ENVIRONMENTAL ASSESSMENT WORKSHEET
Note to preparers: An electronic version of this Environmental Assessment Worksheet (EAW) form and a fact sheet on preparing one are available at the Minnesota Pollution Control Agency (MPCA) Web site http://www.pca.state.mn.us/programs/envr_p.html. A booklet, EAW Guidelines, is also available at the Minnesota Environmental Quality Board (EQB) Web site http://www.eqb.state.mn.us or by calling 651-201-2492. The EAW provides information about a project that may have the potential for significant environmental effects. The EAW is prepared by the Responsible Governmental Unit (RGU) or its agents to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer must supply any reasonably accessible data for — but should not complete — the final worksheet. If a complete answer does not fit in the space allotted, attach additional sheets as necessary. The complete question as well as the answer must be included if the EAW is prepared electronically. Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling 651-757-2101. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw.
1. Project Title: Hennepin Energy Resource Company Capacity Optimization
2. Proposer: Covanta Hennepin Energy 3. RGU: Minnesota Pollution Control Agency Resource Company LP
Contact Person Dan Fish Contact Person Steve Sommer
and Title Environmental Engineer and Title Project Manager
Address 505 Sixth Avenue North Address 520 Lafayette Road North
Minneapolis, MN 55405 St. Paul, Minnesota 55155-4194
Phone (612) 332-9428 Phone (651) 757-2746
Fax (612) 333-7347 Fax (651) 297-2343
E-mail [email protected] E-mail [email protected]
4. Reason for EAW Preparation: EIS Mandatory Citizen RGU Proposer Scoping EAW Petition Discretion x Volunteered
If EAW or EIS is mandatory give EQB rule category subpart number and name:
p-ear1-04 TDD (for hearing and speech impaired only): 651-282-5332 Printed on recycled paper containing 30% fibers from paper recycled by consumers Minnesota Rules Chapter (Minn. R. ch.) 4410.4300 subp. 17d requires the preparation of an EAW “for the construction or expansion of a mixed municipal solid waste energy recovery facility or incinerator, or the utilization of an existing facility for the combustion of mixed municipal solid waste or refuse derived fuel, with a capacity of 30 or more tons per day of input”.
Covanta Hennepin Energy Resource Company LP (Covanta) proposes to remove the fuel use limit contained in Air Emission Permit No. 05300400 – 003 issued by the Minnesota Pollution Control Agency (MPCA) and proposes to modify the Conditional Use Permit #61061 for the Hennepin Energy Resource Company (HERC), a mass-burn municipal waste combustor owned by Hennepin County and operated by Covanta. The Air Emission Permit and Condition #1 of the Minneapolis Conditional Use Permit limit HERC’s throughput of municipal solid waste (MSW) to 365,000 tons per year (tpy) or an annual average of 1,000 tons per day (tpd). Covanta proposes to allow HERC to process at its design capacity of 442,380 tpy.
The language in Minn. R. ch. 4410.4300 subp. 17d suggests that Covanta’s proposal may be subject to a mandatory EAW. However, Minn. R.ch. 4410.0200 subp. 28 defines “expansion” as “an extension of the capability of a facility to produce or operate beyond its existing capacity. It excludes repairs or renovations that do not increase the capacity of the facility”. Furthermore, Minn. R. ch. 4410.0200 subp. 6a defines “capacity” as “the maximum daily operational input volume a facility is designed to process on a continuing basis”.
Covanta is not proposing to change the design capacity of HERC. This EAW is being prepared at the discretion of the Responsible Governmental Unit (RGU), the MPCA.
5. Project Location: County Hennepin City/Twp Minneapolis
NE 1/4 SW 1/4 Section 22 Township 29N Range 24W
GPS Coordinates: Facility center point N 44.9828 W 93.2803
Tax Parcel Number
Tables, Figures, and Appendices attached to the EAW:
Tables
Table 1 –Fuel Use Summary Table 2– Building Height Summary Table 3 – Permits and Approvals Table 4 - 2009 Rejected Waste Summary Table 5 – 2005 to 2009 Landfill Leachate Data Summary Table 6 - Projected Annual Rejected Waste Summary Table 7- Facility Chemical Use and Handling Table 8 - Petroleum Product Storage Table 9 - HERC Emission Sources Table 10 - Summary of Potential and Actual Emissions for the MSW Combustors Table 11 - Summary of Future Potential and Projected Actual Emissions for MSW Combustors Table 12 - CO2e Emissions Summary Table 13 – Summary of Lifecycle Greenhouse Gas Emissions Table 14 - National Ambient Air Quality Standards Table 15 – Minnesota Ambient Air Quality Standards
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 2 Worksheet Table 16 – Summary of Ambient Air Quality Modeling Analysis Table 17 – Summary of Long-Term Risk Table 18 - Summary of Acute Inhalation Risk based on Maximum Modeled 1-hour Concentration Table 19 – IEUBK Modeled Incremental Blood Lead Levels Table 20 -Table 19 Cumulative Inhalation Risk Table 21- Summary of 2006 Noise Monitoring Data Table 22 - MPCA Noise Area Classification Standards
Appendix A – Figures
Figure 1 - Site Location in Hennepin County Figure 2 – Site Topographic Map Figure 3 – Site Plan Figure 4 – Project Location Map Figure 5 – Land Use Map Figure 6 – HERC Water Process Flow Diagram Figure 7 – HERC Storm Sewer Connections Figure 8 – HERC Chemical Storage Figure 9 – Traffic Counts Figure10 – HERC Odor Analysis Sampling Site Locations Figure 11 – Noise Monitoring Sites Figure 12 – Warehouse Districts, Minneapolis and National Register Designation
Appendix B – DNR Division of Ecological Resources Correspondence
Appendix C – Facility Documents x 2008 Production Summary x 2009 Production Summary x HERC Storm Water Pollution Prevention Plan x HERC Spill Prevention Control and Countermeasure Plan
x HERC Biogenic CO2 Sample Results
6. Description:
a. Provide a project summary of 50 words or less to be published in the EQB Monitor.
Covanta proposes to remove the fuel use limit from Air Emission Permit No. 05300400–003, which limits annual fuel use to 365,000 tpy and allow HERC to process up to its design capacity of 442,380 tpy. However, the actual throughput will likely reach only 405,000 tpy due to operational constraints.
b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities.
Covanta proposes to remove the fuel use limit contained in Air Emission Permit No. 05300400 – 003 issued by the Minnesota Pollution Control Agency (MPCA) and proposes to modify the Conditional Use Permit #61061 for HERC, a mass-burn MSW combustor owned by Hennepin County and operated by Covanta.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 3 Worksheet The HERC location and layout are shown in Figures 1-4. The City of Minneapolis issued CUP #61061 for the HERC on April 10, 1987, prior to its construction. At the time the CUP was issued, Minnesota Statutes (Minn. Stat.) § 383B.235 limited the average daily throughput of a resource recovery facility built in the City of Minneapolis to 1,000 tpd.
In January 2000, Minn. Stat. § 383B.235 was revised to eliminate the 1,000 tpd limit (Minnesota Session Laws 2000, ch. 488, art. 3, sec. 30):
“Existing facility may use its capacity. Notwithstanding subdivisions 1 and 2, an existing resource recovery facility may reclaim, burn, use, process, or dispose of mixed municipal solid waste to the full extent of its maximum yearly capacity as of January 1, 2000. The facility must comply with all federal and state environmental laws and regulations and must obtain a conditional use permit from the municipality where the facility is located.”
Project Description
By original design, HERC has a rated daily processing capacity of 1,212 tpd of MSW which equates to a maximum yearly capacity of 442,380 tons per year (tpy). Covanta intends to modify the HERC’s Clean Air Act Title V Permit (#05300400) to remove the state only limit on fuel usage of 365,000 tpy. Correspondingly, Covanta also intends to change the language of CUP Condition #1 in accordance with the January 2000 Minn. Stat. modification to allow HERC to process MSW at its design capacity.
Operating at design capacity will not require any physical or operational modifications to existing equipment or industrial processes or the demolition, removal, or remodeling of existing structures. Covanta maintains compliance with the 365,000 tpy fuel use limit by controlling HERC’s processing rate and managing maintenance downtime. HERC routinely achieves a fuel use rate of greater than 1,000 tpd. As shown in Table 1 - Fuel Use Summary, HERC processed over 1,000 tons of MSW on 255 days in 2008 and 260 days in 2009.
Table 1 –Fuel Use Summary Daily Fuel Use – Tons per Day 2008 Number of Calendar 2009 Number of Calendar Days1 Days
Full Capacity 69 114 Between 1,100 and 1,200 151 115 Between 1,000 and 1,100 35 31 Less than 1,000 111 105 1 2008 had 366 operating days because it was a Leap Year.
