSTION PRACTICE (GCP) MONITORING REQUIREMENTS EMISSION LIMIT AVERAGING PERIOD (1) 80% REDUCTION OR 30 PPMV ` (1) 95 % REDUCTION OR 25 PPMV DAILY GEOMETRIC AVERAGE 0.015 GR/DSCF (34 MG/DSCM) 10 PERCENT NONE SPECIFIED 6-MINUTE AVERAGE 30 NG/DSCM 100 PPMV 180 PPMV ((2) 1-HOUR MINIMUM SAMPLING TIME 4-HOUR MINIMUM SAMPLE TIME PER TEST RUN 4-HOUR BLOCK AVERAGE 24-HOUR BLOCK AVERAGE MAXIMUM LOAD LEVEL DEMONSTRATED DURING DIOXIN/FURAN PERFORMANCE TESTS MAXIMUM PM CONTROL DEVICE INLET TEMPERATURE DEMONSTRATED DURING DIOXIN/FURAN PERFORMANCE ASME OPERATOR CERTIFICATION SITE SPECIFIC OPERATING MANUAL NOX: CEMS 24 HR ARITHMETIC MEAN SO2: CEMS OPACITY: COMS CO, LOAD, TEMPERATURE: CEMS 24 HR GEOMETRIC MEAN 6 MINUTE AVERAGE 4-HOUR BLOCK AVERAGE TEST NOTES: GENERAL – ALL POLLUTANT CONCENTRATIONS CORRECTED TO 7% 02 ON A DRY BASIS. (1) WHICHEVER REQUIREMENT IS LESS STRINGENT MAY BE USED. (2) TOTAL DIOXINS AND FURANS (NOT TOXIC EQUIVALENTS). Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual TABLE A-2 EMISSION GUIDELINES APPLICABLE TO THE DBA UNITS AT THE COVANTA NIAGARA FACILITY Regulated Pollutant by Category MWC Acid Gases Sulfur Dioxide (SO2) Hydrogen Chloride (HCl) MWC Metals Particulate Matter (PM) Opacity Cadmium (Cd) Lead (Pb) Mercury (Hg) MWC Organics Dioxins/furans Carbon Monoxide (CO) Nitrogen Oxides (NOX) Fugitive Ash Emissions All MWC Emissions Good Combustion Practice (GCP) Emission Guideline Subpart Cb Emission Limit (1) 75% reduction or 29 ppmcv 95% reduction or 29 ppmcv (1) Daily geometric average 1-hour minimum sampling time 27 mg/dscm 10% and annual test 40 g/dscm 440 g/dscm 85% reduction or 80 g/dscm(1) None specified 6-minute average None specified None specified None specified 30 ng/dscm(2) 4-hour minimum sample time per test run 4-hour block average 24-hour block average 1-hour test runs 100 ppmcv 205 ppmcv Visible emissions less than 5% of time from ash transfer systems except during maintenance and repair activities. Monitoring Requirements Averaging Period Site specific operating manual EPA or State MWC Operating training course ASME provisional and full certification MWC load level not to exceed 110% of maximum load demonstrated during dioxin/furan performance tests. PM control device inlet test flue gas temperature not to exceed 30º F above maximum temperature demonstrated during dioxin/furan performance tests. CO, load, PM control device 4-hour block average inlet temperature CEMS 6-minute average Opacity: COMS 24-hour geometric mean SO2:: CEMS 24 hours arithmetic mean NOX: CEMS Notes: General - all pollutant concentrations corrected to 7% O2 on a dry basis. (1) Whichever is less stringent may be used. (2) Total dioxins and furans not (not toxic equivalents). Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual TABLE A-3 SUMMARY OF PRESUMPTIVE NOX RACT LIMITS FOR EFW BOILERS #1 AND #2 AT COVANTA NIAGARA Emission Source EFW EFW EFW (1) (2) (3) (4) Size (MMBtu/hr ) Presumptive NOx RACT Limit (lb/MMBtu) (1) (2) Current Phase II (3) Fuel Averaging Period Natural #1 440 0.20 0.08 Gas 24-hr daily avg. (ozone Natural season) #2 440 0.20 0.08 Gas 30-day rolling avg. (nonozone season) Waste #2 440 0.33 (4) Wood Effective through June 30, 2014 Effective on July 1, 2014 Per 6 NYCRR 227-2.6(b) for units equipped with a continuous emissions monitoring system (CEMS) Case-by-Case Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual TABLE A-4 SUMMARY OF PHASE II NOX RACT PLAN FOR COVANTA NIAGARA EFW BOILERS #1 AND #2 Emission Source Compliance Option Phase II NOx RACT(1) EFW #1 Boiler – natural Meet Presumptive Limit 0.08 lb/MMBtu(2) gas EFW #2 Boiler – natural Meet Presumptive Limit 0.08 lb/MMBtu(2) gas only EFW #2 Boiler – alternative (3) fuel with or without natural Case-by-Case 0.25 lb/MMBtu gas (1) Compliance with the Phase II limits must be demonstrated on and after July 1, 2014. (2) Compliance based on a block 24-hour average during both the ozone season (May 1 – September 30) and the non-ozone season (October – April). (3) Compliance based on a block 24-hour average during the ozone season and a 30-unit operating day basis for the non-ozone season. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 11 Doc OM-A Rev. No. 4 Revision Date: 3/3/14 COVANTA NIAGARA O&M/ECOM Manual TABLE A-5 EMISSION LIMITS AND OPERATING LIMITS APPLICABLE TO EFW BOILER #2 AT THE COVANTA NIAGARA FACILITY Regulated Pollutant Emission Guideline Subpart DDDDD Emission Limit (a) Averaging Period Particulate Matter (filterable) 11 mg/dscm Stack test Hydrogen Chloride (HCl) 0.20 ppmv Stack test Sulfur Dioxide 7.3 ppmv 30-day rolling avg Carbon Monoxide 260 ppmv 30-day rolling avg Nitrogen Oxides 290 ppmv 30-day rolling avg Mercury 2.2 ug/dscm Stack test Lead 14 ug/dscm Stack test Cadmium 1.4 ug/dscm Stack test Dioxins/Furans (total) 0.54 ng/dscm Stack test Dioxins/Furans (toxic equivalents) 0.12 ng/dscm Stack test Fugitive Dust 5% opacity Visible emissions test (a) (b) All emission concentration limits are corrected to 7% oxygen, dry basis. Must meet either the total or toxic equivalents limit. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 11 Doc OM-2 Rev. No. 6 Revised Date: 3/07/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 2 Covanta Niagara L.P. Niagara Resource Recovery Facility ASH MANAGEMENT PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 13 Doc OM-2 Rev. No. 6 Revised Date: 3/07/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 2 COVANTA NIAGARA ASH MANAGEMENT PLAN 2.1 Introduction 2.2 Ash Generation and Handling 2.2.1 DBA Solid Waste Mass Burn Furnace/Boiler Ash Generation and Handling 2.2.2 Alternate Fuel Fired Furnace/Boiler Ash Generation and Handling 2.3 Maintenance and Housekeeping 2.4 Quantity of Ash 2.5 Beneficial Use of Ash 2.6 Ash Storage Capacity 2.7 Ash Transportation 2.8 Ash Residue Landfill 2.9 Ash Residue and Bypass Waste Disposal Contract Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 13 Doc OM-2 Rev. No. 6 Revised Date: 3/07/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 2 ASH MANAGEMENT PLAN LIST OF ATTACHMENTS ATTACHMENT NUMBER 2-1 TITLE Major Revisions to Ash Management Plan Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 13 Doc OM-2 Rev. No. 6 Revised Date: 3/07/14 COVANTA NIAGARA O&M/ECOM Manual ASH MANAGEMENT PLAN The ash management plan is provided to comply with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (10) - procedures for handling ash, and to comply 6 NYCRR Part 360-3.5(f). 2.1 INTRODUCTION Covanta Niagara’s resource recovery facility combusts refuse in two Deutsche Babcock Anlagen (DBA) mass burn furnace boilers. Refuse is the primary fuel used in these two furnace boilers. The facility receives and combusts only household wastes delivered by over the road trucks or containerized via the RTIF, commercial wastes and NYSDEC approved non-hazardous industrial wastes (NHIW). No hazardous wastes are accepted at the facility. In addition, the facility also combusts alternate fuels (i.e. waste wood) in a third furnace/boiler. To assure that no hazardous wastes enter the facility, the following steps have been implemented: Signs (see Section 1 - Waste Control Plan) at the entrance to the facility, scale house and tipping floor state which wastes are prohibited from the facility. All existing contracts clearly state that hazardous wastes cannot be accepted at the facility. A waste inspection program, where a minimum of two (2) incoming loads are inspected each day. See Section 1.10 of the Waste Control Plan for details with respect to the truck inspections. 2.2.1 DBA SOLID WASTE MASS BURN FURNACE/BOILER ASH GENERATION AND HANDLING A by-product from the combustion of refuse is an ash residue consisting of a heavy fraction - bottom ash and a light fraction - flyash. The DBA boilers are built with a grate system consisting of six roller grates that are on an incline of approximately 20 degrees from the first to last roller grate. At the back of the furnace, refuse is charged into a refuse chute where it acts as an air lock to impede Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 entry of tramp air from the feeding system into the furnace. A ram feeder pushes the refuse from the bottom of the refuse chute onto the uppermost roller grate. Refuse tumbles and mixes as it travels over the grate system. Primary air for combustion is blown into each of the roller grates, and spaces between the bars allow the combustion air to penetrate the refuse. As each roller rotates forward, refuse slowly moves towards the next lower roller. Between each of the rollers a transition piece causes the refuse to tumble and roll, an action that exposes previously concealed unburned refuse to the fire. The DBA grate system is designed in this manner to allow thorough burnout of all waste charged to the furnace. While on the first roller and at least part of the second roller, refuse is dried by hot combustion gases. The dried refuse ignites as it crosses the second roller and burns thoroughly as it travels across the third and fourth rollers; occasionally, wet or low heat content waste may continue to combust on the fifth roller grate as well. The burnout is completed as bottom ash passes over the sixth roller. The ash falls off the sixth roller grate into an enclosed ash extractor. The lighter fraction of ash, flyash, is entrained in the combustion gases and carried in those combustion gases up through the boiler and the boiler passes and into the air pollution control system. The bottom ash in the ash extractor is pushed up an inclined chute, by a hydraulic ram, where it is discharged through a bifurcated chute onto one of two vibratory conveyors. The inclined chute is used to maintain a water seal on the boiler preventing the entry of tramp air and to allow the bottom ash to dewater. The bottom ash will have a moisture content of approximately 25%. The vibratory conveyors traverse the length of the boiler building and evenly spread out the piles of bottom ash as the ash travels the length of the conveyor. Two trains of vibratory conveyors, each of which could carry the quantity of bottom ash from both boilers, minimize the potential downtime. From the vibratory conveyors, the ash is discharged onto inclined belt conveyors which transport the ash up and into the ash processing building. In the ash processing building, the belt conveyors discharge the bottom ash onto vibratory screens (finger sizers) which separates bulky items greater than four inches from a finer ash (less than 4 inch size) stream. The bulky items are then passed over a drum magnet which pulls off ferrous materials while the remainder of the bulky material (not pulled out by the magnet) is discharged into a steel bed truck for transport back to the tipping floor so that the material can be put back through the furnace/boiler or subsequently loaded into a truck for transport to the landfill. Meanwhile, the “bulky” ferrous material is discharged into the ferrous storage area. The undersized ash stream is passed under a second magnet which pulls out undersized ferrous materials Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 and then discharges that material into the ferrous storage area. The combined ferrous magnets remove recoverable ferrous metal from the ash stream. Ferrous metals are loaded into trucks, using an electric pedestal crane equipped with a magnet, for transport to the recycling facility. Ferrous material is mixed with other steel products and the sent to various mills. The remaining undersized ash stream continues on a series of three conveyor (9, 210 and 220) belts to a vibratory pan (230) which discharges onto a vibratory screen (240) which separates fine bottom ash (less than 3/8 inch) from larger ash material. The greater than 3/8- inch material passes over the eddy current (300) system which throws the nonferrous metal onto the 310 conveyor belt. The ash residue falls off the eddy current system onto the 500 conveyor belt which discharges onto the 510 ash loadout belt. The nonferrous 310 conveyor belt discharges the nonferrous metals into a pile in the south west corner, ground floor of the ash loadout building. The less than 3/8-inch ash that passed through the 240 vibrating screen falls onto the 400 vibrating pan which discharges onto the 410 vibrating eddy current system. The less than 3/8- inch material passes over the eddy current (410) system which throws the finer nonferrous metal onto the 420 conveyor belt. The ash residue falls off the eddy current system onto the 500 conveyor belt which discharges onto the 510 ash loadout belt. The nonferrous 420 conveyor belt discharges the finer nonferrous metals into a pile in the south east corner, ground floor of the ash loadout building. To additionally prevent fugitive dust emissions, the entire bottom ash conveyance and separation processes are done inside buildings and conveyor galleries. Flyash which was entrained in the flue gas during the combustion process is removed in several locations. Heavier flyash tends to drop out of the flue gas as the flue gas makes several changes of direction through each of the boiler passes. Each boiler pass has a hopper with associated valves and connections to the ash handling system. Fly ash collected in these hoppers is transferred by enclosed conveyors back to the bottom ash extractors. After leaving the boiler, the flue gas passes through the flue gas cleaning system which consists of a dry scrubber followed by a reverse air baghouse. In the scrubber, lime slurry is injected through rotary atomizers into the flue gas. The lime reacts with the acid gases (forming calcium salts such as calcium sulfate, calcium chloride, etc.), removing pollutants as calcium salts. Some ash salts drop out of the gas stream and are collected in the scrubbers’ hoppers. Ash collected in the scrubber hopper is transferred into the flyash handling system. After exiting the scrubber, the flue gas enters the reverse air fabric filter baghouse where essentially all the remaining flyash and salts are removed. Each baghouse compartment is equipped with a hopper and associated valves and connections to the flyash conveyance system. The flyash and Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 scrubber salts are transported in sealed conveyors (screw and drag chain) to the flyash surge silo (teacup) located in the ash processing building. The flyash surge silo provides surge capacity while feeding the flyash/scrubber salts via enclosed variable speed screw feeders into pug mills for treatment with water to prevent dusting. From the pug mills, the wetted flyash drops on top of the bottom ash (system described above) on the 510 loadout belt conveyor which transports the combined ash to the ash hopper for direct truck loadout. Nonferrous materials are loaded out approximately once per week, inside the building, into a truck for transport to the scrap mill. Nonferrous materials, aluminum and copper are not separated at the Niagara facility, but at the processing facility. Any resulting ash residue is to be disposed of as required by regulations and applicable laws. Typically, ash remains as a portion of the nonferrous material that goes into the smelter and ends up as slag residue from the smelting process. All ash loadout is done inside the ash processing building. After the trucks pull into position under the ash loadout hopper, one of the access doors (usually the south door) on the loadout roadway is closed to reduce the potential for fugitive emissions. Currently the ash trucks are owned and operated by Modern Corporation under contract to Covanta Niagara. The ash is then hauled to either Republic Services’ Pine Avenue landfill located at 56th Street and Niagara Falls Boulevard in Niagara Falls, New York (approximately 2 miles north of the facility) or to the Modern Corporation’s landfill in Lewiston, New York (approximately 20 miles from the facility). To prevent fugitive dust emissions, the entire bottom ash conveyance and separation processes are done inside buildings and conveyor galleries. 2.2.2 ALTERNATE FUEL FIRED BOILER #2: ASH GENERATION AND HANDLING Like the combustion of refuse by the DGA units, the combustion of alternate fuel (i.e. waste wood) results in the generation of an ash residue consisting of a heavy fraction – bottom ash, and a light fraction – flyash. However, compared to the combustion of refuse there is much less ash generated during the combustion of alternate fuels (waste wood typically has a 2 - 5% ash content). The alternate fuel fired boiler #2 consists of a stoker traveling grate system. As the alternate fuel is charged into the furnace through the feed chutes, the heavier material Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 lands on the grates while the very light component burns in suspension. Primary air for combustion is blown into the space below the grates and then passes up into the furnace through small holes that are in each grate bar. As the grates move (traveling from front to back), the alternate fuel burns out with the ash residue falling off the grates, at the front of the furnace, into a water filled quench tank. The lighter fraction of ash, the flyash, and the calcium salts, generated when lime is blown into the furnace to remove acid gases, pass through the boiler and are removed in the electrostatic precipitator. The bottom ash in the quench tank is dragged out of the tank with a drag chain conveyor, up an incline to allow partial dewatering, and discharged into the ash hopper. When the ash hopper is full, it is taken to the tipping floor and dumped into the DBA refuse bunker. The flyash which is removed in the electrostatic precipitator is removed from the plates by a rapper mechanism and collected in hoppers. From the hoppers, the flyash is discharged into drag conveyors through a double flapper valve system. The drag conveyors transport the flyash to a storage silo. From the storage silo, the flyash is fed through a rotary feeder into a pugmill where the flyash is wetted to prevent dusting. From the pug mill the wetted flyash drops into a chute and down into an ash truck. When the truck (which is owned and operated by Modern Corporation) is full, a cover is put over the ash and the ash is then transported to either the Modern Corporation or the Republic Services’ Pine Avenue landfill - the same landfills that are used for the disposal of the ash residue from the combustion of refuse in the DBA mass burn furnace/boilers. 2.3 MAINTENANCE AND HOUSEKEEPING As described above, the bottom and flyash generation, handling, storage, and loadout equipment are designed to prevent the uncontrolled (fugitive) emissions of ash residue. Covanta Niagara’s preventative maintenance program includes the ash handling equipment and assures reliability of this equipment. When a piece of equipment does break down, it is repaired either by Covanta Niagara’s maintenance personnel or outside contractors. In addition operators are assigned to make rounds during each shift to check the ash handling equipment to ensure that the equipment is working properly. Housekeeping and operating personnel are specifically assigned to clean the ash processing areas on a daily basis. Personnel cleaning up spilled wetted ash or working on equipment that contains wetted ash wear coveralls and gloves. Plant policy requires that when personnel clean up spilled dry ash or work on equipment containing dry ash, they wear, in addition to the Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 coveralls and gloves, a half face respirator or a full face respirator (depending on the specific situation) with high efficiency dual cartridge filters. All the ash handling/processing areas and equipment are either inside buildings, enclosed conveyor galleries, or enclosed sealed conveyors. The ash loadout, ferrous metal loadout and nonferrous metal loadout are all done inside the ash processing building. The area around the ash loadout building is paved. Stormwater runoff is collected in catch basins. The storm water sewer servicing the area around the ash loadout building is plugged and the storm water is pumped into the cooling tower. The cooling tower blowdown is used in the DBA boilers’ acid gas scrubbers. Areas under the scrubbers and baghouses are designed to prevent the migration of ash into the groundwater or surface water; the entire area is paved with asphalt or concrete and sloped to trenches. The trenches connect to the facility's process water recycle sump. Water collected in the process water recycle sump is utilized in the ash extractor for quenching the ash. The area under the alternate fuel ash loadout belt is paved and drains to a catch basin that is tied into the sanitary sewer discharge system. 2.4 QUANTITY OF ASH The ash content of the refuse is estimated to be on average approximately 25% (including moisture). Therefore, based on the average combustion of 2250 tons per day of refuse, approximately 675 tons per day of ash is generated. The ash content of the alternate fuel (i.e. waste wood) combusted by Boiler #2 is estimated to average approximately 3%. In addition, lime is injected into the furnace at a rate such that the total quantity of ash and lime salts is approximately 7% of the alternate fuels burned. When the alternate fuel fired boiler #2 is operating, approximately 500 tons of alternate fuel per day is burned, generating approximately 35 tons of ash. 2.5 BENEFICIAL USE OF ASH Removal of ferrous and nonferrous metals from ash produced from the DBA furnace/boiler combustion system has been described previously in this section. Approximately 20,000 tons of ferrous and 1100 tons of nonferrous metals are sent to the scrap mills each year. Current data indicates approximately 2-3 % of the ash residue produced from refuse is recoverable ferrous metal and approximately 0.5% is recoverable nonferrous metals. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 As bottom ash from the alternate fuels combustion is put into the DBA refuse hopper, ferrous metals that are in the alternate fuels are likely to be recovered in the DBA ferrous recovery system. Ash generated by the Covanta Niagara facility is used as daily cover (instead of dirt) in landfills. Both Modern Corporation and Republic Services use the ash as daily cover in their landfills. There are other potential uses for the ash such as an aggregate in some asphalt or concrete. However, at this time, the reuse of these ashes is not widespread and regulatory/liability issues/questions appear to be the major obstacle limiting beneficial re-use. 2.6 ASH STORAGE CAPACITY The DBA facility was designed and had been operated with direct ash loadout to eliminate the need for on site ash storage. However, beginning on January 1, 2006 storage of ash on site became necessary because neither Modern Corporation’s landfill nor Republic Services’ Pine Avenue landfill is open 24 hours per day. Modern Corporation has covered trailers and rolloff boxes in which the ash is stored at the Covanta Niagara facility when the landfills are closed. Currently the Modern Landfill is open from 6:00 am to 6:00 pm Monday through Friday, while the Republic Services landfill is open 6:00 am to 6:00 pm Monday through Friday, 6:00 am to 2:00 pm on Saturday and 6:00 am to 3:00 pm on Sunday. It is estimated that the maximum ash stored on the Covanta Niagara site would be 750 tons. In addition the ash processing building’s equipment has been designed to allow all the ash to be diverted storage area in the northeast corner of the building in the event that loadout into the trucks or rolloff boxes could not be done. Use of this area in an emergency situation would allow onsite storage of ash for approximately twenty-four hours. The ash could then be loaded out in the ash trucks with front end loaders or processed through the nonferrous metals recovery system. Ash storage capacity in the DBA hoppers, silos, or ash extractors is limited to approximately one hour. The alternate fuels flyash silo has approximately five (5) days storage capacity while the bottom ash hopper has approximately one (1) day storage capacity. 2.7 ASH TRANSPORTATION Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revised Date: 3/07/14 Currently Modern Corporation transports the ash residue, in their vehicles, to either the Modern Corporation or Republic Services landfill. 2.8 ASH RESIDUE LANDFILL Approximately 100,000 tons of the ash goes to the Modern Landfill and 75,000 tons of ash goes to the Republic Services landfill. Ash in excess of the 175,000 tons would go to the Republic Services landfill. Both the Republic Services and Modern landfills are located in Niagara County in New York State. Both landfills have operating permits through the NYSDEC Region 9. 2.9 ASH RESIDUE CONTRACT AND BYPASS WASTE DISPOSAL Covanta Niagara has a contract with both Modern Corporation and Republic Services – which now owns BFI Waste Systems of North America for the disposal of ash residue. The ash disposal contracts expire at the end of 2015. Covanta Niagara has a relationship with Modern Corporation that would allow, when required, the disposal of diverted or bypass waste. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 13 Doc OM-2 Rev. No. 6 Revised Date: 3/07/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 2-1 MAJOR REVISIONS TO THE ASH MANAGEMENT PLAN February 2006 Name change to Covanta from American Ref-Fuel Section 2.2.1 Modified to reflect that ash hauling is now done by Modern Corporation and that both Modern Corporation and BFI Waste Systems of North America’s Pine Avenue landfills are used to dispose of the ash residue. Section 2.2.2 Modified to reflect the same change as noted in Section 2.2.1 Section 2.5 Modified to reflect that ash is used as a daily cover in the landfills Section 2.6 Modified to reflect that Modern Corporation stores ash residue trailers and/or rolloff boxes on site during nights and weekends when the landfills are closed. Section 2.7 Modified to reflect that Modern Corporation is now the transporter for the ash residue Section 2.8 Modified to reflect that Modern Corporation’s and BFI’s landfills are used for ash disposal. February 2010 Section 2.2.1 Modified to reflect that ferrous material is now purchased by Niagara Metals Section 2.2.2 Modified to reflect that Republic Services now owns BFI Pine Avenue landfill January 2011 Section 2.8 Modified to reflect the ash tonnage that is disposed of at two landfills Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 12 of 13 Doc OM-2 COVANTA NIAGARA O&M/ECOM Manual Section 2.9 Rev. No. 6 Revised Date: 3/07/14 Modified to reflect that ash disposal contracts now expire in December 2015 May 2013 Section 2.2.1 Modified to reflect the major modification made to the nonferrous metal processing system in the ash loadout building. March 2014 Included reference to RTIF project with conforming revisions to the solid waste facility permit. Removed landfill contract copies. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 13 of 13 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 3 COVANTA NIAGARA, L.P. NIAGARA RESOURCE RECOVERY FACILITY WASTE CONTROL PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 3 COVANTA NIAGARA WASTE CONTROL PLAN 3.1 INTRODUCTION 3.2 CONTRACTS 3.3 SIGNS AT FACILITY 3.4 SELECTION OF NHIW 3.5 RAILCAR RECEIVING PROCEDURES 3.6 CONTAINERIZED WASTE RECEIVING PROCEDURES FROM THE RTIF 3.7 RECEIPT OF SOLID WASTE FROM OVER THE ROAD TRUCKS 3.8 SOLID WASTE UNLOADING, STORAGE AND HANDLING 3.9 BULKY AND REJECTED SOLID WASTE 3.10 WASTE INSPECTIONS 3.11 RTIF RE-LOADING PROCEDURES 3.12 REGULATORY AUTHORITY NOTIFICATION 3.13 BY-PASS WASTE 3.14 ALTERNATE METHODS OF HANDLING MUNICIPAL SOLID WASTE 3.15 WASTE CONTROL SURVEY 3.16 EDUCATION 3.17 VECTOR CONTROL Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual 3.18 REGULATORY REPORTING REQUIREMENTS 3.19 ASH RESIDUE TESTING REQUIREMENTS 3.20 EMPLOYEE SAFETY Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 3 WASTE CONTROL PLAN LIST OF FIGURES FIGURE NUMBER TITLE 3-1 PROHIBITED WASTES Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 3 WASTE CONTROL PLAN LIST OF ATTACHMENTS ATTACHMENT NUMBER TITLE 3-1 MAJOR REVISIONS TO WASTE CONTROL PLAN 3-2 SOLID WASTE DISPOSAL AGREEMENT 3-3 WEIGH SCALE TICKET 3-4 INSTRUCTIONS TRUCK INSPECTIONS FOR PROHIBITED WASTE 3-5 SOLID WASTE TRUCK INSPECTION FORM 3-6 QUARTERLY SOLID WASTE REPORT 3-7 ANNUAL SOLID WASTE REPORT 3-8 EXPOSURE CONTROL PLAN 3-9 HAZAROUS WASTE IDENTIFICATION TRAINING PROGRAM 3-10 ALTERNATE FUELS – QUALITY ASSURANCE/QUALITY CONTROL PLAN 3-11 ENGINEERING DRAWING EDC-001 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual WASTE CONTROL PLAN 3.1 INTRODUCTION Covanta Niagara’s Waste Control Plan ensures that only refuse as established by the Solid Waste Facility Permit and acceptable to Covanta Niagara are received, processed and combusted, whether they are delivered as containerized waste via the Rail Transfer Intermodal Facility (RTIF) or by over the road trucks. Refuse includes mixed municipal solid waste (MSW), construction and demolition (C&D) debris, and wastes that have received written approval from the Regional Materials Management Engineer or the Facility Monitor: non-hazardous industrial/commercial waste (NHIW), sewage sludge, and treated regulated medical waste..Treated regulated medical waste must also be accompanied by a NY State Department of Health approved certificate of treatment signed by an authorized individual at the generating facility. , Approved refuse is combusted at the facility in the two DBA solid waste-fired mass burn furnace/boilers. This waste control plan is provided to comply with 6 NYCRR Part 360-3.3(j) as well as with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (3) - procedures for receiving, handling and feeding municipal solid waste. In addition, this waste control plan includes a Quality Assurance/Quality Control (QA/QC) Plan (Attachment 1-12) for alternate fuels and solid waste fired by EFW Boiler #2. This QA/QC plan controls the type of alternate fuels and solid waste brought into and combusted by EFW Boiler #2. Periodic revisions to this Waste Control Plan are documented in Attachment 1-1. 