Covanta has submitted an application for a Major Modification to the HERC’s Air Emission Permit No. 5300400-003. The existing air emission permit, limits the maximum emissions that HERC is allowed to emit based on:
x Facility design and operating conditions;
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 4 Worksheet x Existing Federal Regulations including New Source Performance Standards, Maximum Achievable Control Technology Standards, and Prevention of Significant Deterioration regulations
x Existing Minnesota Regulations;
x Federally enforceable permit conditions; and
x Minnesota state-only permit conditions.
As discussed in detail in the response to Question 23 below, Covanta has requested changes in HERC’s annual potential to emit (PTE) for certain air pollutants as part of the Air Emission Permit Modification application. The proposed PTE for NOX will decrease from 881 tpy to 550 tpy after the installation of a selective non-catalytic reduction (SNCR) system at HERC. If the permit modification is approved, Hennepin County and Covanta have committed to the SNCR system installation to achieve this reduction. The proposed annual PTE for mercury will decrease from 0.126 tpy to 0.0314 tpy because of the permit modification.
Because Covanta routinely operates HERC at its design capacity, the maximum daily actual emissions of regulated pollutants will not change. However, the annual actual emissions will increase for some regulated pollutants.
Hennepin County manages the flow of MSW within its boundaries. Under the proposed permit modification, up to an additional 77,380 tons of MSW per year will be approved for processing at HERC. Hennepin County’s goal is to process at least 40,000 additional tons of MSW at HERC. The additional MSW, to be processed at HERC above the existing limit, is generated by residences and businesses in Hennepin County and would otherwise be disposed of in the Elk River landfill.
In 2009, HERC received 361,879 tons of MSW and produced 84,695 tons of ash. Processing an additional 77,380 tpy of MSW, above the existing 365,000 ton per year limit would produce approximately 18,000 tpy of additional ash that would be disposed of in the same licensed landfills that HERC currently uses for ash disposal. These existing landfills have the capacity to handle the additional ash volume.
After the permit modification there will be an increase in the number of transfer trailers hauling MSW to HERC. HERC currently receives about 210-220 trucks per day during the week, 60-70 trucks per day on Saturday and 25 trucks on Sunday. Hennepin county will utilize their contractual relationships with haulers so that the additional MSW will be hauled by transfer trailer from the Brooklyn Park Transfer Station to HERC. Up to an additional 14 transfer trailer MSW trucks and 2 ash trucks would go to HERC.
The principal access routes to HERC will not change. The number of employees at HERC will not change, so employee-related traffic and parking will not be affected by the proposed modification.
The proposed project will not result in any change in the use of other resources or production of other wastes.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 5 Worksheet c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries.
The purpose of the project is to improve Hennepin County’s compliance with the Minnesota Waste Management Act. Along with the county’s programs to reduce waste and recycle more, processing more waste at HERC will reduce the amount of waste sent to landfills.
Processing more waste at HERC would increase the amount of energy generated at the facility, which would reduce the reliance on energy generated from the combustion of fossil fuels such as coal, natural gas and oil. Generating more energy at HERC would offset the cost and pollution associated with using energy generated from fossil fuels.
Waste management in Hennepin County
The following chart shows how waste is managed in Hennepin County. In 2010, an estimated 1.5 million tons of waste will be generated in Hennepin County. The amount of waste generated is projected to increase to 1.6 million tons by 2015. The additional 77,380 tons of waste that could be processed at HERC if it were to operate at capacity represents just 5.1 percent of the total waste generated in the county.
Waste projected to increase from 1.5 m tons to 1.6 m tons from 2010 - 2015 2010 projection % change 2013 target 2010-2015 2015 target
595,000
872,500 Recycle 82% 1,044,500
365,000 HERC 405,000 11% Waste-to-Energy 405,000
540,000 Landfill 322,500 -76% 150,500
0 400,000tons 800,000 1,200,000
For 2013 and 2015, the waste generation projections include targets to significantly increase the amount of waste recycled and composted along with increased processing capacity at HERC. The MPCA, in their draft Metropolitan Solid Waste Management Policy Plan for 2010-2030, outlines targets for increasing recycling to 45 percent and organics collection to 3-6 percent by 2015 and ultimately recycling and composting almost 70 percent by 2030. Hennepin County is developing a plan that would include similar targets to increase recycling and organics collection.
As shown, even with a significant increase in the recycling rate and processing 40,000 additional tons at HERC, there would still be 150,500 tons of waste generated in Hennepin County sent to landfills.
This means that the additional throughput of waste at HERC will not adversely impact the efforts of Hennepin County to increase recycling and composting – processing waste at HERC is the environmentally preferable way to deal with the waste that cannot be recycled or composted.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 6 Worksheet Waste management policies
Waste is managed in Hennepin County to fulfill requirements of state statutes and regulations that oversee solid waste. The county’s programs to reduce waste, recycle, compost and process waste at HERC are part of a comprehensive system to fulfill these requirements.
The Minnesota Waste Management Act requires waste to be managed in accordance with the waste management hierarchy. According to the hierarchy, state policy is to reduce the amount of municipal solid waste that is sent to landfills by placing priority on reducing waste, recycling, composting and using resource recovery, which includes waste-to-energy.
Furthermore, Minnesota Statute 473.848 requires waste generated in the metropolitan area to be processed before disposal, which means recovering materials and energy from waste prior to landfilling. The Minnesota Pollution Control Agency has incorporated these requirements in its Metropolitan Solid Waste Management Policy Plan. The policies and requirements of the Metropolitan Solid Waste Management Policy Plan were incorporated into Hennepin County’s Solid Waste Management Master Plan, which was approved by the MPCA.
Landfilling is the least preferable waste management option. Landfilling waste results in the loss of material and energy. Landfills create air pollution in the form of methane and other volatile organic gases. Even when a landfill collects methane gas, it is only recovers a fraction of the potential energy from the waste.
From 1989 to 1994, Hennepin County used waste designation to direct waste to processing facilities. In 1994, the last year that the county enforced designation, l40,000 tons of waste generated in Hennepin
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 7 Worksheet 544,094 1994 (1.3 m) 597,777 2008 (1.5 m) Recycle 573,012 2009 (1.4 m) 595,000 2010 projection (1.5 m)
610,952 539,091 Waste-to-Energy 453,922 365,000
140,305 344,313 Landfill 359,692 540,000
- 400,000tons 800,000 1,200,000 County was sent to landfills. As shown in the following chart, the amount of waste sent to landfills has steadily increased since the end of designation. It is projected that 540,000 tons of waste will be landfilled in 2010.
NOTE: Waste to energy quantities in the figure above represent the total for multiple waste to energy facilities in Hennepin County, which includes the HERC.
Recycling and waste reduction programs
Increasing waste reduction, recycling and composting is a priority for Hennepin County. The county has been measuring and reporting recycling activities since 1984, when the rate was 22 percent. Through the efforts of the county and its partners, the recycling rate has increased to 49 percent in 2009. Hennepin County’s recycling rate is comparable to other high performing communities in the United States and Canada, including Seattle, Washington; Portland, Oregon; Alameda County, California; San Jose, California; Vancouver, British Columbia; and Toronto, Ontario.
Hennepin County Recycling Rate
60%
50%
40%
30%
20%
10%
0% 1984 1994 1999 2004 2009
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 8 Worksheet The recycling rate in Hennepin County has not changed significantly since the mid-1990s. To address this, the county has conducted studies to assess how well established recycling programs are working and to identify opportunities for recycling new materials.
Curbside recycling programs are the cornerstone of the county’s recycling efforts. The county has conducted recycling recovery rate studies in Minneapolis (2006), Minnetonka (2009), and St. Louis Park (2009) to study the effectiveness of curbside programs and identify areas for improvement. The cities were chosen to be representative of a range of urban and suburban communities in the county. The study looked at recycling recovery rate, or how much material that could be recycled is being recycled. The following chart shows the results of the study.
St. Louis Recycling Recovery Rate Minneapolis Minnetonka Park Rate = Separated recyclables/ Recyclables remaining in waste 44% 82% 81%
Results from the recycling recovery rate studies has also helped the county identify what materials comprise a large portion of the garbage and could be targeted by new recycling programs. The following chart summarizes the contents of garbage carts in the studies. Organic waste, which includes food waste and non- recyclable paper, accounts for 34 percent by weight of the residential waste. This was the most prevalent waste that could be targeted for new recycling efforts and the county is developing strategies to recover organic materials from the waste stream. The county is also targeting ways to increase the diversion of recyclable paper, bottles and cans that were found in the garbage.
Recycling Recovery Rate Studies - Contents of Garbage Carts
Trash 46% (nonrecyclables)
Organics 34%
Fibers 13% (paper & cardboard)
Rigids 6% (bottles & cans)
HHW & 1% Problem Materials
0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%
In addition to curbside recycling programs, Hennepin County has implemented a variety of programs to divert waste from landfills. Examples of waste diversion projects managed by the county include:
x Organizing an annual Choose to Reuse Campaign to promote reuse opportunities in Hennepin County. In 2009, 80 reuse organizations participated and 100,000 coupon books were distributed. More than 19,000 coupons were redeemed at reuse retailers.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 9 Worksheet x Operating Free Product Centers at the county drop-off facilities. The program makes usable products brought to the drop-off facilities for disposal available to the public free of charge. In 2009, more than 52,000 items were taken from the Free Product Centers. x Implementing and supporting organics recycling programs in nearly 100 schools, numerous businesses and more than 5,000 households in nine cities. The amount of organics material collected has increased from a few hundred tons in 2006 to more than 6,800 tons in 2009. This increase is due in large part to the county’s subsidized tipping fee of $15 per ton for organics delivered to the county’s transfer station in Brooklyn Park. The county is also collaborating with the University of Florida, the St. Paul Port Authority and others to assess the feasibility of processing organics by anaerobic digestion. x Supporting an organics pilot project in the Linden Hills and ECCO neighborhoods of Minneapolis in which organic material is collected separately from trash and yard waste. The Linden Hills pilot was funded by a $76,800 Waste Abatement Incentive Fund grant from Hennepin County. The average pounds collected per household per week is 12.1 pounds. x Developed one of the first mattress recycling programs in the United States in partnership with PPL Industries, known as the Second Chance Recycling Program. PPL’s mission is to work with lower- income individuals to help them achieve greater self-sufficiency through employment training, support services and education. PPL Industries disassembled 65 tons of mattresses in 2009 to recover the foam, metal, cotton and wood. Hennepin provided $250,000 to help PPL start up the program, and has budgeted an additional $300,000 to covers the costs of recycling mattresses collected at the Brooklyn Park Transfer Station and through curbside pick up in Minneapolis. The county is also assisting with PPL’s expansion of the Second Chance Recycling Program to high-volume generators throughout the metro area. x Providing technical assistance to businesses to reduce waste and improve recycling by conducting waste audits and offering online resources. x Distributed more than 22,000 compost bins from 2001 to 2008 to encourage residents to compost food and yard waste at their homes. x Operating an electronic waste program to recycle televisions, computers and other e-waste. E-waste is collected at the county drop-off facilities and household hazardous waste events. The county also arranges for the recycling of e-waste collected curbside by the city of Minneapolis and at events held by other cities. The county supported legislation that now requires manufacturers to share responsibility for recycling e-waste in Minnesota. The electronics program collected 3,229 tons in 2009. x Operating two permanent drop-off facilities and organizing three to five collection events each year to collect and properly dispose of problem materials and household hazardous waste (HHW). Wastes collected include automotive products, batteries, corrosive cleaners, electronics, fluorescent & HID lights, mercury, paint, and pesticides. More than 120,000 people visited the facilities and events to drop off 5,130 tons of problem materials & HHW in 2009. x Collecting batteries at multiple locations throughout the county. In 2009, the county collected more than 113 tons of household batteries. The county also supports and promotes the recycling of rechargeable batteries through the Call2Recycling program, a program created by battery and product manufacturers. The County provides significant financial and technical assistance to support the work of other local governments and nonprofit organizations. The following are examples of how Hennepin County supports waste diversion activities of others:
x Distributes 100 percent of SCORE funding from the State of Minnesota ($2.9 million in 2010) annually in grants to municipalities for curbside recycling program. x Provides $300,000 annually in Waste Abatement Incentive Grants to cities, schools and public organizations for innovative reuse, recycling and composting programs. Since 2000, the county has
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 10 Worksheet awarded $1.7 million in grants, which included $1.2 million to support the collection of organic waste for recycling into compost. x Awards Community POWER (Partners on Waste Education and Reduction) grants to community organizations and schools to conduct waste reduction, toxicity reduction and recycling education projects. In partnership with the Solid Waste Management Coordinating Board, the county has worked with 102 community organizations and provided $785,000 in funding to grantees during the past 10 years. x Provide funding for a dual sort recycling program in Minneapolis, which begins in Fall 2010. Results of the study will be available in late 2011. x Provide financial support since 1995 to Second Harvest Heartland to operate a recovery program for fresh produce that would otherwise be disposed. In 2009 more than 660 tons of fresh produce were collected by Second Harvest. x Support the Green Institute’s deconstruction program to divert demolition materials from landfills. The county has supported this program since 1993. Deconstruction materials diverted by the Green Institute are sold at their Reuse Center. x Provided funding since 2000 for the collection of plastic bags through “Its in the Bag” program. x Sponsored re-use projects at the Brooklyn Park Transfer Station with the Network for Better Futures, which is an organization that promotes recovery, resiliency and prosperity of high-risk adults. Re-usable items are sorted from trash delivered to the Brooklyn Park Transfer Station. The reusable items are sold or dismantled for recycling by the NetWork for Better Futures.
The county also demonstrates leadership in managing its own waste in accordance with the waste management hierarchy by revising county purchasing and management policies. Examples include the following:
x Implemented a Green Products Initiative for the purchase of office supplies that automatically substitutes more environmentally friendly office supply products. Since the program began, more than 50 percent of the products purchased have been green products at no extra cost to the county. Environmentally preferable components were also added to county contracts for deicers, ceiling tiles, carpets and adhesives. x County staff worked with the state to specify compostable bags and compostable foodservice ware for a cooperative purchasing contract. The county also collaborated with other agencies to write the Environmentally Preferable Purchasing Guide. x Administers a Lead-by-Example Incentive Fund that supports county departments in implementing new innovative, internal waste reduction and recycling projects.
The county continues to identify and develop new programs to increase recycling rates, but the county cannot achieve a significant increase in recycling and composting on its own. Increasing the recycling rate will require the commitment and work of many partners, including the waste generators, waste collectors, municipalities and state government. The state government and legislature can pass laws and implement programs that extend producer responsibility and product stewardship, increase recycling opportunities by focusing on market development, and provide additional funding for waste abatement programs. Only by working together can we change behavior and increase recycling.
As the county works with partners to increase recycling, a portion of waste that cannot be recycled will still remain. The county can divert some of the remaining waste from landfills and use it to produce energy at HERC. Waste processed at HERC generates valuable steam that is sent to the downtown Minneapolis district energy system and electricity for the grid. Steam generated at HERC is also used in the county district energy system, which reduces energy costs to heat and cool county buildings.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 11 Worksheet Generating energy from waste at HERC reduces the reliance on and pollution associated with burning fossil fuels, such as coal, oil and natural gas, to produce energy. Processing waste at HERC allows the county to manage the portion of waste that cannot be recycled in an environmentally preferable way that reduces the amount of waste sent to landfills. d. Are future stages of this development including development on any other property planned or likely to happen? Yes No
If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review.
e. Is this project a subsequent stage of an earlier project? Yes No
The proposed removal of the fuel use limit is neither part of a previous project nor part of a planned future project.
If yes, briefly describe the past development, timeline and any past environmental review.
7. Project Magnitude Data
Total Project Area (acres) 13.1 or Length (miles) NA
Number of Residential Maximum Units Per Units: Unattached 0 Attached 0 Building: 0
Commercial/Industrial/Institutional Building Area (gross floor space): total square feet ~161,800
Indicate area of specific uses (in square feet): Office ~10,000 Manufacturing 0 Retail 0 Other Industrial ~151,800 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Landscaped _~90,000______
Building height If over 2 stories, compare to heights of nearby buildings
Table 2– Building Height Summary
HERC Building Heights Feet Nearby Building Feet Heights from the base elevation of HERC HERC Tipping Hall 63 Target Field 138 HERC Fuel Storage 113 Target Center 158 HERC Boiler Building 123 6th Street Parking Ramp 90 HERC Baghouse Building Hennepin County Office 65 Building 32 HERC Ash Loadout 46 Nearest Office Tower 150 HERC Stacks 216 Cooling Towers 74
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 12 Worksheet 8. Permits and approvals required. List all known local, state and federal permits, approvals and financial assistance for the project. Include modifications of any existing permits, governmental review of plans, and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minn. R. 4410.3100.
Table 3 – Permits and Approvals Unit of Government Type of Application Status Minnesota Pollution Control Title V Permit #5300400-003 Renewal Submitted Agency City of Minneapolis Conditional Use Permit #61061 Pending Minnesota Pollution Control Major Modification of the Title V Submitted Agency Permit #5300400
9. Land use. Describe current and recent past land use and development on the site and on adjacent lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines.
The proposed project will not affect land use on the site or on the surrounding areas. Figure 4 shows the existing site boundaries that will not change as part of the proposed modification.