3.2 CONTRACTS Covanta Energy in 2013 entered into a new 20-year agreement with New York City Department of Sanitation to transport and sustainably dispose municipal solid waste (“MSW”) delivered to a pair of marine transfer stations located in Queens and Manhattan. The contract calls for this waste to be transported via sealed containers using a multi-modal approach including barges and railcars which will significantly reduce long-haul truck transportation of MSW. The RTIF is one of the disposal facilities designated to receive this containerized waste. Covanta Niagara L.P, as a privately owned solid waste management facility, has contractual agreements with various municipalities, waste haulers, and industries to process their wastes. All waste contracts make it clear that asbestos waste, explosives, hazardous wastes, radioactive wastes, regulated untreated medical waste and bulky (nonprocessible) wastes are not accepted at the facility. An example of the Covanta Niagara contract stating that hazardous wastes are not accepted at the facility is shown in Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 Attachment 3-2. A list of the prohibited and nonprocessible wastes (shown in Figure 3-1) has been sent to the customers that deliver household and commercial wastes. 3.3 SIGNS AT THE FACILITY The following signs, which are visible for a distance of at least 25 feet, are posted at the Facility: Entrance Gate 1) Hazardous waste are not permitted at this Facility. Delivery of hazardous waste may result in imprisonment for 5-15 years and fines of $50,000 to $1,000,000. 2) Visitors and unauthorized personnel must report to the Administration Building. Main Scale House 1) Hazardous wastes are not permitted at this Facility. Delivery of hazardous waste may result in imprisonment for 5-15 years and fines of $50,000 to $1,000,000. Radioactive wastes are not permitted at this facility. 2) This Facility is only authorized to receive household waste, non-hazardous commercial wastes and NYSDEC approved, non-hazardous industrial wastes. See scale house or tipping hall attendant for a list of prohibited wastes. 3) Bulky wastes are not processible. If you have any non processible materials in your load, they must be separated out and placed on the tipping floor as directed by the tipping floor attendant. Entrance to Tipping Floor 1) This facility is only authorized to receive household waste, non hazardous commercial and NYSDEC approved non hazardous industrial waste. See scale house or tipping hall attendant for a list of prohibited wastes. 2) Bulky wastes are not processible. If you have any non processible materials in your load, they must be separated out and placed on the tipping floor as directed by the tipping floor attendant. A list (available at the main scale house and the RTIF Building) of currently prohibited and non-processible wastes is shown in Figure 3-1. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual FIGURE 3-1 The following wastes are PROHIBITED from disposal at the Covanta Niagara facility: ASBESTOS WASTES EXPLOSIVES HAZARDOUS WASTES RADIOACTIVE WASTES REGULATED UNTREATED MEDICAL WASTE MOTOR VEHICLE BATTERIES MERCURY CELL BATTERIES The New York State Department of Environmental Conservation (NYSDEC) requires that Covanta Niagara take measures to exclude the wastes listed below from disposal at the facility. Waste generators and haulers should not dispose of the wastes shown below at the Covanta Niagara facility. : air conditioners bed springs bicycles crank cases dry cell batteries dryers engines file cabinets vehicle frame parts furnaces hot water heaters lawn mowers metal furniture oil storage tanks propane tanks refrigerators snow blowers stoves tires (bulk deliveries) transmissions freezers washers water softeners water storage tanks yard wastes Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 Nonhazardous industrial wastes (NHIW) can only be accepted with prior approval of the NYSDEC. 3.4 SELECTION OF NHIW Both from the regulatory (potential emissions) and operations (equipment wear and tear) standpoint Covanta Niagara is selective in the type of non-hazardous industrial wastes (NHIW) (both solid and liquid) that are accepted for disposal. Generators of industrial waste that want to dispose of their wastes at Covanta Niagara must characterize their waste streams to ensure that the waste sent to the facility is nonhazardous. Information such as analytical data, material safety data sheets, and generator knowledge are used by a dedicated evaluation team to evaluate (characterize) each industrial waste stream to determine whether the waste is suitable for disposal at Covanta Niagara. If Covanta approves the waste for disposal, Covanta Niagara must then obtain approval from the NYSDEC (using Form 47-19-7 and accompanying waste analyses) before accepting the material. The industrial wastes (both liquid and solid) include but are not limited to process wastes, returned/off-specification products, returned/off-specification consumer packaged products, returned/off-specification pharmaceuticals, remediation project soils (i.e. oil spills, wood tar and coal tar), etc. The NYSDEC approved NHIW is received from several sources including (but not limited to): NHIW that is either shredded or mixed together at a transfer storage disposal facility (TSDF) and then transported in a dump trailers containerized NHIW that is shipped in van trailers directly from the generator or TSDF remediation soils excavated at the site and transported in dump trailers NHIW bulk liquids that are shipped in tankers. The containerized NHIW that is shipped in van trailers will be contained in steel drums, plastic drums, fiber drums, plastic totes, mild steel totes, gaylord fiber boxes, gaylord nylon (super) sacks, consumer size packages, etc. These types of containers are usually put on pallets and then delivered to the plant in van trailers. This containerized NHIW is staged on the tipping floor of the tipping hall and processed in a manner and rate that is consistent with the associated approvals (from both NYSDEC and Covanta) granted. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 Bulk liquid NHIW that is delivered to the plant in tanker trucks is normally injected directly into the DBA furnaces through the liquid injection system. Occasionally a tanker of thicker, sludge like waste will be unloaded onto the solid waste in the refuse bunker. Liquid waste that would most likely be disposed of through the liquid injection system, which injects the liquid into the furnace, would be relatively low in suspended solids content and has the approximate specific gravity of water. Liquid wastes that would be unloaded directly onto the solid waste in the refuse bunker would be viscous liquids such as: sludge, latex paint, oil tank bottoms, etc. In addition the NYSDEC has approved Covanta Niagara to dispose of treated (autoclaved) regulated medical waste from several autoclave facilities. When this waste is received, it is immediately put into the refuse bunker. If the Niagara facility would seek to dispose of treated medical waste from any other sources, appropriate requests would have to be submitted to the NYSDEC. 3.5 RAILCAR RECEIVING PROCEDURES RTIF track will be maintained by Covanta Niagara or its specialized sub-contractors under the direction of the RTIF Superintendent. Track will be maintained in good working order, free from debris, weather-related impediments and worker hazards. Appropriate flagging and signage will be used at all times. The RTIF Superintendent will direct a Certified Track Inspector to regularly inspect all track, switches, derailers, signals and signage at the RTIF. The RTIF Superintendent will direct any preventative or corrective maintenance deemed necessary as a result of the Certified Track Inspector’s findings and as regularly scheduled as part of the RTIF Program. The RTIF rail design provides for two distinct track sections (each section consists of 2 parallel lines) each of which can accommodate a unit train. Should the RTIF Superintendent deem any track to be out-of-service, then the RTIF Superintendent will direct the Rail Transportation Subcontractor, CSX Transportation, Inc. (CSXT) to place railcars loaded with full containers onto alternative tracks within the RTIF. The RTIF Superintendent will make all appropriate notifications to CSXT and RTIF personnel and specialized sub-contractors tag and lock the switch out of service, and immediately direct corrective maintenance of the affected track. The RTIF Superintendent will ensure that all safety procedures are followed prior to, during and after delivery of the railcars loaded with full intermodal containers, unloading and reloading of railcars and trailers, and release of railcars loaded with empty containers. Safety procedures will incorporate the requirements of: • the Federal Railroad Administration; • the Occupational Safety Health Administration; • Roadway Worker Safety Training; Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual • • Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 CSXT Sidetrack Agreements; and Covanta Energy Corporation policies and procedures. Railcars loaded with full intermodal containers will be delivered by CSXT in unit train service. Upon notice to the RTIF Superintendent, CSXT will place the railcars loaded with full intermodal containers on the track(s) designated by the RTIF Superintendent. In the event of derailment or similar railcar related incident, Covanta employees or specialized sub-contractors under the direction of the RTIF Superintendent will re-rail the railcars. In the event that one section of track is fully inoperable, then the RTIF Superintendent will direct CSXT to place the railcars loaded with full intermodal containers onto one or more of the other tracks available within the RTIF. After ensuring the safe delivery of the railcars, the RTIF Superintendent will ensure that the railcars are correctly positioned. Any necessary repositioning of the railcars will be conducted by CSXT personnel, or by RTIF personnel or specialized sub-contractors under the direction of the RTIF Superintendent. Once the railcars loaded with full intermodal containers are placed according to the RTIF Superintendent’s instructions, the RTIF Superintendent will then direct CSXT to remove railcars loaded with empty intermodal containers. The railcars loaded with empty containers will be delivered to the origin NYC MTS by CSXT. If necessitated by weather, need for corrective maintenance or other unforeseen circumstance, CSXT will remove railcars loaded with empty intermodal containers before delivering railcars loaded with full intermodal containers. See ED C-001 for the areas, buildings, and scales discussed in this Section. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual 3.6 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 CONTAINERIZED WASTE RECEIVING PROCEDURES FROM THE RTIF Radio Frequency Identification (RFID) technology is utilized to track container movements and elapsed time from the origin NYC MTS to the Niagara RTIF. Passive RFID technology captures data entering and leaving the Covanta Niagara facility to assist in the management of containers. Total transit from the origin NYC MTS to the RTIF is expected to vary between 4 and 8 days. The RFID system (two tags per container) will verify that the container was sourced at the origin NYC MTS and identify the travel time to the Niagara RTIF. Full intermodal containers will be received at the RTIF loaded with four containers per railcar. After delivery of the railcars loaded with full containers, the RTIF Superintendent will review the RFID container data log, ensure that each container is in good working order and discern any odors. Should any containers exhibit odors in comparison to other containers from the same unit train, the RTIF Superintendent will direct certain containers to offloaded on a priority basis to the tipping hall; establishing a first in, first out offloading process. Any discrepancies with the RFID container data log will be immediately noted and reported to the Rail Transportation Manager. The CSXT Bill of Lading is also cross-checked with the RTIF schedule for receipt of containers. Intermodal containers will be offloaded from the railcars via a dedicated container handler (Reach Stacker) designed specifically for intermodal container transfer operations. Full intermodal containers will be lifted from the railcars and then be loaded by the container handler onto a yard tractor with tipping chassis. These tipping chassis are specifically designed for the transportation of intermodal containers. The yard tractor units, with the full intermodal containers, will then proceed to the RTIF scale, or in the event of an RTIF scale outage, to the Main Facility Scale House. The RTIF scale is automated for weighing RTIF containers being transported from the rail car siding. If a RTIF container being transported enters the weigh-in scale and cannot be identified in the computer system, the container will not be allowed to proceed to the tipping floor and unload. The driver will proceed to a holding area and must contact the RTIF Superintendent or Lead Operator for reconciliation before receiving approval to unload. The RFID system will also notify the control room operator of the discrepancy who will communicate with the RTIF Superintendent to confirm resolution has been achieved. Radiation Monitoring: A LFM-3 radiation monitoring system is installed at the RTIF scale. Similar to the system installed and the Main Scale House, the LFM-3 system includes two 2-inch sodium iodide scintillation detection tubes mounted approximately 15 feet apart. All RTIF containers are required to pass through the RTIF radiation detection system as they Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 12 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 are weighed in. As RTIF containers are initially screened at the origin MTS, the RTIF radiation monitors provide verification that the RTIF containers are below the setpoints established for acceptance of waste at the Covanta Niagara Facility. This screening is consistent with the radiation screening procedure that is conducted at the MTS. Signalization of the radiation alarm would occur if the radiation detector’s reading is above 8.0 kcounts per minute (not to exceed 5.0 times background), the truck would not be allowed to proceed to the tipping floor. Tower Assembly will be activated to allow the truck with the RTIF container to proceed to the tipping hall when the RTIF container is successful identified, weighed and no radiation alarm has been triggered. Any time the RTIF radiation alarm is activated and verified to be valid, Covanta Niagara would initiate screening procedures within the tipping hall to identify the source of the radiation and dispose the source with the requirements set forth by 6 NYSRR 380 and associated DOT requirements. RTIF containers that have elevated radiation readings will be parked in the RTIF temporary storage area. A radiation consultant will be notified to discern the appropriate disposition of the container. MSW which triggers the radiation alarm is deemed to be Unacceptable Waste pursuant to the Solid Waste Facility Permit and the contract with New York Department of Sanitation. Records will be maintained of all verified RTIF radiation alarm activations and the final disposition of the source. Frozen Loads: In the event that full intermodal containers require the application of heat in order to allow the municipal solid waste to be discharged, then the RTIF Superintendent or Lead Operator will direct the tractor driver to enter the thaw shed. The yard tractor units loaded with the full intermodal container will remain inside the thaw shed for a time sufficient to allow the outermost portion of municipal solid waste to de-ice and release from the interior walls of the intermodal containers. The yard tractor units loaded with full intermodal containers will then proceed to the tipping hall to discharge the municipal solid waste. Any collected drainage from the thawing operation will be discharged thru a sewer monitoring station MS-2 and is combined with other stormwater discharges from the RTIF site. Container Maintenance: Containers will be serviced on a periodic basis as tracked by the RFID system. In addition, any containers requiring maintenance from inspections will be serviced at the RTIF Building. Wash waters generated from cleaning the exterior of containers will be discharged thru a sewer monitoring station MS-2 and is combined with other permitted water discharges from the RTIF site. Prior to any inside container maintenance, the container will either be sanitized or washed or both. All discharges of interior container wash waters are directed to an internal sump and pumped to a holding tank for analysis prior to being released either to the Niagara Falls Water Board or thru the Liquid Direct Injection (LDI) system as an accepted profiled waste, approved by the NYSDEC via the Form 47 NHIW process. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 13 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 Container Unloading: Once inside the tipping hall, the yard trucks will be directed to the open tipping area as directed by Covanta personnel managing the area. The tipping chassis will be engaged to discharge the municipal solid waste from the full intermodal container. Covanta personnel will conduct an inspection according to established procedures (Attachment 3-4 and 3-5 herein) to ensure that the full intermodal container contains municipal solid waste. Any discrepancies will be managed according to this Waste Control Plan, and the Rail Transportation Manager will be notified. Complete discharge of the municipal solid waste will be verified before the intermodal container doors will be closed. The yard trucks with the empty intermodal containers will then proceed to either the active railcar loading area or to the empty container storage area. Incidental grounding of full containers may occur to accommodate the unit train unloading schedule as directed by the RTIF Superintendent and full containers may be temporarily stored to facilitate efficient dumping at the Covanta Niagara Facility for a period up to 48-hours. 3.7 RECEIPT OF SOLID WASTE FROM OVER THE ROAD TRUCKS The facility has a computerized system for weighing over the road trucks entering and leaving. If an over the road truck enters the weigh-in scale and cannot be identified in the computer system, the truck will not be allowed to proceed to the tipping floor and unload. In addition, a Bicron Corporation LFM-2 radiation monitoring system is installed at the scalehouse on both the inbound, as well as outbound weigh scales. The LFM-2 system includes two 2-inch sodium iodide scintillation detection tubes mounted approximately 15 feet apart. All trucks hauling solid waste are required to pass through the scalehouse radiation detection system as they are weighed in. This type of radiation detection system is consistent with the recommendations of the Conference of Radiation Control Program Directors (CRCPD) publication 98-3 titled “Detection and Prevention Contaminated in Solid Waste Facilities”. The Bicron LFM-2 monitors are currently set to warn at approximately 2 times background (background is approximately 1.6 kcounts per minute). Plant personnel follow the procedures detailed in the plant's safety operating procedure #1 "Radioactive Waste Detection Alarm." If a truck hauling solid waste activates the radiation warning (approximately 3.2 kcounts per minute), the scalehouse attendant would require that the truck go back through the radiation detection system a second time for further confirmation. If the radiation detector’s reading is above 8.0 kcounts per minute (not to exceed 5.0 times background), the truck would not be allowed to proceed to the tipping hall, but instead must be parked in a temporary staging area along Covanta Niagara’s fence line. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 14 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 A truck with an elevated radiation reading is not allowed to leave the facility unless the trucking company obtains a DOT – SP 11406 Shipment Approval Form signed by the NYSDEC that allows the truck to be taken back to the generators’ site. The acceptable setpoint of 8.0 kcounts/minute (not to exceed 5 times background) for the waste trucks is based on the NYSDEC’s Guidance (draft) titled “Information Notice to Operators of Solid Waste Facilities Monitoring for Radioactive Material in Municipal Solid Waste”, dated September 28, 1999, and the CRCPD document. Both documents are kept in the plant Environmental Engineer’s office. Trucks that have elevated radiation readings and are parked in the temporary staging area are periodically checked by Covanta Niagara personnel, using a hand held radiation detector, to see if the radiation level has decreased. When the hand held detector shows a substantial reduction (normally takes 5 –15 days) from the initial reading, the truck is brought back through the scale house radiation detection system. Radiation sources that are found in the waste tend to be of a low-level that degrade quickly. Only after the radiation reading from the truck is below 8.0 kcounts/minute is the truck allowed to proceed to the tipping hall and unload. A log sheet is maintained for each truck that has been detained because of an elevated radiation level. Each time a radiation level reading is obtained it is recorded on the log sheet. When the scalehouse detection system reading is below 8.0 kcounts/minute, the final reading is recorded and then the log is forwarded to the plant environmental engineer with a copy to the NYSDEC’s on-site monitor. To facilitate the weigh-in process, trucks carrying solid waste that routinely visit the facility are given an identification number and their tare weight stored in the computer - thereby eliminating the need to be weighed as they leave after unloading. Trucks loaded with bulkies (nonprocessible) waste, destined to be disposed of at the landfill, are also weighed at the scalehouse. Weight data are stored in the computer system. In addition, a multipart, carbonless weigh scale ticket (shown in Attachment 3-3) is given to the truck drivers. The Covanta Niagara Accounting Department includes the weight data in a daily report and also uses the data for billing and payment purposes. Some of the data included in Covanta Niagara's daily reports are included in the quarterly solid waste reports submitted to the NYSDEC. Sources/haulers of non-hazardous industrial waste are assigned a code. This code enables the scalehouse computer system to track the quantity of non-hazardous industrial Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 15 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 waste received at the facility. The quantity of nonhazardous industrial waste is reported to the NYSDEC in the quarterly solid waste reports. 3.8 SOLID WASTE UNLOADING, STORAGE, AND HANDLING All solid waste unloading (with the exception of the tank trailers of liquid waste for the liquid injection system), storage, and handling are done inside buildings. The facility receives solid waste in various covered or contained vehicles (i.e. packers, rolloffs, transfer trailers, dump trailers, van trailers, tank trailers, etc.) and containerized waste. Inside the tipping hall, the transfer and dump trailers are normally backed up and unloaded directly into the large concrete refuse bunker. The smaller waste delivery trucks (i.e. packers and rolloffs) are unloaded on the tipping floor and then a payloader is used to push these loads into the refuse bunker. During the day at least two transfer or dump trailer loads are unloaded on to the tipping floor, inspected and then pushed into the refuse bunker. Van trailers containing pallets of various waste, drums (liquids and solids), super sacks of powder and boxes of consumer packaged products, are unloaded by forklift using a portable unloading dock. Pallets of super sacks containing powders are temporarily staged on the tipping floor (either the south or north ends) and then put into the refuse bunker, one or two sacks at a time, so that they can be picked up by the grapple crane and put directly into the furnace hopper without breaking the super sack and creating a dust cloud. Most pallets of drums (steel, plastic or fiber) and totes (plastic or mild steel) are temporarily staged in the drum storage area at the north end of the tipping floor until the containers can be processed through the Komar shredder. Bulk liquid wastes arrive at the facility in tank trailers (nominal size – 5,000 gallons). Most of those tank trailers are staged in a concrete secondary containment dike on the north side of the DBA boiler building and then the liquid is pumped from the trailer, through a strainer and into a storage tank. A Komar shredder (approved by the NYSDEC in October 2002) was installed on the tipping floor to process drums (steel, plastic and fiber) and tote containers (mild steel and plastic). The drums and totes can contain liquids, solids or semisolids. The drums and totes are put into the shredder where an auger pushes the containers against a shear plate which results in the container being torn apart. As the container gets torn apart, the auger pushes the contents, as well as, parts of the container out the discharge chute and onto to the solid waste in the refuse bunker. A liquid waste injection system (approved by the NYSDEC in 2003 and additional approvals in 2010 and 2011) is used to inject the liquid waste directly into the combustion zone of the DBA boilers. Six permanent storage tanks were installed in 2011 inside a concrete secondary containment dike. The tanks have a total storage capacity of 300,000 gallons. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 16 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 From the tanker the liquid waste flows through a strainer (to remove solids that would plug the injection nozzles), then into a pump, through a grinder and then into one of the storage tanks. From the storage tank the liquid waste is pumped directly (through spray nozzles) into the combustion zone of the DBA boilers. The direct injection liquids are the only wastes that are not put into the refuse bunker prior to being put into the furnace. The bunker is designed to provide in excess of three days solid waste storage capacity. This storage capacity allows the facility to handle short term waste flow fluctuations. No solid waste may be stored outside the tipping hall/refuse bunker areas. The refuse bunker is completely enclosed and contains two full-span, overhead traveling cranes. The crane operator picks up the solid waste with the grapples on the crane and puts it into the furnace feed hoppers. Each crane is operated from a common pulpit and is able to satisfy the fuel requirements for each of the two furnaces. During the course of normal operations, the crane operators scan the contents of the refuse bunker pile, pick up the solid waste with the grapples and mix it in order to make it more uniform for firing. The operators keep a watch out for containers and materials which may be unacceptable. Any such items are picked out of the solid waste pile by the grapple and set aside in an area next to the feed chutes. At a later time, the material is inspected to determine if it is acceptable or unacceptable. All solid waste unloading, storage and handling is done inside buildings. No solid waste is stored outside. The facility effectively controls refuse odors, dusts and litter; all refuse handling occurs in the enclosed tipping hall and refuse bunker areas which are maintained under a negative air pressure. Primary air for the furnace is drawn from the tipping hall and refuse bunker so that solid waste odors are swept into the furnace and combusted. The facility also has a crew of housekeepers that are responsible for cleaning and picking up litter both the inside and outside of buildings. 