HERC is an existing mass-burn municipal waste combustor and the site includes the combustor, associated driveways, MSW receiving and storage building, pollution control equipment, ash loadout building, offices, a surface water runoff bioretention area, and parking areas.
As shown on Figure 5, surrounding land has a typical mixture of urban uses including office towers, commercial buildings, light manufacturing, high occupancy residential buildings, parking garages and streets/highways. Other area land uses include the Target Center (a multipurpose sports and entertainment arena), and Target Field (a baseball stadium). The existing land use is compatible with the City of Minneapolis Planning Department Downtown East / North Loop Master Plan, Adopted October 2003.
The HERC Site occupies a closed former leaking underground storage tank (LUST) site (Greyhound – Hennepin Incinerator Site, MPCA Leaksite #318). The release was reported in 1985 and the LUST file was closed by the MPCA in 1998. Petroleum contamination to soil and groundwater remains on-site. The petroleum tank release file for the site was closed because the decreasing concentrations of petroleum in the soil met the regulatory levels established by the MPCA. Most of the site is now covered with buildings and parking lots associated with Covanta, which reduces water infiltration and precludes human exposure to contaminants. The proposed modification will not result in any physical changes to the HERC Site, so no impacts to geology, contaminated sediments or groundwater would occur.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 13 Worksheet 10. Cover Types. Estimate the acreage of the site with each of the following cover types before and after development: The proposed modification will not result in any change in cover types.
Before After Before After Types 1-8 wetlands 0 0 Lawn/landscaping ~2.1 ~2.1 Wooded/forest 0 0 Impervious Surfaces ~11.0 ~11.0 Brush/grassland 0 0 Stormwater pond 0 0 Cropland 0 0 Other (describe) 0 0 TOTAL 13.1 13.1
If before and after totals are not equal, explain why.
11. Fish, Wildlife, and Ecologically Sensitive Resources.
a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be affected by the project. Describe any measures to be taken to minimize or avoid impacts.
HERC is located in an urban setting. Wildlife that is sometimes present in an urban setting may include squirrels, rabbits, raccoons, skunks, woodchucks, bats, and birds. No construction activity or physical modifications are proposed; therefore urban wildlife present at HERC Site will not be impacted.
b. Are any state (endangered or threatened) species, rare plant communities or other sensitive ecological resources on or near the site? Yes No
Peregrine falcons have been observed at three locations within downtown Minneapolis. The Black Sandshell has been observed in the Mississippi River. However, the Minnesota Department of Natural Resources has concluded that the proposed project is unlikely to have a negative effect on any known occurrences of rare features.
If yes, describe the resource and how it would be affected by the project.
Describe any measures that will be taken to minimize or avoid adverse impacts. Provide the license agreement number (LA-______) and/or Division of Ecological Resources contact number (ERDB 20100644) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources. Indicate if any additional survey work has been conducted within the site and describe the results.
A copy of the Natural Heritage Information System letter from the DNR Division of Ecological Resources is included in Appendix B.
12. Physical Impacts on Water Resources. Will the project involve the physical or hydrologic alteration (dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No
The proposed modification will not involve any physical or hydrologic alteration of any surface water resource.
Statewide Mercury Total Maximum Daily Load
Minnesota has developed a Total Maximum Daily Load (TMDL) Pollutant Reduction Plan for mercury that describes the reduction requirements for sources contributing mercury to the impaired water bodies in
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 14 Worksheet Minnesota. The long-term goal of the mercury TMDL is for the lakes to meet water quality standards. Minnesota’s approach is to achieve mass reductions from state mercury sources.
The EPA approved Minnesota's Statewide Mercury Total Maximum Daily Load Pollutant Reduction Plan in March 2007. Between June 2007 and May 2008, stakeholders representing a broad range of interests worked with the MPCA to identify strategies and timelines that would be included in an implementation plan. The stakeholders' recommendations, completed in June 2008, are contained in the Mercury TMDL Implementation Plan (http://www.pca.state.mn.us/air/mercury-reductionplan.html). The Mercury TMDL Implementation Plan includes reduction goals for various mercury emission sources by category. Municipal waste incineration has not been targeted for future reductions in the Mercury Implementation Plan because mercury emissions from the industry, including the HERC, are already highly controlled.
The Mercury TMDL Implementation Plan deals with how increases in mercury emissions for new and modified sources are addressed. The Mercury TMDL Implementation Plan states that after May 1, 2008, new and expanding air emission sources of mercury will be allowed provided the following measures are employed to ensure that the new and expanding sources do not result in an eventual exceedance of the TMDL goals:
1. The source is required to achieve best control. 2. The source must complete environmental review as applicable, including evaluation of local and cumulative impacts. 3. The source must submit a plan to the MPCA to account for the proposed emission. New or modified sources are expected to offset new emissions by arranging a reduction equal to the new emissions from existing sources in the state beyond those otherwise required in the reduction strategy for the existing sources. If mercury reductions from an existing facility in Minnesota cannot be identified, a new or expanding facility may propose alternative mitigation strategies in lieu of in-state air emission reductions. If an expanding source can demonstrate net increases less than three pounds per year from their proposed project, no additional offsets are required.
As discussed in more detail in Question 23, the HERC installed an activated carbon system to control mercury emissions. This technology has been determined to be the best control technology for mercury control. Thus, measure #1 has been satisfied.
This EAW satisfies measure #2.
As discussed further in Section 23, Covanta is proposing to accept an emission limit for mercury that will result in a reduction in the PTE from 0.126 tons/year to 0.0314 tons per year. Additionally, the actual mercury emissions from the HERC were 5.89 lbs in 2007; 7.16 lbs in 2008; and 9.68 lbs in 2009. The actual MSW throughput for 2007, 2008, and 2009 were 365,017 tons, 365,010 tons, and 361,003 tons, respectively. Based on the assumption that mercury will increase in direct proportion to the increase in MSW combustion (442,380 tons vs. 365,000 tons) and using the highest emission rate (2009), the increase in actual mercury emissions will be 2.05 lbs per year. Since the increase at an existing facility is less than 3 lbs per year, measure #3 is satisfied and no further actions or offsets are required.
Mercury is present in products that are used and sold in the state. Additional mercury reduction could be achieved if the State were to further control and restrict the use and sale of products that contain mercury.
If yes, identify water resource affected and give the DNR Public Waters Inventory (PWI) number(s) if the water resources affected are on the PWI. NA Describe alternatives considered and proposed mitigation measures to minimize impacts.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 15 Worksheet 13. Water Use. Will the project involve installation or abandonment of any water wells, connection to or changes in any public water supply or appropriation of any ground or surface water (including dewatering)? Yes No
The proposed modification will not involve the installation or abandonment of any water wells, new connections to or changes in any public water supply or the appropriation of any ground or surface water (including dewatering).
The HERC uses water from the Minneapolis municipal system. The proposed modification will not require an increase in the daily water use rate. The HERC currently uses an average of 625,000 gallons of water per day for operations. The amount of water varies seasonally with higher water use occurring in the summer. During the summer months, more water is required for cooling tower make- up due to higher evaporation rates. Also, landscaped areas on the HERC Site periodically require watering during the summer. Figure 6 shows the current water balance for the HERC.
If yes, as applicable, give location and purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine.
14. Water-related land use management districts. Does any part of the project involve a shoreland zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No
If yes, identify the district and discuss project compatibility with district land use restrictions.
15. Water Surface Use. Will the project change the number or type of watercraft on any water body? Yes No
If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses.
16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 0 acres; 0 cubic yards. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction.
No construction or physical changes to the HERC are proposed. The proposed modification will not require any grading or result in site disturbance.
17. Water Quality – Surface-water Runoff.
a. Compare the quantity and quality of site runoff before and after the project. Describe permanent controls to manage or treat runoff. Describe any storm-water pollution prevention plans.
Since the proposed modification will not include any construction or physical changes to the HERC, discharges to the municipal storm water system will remain unchanged. As shown in Figure 7, water discharge to the municipal storm water system from the HERC Site includes storm water and cooling tower blowdown. Clean hydrostatic test water from testing the boilers, air compressor cooling water, and water from the condensate polisher may be reused as cooling tower makeup water. Discharges to
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 16 Worksheet the existing municipal storm water system average approximately 85,000 gallon per day and can reach a maximum of 300,000 gallons per day, depending on the magnitude of storm events. The HERC has existing National Pollutant Discharge Elimination System (NPDES) permit #MN0057525 for this discharge. The NPDES permit was issued on October 1, 2009 and expires on September 14, 2014.
The NPDES permit requires Covanta to monitor flow rate, pH, chlorine content, phosphorous content and temperature on the non-contact cooling water. The permit also requires Covanta to monitor flow rate and duration of discharge for boiler blowdown water.
As required by the NPDES permit, Covanta has a Storm Water Pollution Prevention Plan (SWPPP) that identifies:
x Areas where significant materials are stored on-site that could be exposed to storm water,
x Best Management Practices (BMPs) that are used to minimize or eliminate exposure of these materials to storm water, and
x Inspections that are completed to ensure that the provisions of the SWPPP are implemented properly.
Copies of the NPDES permit and SWPPP are included in Appendix C.
b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters.
Figure 7 shows the storm water flow paths to the municipal storm water system. Storm water from the HERC Site would continue to discharge to the existing municipal storm water system, combine with storm water runoff from roads, other buildings and/or impervious areas, and ultimately discharge to the Mississippi River. In 2009, Covanta added a storm water retention pond and a rain garden on-site to reduce peak flows to the storm sewer system and improve storm water quality. The HERC Site does not have a direct outfall to the Mississippi River.
18. Water Quality – Wastewater.
a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site.
Because the proposed project will not include any construction or physical changes to the HERC, discharges to the municipal wastewater system would remain unchanged. As shown on Figure 6, Water Process Flow Diagram, the HERC discharges up to 15,000 gallons per day of wastewater to the Metropolitan Council Environmental Services (MCES) sanitary sewer system under Permit #0770. The permit contains limits for cadmium, chromium, copper, cyanide (total), lead, mercury, nickel, zinc and pH. The permit prohibits the discharge of flammable liquids, solids that might block a sewer line and waste that could cause a public nuisance and hazardous wastes.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 17 Worksheet The MCES permit was issued on May 1, 2008 and expires on April 30, 2011. Wastewater sources include sanitary wastewater, ash quench tank wastewater, boiler blowdown and facility washdown water.
Covanta monitors the flow of wastewater continuously and samples the discharge annually for pH, chemical oxygen demand, total suspended solids, oil and grease, copper, lead, mercury and zinc.
b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies (identifying any impaired waters), and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems.
As shown on Figure 6, Covanta reuses many of the wastewater streams generated by the HERC to reduce the amount of water required for operations and the amount of wastewater generated. For example, cooling tower blowdown water is used in the ash quench tank and clean non-potable water and overflow from the quench tank are used in various processes such as the ash dischargers and the undergrate conveyor system. Other than on-site settling to remove solids, Covanta does not pre-treat wastewater prior to discharge to the MCES sanitary sewer system.
c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe any pretreatment provisions and discuss the facility’s ability to handle the volume and composition of wastes, identifying any improvements necessary.
As noted above, other than on-site settling to remove solids, Covanta does not pre-treat wastewater prior to discharge to the MCES sanitary sewer system. The MCES is currently able to process the wastewater from the HERC. The volume of waste water being discharged to the MCES sanitary system is not expected to increase as a result of the fuel use limit removal.
19. Geologic hazards and soil conditions.
a. Approximate depth (in feet) to Ground water: (perched) 4 minimum; 10 average. Bedrock: 100 minimum; 140 average.
The depths identified above are based on boring and well logs taken at or near the HERC Site as part of various investigations conducted in the area as well as the Minnesota Geologic Survey, Hennepin County, Minnesota Geologic Atlas (County Atlas Series Atlas C-4), University of Minnesota, 1989.
Describe any of the following geologic site hazards to ground water and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards.
No shallow limestone bedrock formations, sinkholes or karst conditions are located in the area.
b. Describe the soils on the site, giving Natural Resources Conservation Service classifications, if known. Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 18 Worksheet Urban fill material consisting of soil mixed with wood, bricks, cinders and miscellaneous debris overlies lacustrine deposits or swamp deposits (peat, muck, and organic silts and clays) and varved silts and clays. Sandy outwash materials under the swamp deposits transition to glacial till consisting of silty clay and clay. The St. Peter Sandstone bedrock underlies the till deposits.
During the construction of the HERC, petroleum contaminated soils and free phase petroleum were encountered on site. The petroleum was assumed to be from storage tank leaks and spills at a Greyhound bus maintenance facility that had previously occupied the property and from gas stations adjacent to the site. Petroleum was recovered and groundwater was treated via a pump-and-treat operation and from high-volume dewatering to lower the site water table to construct the fuel storage building. Contaminated soils were treated by mechanical aeration and by use in on-site landscaping. A network of 30 groundwater monitoring wells was installed in and around the site and monitored from 1989 to 1996. No free phase petroleum was detected in the monitoring wells during that period and the levels of petroleum contaminants in the groundwater were observed to have decreased significantly. In 1998 the MPCA determined that the investigation and cleanup had adequately addressed the petroleum release and closed its file on the site
The proposed modification will not result in any physical changes to the site, so no impacts to geology, contaminated sediments or groundwater would occur.
20. Solid Wastes, Hazardous Wastes, Storage Tanks.
a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments.
In 2009, HERC received a total of 361,879 tons of MSW for processing. Each load of MSW is inspected when received and items that are prohibited from combustion or would cause problems with the material handling equipment are removed. These items include vehicle batteries, appliances, electronics, tires, large pieces of metal and items too large to go through the feed chute (i.e. concrete, long boards, large pieces of foam etc.). The County contracts for waste deliveries. Waste delivery contracts prohibit hazardous waste and haulers must pay fees for delivering non-processible items, which discourages delivery of such items. In 2009, 363.6 tons of rejected wastes were removed from the HERC tipping floor. The tipping floor is where trucks unload MSW. These wastes were segregated and disposed of or processed as identified in Table 4.
Table 4 - 2009 Rejected Waste Summary Waste Type Tons Sent to Appliances 13.9 JR’s Appliances, Inver Grove Heights, Minnesota Tires 4.9 Liberty Tire Services of Ohio, Savage, Minnesota Electronics 0.4 Special Waste Disposal Inc., Blaine, Minnesota Non-processable MSW 344.4 Pine Bend Landfill, Inver Grove Heights, Minnesota Total 363.6
Batteries removed from the MSW and used batteries from the HERC are disposed off-site in accordance with MPCA regulations. The batteries are shipped to Stericycle Specialty Waste Solutions in Blaine, Minnesota for recycling. Covanta also removes large pieces of metal on the tipping floor, referred to as front end metal. In 2009, Covanta removed 54.0 tons of front end metal from the tipping floor. This metal is shipped off-site for recycling at a metal recycler, currently American Iron Supply Company in
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 19 Worksheet Minneapolis. In addition to the prohibited wastes, non-processable wastes and front end iron, Covanta disposes of ash and recyclable metals (back end metal) from the two combustors. In 2009, Covanta disposed of 84,695 tons of ash and recycled 11,145 tons of back end metal. The back end metal is also shipped off-site for recycling at American Iron Supply Company in Minneapolis.
Ash is currently disposed of in one of two landfills. Approximately 80% of the ash is hauled to Ash Monofill Cell #4, at the SKB Landfill in Rosemount, Minnesota. Cell #4 is used exclusively for the ash from the HERC. Leachate, which is comprised of the stormwater which accumulates in the ash monofill, is collected, tested for compliance with USEPA and MPCA regulations, and discharged to the existing Metropolitan Council Environmental Services, (MCES) Metropolitan Waste Water Treatment facility in St. Paul, Minnesota. Table 5 summarizes the data for the leachate from 2005 to 2009. The Maximum Leachable Contaminant Level (MLCL) is the limit allowed under Minnesota Regulation 7035.2885 Subpart 5. Table 5 – 2005 to 2009 Landfill Leachate Data Summary 2005-2009 Parameter Name Units Average MLCL Acetone ug/L 37.74 N/A Aluminum (Total) ug/L 1,087.45 N/A Ammonia mg/L 30.50 N/A Antimony ug/L 62.745 N/A Arsenic (Total) ug/L 142.41 750 Barium (Total) ug/L 6,273.00 30,000 Benzene ug/L 5.05 N/A Beryllium (Total) ug/L 15.50 N/A Boron (Total) ug/L 1,213.45 9,000 Cadmium (Total) ug/L 3.55 60.00 Calcium (Total) ug/L 4,924,333.33 N/A Chloride mg/L 22,176.67 N/A Chromium (Total) ug/L 31.00 1,500 Copper (Total) ug/L 38.33 15,000 Iron (Total) ug/L 11,407.00 N/A Lead (Total) ug/L 12.06 300 Magnesium (Total) ug/L 39,079.00 N/A Manganese (Total) ug/L 4,495.40 9,000 Mercury (Total) ug/L 0.20 30 Nickel (Total) ug/L 62.30 2,100 Nitrogen(No2 Plus No3) mg/L 4.18 N/A pH 7.01 N/A Phenol ug/L 56.33 N/A Potassium (Total) ug/L 2,816,000.00 N/A Selenium (Total) ug/L 61.44 300 Silver (Total) ug/L 31.00 300 Sodium (Total) ug/L 5,754,050.00 N/A Sulfate mg/L 147.80 N/A Thallium (Total) ug/L 58.50 N/A Tin (Total) ug/L 395.80 60,000 Zinc (Total) ug/L 63.38 21,000 Notes & Abbreviations: mg/L = miligrams per liter, ug/L = micrograms per liter
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 20 Worksheet As shown, the leachate from Cell #4 is in compliance with the applicable MPCA regulatory limits.