3.9 BULKY AND REJECTED SOLID WASTE When bulky items are found in the tipping hall, if it is known which truck (hauler/generator) or trucking company delivered the item, then the item is put back on the truck. If the source is unknown, then the payloader may be used to crush some bulky items and then process them through the furnace. Any bulky items that cannot be put back on the hauler’s truck and cannot be processed through the furnace would be pulled out of the waste and sent to the landfill. Any metals associated with the bulky items that are processed through the furnace are recovered in the ferrous or nonferrous metal recovery systems and then sent to the scrap metal mill. If the item is a refrigerator or air conditioner that can not be identified as to the hauler/generator, the item would be inspected to ensure that the freon is no longer in the item. If the tipping floor personnel can not determine if the freon is no longer in the item, then the item is set to the side of the tipping floor and a certified contractor would be Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 17 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual called to inspect the item and, if necessary, remove the freon. The landfills currently used by Covanta Niagara to dispose of bulky items are: Niagara Recycling (Republic Industries) Niagara Falls, New York Modern Environmental Model City, New York 3.10 WASTE INSPECTIONS In addition to language cited in Covanta Niagara’s contracts to specifically prohibit the delivery of regulated hazardous waste at the facility, tipping hall operators have been trained to do random waste inspections of trucks delivering solid waste to the facility. Waste inspection instructions and a sample inspection sheet are shown in Attachment 1-4 and Attachment 1-5, respectively. The operators have been trained in the characteristics of the various types of hazardous waste (i.e. toxic, flammable, corrosive, reactive, listed, etc.) and what to look for during the truck inspections. A copy of the training program is shown in Attachment 1-9. The operators look for drums labeled "hazardous wastes", drums containing chemicals, gasoline containers, regulated medical waste, lead acid batteries, etc. The Niagara facility inspects a minimum of two (2) incoming loads each day. The inspection sheet is shown in Attachment 1-5. The tipping floor operators will select trucks at random to inspect, however transfer trailer loads and commercial waste loads will be inspected more frequently compared to household waste loads. The truck driver will be told to unload their trucks on the floor instead of into the refuse bunker. Tipping floor operators inspect the load and look for prohibited wastes. If warranted, a payloader is used to assist in spreading out the solid waste. In addition, the operators are looking for material, such as tree stumps, sheet rock, etc. that could have the potential to cause either an operational or environmental emissions problems. The inspection is then documented with the inspection sheet retained on file. Several months of inspection records are maintained at the facility. Older inspection records are archived with a document retention company. Records are stored for seven (7) years. If wastes that are unacceptable from an operational (i.e. tree stumps) or environmental (i.e. sheet rock) standpoint, then those wastes may be put back on the truck and not accepted at the facility. When unacceptable waste is found, the hauling company would be contacted and told not to bring the objectionable material into the facility. If any prohibited wastes such as hazardous or untreated regulated medical wastes are found, the material would be isolated from the other waste and the shift supervisor, the NHIW manager and environmental engineer are notified. In addition, the NYSDEC on-site Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 18 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 monitor would be notified and supplied with as much information as available with respect to the load (e.g. source, truck hauler identification, etc.). If the truck that hauled the material to the facility can be identified, an attempt would be made to put the prohibited material back on that truck. If the material was to be put back on the truck, the NYSDEC would be notified prior to releasing the truck from the facility (to ensure that the NYSDEC approved the release of the truck) and given information regarding the truck. If the waste source cannot be identified or cannot be transferred back to the source, the material will be temporarily stored onsite until proper offsite disposal can be arranged. Depending on the condition of the material, it may be necessary to repack the material in a new container for temporary storage. Containers of hazardous wastes would probably be stored either in an isolated area of the tipping floor or in the oil drum storage area which has a concrete dike whereas any untreated regulated medical waste would be stored in an isolated area of the tipping hall. Any hazardous waste would probably be disposed of through an authorized contractor with whom Covanta has business relationship. Regulated medical wastes will be disposed of through an authorized contractor. 3.11 RTIF RE-LOADING PROCEDURES The yard tractor units with empty intermodal containers will be directed to either the active railcar loading area or to the intermodal container storage area. In the active railcar loading area, yard tractor units will be directed to the correct position alongside the railcar being reloaded with empty intermodal containers. The container handler will lift the empty intermodal container from the tipping chassis and place the empty intermodal container onto the appropriate railcar. The railcar utilizes automatic locking mechanisms secure the container to the rail car. The RFID system will record the exiting containers and railcars leaving the RTIF. In the intermodal container storage area, tractor trailers will be directed to a position alongside the designated storage area. The container handler will lift the empty intermodal containers from the chassis and place the empty intermodal container into empty storage positions either on the ground or on top of other empty intermodal containers. Containers will be stacked a maximum of three containers high. The RTIF’s intermodal container storage area could allow up to 150 containers to be reloaded in the event of a delay at the EfW Facility. Container handlers will be able to reload the railcars with empty containers from the storage area, if desired. The empty container storage area will also ensure that each railcar is loaded with four empty intermodal containers, in the event that containers require maintenance prior to being Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 19 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual reloaded onto the railcar. Use of the intermodal container storage area will be at the discretion of the RTIF Superintendent in consultation with the Rail Transportation Manager in order to most effectively distribute empty intermodal containers to ensure consistent service, to remove excess equipment during periods of low waste flow, or to facilitate intermodal container maintenance. 3.12 REGULATORY AUTHORITY NOTIFICATION If hazardous or regulated medical waste, and as appropriate other prohibited wastes, are found in solid waste, the plant environmental engineer or a delegated individual will notify the NYSDEC on-site monitor. In the event that the NYSDEC on-site monitor is not available, the NYSDEC Regional Materials Management Engineer (RMME) will be notified. The NYSDEC will be provided known information regarding the waste. At this time there is no requirement to notify the NYSDEC’s central office. The NYSDEC phone numbers are: On-Site NYSDEC Monitor NYSDEC RMME 716-278-8527 716-851-7220 If the radiation detector alarms and the alarm is confirmed through a check procedure, then the NYSDEC’s on-site monitor will be notified: On-Site NYSDEC Monitor 716-278-8527 Only in the event that the radiation source in the waste appears to have an unusually elevated radiation reading (most readings with the hand held radiation monitor are near background levels until the monitor is only a few inches from the side of the truck) or does not decay in a timely manner would the NYSDEC's central office and the NYS Department of Health (NYSDOH) be notified. Those agencies contact phone numbers are: Central (Albany) NYSDEC 518-402-8579 Regional NYSDOH 716 8457-4500 Central (Albany) NYSDOH 518-402-7590 3.13 BYPASS WASTE RTIF: In the event that full intermodal containers cannot be received by the RTIF for processing at the EfW Facility, loaded intermodal containers at the MTS will be directed to an alternative location that accommodate rail to intermodal transfer. Locations may include either Covanta’s Delaware Valley facility or a landfill in Lee County South Carolina. During periods when the EfW facility cannot accept containerized waste, loaded intermodal containers will remain on the railcars on the RTIF site until such time as discharging the full Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 20 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 intermodal containers at the EfW Facility is possible. Full intermodal containers will only be placed in the RTIF intermodal container storage area as a last option, for a maximum period of two additional days. The maximum time that a loaded container can remain onsite is four (4) days. The RTIF Superintendent in consultation with the Rail Transportation Manager and the Project Manager may direct the reloading of full intermodal containers onto the railcars as necessary, and direct CSXT to deliver the railcars loaded with full intermodal containers to alternative disposal locations, including the Covanta Delaware Valley facility in Chester PA. or a landfill in Lee County South Carolina or other disposal locations that accommodate rail-to-intermodal transfer. RTIF waste will only be reported as bypass waste when Covanta requires to re-send any rail containers that were received by the RTIF. RTIF waste that is re-directed either at the NYC MTS or enroute to the RTIF will not be considered Bypass Waste as defined by 6 NYSRR Part 360-1.2(b) (22). Over the Road Refuse Delivery: Although Covanta Niagara does not anticipate needing to bypass over the road trucked solid waste, in the event that it became necessary to bypass solid waste, two local landfills shown below could be used. Modern Environmental Landfill in Model City, New York Waste Management Landfill in Chaffee, New York If it is necessary to bypass solid waste, the solid waste would go to a landfill . Trucks carrying the bypass solid waste would be weighed at the landfill and the weight data sent back to Covanta Niagara. 3.14 ALTERNATE METHODS OF HANDLING MUNICIPAL SOLID WASTE During periods of emergencies, equipment breakdowns or facility shutdowns, Covanta Niagara has the following solid waste handling options: • Fill the refuse bunker to the maximum capacity and then also temporarily store solid waste on the tipping floor. • Bypass the solid waste to landfills. During these periods, the onsite NYSDEC Monitor must be notified when municipal solid waste is initially stored on the floor. Additional notification may be required dependent on the duration in accordance with the Solid Waste Facility Permit. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 21 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual 3.15 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 WASTE CONTROL SURVEY A Waste Control Survey, identified in 360-3.3(j)(1)(ii), is not necessary as Covanta Niagara personnel ensure that each industry, commercial establishment and/or institution that provides waste to the facility must have a contract in place with Covanta Niagara that identifies: authorized and unauthorized wastes, how to add another waste for disposal, only nonhazardous waste is accepted, and that no major changes to the type of waste provided occurs. 3.16 EDUCATION The facility gives tours to various groups ranging from high school students to senior citizens, from non-technical to technical. The primary purpose of the tours is to educate the public about the solid waste combustion process. Included in the tour/presentations is information on the type of wastes that can and cannot be accepted at the facility. 3.17 VECTOR CONTROL The facility maintains a contract with a licensed vector control contractor. With the addition of the RTIF site, and resultant outdoor management of contained refuse, expanded initial placement of tamper proof rodent bait boxes are secured along the RTIF fence line spaced pursuant to contractor guidelines for rodent movement. The bait material is a single feeding type of anticoagulant, First Strike brand which is considered to be the safest bait to use. For the combustion building, baiting is placed in areas that are not normally accessed by plant personnel (i.e., behind a barrier wall in the tipping hall). This baiting is typically done only in the solid waste storage areas inside the building; however, baiting frequency will be increased as conditions warrant. Additional bait boxes next to and around the RTIF building are placed with multi catch rodent traps inside the RTIF building. The exact number of bait boxes and traps and frequency of service for all locations is determined based upon rodent activity, which is typically conducted once to twice weekly. 3.18 REGULATORY REPORTING REQUIREMENTS Quarterly and annual solid waste reports are submitted to the NYSDEC. The format and data required by the NYSDEC in the quarterly and annual reports are shown in Attachment 3-6 and Attachment 3-7, respectively. In the event of an emergency affecting plant operations and which could threaten human health or the environment beyond the facility, Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 22 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 NYSDEC shall be notified within 24 hours of discovery and provide a report within 5 working days of the event. 3.19 ASH RESIDUE TESTING REQUIREMENTS Covanta Niagara has a detailed Ash Sampling and Analysis Plan that is found in Section 5 of the facility’s Operations & Maintenance/ECOM Manual Administrative Plan. 3.20 EMPLOYEE SAFETY At Covanta Niagara, the potential exists for employees to be exposed to bloodborne pathogens that are in the solid waste stream. Covanta Niagara has a written Exposure Control Plan that details employee training and actions to be taken in the event an employee has been injured (i.e. cut. puncture wound, etc.) and exposure is possible. In addition, Covanta Niagara offers to each employee a tetanus shot and Hepatitis B vaccination. The Exposure Control Plan is shown in Attachment 3-8. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 23 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-1 MAJOR REVISIONS November 2005 Name change to Covanta Energy from American Ref-Fuel Company of Niagara Section 1.7 BULKY AND REJECTED SOLID WASTE This section has been modified to explain how bulky items are currently handled at the facility. February 2011 Section 1.5 RECEIPT OF SOLID WASTE This section was modified to explain the receipt of some potassium compounds that may have low levels of naturally occurring radioactivity. March 2012 Section 1.6 SOLID WASTE UNLOADING, STORAGE AND HANDLING This section was modified to reflect the new liquid waste storage tanks and pumping system. May 2013 Several minor revisions were made. Section 1.12 WASTE CONTROL SURVEY Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 24 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 This section was modified to state that a waste control survey is not necessary as long as the contracts with customers state that no hazardous waste can be accepted at Covanta Niagara. March 2014 Conforming revisions to include the operation of the RTIF and the solid waste facility permit were made. May 2014 Revisions to Section numbers. Update to Section 3.13 – Bypass Waste. July 2014 Minor update to Section 3.7 RECEIPT OF SOLID WASTE FROM OVER THE ROAD TRUCKS, paragraph 3. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 25 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-2 SAMPLE COPY FIRST PAGE SOLID WASTE DISPOSAL AGREEMENT Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 26 of 37 ATTACHMENT 1-2 ( DISPOSAL SERVICES AGREEMENT This Disposal Services Agreement (this "Agreement"), dated January 1, 2006, by and between Covanta Niagara, L.P., a Delaware limited partnership located at 100 Energy Blvd. 1 @ 56 h Street, Niagara Falls, NY 14304 ("Covanta "), and BPI Waste Systems of North America, Inc., a Delaware corporation located at 2321 Kenmore A venue, Kenmore, NY 14217 ("BPI"). RECITALS A. Covanta owns and operates the Niagara Resource Recovery Facility located at 100 Energy Blvd. @ 561h Street, Niagara Falls, NY 14304 (the "Facility"). B. BPI owns and operates the Pine A venue Landfill located at 561h St. & Niagara Falls Blvd., Niagara Falls, N.Y. 14304 (the "BPI Landfill"). C. BPI desires to deliver to Covanta, and Covanta desires to accept from BPI at the Facility, certain quantities of Acceptable Waste (hereinafter defined) in accordance with this Agreement. D. Covanta desires to deliver to BPI, and BPI desires to accept from Covanta disposal at the BPI Landfill certain quantities of Process Residue (hereinafter defined) in accordance with this Agreement. AGREEMENT NOW, THEREFORE, for and in consideration of the mutual covenants contained herein and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, BPI and Covanta hereby agree as follows: Section 1 Definitions The following words and phrases, when used m this Agreement shall have the meaning indicated: "Acceptable Waste" means all materials or substances generally discarded or rejected as being spent, worthless, useless or in excess to the owners at the time of such discard or rejection, including but not limited to trash, garbage, refuse, rubbish, discarded materials from residential, commercial and industrial activities, yard waste, and vegetative waste, but not including either Hazardous Waste or Pathological Waste. Acceptable Waste does not include bulky waste or waste which is of a size and composition that the Facility is unable to process it or the BPI Landfill is unable to dispose of it. Page I of 8 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-3 SAMPLE COPY WEIGH SCALE TICKET Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 27 of 37 ~.-3.11:3 r "\Cil i t;y l'J0 Ene-rqy Lilvd. ~ ·::6th : lt-reet i·li. J.g01.·ra F:\lls, i·rt 1 ~ J 04 ill .\q.H 3. rick.et: 't8/:i81 Od te: .J/'J/2~ji0 rime: 86:05:33 - 86:~5:J5 '3 r.:: .: ll f:? r ruck: tJ-rnss: j281i0 lb fa·re:3'3560 lb Customer: 13~i~10DERN DISPOSAL :·let:l32130 lb Ca·rde·r: JJUHOOEl:;:N DISPOSAL CAfruck fype: Rear Loading Packer 2':J44 Comment: 1Jri. gin 11at:::-"l'ials 111+8/i•lodel City, NY ltd~" .~ \ - ----~2 ''l t o·ri ve·r = I 1 '--1' / - ). 6.64 ton ( )</ I. y~ .I , f \ I -i._) Cluanti ty Unit of i"'ISW- fGN/l'ISW-10-fon-I / ( '.Je-rvices Deputy ( ln ~ 3..:.J.lt:? P. T. Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-4 INSTRUCTIONS TRUCK INSPECTIONS FOR PROHIBITED WASTES Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 28 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-4 COVANTA NIAGARA INSTRUCTIONS - TRUCK INSPECTION FOR PROHIBITED WASTES (Excludes Profiled Waste Approved by NYSDEC) In addition to being observant for non processible solid waste, the tipping hall operators will conduct daily inspections of solid waste truckloads and observe for prohibited materials. The facility inspects a minimum of two (2) of the incoming truckloads/RTIF containerseach day. No truck operator should be exempt from these occasional inspections: 1) Each day trucks (either a direct tip, RTIF container or a transfer truck) are to be selected at random and the driver asked to dump the load onto the floor. Note: Trucks carrying commercial or industrial solid wastes are the preferred trucks for inspections. 2) As necessary, the payloader should be used to help spread the load. After the solid waste is spread out, the tipping floor operator is to make an inspection, looking specifically for hazardous wastes as well as the non processible wastes. The operator is to fill in the appropriate information on the inspection sheets. 3) Examples of hazardous waste or waste that are suspicious would include, but is not limited to: - Drums or containers labeled "Hazardous Wastes." - Drums or containers labeled "Flammable" or "Combustibles." - Drums or containers labeled "Acid" or "Caustic." - Drums or containers labeled "toxic" or "Poisonous." - A container labeled "Regulated Medical Waste" (unless it is the approved autoclaved waste.) - Gasoline containers. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 29 of 37 Doc OM-3 COVANTA NIAGARA O&M/ECOM Manual 4) Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 All the various hazardous wastes cannot be listed here. However, when a tipping hall operator finds a hazardous waste or a suspicious waste, he should immediately do the following: - Stop the truck from leaving the tipping hall - Call the Shift Supervisor - Call the Environmental Engineer - Call the Chief Engineer 5) After the inspection, if no hazardous wastes are found, the solid waste will be put into the refuse bunker. 6) If a hazardous waste is found, it must be separated from the other waste to await proper disposal. The Environmental Engineer or his delegate will determine how and where to temporarily store the hazardous waste and how to properly dispose of it. 7) The inspection sheet must be filed with the NHIW Manager. 8) If a suspicious waste is found and the plant environmental engineer is not immediately available, that waste material should be isolated on the floor. 9) Under no circumstance is suspicious waste to be pushed into the pit until plant supervision has had time to inspect the material. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 30 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-5 SOLID WASTE TRUCK/RTIF CONTAINER INSPECTION FORM DATE: _______________________________________ TIME: ________________________________________ HAULER’S NAME: ______________________________ TRUCK/CONTAINERNUMBER: _______________________________ IS ANY HAZARDOUS WASTE OBSERVED IN THE LOAD? ______________________ IF YES, DESCRIBE: _______________________________________________ IS ANY UNTREATED REGULATED MEDICAL WASTE OBSERVED? ______________ IF YES, DESCRIBE: ________________________________________________ DESCRIBE WHAT WASTES ARE OBSERVED IN THE LOAD: ___________________ Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 31 of 37 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-6 QUARTERLY SOLID WASTE REPORT Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 32 of 37 Chris Schifferli, PE, CEM Environmental Engineer 100 Energy Blvd, Niagara Falls, NY 14304 Tel 716 278 8524 / Fax 716 284 2961 cschifferli@covanta.com January 28, 2014 Dennis Weiss Regional Solids Material Engineer NYS Department of Environmental Conservation 270 Michigan Avenue Buffalo, NY 14203 via email drweiss@gw.dec.state.ny.us Subject: Covanta Niagara Permit No. 9-2911-00113/00023 Quarterly Solid Waste Report Fourth Quarter 2013 Dear Mr. Weiss: Attached is the quarterly Solid Waste Report for the Subject period. Also attached is a list of municipalities that disposed of municipal solid waste at the facility. The Contingency Plan was not activated during the quarter. During the quarter, 55,043 tons of NYSDEC approved, non-hazardous, industrial solid waste and 5,023 tons of NYSDEC approved treated medical waste (defined as solid waste) were burned at the facility. Please note that essentially all steam produced at the plant is used in the turbine being either condensed or extracted. Extracted steam is used internally and exported to Occidental Chemical Corporation’s Niagara Plant, Praxair Niagara Plant, Goodyear Niagara Plant, Niacet Niagara Plant, Norampac Industries, Inc., and GreenPac Mill, LLC. I certify, under penalty of law, that based on information, and belief formed after reasonable inquiry, the statements and information contained herein are true, accurate and complete. The solid waste fired DBA mass burn boilers’ downtime was as follows: Boiler 3 Date 10/16 – 10/19 11/4 11/27 – 11/28 11/30 – 12/6 Reason Tube failure Switchgear failure Tube failure Grate failure Boiler 4 Date 11/4 11/12 – 11/14 11/24 – 11/26 Reason Switchgear failure Tube failure Boiler Feed Chute Integrity Please contact me with questions. Thank you. Regards, dist: 6 pages James Devald, NC Health Department, james.devald@niagaracounty.com David Vitale, NYSDEC, dxvitale@gw.dec.state.ny.us Brian Kent, Covanta, bkent@covanta.com Liam Curry, Covanta, lcurry@covanta.com Kevin O’Neil, Covanta, ko'neil@covanta.com Municipalities Contracted With Covanta Niagara Municipality Contract Expiration Date Angola, Village Of Republic 12/31/2017 Blasdell, Village Of Covanta 7/1/2014 Clarence, Town Of Republic 12/31/2013 Depew, Village Of Modern 12/31/2014 Eden, Town Of Republic 12/31/2014 Evans, Town Of Republic 12/31/2014 Grand Island, Town Of Republic 12/31/2013 Hartland, Town Of Republic 12/31/2013 Kenmore, Village Of Covanta 12/31/2017 Marilla, Town Of Republic 12/31/2013 Newstead, Town Of Republic 12/31/2014 Niagara, Town Of Republic 12/31/2015 Orchard Park, Town Of Republic 12/13/2015 Tonawanda, City Of Covanta 12/31/2017 Tonawanda, Town Of Covanta 12/31/2017 Alternate Fuels Combustion EFW Boiler No. 2 Alternate Fuels Received During Quarter: 8,752 tons Alternate Fuels Combustion During Quarter: 9,452 tons Steam Produced from Alternate Fuels Combustion: 217,912 klbs Average wood steam flow from EFW No. 2: Steam Flow (klbs/hr) 60 57 46 Month October November December Average BTU content of alternate fuels sampled: Hours of Operation 144 296 148 5,779 Btu/lb Air Emissions (average pounds per operating hour): Sulfur Dioxide Nitrogen Oxides Carbon Monoxide Note: 1.5 40.4 26.8 A daily report with hourly emission data is available to the NYSDEC site monitor. In addition, emission totals (quarter and year-to-date) for above parameters are shown in the quarterly “Fuels Summary Report.” Covanta wood suppliers: BFI Accounts (GM, NYSEG, Bethlehem Steel) BFI Kenmore P. O. Box 571 Kenmore, NY 14217 York Resource Recovery 111 Ingram Street Toronto, Ontario Zoladz Construction 13600 Railroad Street PO Box 157 Alden, NY 14004 Wasteco 161 Bridgeland Ave. Toronto, Ontario Goodyear Tire & Rubber Co. 5408 Baker Avenue Niagara Falls, NY 14304 Village of Kenmore Municipal Building 2919 Delaware Avenue Kenmore, NY 14217 Modern Corporation 4746 Model City Road P. O. Box 209 Model City, NY 14107 Walker Norjohn Walker Industries Holding Ltd. P. O. Box 100 Thorold, ON L2V 3Y8 Covanta railroad tie suppliers: Zoladz Construction 13600 Railroad Street PO Box 157 Alden, New York 14004 4Q13 COVANTA NIAGARA PART 360 QUARTERLY REPORT Facility: Covanta Niagara, L.P. #32E01, 100 Energy Boulevard, Niagara Falls, NY 14304 Permit: 9-2991-00113/00006-0 Report Prepared By: Chris Schifferli, 100 Energy Boulevard, Niagara Falls, NY 14304, Telephone: 716-278-8524 Wk 1 10/1 Period Begin 10/6 Period End 6 Period Days 12,980 Waste Received (Tons) 259 Alt Fuels Received (Tons) 0 Waste Bypassed (Tons) 156 Nonprocessible Waste (Tons) 83,328 Stm Gen - Solid Waste (Klbs) 0 Stm Gen - EFW (Klbs) 0 Boiler #1 Ops (Hours) 0 Boiler #2 Ops Alt Fuels (Hours) 144 Boiler #3 Ops (Hours) 144 Boiler #4 Ops (Hours) 144 #1 Turbine Ops (Hours) 144 #2 Turbine Ops (Hours) 83,328 Turbine Stm Cons (Klbs) 4,080 Net Power Generation (Mwh) Water Consumed (gal) Purchase Power (Mwh) 3,196 Ash Residue (Tons) 10.8 Volatile Matter in Ash (%) 203 Ferrous Mtl Shipped (Tons) 23 Nonferrous Mtl Shipped (Tons) All Boiler Downtime (Hours): Boiler #2 Boiler #3 Boiler #4 Wk 2 Wk 3 Wk 4 Wk 5 Wk 6 Wk 7 Wk 8 Wk 9 Wk 10 Wk 11 Wk 12 Wk 13 Wk 14 Total 10/7 10/14 10/21 10/28 11/4 11/11 11/18 11/25 12/2 12/9 12/16 12/23 