The remaining 20% ash is hauled to the ash monofill at the Lake Area Disposal Landfill in Sarona, Wisconsin. Ash from the HERC is combined with ash from other waste combustor facilities and disposed in the ash monofill.
The amount of recyclable metal, non-processable waste, tires and appliances in the waste stream is minimal compared to the amount of MSW processed. However, for the purposes of this proposal, Covanta is estimating that the ratio of these materials in the next few years will be in approximately the same ratios as current operations and will be sent to similar facilities for disposal/processing (Table 6).
Table 6 - Projected Annual Rejected Waste Summary Waste Type Projected Tons Appliances 17.0 Tires 6.0 Electronics 0.5 Non-processable MSW 420.5
Disposal of these wastes would be handled in the same manner as currently completed, although the individual facilities used might change depending on market conditions. An estimated additional 18,000 tons of ash would be generated per year for a total of approximately 103,000 tons per year of ash. SKB has determined that at the present time they have 39 years of capacity in Cell #4 at the current disposal rate. The increase in ash disposal would reduce that capacity to 32 years.
b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be used to prevent them from contaminating ground water. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission.
The proposed modification would not require any change in the types, locations or storage volumes of chemicals on-site. Covanta uses a number of chemicals to support operations at the facility. Table 7 lists the chemicals, use, storage, methods, and storage locations.
Table 7- Facility Chemical Use and Handling Raw Material Storage Storage General Handling Name Use Location Container Operation Chem Treat Cooling Tower INSIDE Aboveground, x Chemicals are piped into CT709 Water Cooling plastic storage tanks the cooling tower water Corrosion Treatment Tower with concrete treatment system. Inhibitor Chemicals Building containment. x Storage tanks are filled Chem Treat via tanker truck. CL4848 x During filling operations, Synthetic the tanker truck is parked Polymer in a bermed, concrete area Chem Treat able to contain accidental CL241 releases. Defoamer Chem Treat CL215 Biocide
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 21 Worksheet Table 7- Facility Chemical Use and Handling Raw Material Storage Storage General Handling Name Use Location Container Operation Chem Treat INSIDE Aboveground, x Contents of shipping B-120 Boiler plastic storage tanks containers are pumped Chlorine Building with concrete into the bulk storage tank. Scavenger containment. x Filling operations take place inside the facility. Chem Treat Boiler Water INSIDE Bulk Steel Storage x Contents of shipping BL1283 Treatment Boiler Tank inside containers are pumped Oxygen Chemicals Building Concrete into the bulk storage tank. Scavenger Containment x Filling operations take Chem Treat INSIDE Bulk Steel Storage place inside the facility. B144/144 Boiler Tank inside Phosphate Building Concrete Containment Chem Treat INSIDE Bulk Steel Storage CL-16 Boiler Tank inside Condensate Building Concrete Polisher Containment
Caustic Resin INSIDE x Bulk Steel Storage x Contents of shipping Soda Regeneration Boiler Tank inside containers are pumped & Water Building Concrete into the bulk storage tank. Neutralization Containment x Filling operations take Sulfuric INSIDE x 55-Gallon Drums place inside the facility. Acid Boiler (plastic) inside Building Concrete Containment. x Caustic and acid have separate containment areas. Brine Demineralizati INSIDE x Bulk Fiberglass x Brine is added manually on Process Boiler Storage Tank to the storage tank and Building inside Concrete mixed with water to make Containment a solution. x 50 Pound Bags x Filling operations take inside Concrete place inside the facility. Containment Oil and Various INSIDE x Bulk Steel and x Filled via bulk trucks Hydraulic Equipment Boiler Plastic Storage using a hose. Fluids throughout the Building Tanks inside Steel x Bulk truck parks in an Facility Containment outside area which is x Temporary Bulk contained using a Plastic Storage concrete floor, sloping Tanks and concrete curbing. containment Citric Acid Nozzle & INSIDE x Bulk Metal x Powdered citric acid is Powder Hose Cleaning Scrubber Storage Tank mixed with water as Operations Building x 50 Pound Bags needed to replenish the inside Plastic bulk storage tank.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 22 Worksheet Table 7- Facility Chemical Use and Handling Raw Material Storage Storage General Handling Name Use Location Container Operation Container x Solids that collect on the bottom of the tank are removed as needed and placed in the pit for energy recovery. Kerosene Space Heaters INSIDE Bulk Steel Storage x Filled via bulk trucks & Boiler Tank, Double lined using a hose. Miscellaneous Building Steel Storage Lank x Bulk truck parks in an Equipment with a leak detection outside which is contained system. using a concrete floor, sloping and concrete curbing. Dolomitic Combined Ash OUTSIDE Metal Storage Silo x Filled pneumatically via Lime Treatment Powder located inside diked tanker trucks. APC Area cement area with x Caps to fill port are Near wastewater locked requiring vendors Facility collection system. to receive authorization from Covanta personnel prior to conducting filling operations. Pebble Lime Lime Slurry OUTSIDE Metal Storage Silo x Filled pneumatically via Scrubber Powder located inside diked tanker trucks. APC Area cement area with x Caps to fill port are Near wastewater locked requiring vendors Facility collection system. to receive authorization from Covanta personnel prior to conducting filling operations. . Pebble Lime Lime Slurry INSIDE Metal Holding Tank Powder pebble lime is Scrubber Slurry inside Scrubber mechanically mixed with Scrubber Building water to make slurry and Building routed to the scrubber. Activated Mercury OUTSIDE Metal Storage Silo x Filled pneumatically via Carbon Control Powder located inside diked tanker trucks. Additive APC Area cement area with x Caps to fill port are Near wastewater locked requiring vendors Facility collection system. to receive authorization from Covanta personnel prior to conducting filling operations. Propane Forklifts/ OUTSIDE Metal Cylinders Covanta personnel fill Forktrucks Area North located inside a non- cylinders at a nearby gas of Boiler flammable steel station. Building cabinet. Gasoline Pumps, OUTSIDE Metal Cylinders Covanta personnel fill Compressors, Area North located inside a non- containers at a nearby gas etc. of Boiler flammable steel station. Building cabinet.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 23 Worksheet Table 7- Facility Chemical Use and Handling Raw Material Storage Storage General Handling Name Use Location Container Operation Ecosorb 606 Odor INSIDE Plastic drum and x Containers in tipping hall solution neutralizer for Warehouse plastic tank in vapor protected by heavy steel vapor phase and tipping phase box enclosure structure system hall x Product moved from drum to tank via drum pump Parts Parts Washer INSIDE Steel container/parts Serviced by Industrial Washing Maintenanc washer. Services that handles the Solvent e Shop transporting, disposing and restocking the parts washer fluid.
Figure 8 shows the locations of chemicals stored on-site. As shown, the majority of the hazardous chemicals are stored inside the buildings on-site. Additionally, within the buildings, the bulk storage locations are generally equipped with secondary containment structures. Therefore, in the event of spill inside a building, the spill would be contained to a small area inside the secondary containment.
Covanta routinely inspects HERC and specifically the chemical storage areas in accordance with the inspection procedures detailed in the SWPPP. A copy of the SWPPP is included in Appendix C.
c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans.
The proposed modification will not require any change in the types, locations or storage volumes of petroleum products on-site. Table 8 lists the oils and fuels, Covanta stores on-site along with the storage location and volumes. Storage locations are also shown on Figure 8.