12/30 10/1 10/13 10/20 10/27 11/3 11/10 11/17 11/24 12/1 12/8 12/15 12/22 12/29 12/31 12/31 7 7 7 7 7 7 7 7 7 7 7 7 2 92 17,407 15,530 14,267 18,183 17,163 15,965 15,799 12,448 11,868 11,764 13,240 12,825 5,623 195,062 24 0 166 835 301 758 1,341 1,733 1,829 995 0 0 512 8,753 0 0 0 0 0 0 0 0 0 0 0 0 0 0 130 124 391 652 825 174 330 218 113 89 178 134 182 3,696 91,840 82,048 99,328 84,800 101,376 67,497 66,688 101,568 95,616 95,744 27,763 1,199,920 0 14,744 8,388 21,424 15,616 26,292 20,244 37,448 33,996 13,312 8,032 11,856 6,560 217,912 0 60 12 82 168 148 35 168 168 168 104 0 0 1,113 100,608 101,716 0 0 57 87 0 65 108 123 9 0 0 91 48 588 168 107 168 168 164 168 168 95 50 168 168 168 48 1,952 168 168 168 168 166 112 165 121 168 168 168 168 48 2,100 129 168 168 168 163 168 168 168 168 168 168 168 48 2,164 155 113 127 168 166 115 168 86 57 168 168 168 48 1,851 91,840 96,792 34,323 1,417,832 4,064 3,472 1,138 49,347 108,996 123,140 114,944 111,092 121,620 104,945 100,684 114,880 103,648 107,600 3,824 4,428 4,032 3,520 4,160 2,501 2,208 4,464 3,920 3,536 433,297 859 433,297 16,443 NA from National Grid as of 1/28/14 17,302 3,768 3,425 3,384 3,610 3,690 3,285 3,600 2,912 2,270 3,504 3,481 3,451 1,092 44,668 10.3 6.3 8.6 5.9 5.7 11.1 8.9 6.8 13 9.2 13.7 19.5 15.2 10 430 349 294 490 308 367 339 339 260 278 290 371 199 4,517 23 22 44 22 23 21 46 21 21 46 0 46 23 381 144 168 168 111 81 168 103 60 45 159 168 168 77 0 1,620 0 0 61 0 0 4 0 0 73 118 0 0 0 0 256 0 0 0 0 0 2 56 3 47 0 0 0 0 0 108 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-7 ANNUAL SOLID WASTE REPORT Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 33 of 37 Chris Schifferli, PE, CEM Environmental Engineer 100 Energy Blvd, Niagara Falls, NY 14304 Tel 716 278 8524 / Fax 716 284 2961 cschifferli@covanta.com February 25, 2014 NYS Department of Environmental Conservation Division of Materials Management Bureau of Permitting and Planning 625 Broadway Albany, NY 12233-7260 via email swpermit@gw.dec.state.ny.us Subject: Covanta Niagara Permit 9-2911-00113/00023 2013 Annual Operating Report Dear Bureau of Permitting and Planning Representative: Please see the Subject operating report. Supplemental information is included on additional sheets. Also attached is the Annual Facility Inspection Report per Section 9 and Closure Plan per Section 12. Regards, dist: Dennis Weiss, NYSDEC, 270 Michigan Ave, Buffalo, NY 14203, drweiss@gw.dec.state.ny.us Anthony Poupalos, NYSDEC, anpoupal@gw.dec.state.ny.us James DeVald, Niagara County Health Department, james.devald@niagaracounty.com Brian Kent, Covanta, bkent@covanta.com 40 pages I certify, under penalty of law, that based on information, and belief formed after reasonable inquiry, the statements and information contained herein are true, accurate and complete. Division of Materials Management New York State Department of Environmental Conservation Albany, New York 12233-7260 MUNICIPAL WASTE COMBUSTION FACILITY Forms for all solid waste management facilities and a brief description of each type of facility can be found at http://www.dec.ny.gov/chemical/52706.html. Annual/Quarterly Report Submit the Annual Report no later than March 3, 2014. Reporting of the information indicated on this Municipal Waste Combustion Facility Annual/Quarterly Report form is required pursuant to 6 NYCRR 360-1.4(c); 360-1.14(e)(2), (i)(1); and 360-3.4(f). Failure to provide the required information requested is a violation of Environmental Conservation Law. Timely submission of a properly completed form to the Department’s Regional Office that has jurisdiction over your facility and to the Department's Central Office is required to meet the Annual/Quarterly Report requirements of 6 NYCRR Part 360. Where the Annual Report requirements have been modified, appropriate Sections (as necessary to reflect the modification) must be completed and submitted with a copy of the Department's written notification which allows the modification. Entries on the report forms should be either typewritten or neatly printed in black ink. Attach additional sheets if space on the pages is insufficient or supplementary information is required or appropriate. Reprinted (01/14) Page 1 ANNUAL/QUARTERLY REPORT A. This Municipal Waste Combustion Facility Report is for the year of operation from January 01, 2013 to December 31, 2013 B. Quarterly Report for: ___Quarter 1 ___Quarter 2 ___Quarter 3 ___Quarter 4 SECTION 1 – FACILITY INFORMATION FACILITY NAME: Covanta Niagara FACILITY LOCATION ADDRESS: FACILITY CITY: 100 Energy Boulevard Niagara Falls STATE: ZIP CODE: NY 14304 FACILITY TOWN: FACILITY COUNTY: FACILITY PHONE NUMBER: Niagara Niagara 716-278-8500 FACILITY NYS PLANNING UNIT: (A list of NYS Planning Units can be found at the end of this report). Niagara County 360 PERMIT #: DATE ISSUED: 9-2911-00113/00023 4/1/2005 3/31/2015 32E01 FACILITY CONTACT: public private Chris Schifferli DATE EXPIRES: NYSDEC REGION #: 9 NYS DEC ACTIVITY CODE OR REGISTRATION NUMBER: CONTACT PHONE NUMBER: CONTACT FAX NUMBER: 716-278-8524 716-284-2961 CONTACT EMAIL ADDRESS: cschifferli@covanta.com OWNER NAME: OWNER PHONE NUMBER: Covanta Niagara, L.P. 716-278-8500 OWNER ADDRESS: OWNER FAX NUMBER: 716-284-2961 OWNER CITY: 100 Energy Boulevard Niagara Falls OPERATOR NAME: OPERATOR PHONE NUMBER: same as owner STATE: ZIP CODE: NY 14304 OPERATOR FAX NUMBER: public private OPERATOR EMAIL ADDRESS: Preferred address to receive correspondence: Facility location address Owner address Contact Operator Other (provide): Preferred email address: Other (provide): Did you operate in 2013? Yes; Complete this form. No; Complete and submit Sections 1 and 16. If you no longer plan to operate and wish to relinquish your permit/registration associated with this solid waste management activity, also complete the “Inactive Solid Waste Management Facility or Activity Notification Form” located at: http://www.dec.ny.gov/chemical/52706.html . Reprinted (01/14) Page 2 SECTION 2 - SOLID WASTE RECEIVED/PROCESSED Provide the tonnages of solid waste received. DO NOT REPORT IN CUBIC YARDS! Specify the methods used to measure the quantities received and the percentages measured by each method 100 _____% Scale Weight _____% Truck Count Type of Solid Waste _____% Estimated _____% Other (Specify: ______________________) January (tons) February (tons) March (tons) April (tons) May (tons) June (tons) July (tons) Construction & Demolition Debris (mixed) Industrial Waste (Including Industrial Process Sludges) Mixed Municipal Solid Waste (Residential, Institutional & Commercial) 15,483 13,028 12,646 13,603 11,375 15,215 15,137 44,226 48,140 52,648 47,074 30,028 52,618 52,192 1,606 1,384 1,282 1,486 1,224 1,661 1,449 Sewage Treatment Plant Sludge Treated Regulated Medical Waste Emergency Authorization Waste (Storm Debris) Other (specify) Total Tons Received Total Tons Processed 62,592 66,576 62,163 42,627 69,494 58,773 58,446 69,333 57,295 43,687 71,470 61,315 68,778 63,811 Reprinted (01/14) Page 3 SECTION 2 - SOLID WASTE RECEIVED/PROCESSED (continued) Type of Solid Waste Tip Fee ($/ton) August (tons) September (tons) October (tons) November (tons) December (tons) Total Year (tons) Daily Avg. (tons) Construction & Demolition Debris (mixed) Industrial Waste (Including Industrial Process Sludges) variable Mixed Municipal Solid Waste (Residential, Institutional & Commercial) variable 14,405 15,053 18,038 16,756 15,228 175,967 482 46,831 46,053 54,106 47,765 38,148 559,869 1,534 1,426 1,388 1,615 1,461 1,945 17,927 49 Sewage Treatment Plant Sludge Treated Regulated Medical Waste variable Emergency Authorization Waste (Storm Debris) Other (specify) Total Tons Received 62,662 62,494 73,759 65,982 55,321 753,763 2,065 Total Tons Processed 69,543 59,544 70,802 65,268 61,623 749,596 2,054 Reprinted (01/14) Page 4 SECTION 3 – SERVICE AREA Identify the facility’s service area by indicating the type of solid waste received, the Solid Waste Management facility (SWMF) from which it was received (or Direct Haul), the corresponding State/Country, the County/Province, and the NYS Planning Unit and the amount received. Refer to the list of NYS Planning Units that can be found at the end of this report. DO NOT REPORT IN CUBIC YARDS! Note: This is not the facility identified in Section 1. Please report the facility from which you Specify transport method and percentages of total waste transported by each: received the solid waste. “Direct Haul” means 100 _____% Road _____% Rail waste hauled directly to your SWMF which did not go through another SWMF. _____% Water _____% Other (specify: _______________________________________) Explain which waste types and service areas below are included in these transport methods ________________________________________________________ _________________________________________________________________________________________________________________________________ SERVICE AREA TYPE OF SOLID WASTE SOLID WASTE MANAGEMENT FACILITY FROM WHICH IT WAS RECEIVED (Name & Address) OR “Direct Haul” SERVICE AREA STATE OR COUNTRY SERVICE AREA COUNTY OR PROVINCE SERVICE AREA NYS PLANNING UNIT (See Attached List of NYS Planning Units) TONS RECEIVED None. Construction & Demolition Debris (mixed) See attached. Industrial Waste (Including Industrial Process Sludges) Reprinted (01/14) Page 5 SERVICE AREA TYPE OF SOLID WASTE SOLID WASTE MANAGEMENT FACILITY FROM WHICH IT WAS RECEIVED (Name & Address) OR “Direct Haul” SERVICE AREA STATE OR COUNTRY SERVICE AREA COUNTY OR PROVINCE SERVICE AREA NYS PLANNING UNIT (See Attached List of NYS Planning Units) TONS RECEIVED See attached. Mixed Municipal Solid Waste (Residential, Institutional & Commercial) None. Sewage Treatment Plant Sludge Treated Regulated Medical Waste (TRMW)* Emergency Authorization Waste (Storm Debris) Other (specify) See attached. None. 753,763 TOTAL RECEIVED (tons): ______________ 821,250 Part 360 Permit Limit (tpy) ________________ Not Applicable Permit Limit based on Steaming rate (tpy) ________________ See attached. * List generators that provide you Certificates of Treatment forms and quantities of TRMW from each ___________________________________________ Reprinted (01/14) Page 6 SECTION 4 – PLANT PERFORMANCE LOG Complete the following Annual/Quarterly Plant Performance Log: PLANT PERFORMANCE LOG ANNUAL/QUARTERLY SUMMARY 0 Processible Waste Bypassed (Tons): _________________ 11,247 Untreatable Waste Bypassed (Tons): _________________ 2,104 Incinerator #1 Operations (Hours): _________________ 1,890 Incinerator #2 Operations (Hours): _________________ 7,845 Incinerator #3 Operations (Hours): _________________ 7,869 Incinerator #4 Operations (Hours): _________________ 4,514,787 Steam Generated (Klbs): _________________ 3,013,070 Steam Sold (Klbs): _________________ 7,887 / 7,785 Turbine Operation (Hours): _________________ 1,321,089 Turbine Steam Consumption (Klbs): _________________ 246,225 Power Generation (MWH): _________________ 263,268 Purchased Power (MWH): _________________ 192,633 Annual Electricity Sold to User (MWH): ____________ 172,305 Ash Residue (Tons): _________________ 9.2 Volatile Matter in Ash (%):_________________ 15,451 Ferrous Metal Recovered (Tons): _________________ 15,451 Ferrous Metal Sold (Tons): _________________ 434 municipal Water Consumption (Kgal): _________________ Facility’s Size Operations 2 solid waste, 1 wood fired Number of Units Installed: ______ Facility is in production: 24 Hours per day: ______ 7 Days per week: ______ 2 x 325klbs/hr, 200klbs/hr Nominal rated capacity of each unit: __________ 365 Days per year: ______ Hours of Downtime Unit #1 Unit #2 Unit #3 Unit #4 Total Scheduled Maintenance na ________ 0 ________ 323 ________ 299 ________ 622 ________ Unscheduled Maintenance na ________ 0 ________ 618 ________ 663 ________ 1,281 ________ Total na ________ 0 ________ 941 ________ 962 ________ 1,903 ________ Availability (%) na ________ na ________ 90% ________ 90% ________ Reprinted (01/14) Page 7 SECTION 5 – TRANSFER OR DISPOSAL DESTINATION Identify the transfer or disposal destination of waste removed by indicating the name of the transfer or disposal facility, the type of solid waste transferred, the corresponding State/Country, the County/Province, the NYS Planning Unit of the transfer or disposal destination facility, and the amount transferred or disposed or used as alternative daily cover (ADC) at each destination. This only includes waste sent off-site for disposal, not metal recovered reported in Section 6. Refer to the list of NYS Planning Units that can be found at the end of this report. DO NOT REPORT IN CUBIC YARDS! Note: This is not the facility identified in Section 1. Please report the facility to which you sent the solid waste. Transport (specify percentages): 100 _____% Road _____% Rail _____% Water _____% Other (specify: __________________________________) Explain which waste types and service areas below are included in these transport methods _____________________________________________________ _______________________________________________________________________________________________________________________________ TRANSFER OR DISPOSAL DESTINATION TYPE OF SOLID WASTE SOLID WASTE MANAGEMENT FACILITY TO WHICH IT WAS SENT (Name & Address) DESTINATION STATE OR COUNTRY DESTINATION COUNTY OR PROVINCE DESTINATION NYS PLANNING UNIT (See Attached List of NYS Planning Units) AMOUNT TO TRANSFER DESTINATION (TONS) AMOUNT TO DISPOSAL DESTINATION (TONS) AMOUNT USED AS ADC (TONS) TOTAL YEAR (TONS) New York Niagara Niagara 96,861 96,861 Allied Landfill, Niagara Falls, NY New York Niagara Niagara 76,509 76,509 New York Niagara Niagara 0 0 Modern Landfill, Model City, NY Ash (MSW Energy Recovery) Bypass Emergency Authorization Waste (Storm Debris) Other (specify) Modern Landfill, Model City, NY 15,559 Bulkies 188,929 TOTAL SENT (tons): ______________ Reprinted (01/14) Page 8 SECTION 6 – METAL RECOVERED Provide the tonnages of metal recovered from the mixed solid waste stream. Identify the location or solid waste management facility to which the recovered metal was sent from your facility, by indicating the name of the facility, the type of metal recovered, the corresponding State/Country, the County/Province, the NYS Planning Unit, and the amount recovered. Refer to the list of NYS Planning Units that can be found at the end of this report. DO NOT REPORT IN CUBIC YARDS! Note: This is not the facility identified in Section 1. Please Transport (specify percentages): report the facility to which you 100 sent the recovered metal. _____% Road _____% Rail _____% Water _____% Other (specify: ____________________________________________) Explain which waste types and service areas are in these transport methods___________________________________________________________________ ________________________________________________________________________________________________________________________________ METAL RECOVERED FOR REUSE/RECYCLING DESTINATION STATE OR COUNTRY DESTINATION COUNTY OR PROVINCE Niagara Metals, Niagara Falls, NY New York Niagara Southern Recycling, Henderson, KY Kentucky DESTINATION METAL RECOVERED (Name & Address) DESTINATION NYS PLANNING UNIT (See Attached List of NYS Planning Units) R9 TONS RECOVERED (out of facility) 15,451 Ferrous Metal 1,399 Non-Ferrous Metal Other Metal (specify) 16,850 TOTAL METAL RECOVERED (tons): _________________ Reprinted (01/14) Page 9 SECTION 7 - FIRE AND SAFETY INCIDENTS Provide a summary of the time, date, and details of any incidents which required the implementation of the contingency plan. The contingency plan was not activated during the year. ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ SECTION 8 - BUDGET Provide an annual income and expense statement providing details on the major accounting items and operating and maintenance costs. See http://investors.covantaholding.com/GenPage.aspx?IID=103347&GKP=209632 for Covanta's form 10-K. ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ SECTION 9 - INSPECTIONS Provide a copy of the annual facility inspection report conducted and stamped by a professional engineer licensed to practice in New York State. A copy of the facility inspection report is attached. ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ SECTION 10 - GOALS Provide a narrative of the goals and objectives to be attained in the next future calendar year and any major repairs or renovations proposed. Construction of a rail spur and natural gas boiler pending DEC permit approval. ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ Reprinted (01/14) Page 10 SECTION 11 – UNAUTHORIZED SOLID WASTE Has unauthorized solid waste been received at the facility during the reporting period? ■ Yes No If yes, give information below for each incident (attach additional sheets if necessary): Date Received Type Received Date Disposed Disposal Method & Location Radiation Monitoring X Yes _____ No Does your facility use a fixed radiation monitor? _____ LFM-2 Identify Manufacturer _____________ and Model _________________ of fixed unit. Thermo Electron X Yes _____ No Does your facility use a portable radiation monitor? _____ Bicron Micro Analyst of fixed unit. Identify Manufacturer _____________ and Model _________________ If the radiation monitors been triggered give information below for each incident: Received Incident Number Date Time Removed Hauler Origin Truck Number Reading Disposal Status Date Time See Attached Reprinted (01/14) Page 11 SECTION 12 - COST ESTIMATES AND FINANCIAL ASSURANCE DOCUMENTS Are there required cost estimates and financial assurance documents for closure? Yes No If yes, attach additional sheets reflecting annual adjustments for inflation and any changes to the Closure Plan? SECTION 13 – PROBLEMS Were any problems encountered during the reporting period (e.g., specific occurrences which have led to changes in facility procedures)? Yes ■ No If yes, attach additional sheets identifying each problem and the methods for resolution of the problem. SECTION 14 – CHANGES Were there any changes from approved reports, plans, specifications, and permit conditions? Yes ■ No If yes, attach additional sheets identifying changes with a justification for each change. SECTION 15 - PERMIT/CONSENT ORDER REPORTING REQUIREMENTS Are there any additional permit/consent order reporting requirements not covered by the previous sections of this form? Yes ■ No If yes, attach additional sheets identifying the reporting requirements with their respective responses. Reprinted (01/14) Page 12 SECTION 16 - SIGNATURE AND DATE BY OWNER OR OPERATOR Owner or Operator must sign, date and submit one completed form with an original signature to the appropriate Regional Office (See attachment for Regional Office addresses and Solid Waste Contacts.) The Owner or Operator must also submit one copy by email, fax or mail to: New York State Department of Environmental Conservation Division of Materials Management Bureau of Permitting and Planning 625 Broadway Albany, New York 12233-7260 Fax 518-402-9041 Email address: swpermit@gw.dec.state.ny.us I hereby affirm under penalty of perjury that information provided on this form and attached statements and exhibits was prepared by me or under my supervision and direction and is true to the best of my knowledge and belief, and that I have the authority to sign this report form pursuant to 6 NYCRR Part 360. I am aware that any false statement made herein is punishable as a Class A misdemeanor pursuant to Section 210.45 of the Penal Law. ________________________________ Signature Chris Schifferli ________________________________ Name (Print or Type) 2/25/2014 _______________________ Date Environmental Engineer ________________________ Title (Print or Type) cschifferli@covanta.com _______________________________________________________________ Email (Print or Type) 100 Energy Blvd. ________________________________ Address NY 14304 ________________________________ State and Zip Niagara Falls ________________________ City 716 278 8524 (_____)_____-____________ Phone Number X ATTACHMENTS: ____ YES ____ NO (Please check appropriate line) Reprinted (01/14) Page 13 NYS PLANNING UNITS When completing the annual report, please use the Planning Unit listed below that corresponds with the municipality and county. Note: The Planning Unit is not the DEC Region. NYS PLANNING UNITS in R1: Babylon (Town) Brookhaven (Town) East Hampton (Town) Fishers Island Waste Management District Glen Cove (City) Hempstead (Town) Huntington (Town) Islip Resource Recovery Agency Long Beach (City) North Hempstead Solid Waste Management Authority Oyster Bay Solid Waste Disposal District Riverhead (Town) Shelter Island (Town) Smithtown (Town) Southampton (Town) Southold (Town) (except Fishers Island) NYS PLANNING UNITS in R2: New York City NYS PLANNING UNITS in R3: Dutchess County Orange County Putnam County Rockland County Solid Waste Management Authority (RCSWMA) Sullivan County Ulster County Resource Recovery Agency (UCRRA) Westchester County NYS PLANNING UNITS in R4: Capital Region Solid Waste Management Partnership (CRSWMP) MUNICIPALITY Southold (Town) Islip (Town) North Hempstead (Town) Oyster Bay (Town) (see last page) MUNICIPALITY Bronx Kings (Brooklyn) New York (Manhattan) Queens Richmond (Staten Island) MUNICIPALITY MUNICIPALITY Albany (City) Altamont (Village) Berne (Town) Bethlehem (Town) East Greenbush (Town) Green Island (Town / Village) Guilderland (Town) Knox (Town) New Scotland (Town) Rensselaer (City) Rensselaerville (Town) Voorheesville (Village) Westerlo (Town) COUNTY Suffolk Suffolk Suffolk Suffolk Nassau Nassau Suffolk Suffolk Nassau Nassau Nassau Suffolk Suffolk Suffolk Suffolk Suffolk COUNTY Bronx Kings New York Queens Richmond COUNTY Dutchess Orange Putnam Rockland Sullivan Ulster Westchester COUNTY Albany Albany Albany Albany Rensselaer Albany Albany Albany Albany Rensselaer Albany Albany Albany Page 14 NYS PLANNING UNITS When completing the annual report, please use the Planning Unit listed below that corresponds with the municipality and county. Note: The Planning Unit is not the DEC Region. NYS PLANNING UNITS in R4 (continued): Colonie (Town) MUNICIPALITY Cohoes (City) Colonie (Town) Colonie (Village) Menands (Village) Columbia County Delaware County COUNTY Albany Albany Albany Albany Columbia Delaware Active Members Eastern Rensselaer County Solid Waste Management Authority (ERCSWMA) Castleton-on-Hudson (Village) Hoosick Falls (Village) Nassau (Village) Pittstown (Town) Schaghticoke (Town) Schaghticoke (Village) Stephentown (Town) Valley Falls (Village) Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Inactive Members Berlin (Town) Grafton (Town) Hoosick (Town) Nassau (Town) Petersburg (Town) Poestenskill (Town) Greene County Montgomery-Otsego-Schoharie Solid Waste Management Authority (MOSA) Schenectady County NYS PLANNING UNITS in R5: Clinton County Essex County County of Franklin Solid Waste Management Authority (CFSWMA) Fulton County Hamilton County Saratoga County Warren County Washington County NYS PLANNING UNITS in R6: Development Authority of the North Country (DANC) Oneida-Herkimer Solid Waste Authority (OHSWA) Montgomery County Otsego County Schoharie County MUNICIPALITY MUNICIPALITY Jefferson County Lewis County St. Lawrence County Oneida County Herkimer County Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Rensselaer Greene Montgomery Otsego Schoharie Schenectady COUNTY Clinton Essex Franklin Fulton Hamilton Saratoga Warren Washington COUNTY Jefferson Lewis St. Lawrence Oneida Herkimer Page 15 NYS PLANNING UNITS When completing the annual report, please use the Planning Unit listed below that corresponds with the municipality and county. Note: The Planning Unit is not the DEC Region. NYS PLANNING UNITS in R7: Broome County Cayuga County Chenango County Cortland County Madison County Onondaga County (except Skaneatles (T) & (V)) Oswego County Tioga County Tompkins County NYS PLANNING UNITS in R8: Chemung County GLOW Region Solid Waste Management Committee MUNICIPALITY MUNICIPALITY Genesee County Livingston County Monroe County Ontario County Orleans County Schuyler County Seneca County Steuben County Wayne County Yates County NYS PLANNING UNITS in R9: Allegany County Cattaraugus County Chautauqua County GLOW Region Solid Waste Management Committee Niagara County Northeast - Southtowns Solid Waste Management Board (NEST) MUNICIPALITY Wyoming County Akron (Village) Alden (Town) Alden (Village) Angola (Village) Aurora (Town) Blasdell (Village) Boston (Town) Brant (Town) Cheektowaga (Town) Clarence (Town) Colden (Town) Collins (Town) Concord (Town) Depew (Village) East Aurora (Village) Eden (Town) Elma (Town) Evans (Town) Farnham (Village) Gowanda (Village) COUNTY Broome Cayuga Chenango Cortland Madison Onondaga Oswego Tioga Tompkins COUNTY Chemung Genesee Livingston Monroe Ontario Orleans Schuyler Seneca Steuben Wayne Yates COUNTY Allegany Cattaraugus Chautauqua Wyoming Niagara Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Erie Page 16 NYS PLANNING UNITS When completing the annual report, please use the Planning Unit listed below that corresponds with the municipality and county. Note: The Planning Unit is not the DEC Region. NYS PLANNING UNITS in R9 (continued): MUNICIPALITY COUNTY Hamburg (Town) Erie Hamburg (Village) Erie Holland (Town) Erie Lackawanna (City) Erie Lancaster (Town) Erie Lancaster (Village) Erie Marilla (Town) Erie Newstead (Town) Erie Northeast - Southtowns Solid Waste Management Board (NEST) North Collins (Town) Erie (continued) North Collins (Village) Erie Orchard Park (Town) Erie Orchard Park (Village) Erie Sardinia (Town) Erie Sloan (Village) Erie Springville (Village) Erie Wales (Town) Erie West Seneca (Town) Erie Amherst (Town) Erie Grand Island (Town) Erie Kenmore (Village) Erie Northwest Communities Solid Waste Management Board (NWCB) Tonawanda (City) Erie Tonawanda (Town) Erie Williamsville (Village) Erie NOT CURRENTLY AFFILIATED WITH A RECOGNIZED PLANNING UNIT Brunswick (Town) Rensselaer Buffalo (City) Erie Canaan (Town) Columbia Coeymans (Town) Albany North Greenbush (Town) Rensselaer Oyster Bay (Town) (portion) **See Below Nassau Ravena (Village) Albany Sand Lake (Town) Rensselaer Schodack (Town) Rensselaer Skaneatles (Town) Onondaga Skaneatles (Village) Onondaga Troy (City) Rensselaer Watervliet (City) Albany **MUNICIPALITIES NOT PART OF THE TOWN OF OYSTER BAY SOLID WASTE DISPOSAL DISTRICT Bayville (Village) Laurel Hollow (Village) Oyster Bay Cove (Village) Brookville (Village) Matinecock (Village) Roslyn Harbor (Village) (portion) Centre Island (Village) Mill Neck (Village) Sea Cliff (Village) Cove Neck (Village) Muttontown (Village) Upper Brookville (Village) East Hills (Village) (portion) Old Brookville (Village) Glenwood – Glen Head Garbage District Lattington (Village) Old Westbury (Village) (portion) Page 17 January 2014 New York State Department of Environmental Conservation Division of Materials Management Bureau of Permitting and Planning MATERIAL MANAGEMENT PROGRAM CONTACTS CENTRAL OFFICE Bureau of Permitting and Planning 625 Broadway Albany, NY 12233-7260 Phone: (518) 402-8678 For Submission of Annual Reports only: Fax: (518) 402-9041 Email : For solid waste management facilities: swpermit@gw.dec.state.ny.us ; REGIONAL OFFICE ADDRESS & LEAD CONTACT PERSON REGION 1 (Nassau, Suffolk) Syed Rahman SUNY @ Stony Brook 50 Circle Road Stony Brook, NY 11790 Phone: (631) 444-0375 REGION 2 (Bronx, Kings, New York, Queens, Richmond) Samsudeen Arakhan 47-40 21st Street Long Island City, NY 11101-5407 Phone: (718) 482-4896 REGION 3 (Dutchess, Orange, Putnam, Rockland, Sullivan, Ulster, Westchester) Thomas Rudolph 21 South Putt Corners Road New Paltz, NY 12561 Phone: (845) 256-3179 REGION 4 (Albany, Columbia, Delaware, Greene, Montgomery, Otsego, Rensselaer, Schenectady, Schoharie) Victoria Schmitt 1130 North Westcott Road Schenectady, NY 12306 Phone: (518) 357-2243 Page 18 REGION 5 (Clinton, Essex, Franklin, Fulton, Hamilton, Saratoga, Warren, Washington) Main Office (Clinton, Essex, Franklin, Hamilton) Sub-office (Fulton, Saratoga, Warren, Washington) Dale Becker Route 86, P.O. Box 296 Ray Brook, NY 12977 Phone: (518) 897-1241 David Mt. Pleasant 232 Golf Course Road Warrensburg, NY 12885 Phone: (518) 623-1230 REGION 6 (Herkimer, Jefferson, Lewis, Oneida, St. Lawrence) Main Office (Jefferson, Lewis, St. Lawrence) Peter Taylor State Office Building 317 Washington Street Watertown, NY 13601 Phone: (315) 785-2513 Sub-office (Herkimer, Oneida) Robert Senior State Office Building 207 Genesee Street Utica, NY 13501 Phone: (315) 793-2745 REGION 7 (Broome, Cayuga, Chenango, Cortland, Madison, Onondaga, Oswego, Tioga, Tompkins) Tim DiGiulio 615 Erie Boulevard West Syracuse, NY 13204 Phone: (315) 426-7419 REGION 8 (Chemung, Genesee, Livingston, Monroe, Ontario, Orleans, Schuyler, Seneca, Steuben, Wayne, Yates) Scott