Covanta maintains a Spill Prevention Control and Countermeasure (SPCC) plan for HERC that specifically addresses the measures put into place prevent a spill or release of petroleum on-site. These measures include: x Installation of double walled ASTs for petroleum products storage located outside of a building x Installation of secondary containment systems for petroleum products storage located inside a building x Routine inspections of petroleum product storage areas; x Implementation of specific unloading and handling procedures; x Training of all employees at the site on spill notification procedures and additional training for employees who handle petroleum productsr x Routine reviews and updates to the SPCC plan
A copy of the SPCC plan is included in Appendix C.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 24 Worksheet Table 8 - Petroleum Product Storage
Type of Oil Stored Storage Container Storage Capacity Hydraulic Oil (13M) Above Ground Storage Tank (AST): Plastic Bulk Storage Container with Steel Containment (Inside 200 Gallons Facility) Hydraulic Oil AST: Steel Storage Container with Steel (DTE25) Containment (Inside Facility) 800 Gallons Lubricating Oil AST: Plastic Bulk Storage Container with Steel (Delvac 1230) Containment (Inside Facility) 200 Gallons Turbine Lubricating 55-Gallon Steel Drums with Plastic Containment (~4 Oil (DTE797) ~220 Gallons drums) (Inside Facility) AST: Double Walled, Steel Storage Container Kerosene (Outside Facility) 470 Gallons AST: Double Walled, Steel Storage Container Diesel Fuel (Outside Facility) 1,000 Gallons 55-gallon or 30-gallons Steel Drums with Plastic Specialty Oils Containment (~4 drums) (Inside Facility) ~220 Gallons 55-gallon or 30-gallons with Steel Containment (~4 Specialty Oils drums) (Inside Facility) ~220 Gallons Compressor Oils 55-gallons Steel Drums (~4 drums) (Inside Facility) ~220 Gallons Oil Filled Transformer (Covanta) with Concrete Insulating Oil Containment (Outside Facility) 307 Gallons Oil Filled Transformer (Covanta) with Concrete Insulating Oil Containment (Outside Facility) 307 Gallons Oil Filled Transformer (Hennepin County) (Outside Insulating Oil Facility) 3,730 Gallons Lubricating Oil Turbine Oil Reservoir with Concrete Containment (DTE797) (Inside Facility) 1,575 Gallons Hydraulic Oil Hydraulic Skid with Steel Containment (Inside (DTE25) Facility) 132 Gallons Hydraulic Oil Hydraulic Skid with Steel Containment (Inside (DTE25) Facility) 132 Gallons TOTAL 9,733 Gallons
21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion): 78 (76 regular, 2 handicapped)
Estimated total average daily traffic generated: Estimated maximum peak hour traffic generated and time of occurrence:
HERC currently receives about 210-220 trucks per day during the week, 60-70 trucks on Saturday and 25 trucks on Sunday. The proposed amendment would result in an increase of, up to 14 transfer trailers and
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 25 Worksheet two ash trucks per day.
Deliveries to HERC have historically varied depending on demand, outage schedules, and operating conditions. The HERC had more than 50 days in each of the last four years when deliveries exceeded 230 trucks per day. The principal access routes to the facility will not change. The number of employees at the HERC will not change, so related employee traffic and parking will not be affected by the proposed modification.
As shown on Figure 9, the average annual daily traffic (AADT) on 6th Street adjacent to HERC in 2007 was 8,800 vehicles per day. The AADT at the intersection of 6th Street and Highway 55 adjacent to the HERC is 10,900 vehicles. The increase in truck traffic going to Covanta would result in a total AADT th 6 ths increase on 6 Street of less than /10 of 1% (0.57%).
For comparison purposes, The Minnesota Urban Ballpark Final Environmental Impact Statement, June 4, 2007 (FEIS) estimated that traffic increases, due to construction of the Target Field, in the North Loop and Warehouse District area would be up to 11,300 additional vehicles for a weekday afternoon game and up to 13,600 additional vehicles for a weekday evening game.
Indicate source of trip generation rates used in the estimates.
Trip generation information for the HERC is based on actual daily MSW receipt information. Traffic data for adjacent streets was based on 2007 data from the Minnesota Department of Transportation.
If the peak hour traffic generated exceeds 250 vehicles or the total daily trips exceeds 2,500, a traffic impact study must be prepared as part of the EAW. Using the format and procedures described in the Minnesota Department of Transportation’s Traffic Impact Study Guidance (available at http://www.oim.dot.state.mn.us/access/pdfs/Chapter%205.pdf) or a similar local guidance, provide an estimate of the impact on traffic congestion on affected roads and describe any traffic improvements necessary. The analysis must discuss the project’s impact on the regional transportation system.
The proposed modification will not result in peak hour traffic generation of 250 vehicles or daily trips in excess of 2,500.
22. Vehicle-related Air Emissions. Estimate the effect of the project’s traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts.
As noted above, Covanta is projecting an increase of up to 14 MSW transfer trucks and two ash trucks per day. . Most of the additional trucks would be bringing MSW to HERC from the existing transfer station in Brooklyn Park. These trucks will be transporting waste fewer miles to HERC than to a landfill, which will result in reduced vehicle emissions.
23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing), any greenhouse gases (such as carbon dioxide, methane, and oxides of nitrogen), and ozone-depleting chemicals (chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 26 Worksheet HERC is an existing mass burn municipal waste combustor that is a classified as a major source of emissions as defined by Minnesota and US Environmental Protection Agency (USEPA) regulations. The HERC is an existing major source under Prevention of Significant Deterioration (PSD) New Source Review regulations. The HERC was originally permitted in 1987, becoming operational in 1989.
HERC operates under Air Emission Permit Number 05300400-003, which is a federally enforceable operating permit, also known as a Title V Permit. In accordance with Minn. R. ch. 7007.0400, subp. 3, Covanta applied for re-issuance of the Title V permit on November 14, 2002. This application is being reviewed and processed at the same time as this EAW. Since the application for re-issuance was considered to be timely, i.e. more than 180 days before expiration, the HERC is permitted to continue operation under the terms of the expired permit as specified in Minn. R.ch. 7007.0450 subp. 3 Continuation of an Expiring Permit, which states:
“If the owner or operator of a stationary source has submitted a timely and complete application for reissuance of a permit, the permit shall not expire (emphasis added) until the permit has been reissued or the reissuance has been denied, unless the agency determines that any of the following are true:
a. The permittee is not in substantial compliance with the terms and conditions of the expired permit or with a stipulation agreement or compliance schedule designed to bring the permittee in compliance with the permit. b. The agency, as a result of an action or failure to act of the permittee, has been unable to take final action on the application on or before the expiration date of the permit. c. The permittee has submitted an application with major deficiencies or has failed to properly supplement the application in a timely manner after being informed of deficiencies.”
HERC has eight emission units (Table 9).
Table 9 - HERC Emission Sources Emission Source Type Emission Source Identification Number MSW Combustor #1 EU-001 MSW Combustor #2 EU-002 Lime Silo - Pebble Lime EU-003 Fly Ash Silo EU-004 Lime Silo - Dolomitic Lime EU-005 Activated Carbon Silo EU-006 Combined Ash Handling EU-007 Cooling Tower EU-008
The two MSW combustors are identical in design. Each MSW combustor was designed and built with a capacity of 606 tons per day of MSW. Each MSW combustor unit (waterwall boiler) is designed according to good combustion principles to minimize the emission of Carbon Monoxide (CO) and
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 27 Worksheet organics. Nitrogen Oxide (NOX) is controlled on a continuous basis by a low NOX overfire air system in the combustion chamber. Flue gases, upon leaving the combustion unit, first pass through a heat recovery system and then through ductwork where activated carbon is injected for mercury control. The mercury control equipment was added in 1994. Flue gases then enter a lime slurry dry scrubber for control of acid gases, followed by a fabric filter for the control of Particulate Matter (PM) (including metals and dioxins). Temperature in the fabric filter is limited, to prevent the formation of dioxins within the fabric filter. Flue
gasses enter the stack, where continuous emissions monitor systems (CEMS) measure opacity, CO, NOX,
Sulfur Dioxide (SO2), and carbon dioxide (CO2). Operators, in turn, use the data from the monitors to determine real-time adjustments to the equipment.
Pebble lime and dolomitic lime are trucked to the site and unloaded into vertical silos. The PM emissions from these silos are controlled by fabric filters. The pebble lime is used in the lime slurry dry scrubber. Spent lime from the fabric filter is collected with the fly ash and disposed of off-site. The dolomitic lime is used for ash stabilization.
The fly ash silo collects fly ash from the MSW combustor fabric filters. The fly ash is pneumatically conveyed to the silo from the fabric filter. The PM emissions from this silo are controlled by a fabric filter.
The fly ash is mixed with the bottom ash from the MSW combustor and is wetted to control PM emissions during handling and loading into trucks for off-site shipment. This is the Combined Ash Handling emission unit.
Activated carbon is trucked to the site and unloaded into a vertical silo. The PM emissions from this silo are controlled by a fabric filter. The activated carbon is used to reduce mercury emissions from the MSW combustors. Spent carbon is collected with the fly ash and disposed off-site.
The cooling towers use water to condense low pressure steam after the turbines. The cooling towers are a source of PM emissions. The PM emissions are controlled by mist eliminators installed on the towers.
Emissions from stationary sources are expressed in two ways, potential emissions and actual emissions. Since HERC has an existing air emission permit, potential emissions are the maximum emissions that a facility is allowed to emit based on:
x Facility design and operating conditions; x Existing Federal Regulations including New Source Performance Standards, Maximum Achievable Control Technology Standards, and Prevention of Significant Deterioration regulations x Existing Minnesota Regulations; x Federally enforceable permit conditions; and x Minnesota state-only permit conditions.