Foti 6274 East Avon-Lima Road Avon, NY 14414 Phone: (585) 226-5408 REGION 9 (Allegany, Catttaraugus, Chautauqua, Erie, Niagara, Wyoming) Dennis Weiss 270 Michigan Avenue Buffalo, NY 14203 Phone: (716) 851-7220 Page 19 Section 3 – SERVICE AREA SERVICE AREA TYPE OF SOLID WASTE Industrial Waste (Including Industrial Process Sludges) SOLID WASTE MANAGEMENT FACILITY FROM WHICH IT WAS RECEIVED (Name & SERVICE AREA COUNTY OR PROVINCE SERVICE AREA NYS PLANNING UNIT OR DIRECT HAUL SERVICE AREA STATE OR COUNTRY Direct Haul Tennessee 585 Direct Haul New York 41,753 Direct Haul California 2 Direct Haul Georgia 12 Direct Haul Canada 42,490 Direct Haul Rhode Island 2,659 Direct Haul Iowa 1,678 Direct Haul Michigan 48,885 Direct Haul Indiana 1,584 Direct Haul Kentucky 2,471 Direct Haul Louisiana 409 Direct Haul Wisconsin 2,402 Direct Haul Ohio 9,071 Direct Haul Pennsylvania 6,445 Direct Haul West Virginia 363 Direct Haul New Jersey 4,063 Direct Haul Missouri 154 Direct Haul Puerto Rico 1,872 Direct Haul Massachusetts 2,537 Direct Haul Illinois 1,946 Direct Haul Virginia 939 Direct Haul Connecticut 1,666 Address) (See Attached List of NYS Planning Units) TONS RECEIVED SERVICE AREA TYPE OF SOLID WASTE SOLID WASTE MANAGEMENT FACILITY FROM WHICH IT WAS RECEIVED (Name & SERVICE AREA COUNTY OR PROVINCE SERVICE AREA NYS PLANNING UNIT OR DIRECT HAUL SERVICE AREA STATE OR COUNTRY Direct Haul North Carolina 1,464 Direct Haul Maryland 241 Direct Haul Minnesota 15 Direct Haul Vermont 261 Ontario, Canada Transfer Stations Ontario Canada Direct New York Erie R9 New York Erie Buffalo 261 New York Otsego MOSA 16,922 New York Chautauqua Chautauqua County 322 Canada Ontario na 422 Address) (See Attached List of NYS Planning Units) Ontario Transfer Stations TONS RECEIVED 258,183 301,686 Mixed Municipal Solid Waste (Residential, Institutional & Commercial) None. Sewage Treatment Plant Sludge Treated Regulated Medical Waste (TRMW)* Roswell Park Buffalo NY Environmental Service Corporation Stericycle Dunkirk Stericycle Toronto SERVICE AREA TYPE OF SOLID WASTE Emergency Authorization Waste (Storm Debris) Other (specify) SOLID WASTE MANAGEMENT FACILITY FROM WHICH IT WAS RECEIVED (Name & Address) OR DIRECT HAUL SERVICE AREA STATE OR COUNTRY SERVICE AREA COUNTY OR PROVINCE SERVICE AREA NYS PLANNING UNIT (See Attached List of NYS Planning Units) TONS RECEIVED None. None. TOTAL RECEIVED (tons): 753,763 Part 360 Permit Limit (tpy): 821,250 tons per year Permit Limit based on Steaming rate (tpy): Not Applicable * List generators that provide you Certificates of Treatment forms and quantities of TRMW from each : All four companies shown above Section 11 – UNAUTHORIZED SOLID WASTE Radiation Monitoring The following information is from when the radiation monitors were triggered: Received Incident Number Date Time Removed Hauler Origin Truck Number Reading Disposal Status 11/5/13 Modern East Side Transfer T-47 >19 Disposed on 11/12/13 when reading was 4.43 kcounts/min 9/23/13 Village of Kenmore Kenmore 3087 7.35 Disposed on 10/9/13 when reading was 5.05 kcounts/min 10/16/13 Modern East Side Transfer 1939 >19 Disposed on 10/24/13 when reading was 1.19 kcounts/min 10/16/13 Modern Amherst 2435 8.38 Disposed on 10/24/13 when reading was 4.51 kcounts/min 11/22/13 Modern Blasdell A-79 18.10 Disposed on 11/29/13 when reading was 1.62 kcounts/min 7/11/13 Modern Niagara Falls 3216 >19 Disposed on 9/7/13 when reading was 5.08 kcounts/min 11/7/13 ATL Wasteco Queensway 8.31 Disposed on 12/2/13 when reading was 0.83 kcounts/min 8/29/13 Modern East Side Transfer 12.35 Disposed on 9/4/13 when reading was 2.8 kcounts/min 9/8/13 AWL Hamburg 9.43 Disposed on 9/18/13 when reading was 5.53 kcounts/min 7/12/13 Modern Amherst, NY 3326 18.86 Disposed on 7/29/13 when reading was 5.08 kcounts/min 7/19/13 Modern Blasdell T-48 >19 Disposed on 8/8/13 when reading was 1.37 kcounts/min 4/20/13 Andrews Trucking REMM Guelph, ON 2470 >19 Disposed on 5/25/13 when reading was 1.29 kcounts/min 2/27/13 Town of Tonawanda Tonawanda 2769 13.5 Disposed on 2/27/13 when reading was 4.69 kcounts/min 2/4/13 Cam Hiltz Wasteco Orenda 800104 6.10 Disposed on 3/15/13 when reading was 1.33 kcounts/min T-31 Date Time 2/25/13 Town of Tonawanda Town of Tonawanda 3237 >19 Disposed on 3/21/13 when reading was 5.89 kcounts/min 4/4/13 Modern East Side Transfer 2181 >19 Disposed on 4/19/13 when reading was 1.69 kcounts/min 2/25/13 Modern Transfer Station 19935 8.65 Disposed on 3/7/13 when reading was 4.65 kcounts/min 3/19/13 Cam Hiltz Guelph 800113 >19 Disposed on 4/9/13 when reading was 4.85 kcounts/min 7/16/13 Allied Waste Niagara Falls 2770 >19 Disposed on 8/2/13 when reading was 5.81 kcounts/min 7/31/13 Town of Tonawanda Town of Tonawanda 2769 >19 Disposed on 8/20/13 when reading was 5.38 kcounts/min 10/17/13 BFI Packer Allied Grand Island 2023 8.42 Disposed on 10/21/13 when reading was 5.42 kcounts/min Covanta Niagara 2013 General Facility Inspection Report NIAGARA RESOURCE RECOVERY FACILITY 2013 ANNUAL FACILITY INSPECTION REPORT By Kenneth E. Armellino - #075733 February 21, 2014 Signed:U M Date: 2/21/2014 Rev. 1 It is a violation of NYS Jaw for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara General Facility Inspection Report 2013 THIS PAGE LEFT BLANK 2/21/2014 Rev. I It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara 1 General Facility Inspection Report 2013 INTRODUCTION The New York State Department of Environmental Conservation (NYSDEC), Division of Solid Waste, document 6 NYCRR Part 360 Solid Waste Management Facilities, Subpart 360-3, SOLID WASTE INCINERATORS OR REFUSE-DERIVED FUEL PROCESSING FACILITIES OR SOLID WASTE PYROLYSIS UNITS, paragraph 360-3.3(h)(6) states: (6) At least annually, a general facility inspection must be undertaken to determine the operating condition of the safety, emergency, security, process, and control equipment. This annual inspection must be performed under the direction of an individual licensed to practi~e engineering in the State of New York. This individual must prepare a summary repon of the inspection which must be submitted to the depanment's central office and the office of the depanment administering the region within which the facility is locate~. as part of the annual facility report (see paragraph 360-3.4(f)(3) of this Pan). This requirement is part of the Solid Waste Permit to Operate #9-2911-00113/00023 (expiration 3/21/15) for the Niagara Reso_urce Recovery Facility, located at 100 Energy Blvd at 55th Street, Niagara Falls, NY 14304, owned and operated by Covanta Niagara, Inc. This report covers the operation and inspection for the year 2013. The inspection and report were carried out by Kenneth E. Armellino, a licensed Professional Engineer in the State of New York (# 075733) and Director, Environmental Science and Community Affairs for Covanta Energy, Inc. located at 445 South St., Morristown, New Jersey 07960. The site inspection and conclusions are based review of compliance with company technical standards, as well as an inspection and document review on December 17, 2013. The site inspection was cond_ ucted included the assistance of Chris Schifferli, the Environmental Engineer at the facility, and other various employees as necessary. 2 OBJECTIVE The objective of this summary report is to document the annual general inspection to determine the operating condition of .the specified plant equipment. This summary report is grouped into the following 4 sections: 1. Safety and emergency equipment. 2. Security equipment. 3. Process & control equipment, i.e. refuse boilers/stokers, air pollution control equipment, turbine and residue and auxiliary systems. 4. Preventive maintenance management system. Page I 2/21/2014 Rev. I It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara 3 General Facility Inspection Report 2013 FINDINGS The operating condition of the safety, emergency, security, process and control equipment at the Covanta Niagara facility, as summarized in the following paragraphs, was found to be acceptable. 3.1 Safety & Emergency Equipment 3.1.1 Fire Protection All observed fire protection equipment (alarms, pumps, valves, extinguishers, etc.) were found to be in proper alignment, in acceptable condition and undergoing quarterly and annual inspections and tests by certified contractors and insurance inspectors, or site personnel, as required. The most recent testing of the sprinkler systems and the refuse bunker fire water showed all systems were functional 3.1.2 Safety Valves All boiler steam safety valves were observed to be in acceptable condition and undergoing annual maintenance and in-situ testing by facility personnel and certified contractors. Balance of plant safety valves also appear to be being maintained. The safety valves on DBA boilers No. 3 and 4 were last tested as required in 2013. 3.1.3 Self-Contained Breathing Apparatus Self-contained breathing apparatus devices are stored in several areas throughout the plant site; outside the logic room on the 2nd floor of the DBA boiler building and on the 3rd floor of "B" building in the safety room. Facility safety personnel inspect the devices ·on a regular basis as part of a PM work order. The devices inspected appear to be in excellent condition. 3.1.4 Personal Protective Equipment Employees and contractors use hard hats, steel toe boots, uniforms, and hearing and eye protection. Workers, as required, were observed to use appropriate breathing protection/respirators. Additional personal protective equipment is required and available for specific tasks. It should be noted that all areas inspected were neat and clean, i.e. free from tripping or slipping hazards. 3.1.5 Eyewash & Shower Stations All emergency eyewash and shower stations were observed to be in satisfactory condition. Facility personnel inspect the emergency eyewash/shower station integrity on a weekly basis. Portable eyewash stations have water changed/treated as required. 3.1.6 Lightning Protection The lightning protection system appeared to be in satisfactory condition and is maintained by the facility. The facility is continually assessing the adequacy of the lightning protection systems and making upgrades as determined necessary. Page 2 2/21/2014 Rev. I It is a violation of NYS Jaw for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara 2013 General Facility Inspection Report 3.1. 7 Radiation Detection Radiation detection monitors are installed at both the inbound and outbound scales and are operational. The detectors are currently set to alarm at 3.2 kcpm (background is 1.5 kcpm), and loads are not allowed to unload if the reading is greater than 6.0 kcpm. The two truck scale monitors have valid calibrations and appeared to be in good operating condition. Labels on the monitors showed them to be properly calibrated within the last year. The handheld monitor used by the plant also is properly calibrated. 3.2 Security Equipment 3.2.1 Fencing The facility perimeter fencing was observed to be free from breaks and in acceptable condition. 3.2.2 Entrance Gates The main entrance and exit gates are operational. All vehicles qiust a gate with a security guard. pa~s through 3.2.3 Security Cameras The facility interior areas are monitored by a camera system. Display monitors for the system are in the facility control room and are observed reg.ularly by the control room operator. 3.3 Process & Control Equipment 3.3.1 Boiler/Stoker During the inspection boilers 3 and 4 were in service. Boilers 1 (natural gas) and 2 (wood) were also on line to meet customer steam demands. A fifth boiler, fueled by natural gas, is in the permitting process. · 3.3.1.1 Boiler/Stoker Performance 3.3.1.1.1 Boiler Heat Output/Losses Based upon historical operating data and current operating conditions, the two units continue to generate steam at permitted levels. Steam conditions approximate design. Review of economizer exit flue gas temperatures and boiler draft losses indicate a normal, acceptable boiler operation. Observed residue quality was good without excessive unburned material. 3.3.J.J.2 Availability Availability for 2013 for the facility was 89.7%. This availability level is indicative of the facility's acceptable maintenance and operations practices. Page 3 2/21/2014 Rev. 1 It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara General Facility Inspection Report 2013 3.3.1.1.3 Refuse Processing The facility NYSDEC permitted throughput is 821,250 tons per year based on a calendar year. Refuse processed in 2013 was 749,596 tons. The plant did not bypass. any processible waste or transfer any processible waste from the facility, so the plant is processing all the acceptable waste that is delivered. The new liquid storage tank facility was put into service in 2012. The new facility consists of six (6) storage tanks with a combined storage capacity of 300,000 gallons. The tanks are in a concrete containment dike. The tanks are vented to the OBA boilers' primary air fan duct so that air/vapor from the tanks is burned in the boilers. Gasket material was breaking down in some instances and plugging strainers. This material was cleaned out of the affected tanks and addressed. A new 13.8 kV transformer, fire protection, and containment were installed to supplement the electrical feed to the facility's systems. 3.3.1.1.4 Energy Recovery The plant averaged a gross electricity recovery ratio in 2013 of.3~8.5 kWh/ ton of refuse processed. In total the facility generated 246,245 gross megawatts in 2013. The Niagara plant generates less electricity compared to similarly sized solid waste combustion facilities because the Niagara plant provides the steam demands of six neighboring manufacturing plants. The facility exported 3,013,070 klbs of steam to external customers in 2013. 3.3.1.2 Boiler/Stoker Critical Control Loops Critical control functions of the boiler were reviewed. Furnace draft control and boiler drum level control are the critical control parameters. Both of these parameters were observed to be controlled automatically with stable results. Both boilers were observed to be operating in auto/cascade mode. . . Note that instrument inputs associated with critical control loops and essential operating data are calibrated regularly. This is part of the Covanta technical standard of which an annual report is issued. The last report from the Niagara facility showed no significant variances from these standards. Informative, redundant and local instrumentation are calibrated only on an as-needed basis. 3.3.1.3 Boiler/Stoker Mechanical 3.3. 1.3. 1 Boiler Tube Failures The plant is primarily managing tube corrosion by replacing tube sections, but also continues to perform ultrasonic thickness test surveys, apply various protective overlays in the furnace and replace tube shields on superheater and generating bank tubes. Outage assessment reports indicate which areas require targeted focus, and those areas are worked into future outage scopes and planning. Page4 2/2112014 Rev. 1 It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara General Facility Inspection Report 2013 3.3.1.3.2 Fans & Dampers All ID, primary and secondary combustion air fans were operating normally with no obvious noise or excessive vibration alarms. Fan/motor vibration levels are monitored regularly by facility operators on rounds, and during preventive maintenance. 3.3.1.3.3 Boiler/Grates Miscellaneous 1. Feed rams and grate drives were observed to operate evenly. 2. Observation doors located at the rear of the boiler were clean and functional. 3. Ash extractors were functioning. 4. Lighting and labels remain excellent throughout the boiler building. 5. Sootblowers continue to operate normally and undergo routine maintenance. 3.3.2 Turbines No oil leaks were observed and vibration indications were all normal. Major overhauls are performed on a five to eight year cycle. A major overhaul was performed on Turbine 1 in 2011 and for Turbine 2 in 2012. Combined turbine availability was 89.5% in 2013 . ......... ... 3.3.3 Air Pollution Control (APC) Equipment 3.3.3.1 APC Operating Data & Stack Emissions A review of CEMS data and the facility's CEMS compliance record for 2013 shows that the air pollution control system appears to be performing very well. Review of monthly operating data for the year showed that scrubber and baghouse draft losses for both units are being maintained at acceptable levels implying that the flue gas paths are being maintained in an acceptably clean condition. APC flue gas data observed on both units showed air infiltration to be in an acceptable range. 3.3.3.2 APC Critical Control Loops Critical control functions of the air pollution control system were reviewed. Lime slurry delivery rate as a function of S02 concentration, with a minimum flow are the critical control parameters. The lime slurry control loop is functional. The scrubber outlet temperature control was observed to be functional and stable. 3.3.3.3 APC Miscellaneous Air pollution control system observations are as follows: 1. All SDA and baghouse discharge valves & all screw conveyors were functioning. 2. Baghouse repairs to address corrosion continue to be completed. New thimbleless stainless steel floors and 8 foot stainless steel lower walls continue to be installed and maintained. All the fabric filter bags in both baghouses were Page5 2/21/2014 Rev. I It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara 3. 4. 5. 6. General Facility Inspection Report 2013 replaced in 2010. Bags are on a 6 year schedule. Stainless steel lining continues in all units to address corrosion. Insulation appeared to be in sound condition, with ductwork expansion joints neatly insulated with insulation jackets. The urea system appeared to be in acceptable condition, with no evidence of urea leakage detectable. Due to Greenhouse Gas reporting requirements, the solid waste fired DBA units had flue gas flow monitors installed in 2011. Diesel generators had catalytic converters installed on exhaust outlets to meet new regulations. 3.3.4 Residue & Fly-ash 1. All fly-ash conveyors were operating and were adequately containing the ash. 2. The ash loadout area was being cleaned at the time of the inspection. New ferrous and non-ferrous systems were installed and started up in 2012. The facility continues to work on optimizing the system's performance. 3. A new magnet was added for separation of the over stream. This is a stronger, rare earth magnet. 4. Improved lighting has been installed in the ash load out building. · 5. Operating procedures include operation of a street sweeper several times weekly except during inclement weather. 6. Many areas where residue has a potential to migrate off site via stormwater have received improved controls and capture for reuse internally. 3.4 Preventive Maintenance 3.4.1 Preventive Maintenance System The facility is using the Maximo maintenance program to generate and track· corrective work orders, and for preventive maintenance work orders. 3.4.2 Outage Schedules The facility conducted maintenance outages on each of the operating units in 2013 sufficient to maintain the equipment in good working condition. A 10-day (annual) scheduled boiler outage was done on each of the DBA boilers. On-line cleaning techniques are used, as ne.cessary, to clean boiler tube surfaces and maintain optimum operating conditions. A 3 day cold iron outage was performed to tie in steam lines for a new steam customer. Outages provide the facility a chance to perform maintenance on critical equipment, perform equipment assessments, and gather data to develop future outage scopes so that the facility continues to run in an acceptable manner. 3.4.3 Outage Tasks Documentation of work performed during outages for the two units was reviewed and indicate that appropriate activities relative to boiler and air pollution control system maintenance are being performed. Page 6 2/21/2014 Rev. 1 It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Covanta Niagara General Facility Inspection Report 2013 3.4.4 Forced Outage Work List The preventive maintenance/work order system contains a category for the type of outage required, i.e. boiler or full plant. A list of items can be queried and printed quickly should an unexpected forced outage occur. 4 CONCLUSION Based upon the above inspections and information, review of company standard compliance, and the conditions observed during site visits, as well as my normal interactions with the facility in the due course of my duties, it is my opinion that the safety, emergency, security, process and control equipment at the Covanta Niagara facility, located at 100 Energy Blvd at 55th Street, Niagara Falls, NY 14304 and owned and operated by Covanta Niagara, Inc. are in acceptable operating condition. Page7 2/21/2014 Rev. I It is a violation of NYS law for any person, unless he or she is acting under the direction of a licensed engineer, to alter any item contained within this report in any way. Doc OM-11 Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 COVANTA NIAGARA O&M Manual SECTION 11 COVANTA NIAGARA, L.P. Niagara Resource Recovery Facility CLOSURE PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 6 Doc OM-11 Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 COVANTA NIAGARA O&M Manual CLOSURE PLAN The following steps will be taken when the closing of the Covanta Niagara facility is anticipated. 1. Covanta Niagara will notify in writing the NYSDEC at least 180 days prior to the date closure is to begin. 2. Covanta Niagara will not accept any waste after the date closure is to begin. 3. Within 30 days after receiving the final quantity of waste, Covanta Niagara will: Combust all solid waste on hand. Clean up all solid waste from the solid waste storage areas – tipping floor, refuse bunker, and boiler feed systems. Clean all boilers (walls, tube sections, etc.) of ash residue. Clean all pollution control devices (scrubbers, baghouse filters, etc.) of ash residue, treatment chemicals, etc. Remove ash and clean all ash silos, conveyors and ash extractors. Clean out all sumps, trenches, etc. Clean all outside areas of any debris. Remove any residual liquids from the liquid waste injection storage tanks. Wash the inside of the liquid waste injection storage tanks. 4. All ash and residual solid waste will be taken to an approved (NYSDEC) disposal site. 5. Within 180 days after receiving the final quantity of solid waste, Covanta Niagara will: Empty and then mothball all tanks containing water treatment, air pollution control, and fire suppression chemicals. Remove from site and properly dispose of, all chemicals (some of which could be returned to vendor) in bags, pails, totes, drums, etc. Empty all storage tanks, equipment reservoirs, etc. that contain fuel oil, hydraulic oil, diesel fuel etc. Remove from site and, if necessary, properly dispose of (some of which could be returned to vendor) all fuel oils, hydraulic oils, electrical oils, hydraulic oil drums full or empty, grease containers full or empty, etc. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 6 Doc OM-11 COVANTA NIAGARA O&M Manual Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 Drain all pipe lines. Properly dispose of all oils and chemicals. Disconnect electrical services (using appropriate method) to all electrical equipment unless equipment is to remain connected for periodic exercising. 6. After closure has been completed, Covanta Niagara will have a licensed professional engineer (licensed to practice in New York State) inspect the facility and assure that closure has been done in accordance with the steps above. 7. After the licensed professional engineer has completed the facility inspection, a certification that the facility has been closed in accordance with this plan will be submitted to the NYSDEC. An estimated cost to close the facility is shown in Table 11-1. The cost is in year 2012 dollars and based on the US Department of Labor Statistics Consumer Price Index (CPI-U). Current costs can be calculated by obtaining the correct inflation factors. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 6 Doc OM-11 Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 COVANTA NIAGARA O&M Manual Table 11-1 CLOSURE PLAN COST ESTIMATE Description Cost 30 DAYS 1. Clean Up All Solid Waste From the Solid Waste Staging Areas Tipping Floor Refuse Bunker RMW Pit (includes disinfectant wash) Charging Deck (includes disinfectant wash) Boiler Feed System Cranes C-Building Surge Bins $3,000 $15,000 $15,000 $3,000 $4,500 $3,000 $7,500 $1,500 2. Clean All Boilers of Ash Residue No. 3 and No. 4 Boiler Tubes No. 2 Boiler Tubes No. 3 and No. 4 Boiler Roller Grates No. 3 and No. 4 Boiler Sifting Ash Hoppers $15,000 $3,000 $7,500 $7,500 3. Clean All Pollution Control Devices of Ash Residue and Treatment Chemicals No. 3 and No. 4 Boiler Scrubbers No. 3 and No. 4 Boiler Baghouse Filters No. 2 Boiler Precipitator No. 2, No. 3 and No. 4 Boiler Flue Gas Ducts No. 2 and DBA Stacks (bottom) $7,500 $15,000 $6,000 $7,500 $1,500 4. Remove All Fly and Bottom Ash No. 3 and No. 4 Boiler Ash Extractors No. 2 Boiler Quench Tank No. 2 Boiler Conveyors No. 2 Boiler Ash Silo DBA Ash Load Out Building and Associated Equipment No. 2 Boiler’s “A”, “B” and 5/6 Transfer Towers $6,000 $1,500 $4,500 $4,500 $15,000 $7,500 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 6 Doc OM-11 COVANTA NIAGARA O&M Manual Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 Description 5. Clean Out All Sumps, Trenches, etc. DBA Boilerhouse Sumps DBA Boiler’s Baghouse Trenches DBA Ash Load Out Building “A” Building “B” Building “C” Building Surface Water Sump $4,500 $3,000 $1,500 $3,000 $4,500 $1,500 $6,000 6. Clean All Outside Areas of Any Debris $6,000 7. Clean the Liquid Waste Injection Storage Tanks Remove and Dispose of Any Residual Liquid Waste Wash the Inside of all the Liquid Waste Storage Tanks Cost $7,500 $7,500 180 DAYS 8. Empty and Clean All Chemical Tanks Water Treatment Air Pollution Fire Suppression Chemicals $7,500 $3,000 $1,500 9. Remove From Site and Properly Dispose of Chemicals in Bags, Pails, Totes, Drums. (Some can be returned to vendor.) $15,000 10. Empty All Storage Tanks, Equipment Reservoirs that Contain Fuel Oil, Hydraulic Oil, Diesel Fuel No. 2 Boiler Quench Tank No. 2 Boiler Surge Bin “C” Building Parascrews DBA Boiler’s Ash Extractors ALO Building Clam Shells “D” Building Turbines DBA Boiler’s Atomizers $1,500 $1,500 $1,500 $1,500 $1,500 $6,000 $1,500 11 . Remove From Site and, If Necessary, Properly Dispose of All Fuel Oils, Electrical Oils, Drums, Grease, etc. $6,000 12. Drain All Pipe Lines, Properly Dispose of All Oils / Chemicals $12,000 13. Disconnect Electrical Services to All Electrical Equipment Unless Equipment Is To Remain Connected for Periodic Exercising. $3,000 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 6 Doc OM-11 Rev. No. 3 Revision Date: 5/29/13 Reviewed Date: 5/29/13 COVANTA NIAGARA O&M Manual Description Cost TOTAL COST $270,000 Major Revisions: 11/8/05 Facility name change from American Ref-Fuel Company of Niagara to Covanta 3/19/12 Plan modified to include the clean out and washing of the liquid waste injection storage tanks when the facility is closed 5/29/13 Costs revised and updated to 2012 dollars. Decommissioned equipment have been removed from Table 11-1. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 6 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-8 EXPOSURE CONTROL PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 34 of 37 COVANTA NIAGARA, L.P. Exposure Control Plan Employee Exposure to Potential Bloodborne Pathogens I Introduction At Covanta Niagara, the potential exists for employees to be exposed to Bloodborne pathogens in the waste stream. The potential also exists through employees who are trained in American Red Cross CPR and basic first-aid. Employees who are trained would respond on a volunteer basis only as Covanta Niagara does not maintain a first-aid response team or require any employee to serve as a responder. This procedure will address two types of exposure which are, a known source or an unknown source. These terms will be defined in the next section. II Definitions A) Exposure incident: Specific contact with eye, mouth, nose (or any other mucous membrane area), open wound, cut or puncture of the skin which contacts any blood, body fluid or other potentially infectious material. B) Known Source: Any item which arrives at Covanta Niagara from the BFI Medical Waste Facility, Sheridan, NY. These items are medical waste which has been treated in a New York State Certified autoclave and has therefore been rendered decontaminated. C) Unknown Source: Any item which arrives at Covanta Niagara from any source other than BFI Medical Waste Facility and therefore its origin cannot be verified. D) HBV: Hepatitis B Virus. E) HBV Vaccination: A series of three shots given at set intervals. This vaccine can be given prior to or immediately following an exposure incident. F) HBV Immunity: Can be from the vaccination or from prior HBV illness. A blood test can be administered to verify immunity. (Check for antibodies to Hepatitis B surface antigen.) G) HIV: Human Immunodeficiency Virus Note: Hazardous waste in not accepted at the Niagara facility. COVANTA NIAGARA, L.P. Exposure Control Plan Employee Exposure to Potential Bloodborne Pathogens III Page 2 Training Covanta Niagara has trained plant personnel on the bloodborne pathogen standard. A packet of information was reviewed that covered: • • • • • • • • • OSHA bloodborne pathogens standards. Bloodborne Diseases Work Place Transmission Personal Protective Equipment Precautions Reducing Your Risk Work Practice Control Good Housekeeping HBV Vaccination A video is also used to reinforce the above topics once training is completed. A quiz is administered to measure level of understanding. Those individuals failing the quiz are re-trained until a higher level of understanding is achieved. IV Safety Aspects A) Proper PPE is worn at all times to eliminate potential exposure. B) All potential exposures are reported to supervision and documented immediately. C) HBV vaccinations were made available to all Covanta Niagara employees in September 1993. D) All Covanta Niagara employees hired after September 1993 were informed of the availability of the HBV vaccination. Any employee who elects not to receive the HBV vaccination must complete and sign a refusal form. (Attachment 1.) E) HBV vaccinations are effective following an exposure incident and will be made available if the employee chose not to receive the vaccination prior to exposure. COVANTA NIAGARA, L.P. Exposure Control Plan Employee Exposure to Potential Bloodborne Pathogens V Page 3 Procedures A) Known Source Exposure Incident: If an employee is exposed to a known treated material, the wound should be cleaned with soap and water immediately. This cleaning should be followed by the use of an antiseptic in the affected area. The wound should then be covered to prevent any further exposure. No further medical attention should be necessary at this time providing the contact was with a known (and verified) source prior to contact with other material. The supervisor is notified and an Exposure Incident Report filled out. (Attachment 2.) B) Unknown Source Exposure Incident: If an employee is exposed to an untreated or unknown material, several precautions must be taken as soon as possible. The supervisor is notified and an Exposure Incident Report filled out. (Attachment 2.) 1. 2. 3. 4. 5. Attempt to isolate and contain material which was contacted. Clean affected area with soap and water immediately. Apply antiseptic to affected area. Cover area to keep clean and prevent further contact. Refer to the Exposure Incident Report for further precautions and information regarding medical monitoring information. Note: If first aid or any assistance is administered by any other employee, latex exam gloves must be worn. These gloves are available in all first-aid kits. HEPATITIS FACT SHEET Definition “Hepatitis” means inflammation of the liver. It may be caused my medicines, alcohol, chemicals, and a variety of infectious agents. Types of Hepatitis There are a number of types of Viral Hepatitis. All are caused by a type of germ called a virus and all are infectious but are spread in different ways. Those of most concern are: • Hepatitis A (Infectious Hepatitis) • Hepatitis B (Serum Hepatitis) • Hepatitis C • Non-A / Non-B Hepatitis A The virus that causes Hepatitis A is present in the bowel movements (feces) of infected persons. In most cases, the virus must be ingested to cause infection. It may be found in food contaminated by direct contact with an infected person’s soiled hands, on objects such as linen and clothing in contact with the feces of an infected person, or in a raw shellfish harvested from waters polluted with sewage. The virus may also be spread by contaminated needles or blood. Only those persons who live in the same house or apartment with an infected person or have very intimate, physical contact are considered to have a significant risk of contracting the disease. Occupational risk of exposure would be very rare. Hepatitis B Hepatitis B is caused by a virus totally different from the virus that causes Hepatitis A. The Hepatitis B virus circulates in the bloodstream and is excreted in the infected person’s body fluids. The disease may be spread by contact with blood or blood products that contain the virus or by contact with objects contaminated with infectious blood or blood products. The virus is also present in other body fluids like saliva, semen and vaginal secretions. Thus, very close personal or sexual contact may cause infection of Hepatitis B. Hepatitis C and Non-A / Non-B Hepatitis C and Non-A / Non-B are viruses much like the Hepatitis B virus. They circulate in the bloodstream and are excreted in the infected person’s body fluids. Over 80% of the blood transfusion-associated cases of viral Hepatitis and 20% of the rare cases of Hepatitis are probably due to Non-A / Non-B or Hepatitis C. Hepatitis B. Hepatitis C and non-A / non-B potentially can be transmitted from an incident that causes a worker to have direct contact with Hepatitis-contaminated blood or other body fluids through a needle stick, an open wound, non-intact skin, or a splash to the eyes, nose or mouth. Signs and Symptoms of Hepatitis Early recovery and the opportunity to take preventive steps to protect others from viral hepatitis is possible with recognition of the signs and symptoms and testing the blood for the virus. Persons with viral Hepatitis may have some or all of these: • • • • • Aches in the head, back or joints Fever, nausea and vomiting Tenderness over the liver or a heavy feeling in abdomen A washed-out feeling, like flu Yellow (jaundiced) appearance of the skin and the eyes The above symptoms can vary widely from person to person. Some infected persons will have no symptoms while others will experience mild to moderate illness. Still others will experience very serious illness. Unfortunately, some will die from the disease and 6-10% of all Hepatitis infected persons will become a carrier of the disease. Treatment There are no drugs that cure Hepatitis. No antibiotics are known to kill the virus-causing disease. Rest, proper nutrition, avoiding alcohol and time are important in a person’s recovery. Hepatitis Vaccination • • • • • Based on current knowledge, Hepatitis B vaccine provides protection against illness and development of the carrier state. This protection lasts 9 years, perhaps longer. Immunization schedule requires three (3) doses of vaccine: initial injection; then second, one (1) month later; and third, at six (6) months. Once immunized, antibodies will reduce below detectable levels within 1-7 years in many people. But if these individuals are exposed to HBV, they develop a rapid recall of the antibody response and the person does not become ill or develop HBV carrier state. Some people experience soreness at the injection site. Some people experience mild symptoms (fever, headache, tiredness or nausea). There have been no severe side effects observed. Attachment 1 COVANTA NIAGARA HBV VACCINATION Approval / Refusal Form Employee Name ___________________________________SSN: _______________________ Department_______________________________________Job Title: ___________________ Covanta Niagara has made available to all of its employees information on the Hepatitis B Virus and Vaccine. Each employee is advised to read this information and complete the form below: ------------------------------------------------------------------ I have received and read the information sheets provided to me regarding HBV and HIV. Based on this information, Covanta Niagara has given me the opportunity to receive the HBV vaccination at no cost to me. I further understand that this vaccination can be given at a later date if I am involved in an exposure incident at Covanta Niagara. ________________(initials) __________Yes, I would like to receive the HBV three shot vaccination series provided by Covanta Niagara. __________No, I do not wish to receive the HBV vaccination at this time. Employee Signature________________________________________Date: ________________ Safety Supervisor Signature__________________________________Date: _______________ _____ Advise employee to report to his doctor for any illness that may occur during the evaluation period, particularly fever, rash, fatigue or flu like symptoms. _____ Advise employee to refrain from donating blood prior to receiving test results. _____ Advise employee to refrain from or to use protective measures during sexual encounters. _____ Advise employee that counseling will be made available to him/her and their family if requested. _____ If female employee, advise not to breast feed prior to receiving test results. _____ Give employee HBV and HIV informational sheets from SOP. Supervisor Signature: ______________________________________Date: _________________ Employee Signature: _______________________________________Date: ________________ Attachment 2 COVANTA NIAGARA EXPOSURE INCIDENT REPORT GENERAL INFORMATION Employee Name: ______________________________________ Date: ___________________ Job Classification _____________________________________ SSN: ___________________ Job being performed at time of exposure (be specific): __________________________________ Location of job being performed: __________________________________________________ Route of exposure (open wound, mucous membrane, needle stick, etc.) ___________________ Type of material contacted (blood or other fluid): ______________________________________ Type of exposure: Known __ Unknown __ Was material recovered and isolated? Y___ N___ TREATMENT PROCEDURES Was first-aid administered per SOP? Y___ N___ Did employee have prior HBV Vaccination? Y___ N___ If no prior vaccination, does employee want to receive vaccination now? Y___ N___ Date of last tetanus shot: __________ (must be within 5 years). Booster needed? Y___ N___ Advise employee of the need for baseline testing and medical monitoring. Employee has the right to have blood drawn now for future testing (within 90 days). All information will be held in confidence. Refused blood sample for testing: Y___ N___ Consents to sample for future testing: Y___ N___ Consents to immediate blood sample and testing: Y___ N___ If testing is to be done, a separate form will be filled out to track medical monitoring. COUNSELING AND FOLLOW-UP HIV / AIDS – FACT SHEET FACTS: • It is estimated that 1 to 1.5 million Americans are infected with HIV, “Human Immunodeficiency Virus.” Most HIOV infections develop into AIDS (“Acquired Immunodeficiency Syndrome”). • HIV lives only in blood and certain other body fluids. It cannot live or grow outside these environments. • HIV infection may be identified through testing the blood for the presence of HIV antibodies. • Antibodies against HIV in an infected individual’s blood can be detected by a series of tests. Tests that show the presence of antibodies are said to be “positive”. • Most people infected with HIV have detectable antibodies within 6 months of infection, with the majority having detectable antibodies between 6 to 12 weeks after exposure. • Some HIV-infected persons suffer less severe symptoms than those with diagnosed cases of AIDS. These lesser symptoms may include loss of appetite, weight loss, fever, night sweats, skin rashes, diarrhea, tiredness, lack of resistance to infection and swollen lymph nodes. • AIDS is the result of the progressive destruction of a person’s immune system which is the body’s defense against disease. This destruction allows diseases that the body can normally fight to threaten the person’s health and life. • A dangerous form of pneumonia, cancer, and certain other infections often invade a body weakened by HIV. • HIV can also attack the nervous system and cause damage to the brain. This may take years to develop. The symptoms may include memory loss, indifference, loss of coordination, partial paralysis or mental disorder. RISK FACTOR FOR HIV INFECTION: The risk factor for HIV infection is behavior. Lifestyle behaviors associated with the transmission of the virus are: intravenous drug use and unprotected, indiscriminate sexual activities. Situations that cause a worker to encounter HIV-contaminated blood or other fluids by needlestick or contact with an open wound or broken, nonintact skins, or mucous membranes of the eyes, nose or mouth, have the potential for infection. There is no risk of transmission of the virus from a HIV-infected person to coworkers through ordinary workplace contact. The Centers for Disease Control studied health care workers who were exposed to blood known to be HIV positive. Most of the workers were stuck by needles that have been used on AIDS patients of the workers exposed – 0.35% (less than one percent) became infected with the AIDS virus. SIGNS AND SYMPTOMS: If infected with the human immunodeficiency virus, a mononucleosis or flu-like syndrome may occur within two months after exposure. • • • • • • • fever diarrhea rash muscle pain joint pain fatigue swollen lymph nodes Some persons infected with the human immunodeficiency virus will develop a persistent, generalized disorder of the lymph system (lymphadenopathy) that lasts more than three (3) months. There are specific diseases considered indicators of AIDS. The most common infections and causes of death in AIDS patients are: • • • • A parasitic disease – Pneumocystis caring pneumonia– “PCP” A malignant skin cancer – Kaposi’s Sarcoma – “KS” Fungal diseases such as candidiasis Viral diseases such as cytomegalovirus IF A POTENTIAL EXPOSURE TO BLOODBORNE PATHOGENS OCCURS: • • • Wash and clean wound with soap and water. Report incident to your supervisor and safety manager. Go to the clinic for proper medical care which will include: • Blood tests for antibodies to Hepatitis B surface antigen and HIV counseling provided prior to testing and continued as needed. • Repeat HIV testing at: 6 weeks after exposure 12 weeks after exposure 6 months after exposure • HBIG (Hepatitis B Immune Globulin) provides temporary protection against Hepatitis B (Passive protection from HBIG only – lasts up to 6 weeks.) • Hepatitis B Vaccine will provide protection for at least nine (9) years – probably longer. Schedule: 1st injection 2nd injection 3rd injection ASAP 1 month later 6 months from 1st injection YOUR MEDICAL RECORDS AND TESTING WILL BE KEPT CONFIDENTIAL Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-9 HAZARDOUS WASTE IDENTIFICATION TRAINING PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 35 of 37 HAZARDOUS WASTE TRAINING Revised June 9, 2009 PAGE 1 ATTACHMENT 3-9 HAZARDOUS WASTE TRAINING PLAN TIPPING FLOOR OPERATORS 1. The Covanta Niagara facility is a solid waste management facility that is permitted to receive only non-hazardous waste. 2. Hazardous waste that Niagara can not accept are those wastes that are USEPA hazardous wastes 3. Tipping floor operators, through their random inspections of truckloads of municipal solid waste (MSW), are part of Covanta Niagara’s Waste Control Plan to assure that hazardous wastes do not enter the facility. Therefore, tipping floor operators need to know what hazardous wastes are. 4. What is a hazardous waste? • A waste that the EPA or the NYSDEC has specifically designated as a hazardous waste. Examples would be halogenated solvents used in degreasing, such as, 1,1,1 – trichloroethane, carbon tetrachloride, trichloroethylene. • A waste that exhibits a characteristic of a hazardous waste - there are four types of characteristics Ignitability: Examples: Corrosivity: flash point less than 60ºC (140ºF). solvents used for parts cleaning and degreasing paint thinners and paint removing compounds. It is aqueous (water) and has a pH of ≤ 2 or ≥ 12.5. It is a liquid and corrodes steel at a rate greater than 6.35 mm (0.25 inches) per year. Examples: alkaline strippers used to strip paint, caustic (sodium hydroxide), battery acid and other waste acids, phenol wastes, some liquid soaps (some types of Cascade) used in dishwashers . Reactivity: normally unstable and readily undergoes change without detonating. reacts violently with water forms potential explosive mixtures with water when mixed with water generates toxic fumes. Examples: Toxicity: Examples: Cyanide bearing electroplating solutions Ordinances and explosives. If a standard leaching procedure results in specific metals or organic concentrations above specific limits. paint waste containing lead, cadmium, chromium, silver. metal strip baths used to remove paint chrome plating wastes. mercury wastes from batteries. analytical instruments lead acid batteries oily debris, if contaminated with lead or benzene HAZARDOUS WASTE TRAINING Revised June 9, 2009 5. PAGE 2 What might an operator think is hazardous waste but as defined by the regulations is not a hazardous waste? • Household municipal waste is exempt from the hazardous waste regulations. Garbage that has come from a household (as opposed to a commercial establishment or industry) is not considered to be hazardous waste – no matter what the waste is. Example: John Smith throws out a half full 5 gallon container of paint thinner. The paint thinner is ignitable but because it came from a household, it is not a hazardous waste. However, if Covanta Niagara tipping floor operators see it on the tipping floor, they should pull it out of the MSW and Covanta Niagara will properly dispose of it. 6. • Empty containers are not hazardous waste. • If there is no more than one inch of residue remaining in a container, then the container is not a considered to be hazardous waste. How is a tipping floor operator going to find a hazardous waste? • If a hazardous waste is found on the tipping floor, it is very likely that it will be in a container and that the container will be labeled. The label will have a Federal Waste Code. The Federal Waste Code will begin with a “D”, “F”, “K”, “P” or “U” For example a waste that is hazardous because it is ignitable will have a D001 Hazardous Waste Number • During the MSW truck inspections, or at any other time, the operator sees a container that has a “Hazardous” label. The operator needs to look over the container – containers may have a “Hazardous” label but may not be hazardous waste – the containers may have an OSHA or DOT hazardous material that is not a USEPA hazardous waste. • The operator sees a container labeled: “flammable material” “reactive material” “toxic material” and the container has more than one inch of residue. • The operator may smell a heavy organic smell in a particular load of MSW. PROBLEM – Some states (for example Massachusetts, California will designate certain wastes as hazardous in their state but the waste may not be federally designated hazardous wastes. Only wastes that are federally designated hazardous wastes are hazardous wastes in New York. For example, Massachusetts designates waste oil as a Massachusetts hazardous waste. The containers of waste oil generated in Massachusetts will have a hazardous waste label – but the waste number will not be a federal number – it will have a Massachusetts identification number. When that Massachusetts hazardous waste comes into New York State that waste oil is no longer a hazardous waste and can be disposed of at Covanta Niagara. HAZARDOUS WASTE TRAINING Revised June 9, 2009 7. PAGE 3 What should the tipping floor operators do if they find hazardous waste or suspect containers/material may be hazardous waste? • If the container of suspected hazardous waste has already been unloaded and is found on the tipping floor, it should be immediately isolated from the rest of the MSW. • If the truck that delivered the hazardous waste is identified – hold the truck and notify tipping floor supervisor, the plant environmental engineer and the chief engineer. • The New York State Department of Environmental Conservation is to be notified immediately and informed that a container of suspected hazardous waste was found on the tipping floor and the truck identified. It is unlikely that the NYSDEC will allow the container to be put back on the truck - the NYSDEC will require that the container be shipped with a hazardous waste manifest. Therefore Covanta Niagara will have to store the container (either in a flagged off area of the tipping floor or in the oil drum storage containment dike) until the generator can arrange proper transportation. DO NOT RELEASE THE TRUCK UNTIL THE NYSDEC HAS BEEN NOTIFIED AND APPROVED THE RELEASE OF THE TRUCK. • If the source of the hazardous waste is unknown, plant personnel as well as the NYSDEC, must be immediately notified. However, it will be Covanta Niagara’s responsibility to properly dispose of the waste. Any containers of hazardous waste that must be disposed of by Covanta Niagara will be moved to the oil drum storage area concrete dike. If the container is leaking, it will be necessary to place the original container in an overpacked drum before moving the container to the storage area dike. 8. If the tipping floor operator has any concerns/questions/suspicions that hazardous waste may be on the truck (for example, when the truck doors are opened a container with a “Hazardous” label is seen), the operator is not to begin to unload the truck until the environmental engineer, or the Secure Services group in Fairfield, has resolved the issue. If the truck is not unloaded, Covanta Niagara can refuse the load and the truck can be released. However, if a truck carrying suspected hazardous waste is rejected, the NYSDEC must be contacted and told that the truck is being rejected. 9. How does a tipping floor operator distinguish between hazardous waste that should be isolated and removed from the MSW and the exempted or non-regulated hazardous waste that could come in from a household? 10. • Size is a reasonable criteria – if the operator sees a half full 8 ounce or 16 ounce can of paint thinner, degreasing agent, spray paint, etc., then a good case can be made that the material came from a household. If the operator sees a couple of dozen of the cans, then assume they came from a commercial establishment and isolate them. • If the operator sees a half full five gallon container of paint thinner, isolate it from the MSW and call supervision. The tipping floor operators should err on the side of caution. If there is suspect waste or containers, they should be isolated and supervision called to investigate. REMEMBER: EMPTY CONTAINERS ARE NOT HAZARDOUS WASTE HOUSEHOLD WASTES ARE NOT HAZARDOUS WASTE HAZARDOUS WASTE TRAINING Revised June 9, 2009 PAGE 4 THIS FACILITY DOES NOT ACCEPT HAZARDOUS WASTE VARIOUS HAZARDOUS WASTES ARE SPECIFICALLY LISTED YOU HAVE TO LOOK AT THE LISTS ON FILE IN THE PLANT HAZARDOUS WASTES ARE TOXIC Paint Sludge Containing Lead, Cadmium, Chromium, Silver Metal Strip Bath Solution / Sludge Mercury Wastes From Batteries Nickel / Cadmium Batteries Lead Acid Batteries Oil Wastes / Sludges / Rags Containing Lead or Benzene HAZARDOUS WASTES ARE IGNITABLE Solvents for Parts Cleaning/Degreasing Paint Thinners Paint Removers Gasolines HAZARDOUS WASTES ARE REACTIVE Cyanide Bearing Electroplating Solutions Ordinances Explosives HAZARDOUS WASTES ARE CORROSIVE Alkaline Paint Strippers Battery Acids Waste Acids / Caustics Phenol Wastes Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-10 ALTERNATE FUELS QUALITY ASSURANCE / QUALITY CONTROL PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 36 of 37 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 COVANTA NIAGARA, L.P. ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONTROL PLAN This Quality Assurance / Quality Control (QA/QC) plan describes how Covanta Niagara controls the alternate fuels combusted in the EFW 2 furnace/boiler. This plan provides essential protocol and procedures that aids Covanta Niagara in meeting the air emission permit limits while combusting alternate fuels. This plan is comprised of eight main sections that outline: 1. 2. 3. 4. 5. 6. 7. 8. 1. Alternate Fuel Type Source of Alternate Fuel Quantity of Alternate Fuel Received Alternate Fuel Storage Capabilities Alternate Fuel Inspection Procedures Alternate Fuel Personnel Training Alternate Fuel Analysis/Fuel Composition and Blending Record Keeping and Reporting Alternate Fuel Type Covanta Niagara identified two types of alternate fuels, waste wood and photographic paper/film that were available in large quantities and are relatively homogeneous in their characteristics. The New York State Department of Environmental Conservation (NYSDEC) approved both these alternate fuels for combustion in the EFW 2 alternate fuels fired furnace/boiler. However due to changes in the consumer photography market place, the photographic paper is no longer available and is not being burned. If an additional potential alternate fuel(s) is identified in the future, a request to approve the alternate fuel (with supporting combustion characteristic data) will be submitted to the NYSDEC. 1.1 Rev. No. 6 Waste Wood The waste wood fuel that Covanta Niagara now accepts is processed (picked and shredded prior to delivery to the facility) waste woods. Processed wood comes from suppliers, such as construction & demolition (C&D) debris processing facilities that sort and separate the wood from the other material and then chip the wood. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 6 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 The various types of shredded waste wood that can be accepted at the Covanta Niagara facility include: creosote treated wood – shredded railroad ties processed (sorted and chipped) C&D wood sorted and separated, unchipped (whole) C&D wood manufactured wood (pressboard, particle board, plywood) unadulterated wood Waste wood delivered to Covanta Niagara must be essentially free of all non-wood materials of concern. C&D processing facilities will be requested to separate sheet rock, rubber, plastic, shingles, paper, pipe, cable, glass, etc. from the wood. Non-wood items containing sulfur, chlorine, and heavy metals (such as lead, chromium, mercury, etc.) could impact air emissions. Covanta Niagara will specify in contracts that it will not accept for combustion in the EFW 2 alternate fuels fired furnace/boiler any waste wood that contains or has been commingled with any of the following: • • • • • • • • • • • • hazardous wastes asbestos large quantities of C&D debris other than wood wastes tar/asphalt shingle products (contains sulfur) wood painted with leaded paints copper, chromium, arsenate treated wood pentachlorophenol treated wood medical wastes municipal solid wastes (MSW) sheet rock (contains sulfur) plastics (can contain chlorine and heavy metals) rubber (contains sulfur) Because the facility has metal recovery/recycling capabilities, waste wood materials containing ferrous metals (nails, bolts, etc.) will be accepted. 1.2 Photographic Paper/Film Photographic is no longer burned in the alternate fuel fired boiler. 2. Source of Alternate Fuels 2.1 Rev. No. 6 Waste Wood Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 6 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 The source of the wood waste materials will primarily be from C&D debris processing (recycling) facilities, railroad companies, utilities, and wood manufacturing/processing facilities. Each supplier must provide shredded waste wood that is essentially free of the unacceptable material previously listed under “Alternate Fuel Type”. All suppliers will be evaluated to ensure that they have procedures to control the material received at their facility and to ensure they separate, sort, and process the material in order to provide a waste wood that would be acceptable for receipt at Covanta Niagara. When a new potential supplier of waste wood has been identified, the NYSDEC must approve the waste wood. The NYSDEC can either visit the supplier’s facility or the supplier may be allowed to bring a truck load of waste wood to the Niagara facility where the wood would be inspected. In order to ensure that Covanta Niagara’s requirements are being met Niagara personnel will, periodically, visit each source. The name and address of each of the suppliers of wood, as well as, the quantity of wood each delivers will be maintained on file. 2.2 Photographic Paper/Film Because of changes in the consumer photography market, photographic paper/film is no longer available as an alternate fuel. 3. Quantity Received All alternate fuels received at Covanta Niagara will be weighed in through the scale house. Records will be maintained as to the suppliers’ names and the weight and types of alternate fuels received from each supplier. Alternate fuels data will be reported to the NYSDEC as a special section in the Quarterly Part 360 Solid Waste Report. The annual operating hours for the alternate fuels boiler are based on the hourly emission rate of dioxin/furans as determined during the annual compliance stack test. 4. Storage On-Site 4.1 Rev. No. 6 Waste Wood Covanta Niagara has substantial onsite storage capacity. Processed wood wastes (chipped) will be received at the facility and either unloaded directly into the C-Building storage area, or unloaded and stored in a 1-3 acre graveled area just north of the facility. The C-Building storage area has a capacity of approximately 4,000 tons. This building has an extensive fire protection system including: a deluge sprinkling system; a heat activated sprinkling system; and a camera system that is monitored in the control room. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 6 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 Wood waste stored in this graveled area will be stored in piles and will be separated by sufficient space to allow easy access by the fire department. In addition, wood from various suppliers could be stored in separate piles, if necessary, to allow better evaluation of the quality of wood from each supplier. The shredded wood, from the north storage area, will be transported to the “C” building storage area when the wood is needed for use in the alternate fuels fired boiler. 4.2 Photographic Paper/Film No photographic paper/film is currently being burned in the alternate fuels fired boiler. 5. Inspection Procedures Covanta Niagara personnel will conduct periodic inspections of the wood waste both at the suppliers’ locations as well as Niagara’s unloading area. 5.1 Inspection at the Supplier Covanta Niagara has a vested interest in conducting periodic inspections of wood suppliers’ processing and storage facilities to ensure that the suppliers are removing unacceptable materials from the wood. As a necessary precaution, Covanta Niagara personnel will conduct periodic inspections at the wood waste suppliers’ processing/storage facilities. At the supplier, Covanta Niagara personnel will observe trucks unloading C&D debris and other waste woods and will monitor the following activities: • • • • how well personnel separate out the unacceptable material; what is done with the unacceptable material; and how the waste wood is being processed how well supplier personnel understand the need to sort and separate material Suppliers who do not provide adequate sorting/ separating and processing procedures (this will be primarily evaluated by ensuring that suppliers provide a contamination free wood product) will not be used for Covanta Niagara’s alternate fuels project. 5.2 Rev. No. 6 Covanta Niagara Location Inspections All trucks delivering waste wood to Covanta Niagara must be weighed in at the scale house prior to entering the facility. Only those suppliers that are under contract to Covanta Niagara and registered in the scale house computer will be allowed to proceed and unload. In the unloading area, selected loads can be inspected to ensure that the materials brought in meet Covanta Niagara’s QA/QC criteria. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 6 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 If the load is found to have unacceptable material, Covanta Niagara will take one of the following actions: • • • put the entire load back on the truck for return to the supplier; pick out the acceptable wood and put the unacceptable material in the refuse bunker for combustion in the DBA boilers; or put the entire load in the DBA bunker for combustion in the DBA boilers. (Note: material found to be unacceptable for combustion in EFW 2 alternate fuel boiler can only go in the DBA bunker if it is an acceptable waste for those boilers). 6. Rev. No. 6 Personnel Training At the Supplier: Supplier’s Personnel Training All of Covanta Niagara’s potential waste wood suppliers will be provided with a copy of this QA/QC plan and will be requested to train their personnel to sort and separate waste wood material so that Niagara does not receive any of the unacceptable materials. Covanta Niagara personnel will be available to assist the supplier in the training. At Covanta Niagara: Covanta Niagara Personnel Training Covanta Niagara tipping floor personnel will be trained on the types of wood waste that are acceptable, the materials that are unacceptable, how to identify unacceptable material, and what to do with the unacceptable materials. All tipping floor personnel will be taken to a supplier’s location to observe unprocessed wood waste to help in their recognition of acceptable and unacceptable materials. 7. Fuel Analysis/ Fuel Composition/ Fuel Blending Covanta Niagara will do periodic sampling of the alternate fuels, primarily waste wood. Samples of the shredded alternate fuels will obtained from the conveyor belt transfer point. The samples will be sent to an analytical laboratory and analyzed for parameters such as: sulfur, chlorine, lead, chromium, arsenic, ash, and BTU content. 8. Record Keeping and Reporting Covanta Niagara will weigh through the scale house computer system all alternate fuels received from each supplier. The quantity of alternate fuels combusted each day will be calculated based on steam production and combustion efficiency. The hourly heat input can also be verified from the above calculation. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 6 Doc QA/QC-2 COVANTA NIAGARA ALTERNATE FUELS QUALITY ASSURANCE/QUALITY CONROL PLAN Revision Date: 5/13/13 Review Date: 5/13/13 As part of Covanta Niagara’s quarterly Fuel Use Summary and Solid Waste reports the following information, with respect to the alternate fuels combusted in EFW 2, will be included: • • • • • • alternate fuels received during quarter alternate fuels combusted during quarter steam produced during quarter average hourly heat input rate average BTU content of alternate fuels sampled during quarter air emission monitoring data, including : sulfur dioxide mass emission rate, nitrogen oxides mass emission rate, and carbon monoxide mass emission rate MAJOR REVISIONS MADE TO THIS PLAN: 10/31/05 Name change Covanta Niagara Rev. No. 6 from American Ref-Fuel Company of Niagara References to the alternate fuel photographic paper/film were revised to reflect that the material is no longer combusted in the alternate fuel fired boiler. 5/13/13 References to unprocessed wood was removed. Only shredded wood is now accepted at Covanta Niagara. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 6 Doc OM-3 Rev. No. 10 Revised Date: 7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 3-11 ENGINEERING DRAWING EDC-001 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 37 of 37 .. IL\BELIL\ WEST Associates, P.C. Relationships -- D I !""''! ::.:Ii, 2.1 2.1 1--- -r---! 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' CONSTRUCTION ACCESS EASEMENT I I / -- t- ~ / [__ 1-· -- -- ----~ .-- -- . _.\ \ \ L -· ·--· -·- \~ ------------------- --- -- -- ---- -- -- --------- -- --- \ \..--· -· .-- _\ \ 30' TEMPORARY ----------~~~~~~~~---------- ·-- -- 1- - \ I I .--- .- -· \ \ I II II l I I I .---- .- -· .-· ---· I I I I I I I I \ I I I ..- -· Results Engineering Architecture Environmental Planning www.labellapc.com 300 STATE STREET ROCHESTER, NY14614 P: (585) 454-6110 F: (585) 454-3066 , WIND SPEED (M/S) -,-0.5 Resources II is a violation of New York Education Law Article 145 Sec.7209, for any person, unless acting under the direclion of a licensed architect, professional engineer, or land surveyor, to alter an item in any way. If an item bearing the seal of an architect, engineer, or land surveyor is altered; the altering architect, engineer, or land surveyor shall affix to the item their seal and notation "altered by" followed by their signature and date of such alteration, and a specific description of the alteration. COPYRIGHT© 2013 LABELLA ASSOCIATES, P.C. \ \ \ \ • \ \ \ \ \ \ • _____ ..si. _ _ _ _ _ _ _ -~ - ·~ ............. _ TEMPORARY CONSTRUCTION STAGING AREA \L ~MPORARY \ (\ FUELING S\TATION \j. I, __ t::::i·. o • \ __ CONSTRUCTION ENTRANCE 0 \ I E N E R G y for a cleaner world 30'TEMPORARY CONSTRUCTION ACCESS EASEMENT ·- -·- -- - - - - - - 100 ENERGY BLVD. AT 56TH STREET NIAGARA FALLS, NY 14304 STABILIZED CONSTRUCTION ROAD -- - - - -~----- - -·- -- - - - - - - - - - --- - - - -- -·- - -·- --- - - - - - - - - - --·-·- -·- -·- - --- -·- - -· () • • ._ . I I \ \ ';. . .. · · ' \ I \ \ --. .. ...... ·--·--·--·--·--·--·--·--·--·--·--·--· vvz . 1:· . \, .,. 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DATE -·-· -·r B ------CSX LEAD TRACK I \ •• \ SHEET 2 OF 3 \ \ SHEET 3 OF 3 -r-.t--,.- -+-+- -·----· ' •• =----+-~-- I Cf) f g ISSUED FOR BID 0 _J I I I I JUNE 28, 2013 OVERALL SITE & STAGING PLAN ~ .r ~ !t" •~ ~ ~ a... = c.o CV) -.. ~ ~~~ 'o:::::t ..,,;!::;~ N DATE1 ~ :::c i-.:. - ISSUED FOR \ \ \ \ LU LU '' --~----- APPROVED BY: \ 0 I DRAWN BY1 \ \ t- ' ' I i REVISION ··-· - 6-28-13 ISSUED FOR BID - - f - - - + - - - - - --I 0 SHEET 110F 3 NIAGARA RAIL TO TRUCK INTERMODAL FACILITY (RTIF) NIAGARA FALLS, NY '. "-~·''.\'- •' COVANTA NIAGARA L.P. ~ ~ N •~ 0C §~"'! ~ f~~ ~U>~ o<~ @?.~;0~ALL SITE & STAGING PLAN C-001 Doc OM-4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 4 COVANTA NIAGARA L.P. NIAGARA RESOURCE RECOVERY FACILITY STAFFING PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 14 Doc OM-4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 4 COVANTA NIAGARA, L.P. STAFFING PLAN 4.1 INTRODUCTION 4.2 BASIC PLANT ORGANIZATION 4.3 SUMMARY OF JOB DESCRIPTIONS 4.4 ADEQUATE STAFF COVERAGE 4.5 CORPORATE AND REGIONAL SUPPORT Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 14 Doc OM-4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 4 LIST OF ATTACHMENTS ATTACHMENT NUMBER TITLE 4-1 MAJOR REVISIONS TO THE STAFFING PLAN 4-2 NIAGARA FACILITY/RTIF STAFFING PLAN FLOW CHART Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual 4.0 STAFFING PLAN 4.1 INTRODUCTION Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 This document overviews the staffing of Covanta Niagara and provides demonstration that adequate staff coverage is provided for both operating and maintaining the facility combustion units and the Rail-Transfer-to-Intermodal Facility (RTIF). 4.2 BASIC ORGANIZATION 4.2.1 Facility and Combustion Units Staffing The Facility Manager is directly responsible for ensuring that the facility operates in a safe mode, complies with all environmental permit conditions and regulations, and achieves high reliability with respect to production. Assisting the Facility Manager with these functions are the Facility Controller, Chief Engineer, Environmental Engineer, Senior Facility Accountants, NHIW Manager, Principal Engineers, Safety Coordinators, and the Senior Purchaser. The operation of the combustion units is the responsibility of the Chief Engineer who has a Control Room Operator and the Auxiliary Control Room Operator reporting to him. Basic plant operations are handled by four separate operations shift crews working twelve hour days on a rotating basis. Each shift is headed by a Shift Supervisor (reports to the Chief Engineer), who has primary responsibility for plant operations during his/her shift. The Control Room Operator operates the furnace/boilers and monitors and controls all facility systems from the control room panels and screens. As necessary, the Control Room Operator provides direction to the Assistant Control Room Operators, the Back End Operators and the alternate fuels operators who are in the field inspecting and checking equipment and making necessary adjustments to maintain the facility within its established operating parameters. Maintenance of the facility is the responsibility of the Maintenance Superintendent. The Maintenance Planner has mechanical and instrument/electrical supervisors that report to him. Their responsibility is to ensure that the facility achieves on-line reliability through a preventative maintenance program, scheduled repairs, and, as necessary, unscheduled repairs. In addition to Covanta Niagara maintenance personnel, the Maintenance Planner would have overall responsibility for any outside contractors that are brought in to ensure that repairs are completed on time and to the proper specifications. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 In addition to the basic facility operation and maintenance, support services are necessary for a well functioning facility. The Facility Controller is responsible for ensuring that the flow of funds is sufficient to provide for maintaining and operating the facility. The Senior Purchaser ensures facility supplies and equipment are purchased and that contracts are in place for the various contractors and vendors who support various facility functions. The Business Manager is responsible for obtaining municipal solid waste customers for the combustion units. The Safety Coordinators are responsible for ensuring that the facility complies with the Occupational Health and Safety Administration (OSHA) regulations and that plant personnel are properly trained in their respective job functions. The Safety Coordinators report to both the Facility Manager and the corporate regional safety manager. The Environmental Engineer is responsible for ensuring that plant personnel are aware of permit and regulatory restrictions and that systems are in place to ensure compliance and to provide for the necessary reporting. The Environmental Engineer reports to the Facility Manager. Additional support is supplied to the facility during periods of major maintenance and for special projects by regional and corporate engineering safety and environmental personnel. 4.2.2 RTIF Operating Groups The RTIF will be operated on a continuous basis by a staff of full-time Covanta personnel divided into three major groups or departments: Management /Administration, Operations and Maintenance. Where appropriate, Covanta Niagara Facility staff may fulfill the duties of both the combustion units and the RTIF. Management / Administration Group The Management/Administration Group will be responsible for day-to-day management of the RTIF as well as providing all support functions necessary for the successful fulfillment of Covanta’s obligations. All business-related and administrative functions will be managed by a client services representative. Management/Administrative personnel typically work five (5) days per week, but group members are always “on call” with hours scheduled to provide continuous support as required. Responsibility for the operation of the RTIF will rest with the RTIF Superintendent. He has authority, in consultation with the Facility Manager, to make all Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 operating decisions and will remain the point contact for operational issues. The current Health and Safety Coordinator and the Environmental Engineer also support the RTIF Superintendent in the operation of the RTIF. Operations Group The RTIF Superintendent is also the head of the Operations Group and is tasked with the safe, efficient, and environmentally sound operation of the RTIF. An operating crew consists of the following: Lead Utility Operator, Utility Operator(s), Container Handler(s), Operator(s), Driver(s), and General Laborer(s). The Operations Group will typically work eight or more hour days on seven work days per week as required. Staffing levels will be monitored and adjusted by the RTIF Superintendent to ensure safe and efficient processing of all incoming and outgoing waste containers. Maintenance Group The Maintenance Group will work eight-hour shifts. They will be directed by the RTIF Superintendent and will be responsible for all onsite maintenance, repair and preservation of rolling equipment, railcars, containers, track, buildings, and other structures, and equipment. The Maintenance Mechanic is responsible for repairing and refurbishing major parts items. The Maintenance Mechanic, in conjunction with the RTIF Superintendent, ensure supplies and materials are ordered for major repairs, and ongoing period maintenance, thus having all parts and material ready for use. 4.3 SUMMARY OF JOB DESCRIPTIONS 4.3.1 Facility Operation Facility Manager - Responsible for all facility functions, including the operation of the RTIF, provides direction to other management to ensure that operating goals are accomplished safely and in compliance with applicable safety and environmental rules and regulations. The Facility Manager is empowered to make day-to-day decisions on behalf of Covanta Niagara and will serve as the primary interface between Covanta Niagara and the Region on operational matters. Facility Controller - Responsible for all accounting and financial functions including accounts payable, accounts receivable, budgeting, financial statements, inventory, property and support of business issues. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 Senior Purchaser - Responsible for the orderly procurement and inventory of supplies, equipment, spare parts, etc. and for developing contracts with various suppliers of services. Ensures adherence to business policy and procedures. Chief Engineer - Responsible for operating the combustion units from receipt of waste, combustion, to ash residue processing and load out. Maintenance Superintendent - Responsible for ensuring that all combustion unit systems receive preventative maintenance to ensure operations within design parameters and that all major repairs are accomplished in a timely fashion and within specifications. Environmental Engineer - Responsible to ensure that all relevant plant personnel are aware of permit conditions and regulatory requirements that the systems are in place to ensure compliance. Safety Coordinators - Responsible for ensuring that the plant is in compliance with OSHA and that all personnel are properly trained for their specific job functions. Power & Steam Supervisor – Responsible for the operation (however not responsible for personnel) of the DBA mass burn boilers, alternate fuel fired boiler and the air pollution control equipment. Shift Supervisors - Responsible for the running of the plant during their shift. All plant functions are directly under the control of the shift supervisor. The four shift supervisors report to the Chief Engineer. All hourly operations personnel report to a shift supervisor. Auxiliary Supervisor - Responsible for the ash residue processing and loadout systems, liquid waste injection and housekeeping. NHIW Manager - Responsible for the operation of the tipping floor area, plant roadways and grounds, and the receipt and unloading of the non-hazardous industrial waste loads. Control Room Operator - Has responsibility for directly implementing the tasks of the shift supervisor as they relate to operation and monitoring of all plant equipment. Assistant Control Room Operator - Provides assistance to the Control Room Operator in the operation and monitoring of all plant equipment. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 Back End Operator - Provides field implementation of plant requirements on an asneeded basis under the direction of the Shift Supervisor, the Control Room and Assistant Control Room Operators. Materials Handler - These positions assist in providing field implementation of plant requirements on an as-needed basis under the direction of the Shift Supervisor. Materials Handlers include the Ash Load Operators, Crane Operators, and Tipping Floor Operators. Non-Hazardous Industrial Waste Operators – This position is responsible for inspecting, unloading and processing of NHIW. Alternate Fuels Operator – Operates equipment associated with the alternate fuel fired boiler. Plant Service Workers – Responsible for cleaning various areas of the plant. Mechanical Supervisor - Supervises and plans all mechanical maintenance work to ensure that the work is accomplished with a minimum of disruption to Operations. Has implementation responsibility for the preventive maintenance program. Instrumentation and Control Supervisor - Supervises and plans all instrumentation and control work to ensure that all instrumentation and controls are properly maintained, repaired and calibrated so that Operations can efficiently use plant systems. Maintenance Planner - Has primary responsibility to review, plan and schedule maintenance work loads in coordination with the Maintenance Manager and Operations Manager. Project Manager – Provides facility support by coordinating and directing resources necessary to complete various site projects. Maintenance Tech I - Provides implementation of maintenance needs for either the Instrumentation and Control Supervisor or the Maintenance Supervisor, depending on training. Maintenance Tech II - Provides assistance to Maintenance Tech I personnel and their respective supervisors to ensure that all maintenance is accomplished as directed. Maintenance Tech III - Provides assistance to other maintenance personnel on an asneeded basis. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 Plant Engineer - Responsible for mechanical engineering projects and providing support to maintenance and engineering groups. Assists on projects at other Covanta plants. Water Treatment Technician - Maintains plant water within specifications to ensure that the plant equipment is not damaged by unacceptable water quality. Liquid Waste Operator – Has primary responsibility for operating the liquid waste injection system. Senior Facility Accountants - Responsible for all accounts payable and general ledger, along with all billings, receivables and scale house. Accounting Clerk - Responsible for paying all invoices. Store Keeper - Responsible for warehouse inventory. Scalehouse Clerk - Responsible for the weighing in/out of trucks. Administrative Assistant - Responsible for all secretarial duties. 4.3.2 RTIF Operation RTIF Superintendent - reporting to the Facility Manager, will be located at and have dedicated responsibility for the safe, efficient, and reliable functioning of the RTIF. The RTIF Superintendent will manage and direct the operational and maintenance requirements of the RTIF. The RTIF Superintendent’s background and experience will include substantial, supervisory, and management responsibilities for day-to-day operating and/or maintenance functions. Lead Operator - reporting to the RTIF Superintendent, will be located at and have dedicated responsibility for the safe, efficient, and reliable functioning of the RTIF. The Lead Operator will manage and direct the daily operational activities of the RTIF on behalf of and at the direction of the RTIF Superintendent through direct supervision of members of the Operating Group. The Lead Operator, or his designee, will act as the Certified Track Inspector at the RTIF. Container Handler Operators - These operators will be responsible for: the operation of the container handling equipment during the loading and unloading of intermodal containers to and from the railcars:. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 operating the container handlers to load and off load the empty intermodal containers to and from the container storage area,and moving railcars as necessary. The container handler operators will have significant experience in operating heavy machinery, lifting equipment, and/or mobile equipment. Utility Operators - These operators will be responsible for: working with the Container Handler Operators to ensure the safe operation and receipt of railcars and movement of railcars. ensuring that containers are placed correctly on railcars and self-tipping chassis and ensure proper application of lock down mechanisms; and operation of the thaw shed. The utility operators will have significant experience in operating heavy machinery and/or mobile equipment. Drivers - The drivers will be responsible for operating the yard trucks and tipping chassis. The drivers will transport the full intermodal containers from the active railcar loading area to the EfW Facility for off-loading, and the empty intermodal containers back to the active railcar loading area or the empty intermodal container storage area. These drivers will have significant experience in driving trucks, as well as any necessary operating licenses. Container Mechanics –Container Mechanics will be responsible for preventive maintenance and repairs to the RTIF containers. Maintenance Mechanic - Coordinates and supervises the day-to-day activities of equipment maintenance. The Maintenance Mechanic duties will include reviewing and assisting in establishing day-to-day work order priorities, planning and scheduling maintenance work, and completing any necessary maintenance work or repairs. The Maintenance Mechanic will oversee and plan all maintenance work, oversee and provide technical assistance (and safety training as required) on the maintenance tasks performed by the various site personnel, and direct the development of maintenance procedures and instructions and assists in the evaluation and development of recommendations for facility improvements. The Maintenance Mechanic will monitor tool and spare parts requirements and verify that adequate provisions for such items are included in the inventory control systems. The position of Maintenance Mechanic requires an individual having significant experience in equipment and maintenance. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual 4.4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 ADEQUATE STAFF COVERAGE The plant is manned on a continuous basis by an operations shift crew (four crews, twelve hour shifts). Maintenance personnel (mechanics and electrical instrument personnel) are scheduled for day and evening shifts Monday through Friday. As necessary, the Covanta Niagara maintenance staff is supplemented with contract personnel, particularly during scheduled outages. In addition to contract personnel, during scheduled outages the Niagara plant normally receives assistance from corporate engineering as well as the regional maintenance group. Should a process upset occur during the day shift, management personnel are available to assist, if necessary, in correcting the upset and bringing the plant back into stable operating conditions. Should a process upset occur during the night or weekend, all management personnel and most maintenance personnel are available on a 24 hour basis via beeper or telephone. Finally, all supervisory personnel are provided with a phone list to enable coordination in the event of a process upset. This staffing program ensures that all essential positions are covered during normal operations, during repair and most importantly during upset conditions. 4.5 CORPORATE AND REGIONAL SUPPORT The operations, engineering and other support staff based at Covanta’s corporate headquarters located in New Jersey and regional corporate staff based at various facilities includes long time, experienced, highly educated professionals in a number of disciplines including engineering, operations, maintenance, environmental compliance, health and safety, asset management, human resources, management information systems, accounting, finance, and legal. A majority of these individuals, especially those in the technical and operating groups, have grown through the Covanta ranks, with many having gained over 20 years of hands-on experience implementing and operating Covanta facilities. This in-house depth of knowledge benefits all Covanta operations with direct access to the wealth of technical specialists available for problem solving and continual improvement in RTIF operations and maintenance. Supporting the RTIF Project, Covanta will have two key Project staff positions based out of the New York Container Terminal, in Staten Island, NY: Company Site Supervisor – Responsibilities include local contact with contract administrators for the duration of the Service Agreement to verify that all obligations under the Service Agreement are being met. The Company Site Supervisor manages Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 14 Doc OM-4 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 activities related to rail movement, that include: The coordination of rail movements to and from the New York Container Terminal (where the intermodal containers will be loaded on and off railcars and transported to the disposal destination); Communicating and interacting with the disposal destination to measure and monitor rail cycle times to ensure efficient processes; Managing unexpected situations, and coordinating a response plan; and Coordinating with RTIF personnel on equipment (railcar and Intermodal Containers) maintenance, inspections, and repairs. Logistics Assistant – The Logistics Assistant supports the Company Site Supervisor with the responsibilities listed above. The Logistics Assistant is a dedicated resource that serves to manage and coordinate the support staff as required to enhance the RTIF operational efficiency. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 12 of 14 Doc OM-4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 4-1 MAJOR REVISIONS TO THE STAFFING PLAN May 2006 Name change to Covanta from American Ref-Fuel. Sections 4.2 and 4.3 Modifications made to some positions and position descriptions February 2010 Sections 4.2 and 4.3 Modifications made to some positions and position descriptions March 2011 Section 4.3 Modifications made to some positions and position descriptions May 2013 Section 4.3 Modifications made to some positions and position descriptions March 2014 General modifications made to include RTIF staffing and Corporate Support and current Facility Staffing. May 2014 Update section numbers. Minor QA/QC edits. July 2014 Updates to Section 4.5 Corporate and Regional Support Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 13 of 14 Doc OM-4 Rev. No. 7 Revision Date:7/12/14 Review Date: 7/12/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 4-2 NIAGARA FACILITY/RTIF STAFFING PLAN FLOW CHART Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 14 of 14 Attachment 4-2 Facility Controller Senior Accountants Niagara Facility/RTIF Staffing Plan Flow Chart Facility Manager Scalehouse Clerks Administrative Assistants Senior Purchaser Accounting Clerks Safety Coordinators Environmental Engineer Maintenance Superintendent Chief Engineer Plant Engineer(s) Project Manager Power and Steam Supervisor Auxiliary Supervisors Mechanical Supervisor Water Treatment Technicians Plant Service Workers Instrument and Control Supervisor Shift Supervisors NHIW Manager NHIW Operators RTIF Superintendent Lead Operator(s) Company Site Supervisor Logisitcs Assistant Maintenance Planner Control Room Operators Container Handler Operators Storekeeper Asst. Control Room Operators Utility Operators Maintenance Technicians I, II, III Back End Operators Drivers Alternate Fuels and Liquid Waste Operators Container Mechanics Material Handlers Maintenance Mechanics Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 5 COVANTA NIAGARA, L.P. NIAGARA RESOURCE RECOVERY FACILITY ASH SAMPLING AND ANALYSIS PLAN Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 1 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 5 COVANTA NIAGARA ASH SAMPLING AND ANALYSIS PLAN 5.1 INTRODUCTION 5.2 SAMPLING LOCATION - ASH LOADOUT BELT CONVEYOR 5.3 VOLATILE MATTER SAMPLING 5.3.1 WEEKLY ASH SAMPLING 5.4 SEMI ANNUAL ASH CHARACTERIZATION SAMPLING 5.4.1 SAMPLING FREQUENCY 5.4.2 ASH SAMPLING PROCEDURE 5.4.3 ASH PREPARATION PROCEDURE 5.5 LABORATORY ANALYSES 5.5.1 VOLATILE ANALYSIS 5.5.2 TOXIC CHARACTERISTIC LEACHATE PROCEDURE ANALYSES 5.6 DETERMINATION OF RESIDUE CHARACTERISTICS 5.7 QUALITY CONTROL 5.8 AMENDMENTS Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 2 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 5 ASH SAMPLING AND ANALYSIS PLAN LIST OF ATTACHMENTS ATTACHMENT NUMBER TITLE 5-1 MAJOR REVISIONS TO THE ASH SAMPLING AND ANALYSIS PLAN 5-2 CHAIN OF CUSTODY SHEET 5-3 ASH SAMPLING LOG SHEET Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 3 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual SECTION 5 ASH SAMPLING AND ANALYSIS PLAN 5.1 INTRODUCTION An overview of Covanta Niagara's ash management process is described in the facility's Ash Management Plan. A detailed description of the ash processing system is in the Systems Description book. 5.2 SAMPLING LOCATION - ASH LOAD OUT BELT CONVEYOR The ash sampling location is at the ash load out belt (510 Belt) head pulley. The sample is obtained using an L-shaped sampling box that is the same width as the load out belt. The box is mounted on rollers on the housing of the ash chute. When the sample is taken, the operator pushes the box into the load out belt. The box goes in under the belt such that all the ash across the entire width of the belt falls into the box. Given the quantity of ash being loaded out, the operator normally only needs to push the box into the belt and then immediately retract it in order to collect a sufficient quantity of ash. Although the ram in the ash extractor cycles, the slip stick conveyor (a vibrating conveyor) spreads out the bottom ash so that there is usually bottom ash on the load out belt. There will not be bottom ash on the load out belt for short time periods when the ash extractor ram is shutdown to correct a boiler or ash extractor problem. In addition there will be no bottom ash on the load out belt if the slip stick is shut down to clear a jam or other problem. The flyash load out is done, basically, on a continuous basis. The flyash is continuously conveyed from the baghouse to a small flyash silo (the “teacup”) at the top of the ash load out building. The flyash silo operates on a high/low level control. When the level in the tank reaches high level, the flyash is fed to the ash conditioner in which the flyash is wetted before it is discharged onto the 510 conveyor belt (normally on top of the bottom ash). When the level in the tank falls to low level, the flyash feed/conditioner system shuts down and does not restart until the high level is reached. With normal operation it takes the flyash tank approximately 10 to 30 minutes to fill from the low to high level – during which time no flyash will be on the conveyor belt. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 4 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual Operators are instructed to try and time the sampling so that samples are taken when both bottom ash and flyash are on the load out belt. However at the designated sampling time the operator will take the sample of whatever ash is on the load out belt. The operator notes on the ash sampling log whether flyash or bottom ash is present in the sample. 5.3 VOLATILE MATTER SAMPLING The volatile matter sampling procedure is provided to comply with 40 CFR Part 60, Subpart Ea, section 60.56a (f) (9) - procedure for monitoring the degree of municipal solid waste burnout. As required in 6NYCRR Part 360-3.5 (c)(2)(i), the following ash sampling procedure is done at least once per week and the samples analyzed for volatile matter. 5.3.1 WEEKLY ASH SAMPLING 1. At least once per week ash samples are collected in the ash processing building from the ash load out belt at the head pulley as the ash is discharged into the ash hopper. Operations personnel are responsible for obtaining the sample, cone and quartering and preparing the sample for shipment. The plant environmental engineer is responsible for preparing the chain of custody and shipping the sample. 2. Each sampling day, samples will be obtained at approximately the following times: 6:00 AM 8:00 AM 10:00 AM 12:00 Noon 2:00 PM 3. At the designated time using the sampling tray that is the same width as the load out belt, the operator collects the ash as follows: The sampling tray is pushed into the ash load out belt head pulley housing. The sampling tray goes under the belt such that all the ash across the entire width of the belt falls into the box. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 5 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual 4. Revision Date: 3/1/14 Reviewed Date: 3/1/14 Place all the ash collected in the sampling tray, including ash, wire, papers, rags, etc., into the 5-gallon sample bucket. Repeat the procedure at each sampling time, putting all the ash from the sampling tray into the same bucket. After the last sample has been taken, the operator dumps the bucket(s) of ash on the platform by the load out belt, mixes up the ash and cone and quarters the sample. The remaining sample is put into the sample jar, the lid is put on the jar and the sample is then taken to the plant environmental engineer's office. 5. Rev. No. 6 Ash not used in the sample is cleaned up and put into the ash hopper. The 5-gallon sample bucket(s) is stored in the ash loadout building. At the plant environmental engineer's office, the jar will be labeled as follows: Covanta Niagara Date___________ Ash - "Consecutive Numbers Beginning With 1" "year" (i.e., ASH-1-13) 6. The sample will then be stored in the plant environmental engineer's office until it is shipped to the analytical laboratory. 7. A chain of custody sheet (sample copy shown in Attachment 3-1) is prepared and must accompany the samples. The required analysis is "Percent Loss on Ignition." The laboratory is requested to include the signed chain of custody sheet with their report on the ash analyses. 8. If a local analytical laboratory is being used, the sample will usually be picked up by the laboratory or sent to the laboratory using a delivery service. If an out of town analytical laboratory is being used, the sample will be prepared for shipping as follows: The jar with accompanying chain of custody will be packed in a shipping box. The box will be secured with tape. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 6 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual 5.4 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 A label with the laboratory’s shipping address and Covanta Niagara return address will be attached to the box. No other identification is necessary at this time. At this time the sample will be picked up and shipped by a commercial carrier. SEMI ANNUAL ASH CHARACTERIZATION SAMPLING This section describes the ash sampling procedures to comply with the U.S. Environmental Protection Agency's draft guidance for the sampling and analysis of municipal solid waste combustion ash for the toxicity characteristics and 6 NYCRR Part 360-3.5(d). It is the NYSDEC that requires the continuation of the semi annual sampling/analyses for the Toxic Characteristic Leachate Procedure (TCLP). 5.4.1 SAMPLING FREQUENCY Individual ash samples will be collected during a 24-hour period each day for ten (10) consecutive days. In order to ensure samples of a high degree of accuracy, samples will be collected every hour (using the sampling tray at the 510 belt head pulley) over the 24-hour period. Therefore, each day's sample will consist of 24 sampling trays full of combined ash and there will be a total of ten (10) samples during the 10-day semiannual sampling period. It is possible that during the ten day sampling period that a plant process upset could occur. Sampling would only be stopped if a minimum of 75 percent (18 of the 24 individual samples) of the samples during the 24-hour period could not be obtained (no flyash and no bottom ash). Examples of such problems would be: both boilers are taken off line failure of the flyash conditioning systems If, during the 24-hour sampling period, 18 of the 24 ash samples (75% of the samples) can be obtained, then the sample would be considered valid and representative of the ash being sent to the landfill. The sample would be prepared for analysis. If plant problems result in a 24-hour sample being invalid, the sampling period would be extended into the 11th day. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 7 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 After each of the 24-hour sampling periods, the ash sample is prepared for submittal to the analytical laboratory. The composite sample is split into at least two sample containers. Approximately 2 pounds of ash is in each container. One of the containers is submitted to the laboratory while the remaining containers are stored at the Covanta Niagara facility. If a problem develops with the analytical laboratory's procedures/analyses for any of the 10 samples submitted, a duplicate sample(s) held at the facility would be resubmitted for analyses. After the final report has been received from the analytical laboratory, the duplicate samples would be retained, in a storage cabinet at Covanta Niagara, for at least one year. 5.4.2 ASH SAMPLING PROCEDURE Per the USEPA guidelines for ash sampling, the following ash sampling and sample preparation is required. The following procedure will be used for obtaining ash samples: 1. Ash samples will be collected during a 24-hour period. 2. Samples will be collected every hour for 24 consecutive hours or every 20minutes for 8-hours. 3. The 24 consecutive hours of sampling should start at 6:00 AM and finish with the 5:00 am sample the following day. Eight hour sampling will start at 6:00 AM and finish at 2:00 PM. 4. At the time to take the sample, the sampling tray, at the head pulley of 510-belt, is pushed under the head pulley and then quickly retracted. Note: At least 18 of the 24 samples (75 %) must be obtained to have a valid sample. If a sample time is missed, take it up to 15 minutes late – otherwise just skip it. Do not double up and use the tray twice at any of the sample times because a sample was missed. If at least 18 of the 24 samples can not be obtained that sampling will have to be redone – extending the sampling period by at least a day. Sample whatever is on 26-belt at the time of sampling – combined fly and bottom ash, bottom ash only, flyash only Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 8 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 5. After the tray is retracted, the operator uses a shovel to take the ash out of the tray and places the ash into a 5-gallon plastic container(s) that is provided. Obtain the same quantity (i.e. 1, 2 or 3 shovelfuls) of ash in the sampling tray with each of the 24 samples Put all the ash (whatever is in the tray - stones, bricks, flyash) that is obtained in the sample into the sample bucket. Whatever is in the tray goes into the sample bucket. 6. Prior to taking the next sample, clean out the sample tray - all the ash that gets in the sample tray between samples must be cleaned out. For each of the hourly samples, start with a clean tray. 7. Complete the sampling log after each sample is obtained. 8. After the sampling has been completed, take all the buckets of ash to the ash processing area - near the 8-Belt load center. 5.4.3 ASH PREPARATION PROCEDURE At the end of the 24-hour sampling period, the operator is to take the container(s) with ash to the ash sample preparation area where the sample is to be prepared for analyses. The following procedures are to be used to prepare the sample: 1. Take each bucket of ash and put the contents through the 3/8 inch screen screen the material slowly enough so that the screened ash goes into the plastic bin that is under the screen – and is not spilled onto the ground. 2. Take the material that does not go through screen (oversized) and put it into a second bin – being careful not to spill any of the unscreened material onto the ground. 3. Take the oversized material and try and crush it using the steel tamper and / or crusher. Do not crush metal, aluminum or paper materials in the crusher. It may be necessary to crush some of the oversized material with the steel tamper before putting the oversized through the crusher. If this is necessary, put the oversized material on an area of the concrete floor that has been previously cleaned with a broom. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 9 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual 4. Put the oversized material that was crushed with the steel tamper or went through the crusher back through the 3/8 screen. Repeat steps 2 and 3 two more times. Put the material that passes through the 3/8 screen into bin with the other material that passed through the screen. 5. After all the oversized material has been crushed, mix up the ash in the cement mixer and put it into two appropriately labeled sample containers. 6. Label each of the sample containers with the same label for that 24-hour period. The plant Environmental Engineer will supply the sample jars. An example of the label is as follows: Covanta Niagara Ash - TCLP - 3 - 13 Sample Date: ____________ 7. After the sample containers have been prepared, fill a 5-gallon bucket with a sample of the ash and discard the remaining ash and clean out the sample buckets, cement mixer, and screener. The floor area around the ash preparation area must also be swept up. Place an appropriate labeled tag on the 5-gallon bucket. 5.5 LABORATORY ANALYSIS 5.5.1 VOLATILE ANALYSIS Covanta Niagara's contract laboratories analyze the ash for total volatile matter. They use a four step procedure as follows: Weigh sample. Dry ash sample to obtain moisture content. Combust remaining ash in muffle furnace at high temperature ( 500 C). Calculate the percent volatile Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 10 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual The laboratories are known to use slight variations in their procedures. Method 160.3 and Method 160.4 of EPA Publication EPA-600/4-79-020 are the basic procedures used for moisture and volatile matter determination. These methods are modified to accommodate an ash sample as opposed to a water sample. 5.5.2. TOXIC CHARACTERISTIC LEACHATE PROCEDURE ANALYSIS For the semi-annual sampling, analysis will be performed following the procedure of the TCLP, Method 1311, specified in SW-846. Per SW-846 the laboratory will be directed to prepare and analyze the ash samples as follows: Parameter Cadmium Lead Preparation Method After TCLP Extraction Analytical Method After TCLP Extraction 3010 3010 6010 6010 Should any laboratory result produce an analytical report with a value that appears abnormal, the portion of that composite sample held for reanalysis would be submitted to an approved laboratory for dual reanalysis of the contaminant(s) that are suspect. If the dual reanalysis agrees with the original, the original analysis would be used in the hazardous determination. If the dual reanalysis disagrees with the original, the average of the dual reanalysis would be used in the hazardous determination. 5.6 DETERMINATION OF LEACHATE CHARACTERISTICS Whether or not a contaminant exists within a sample of the residue stream at a level that is considered hazardous is determined by following procedures already in place and accepted to analyze other solid wastes, namely a comparison of the 90% upper bound confidence interval to the regulatory thresholds above and in 40 CFR 261.24 Table 1. In order to initially analyze the residue stream, the following steps, or other applicable statistical evaluation found in SW-846, should be followed: 1. Use the sampling procedures in this plan to collect the minimum number of samples necessary (n1 ). Ten (10) composite samples should be collected. Extra composites may be collected during the sampling routines, but not Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 11 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual analyzed, in case any additional composites are determined to be necessary as outlined below. 2. For each contaminant that an analysis was performed, calculate the following properties of the data set (10 values) as indicated below: Data Mean: n (xi) i=1 x = ______ n Data variance: n (xi - x)2 i=1 s2 = __________ n-1 Standard Deviation of Data: 2 s=s Standard Error of the Data: S2 = 3. S_ n If the sample mean (x) of a contaminant is greater than the regulatory threshold for that contaminant, then the data should be analyzed to determine if the results exhibit a normal distribution. If there are one or more significant outliers and the sample mean is less than the sample variance, a normal distribution does not exist. If a normal distribution does not exist, the SW-846 and a 1995 EPA guidance document allow a logarithmic transformation to be completed on the data set. With the logarithmic Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 12 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual transformation the calculation is done using the log normal value for each of the lead and cadmium analytical results. 4. Calculate the confidence interval for the data set. The confidence interval that will be used is 90% Upper Bound (single tailed) confidence interval. If the confidence interval is less than the applicable regulatory threshold a determination of nonhazardous has been achieved and the analysis is complete. Otherwise, no determination is concluded, and the analysis continues as outlined in this plan. The confidence interval will be defined as follows: Ci = x + t.20Sx Note: t.20 is determined from table 9-2 of SW-846. This table is for a two-tailed 80% confidence interval. This t value is the equivalent of a single-tailed 90% confidence interval. 5. If no conclusive determination has been made, calculate the minimum number of samples that should be included in the sample set to make the statistical conclusion valid. This is to be done using the current data set, and following the procedure below. If this number (n 2) is less than the number of sample collected (n), the residue stream analyzed demonstrates hazardous characteristics, and this analysis is complete. If n2 is greater than the number of data points collected (n), either any additional samples that were collected and not analyzed, and/or additional composites should be collected so that more than n 2 samples have been analyzed and used in the determination. To determine n 2 , calculate the average of the data set ( x ) and the variance of the data set (s 2) for each contaminant where: n n 2 (xi) (xi - x) i=1 and i=1 x = ______ s2 = ____________n n-1 with the terms defined as follows: x x1 n s2 = = = = average or mean of the data set an individual data point the total number of data points collected the variance of the data set Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 13 of 19 Doc OM-5 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual 6. Rev. No. 6 Calculate the minimum number of data points required to ensure the necessary accuracy and precision of the analysis. This is done by using the following equation: where (t,20)2 s2 n2 = 2 and n2 = t.20 = RT = = RT - x the minimum number of data points that should be used in the analysis The "t" score for the appropriate degrees of freedom from Table 9-2 of SW-846 the regulatory threshold for the contaminant in question 7. Repeat the basic operations in steps 3 through 6 until either the residue is determined to be non-hazardous, or until additional sampling is impractical. If sampling is no longer practical, the residue stream analyzed demonstrates hazardous characteristics, and this analysis is complete. 5.7 QUALITY ASSURANCE In order to be certain that the terminations made with this plan are accurate, the quality of the data needs to be ensured. This plan has been prepared giving careful consideration to ensuring that the procedures utilized will collect a representative set of samples and provide an unbiased determination of toxicity characteristics. In the field, quality assurance will be accomplished by having the sampling procedures performed by people familiar with this plan. Also, throughout all sampling activities, a person knowledgeable about the purpose of the plan and facility operation will be available. Furthermore, records will be kept. The date, name of samplers, activities performed, sampling times, and any other pertinent information will be recorded and kept on site. Samples collected in the field will be stored in labeled containers to prevent spillage, contamination, or loss. Any tools or devices utilized during sampling should be kept as clean as possible and practical to minimize the possibility of crosscontamination of samples and composites. The composite samples requiring metals analysis will be sent to the laboratory in a timely manner. Samples prepared and sent for analysis will be accompanied by a chain of custody form. Those samples held on site for possible future analysis will be kept in a secure location with limited access by facility personnel. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 14 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 Quality assurance performed by the laboratory will consist of at least one extraction fluid blank, a matrix spike for one sample per group (performed after extraction), duplicate data for one sample per group, and surrogate recoveries for any organics. Note at this time the NYSDEC requires analyses for only lead and cadmium. Laboratory detection limits will be at least one tenth the regulatory threshold for any given contaminant. In addition, the laboratory report will include the number of the extraction fluid and both the initial and final pH of the extraction fluid. The laboratory used for NYSDEC required ash analyses must be approved by the NYSDEC. Currently, Test America, Buffalo, New York (ELAP No. NY 10026) is used for volatile analyses and Element One Laboratories, Wilmington, North Carolina (ELAP No. NY 11882215) is used for the TCLP metals analyses. 5.8 AMENDMENTS Any correspondence between Covanta Niagara and the NYSDEC that amend the requirements of ash sampling and analyses will be attached to this plan. Amendments made to the ash sampling requirements are shown in Attachment 3-4. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 15 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 ATTACHMENT 5-1 MAJOR REVISIONS TO THE ASH SAMPLING AND ANALYSIS PLAN December 2006 Name change to Covanta from American Ref-Fuel Company In section 3.4.3 references to weighing the ash sample and oversized material was deleted. In section 3.6 a revision was made to reflect that a logarithmic transformation can be done on the data if there are significant outliers in the analytical results and the data does not exhibit a normal distribution. Section 3.7 was modified to state that QC Laboratories is used for the TCLP analyses. February 2010 Section 3.4.2 was modified to give more detail as to the sampling procedure. Section 3.4.3 was modified to give more detail as to the ash preparation procedure. March 2011 Sections 3.4.1, 3.4.2 and 3.4.3 have been modified to reflect that the semiannual sampling is now a 24-hour sample instead of an 8-hour sample. Section 3.7 has been modified to state that Element One is the laboratory now used for TCLP analyses. May 2013 Sections modified to reflect the new ash loadout belt – resulting from a major modification to the ash loadout building. March 2014 Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 16 of 19 Doc OM-5 COVANTA NIAGARA O&M/ECOM Manual Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 Minor grammatical edits. Addition of 8-hour sampling protocol to the 24-hour sampling protocol. Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 17 of 19 Doc OM-5 Rev. No. 6 Revision Date: 3/1/14 Reviewed Date: 3/1/14 COVANTA NIAGARA O&M/ECOM Manual ATTACHMENT 5-2 CHAIN OF CUSTODY SHEET Printed copies are not document controlled, refer to “S” drive, ISO 14001 Environmental Management Systems file for latest approved version Page 18 of 19 Element One, Inc. CHAIN OF CUSTODY Lab ID # e 6319-D Carolina Beach Road Wilmington, NC 28412 Phone 910-793-0128 / FAX 792-6853 C CA A4 C CA 1 A5 11/1/13 0800-1600 C CA A6 11/2/13 0800-1600 C CA A7 11/3/13 0800-1600 C CA A8 11/4/13 0800-1600 C CA A9 11/5/13 0800-1600 C CA A10 11/6/13 0800-1600 C CA Type: C-Composite, G-Grab Print Relinquished by: 2 Signature Received by: Relinquished by: Received by: Print Element One, Inc. Form 117.1 - Revision 3.1 X X Niagara R9 X 15,451 X Kentucky X X X X 1,399 X X Matrix: BA-Bottom Ash, FA-Fly Ash, CA-Combined Ash, SO-Soil, AQ-Aqueous, NA-Non-aqueous, OT-Other Company Date Time Via Additional instructions / Lab Notes HCl A3 HNO 3 CA H 2 SO 4 C X X X X X X X X X X X X NewNew York York New YorkYork New York NewNew York New YorkYork New York New YorkYork New NewNew York New New YorkYork York NewNew York New YorkYork NewNew York York New New YorkYork New York NewNew York New YorkYork NewNew York New York NaOH A2 Remarks * Rush work needs prior lab approval. Additional charges will apply. NaS2O3 CA Time Non-Compliance pH Matrix2 C Date # Cntrs Type1 A1 Sample Description / ID Compliance ■ Ascorbic Please email results to cschifferli@covantaenergy.com ***NOTE: NY Report Required*** Delivery Due Date Normal 5 day * 3 day * 2 day * 1 day * None cschifferli@covanta.com TCLP Cadmium per SW846/6020A 716-284-2961 TCLP Lead per SW846/6020A Billing information if different: 716-278-8524 Leach with Solution and Determine Final pH per SW846/1311 Project ID: Semi-Annual Characterization Ash Samples Analyses Requested Determine Leachate Solution pH per SW846/1311 100 Energy Blvd. PO #. Phone Fax Email Email Email Container Type, Plastic or Glass email e1lab@e1lab.com Contact: Company: Covanta Energy Address: Page of
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