Actual emissions are calculated based on:
x The actual fuel use at the facility x Information from existing CEMS x Data from performance tests that measure the actual emissions at the facility
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 28 Worksheet x Estimates based on published emission factors
Table 10 shows the current PTE for the HERC and the 2007, 2008, and 2009 actual emissions.
Table 10 - Summary of Potential and Actual Emissions for the MSW Combustors
Pollutant Potential to Emit 2007 Actual 2008 Actual 2009 Actual Tons Per Year Emissions Emissions Emissions Tons Per Year Tons Per Year Tons Per Year PM 94.2 8.09 25.7 16.98 PM10 94.2 8.09 25.7 16.98 SO2 100 9.52 13.05 11.69 NOX 881.2 539.96 525.99 552.87 CO 261.6 49.98 48.31 39.45 VOC 26.2 1.14 0.87 0.58 Lead 1.0 0.00684 0.00233 0.00114 HCl 98.8 65.01 52.74 52.77 Mercury 0.126 0.00294 0.00358 0.00484 Cadmium 0.09 0.00101 0.000317 0.00115 MWC 7.35 x 10-5 1.33 x 10-6 3.29 x 10-6 5.23 x 10-6 Dioxins/Furans MWC Metals1 94.2 8.09 25.7 16.98 1 MWC metals are assumed to equal PM
The actual MSW throughput for 2007, 2008, and 2009 were 365,017 tons, 365,010 tons, and 361,003 tons, respectively. As shown on Table 10, the actual emissions are well below the PTE. Table 10 also shows that actual emissions change year to year. This occurs because of the changing mix of the MSW received, operating conditions at HERC, and the data from the performance tests that are used to calculate emissions. Such variations in actual emissions are normal for operating facilities.
Covanta has submitted a request for a major modification to Air Emission Permit No. 05300400-003 to remove the existing administrative annual fuel usage limit of 365,000 tons/year MSW and allow fuel usage at the design capacity of 442,380 tons/year. Table 11 shows the proposed PTE and projected actual emissions when operating at full design capacity. The reduction in the PTE for NOx is based on the planned installation of a selective non-catalytic reduction (SNCR) system at HERC. Hennepin County and Covanta have committed to the SNCR system installation to achieve this reduction. The proposed annual PTE for mercury will decrease from 0.126 tpy to 0.0314 tpy.
The actual emissions will not change on an hourly or daily basis because the facility has routinely operated at its design capacity for these time periods. Actual emissions would increase on an annual basis due to the increase in fuel use.
The proposed permit modification will not:
x Require any physical modification to the facility x Increase the design or daily fuel use capacity of the facility x Require a change in operations
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 29 Worksheet The lack of a change in operations is demonstrated by the fact that Covanta already routinely achieves a fuel use rate of greater than 1,000 tpd (Table 1). Covanta maintains compliance with the 365,000 tpy fuel use limit by controlling the daily production rate and limiting the annual number of hours of operation.
Table 11 - Summary of Future Potential and Projected Actual Emissions for MSW Combustors
Pollutant Future Potential to Emit Projected Actual Emissions Tons Per Year Tons Per Year PM 90 30.2 PM10 90 30.2 SO2 100 15.3 NOX 550 530 CO 243.6 56.8 VOC 26.2 1.3 Lead 0.8 0.008 HCl 90.4 76.4 Mercury 0.0314 0.0057 Cadmium 0.08 0.0014 MWC Dioxins/Furans 6.28 x 10-5 6.14 x 10-6 MWC Metals1 90 30.2 1 MWC metals are assumed to equal PM
According to 40 CFR 52.21(b)(2)(i), a major modification for the purposes of Prevention of Significant Deterioration (PSD) is:
(2)(i) Major modification means any physical change in or change in the method of operation of a major stationary source that would result in: a significant emissions increase (as defined in paragraph (b)(40) of this section) of a regulated NSR pollutant (as defined in paragraph (b)(50) of this section); and a significant net emissions increase of that pollutant from the major stationary source.
However, in accordance with 40 CFR 52.21(b)(2)(iii)(f)
(iii) A physical change or change in the method of operation shall not include:
( f ) An increase in the hours of operation or in the production rate, unless such change would be prohibited under any federally enforceable permit condition which was established after January 6, 1975, pursuant to 40 CFR 52.21 or under regulations approved pursuant to 40 CFR subpart I or 40 CFR 51.166.
The above analysis is confirmed by the language of the permit regarding the 365,000 tpy fuel use limit which states that “This is a state-only requirement and is not federally enforceable.” Additionally, the referenced regulatory citation is the above-referenced Minnesota law and Minnesota permit regulations.
Since the permit condition limiting fuel use is not federally enforceable and no other physical or operational changes will be required to increase the fuel use, this proposed modification does not require review under PSD regulations.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 30 Worksheet Greenhouse Gas Emissions
A greenhouse gas (GHG) inventory was developed for the HERC and the proposed increase in fuel use using the US EPA's MSW Decision Support Tool modified to include information specific to Minnesota taken from the MPCA General Guidance for Carbon Footprint Development in Environmental Review, p- ear1-07, September 2009 and existing biogenic CO2 emission data for HERC. The MPCA General Guidance follows The Climate Registry General Reporting Protocol (version 1.1, May 2008).. The MSW Decision Support Tool (DST) is intended for use by solid waste planners at state and local levels to analyze and compare MSW management strategies with respect to GHGs and also cost, energy consumption, and environmental releases to air, land, and water.
EPA has done a comprehensive comparison of the WAste Reduction Model (WARM) and MSW-DST tools. EPA does not recommend one in lieu of the other, but rather recommends choosing your tool based on the scope of analysis. Great effort has been made to reconcile differences between the two tools, such that given identical assumptions, the tools would yield identical results. The only major difference between the tools is treatment of carbon storage and sequestration. MSW-DST reports carbon storage and sequestration separately. In accordance with the General Guidance, the GHG inventory for the proposed fuel use limit removal was developed for on-site sources; the municipal waste combustors and purchased power. This is commonly referred to as Scope 1 - Direct Sources and Scope 2 – Indirect Sources. The Scope 1 and Scope 2 sources are those that are normally in the direct control of the facility. Scope 3 sources include upstream and downstream GHG emissions from activities such as employee business travel or shipment of goods to or from the facility. Scope 3 GHG emissions have not been included in this inventory.
MSW contains a wide variety of materials, but the combustibles can generally be divided into organic material derived from biomass (paper, food waste, wood, etc.) and materials derived from fossil fuels (plastics, etc.). CO2 emissions from the combustion of biomass-based organic materials are considered to be biogenic, whereas CO2 emissions from the combustion of fossil based products are anthropogenic. The GHG emissions from both types of materials are included in the inventory. However, in accordance with the General Reporting Protocol of the Climate Registry, biogenic CO2 emissions are kept separate from the Scope 1 and Scope 2 emissions because, over time, they do not cause an increase in the CO2 concentration of the atmosphere.
The primary GHG’s are CO2, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. GHG emissions are reported as CO2 equivalent (CO2e). CO2e is calculated by estimating the emissions of each GHG, multiplying the amount of the individual GHG by its global warming potential (GWP), and summing the total. For example, methane is considered to have a GWP of 25, therefore, one ton of methane would result in a CO2e of 25 tons.
For MSW combustors, the General Guidance identifies CO2, methane, and nitrous oxide as the GHGs of concern. For purchased electricity, the same three GHGs are considered. Per the General Guidance, the GWPs used in the inventory were: CO2 = 1, methane = 25, nitrous oxide = 298.
For the proposed project, CO2 from combustion will comprise the vast majority of the CO2e generated by weight (tons per year). Covanta calculated the CO2 generation rate from HERC using CEMS data for 2009. The total CO2 emission rate, biogenic plus anthropogenic, is 1.08 tons CO2 per ton of MSW combusted. Covanta collected and analyzed 30 exhaust gas samples between May 2007 and March 2010 to determine the biogenic component of the CO2 emissions from the HERC. The average of the 30 samples shows that the biogenic CO2 contribution for the HERC is 64.3%, which equals 0.694 tons CO2 per ton of MSW combusted. Therefore, the anthropogenic CO2 contribution is 35.7% which equates to 0.386 tons CO2 per ton of MSW combusted. A copy of the sample results is included in Appendix C.
In addition to CO2, MSW combustion is a source of N2O and methane. Covanta completed a performance test at a similar MSW combustor in 2009. N2O was measured at <1 ppmv in three consecutive test runs.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 31 Worksheet The highest methane emission rate was measured in three test runs was 1.69 ppmv with an average of 1.51 ppmv. Using performance test data on flow rate from HERC, the emission rate for N20 is 0.019 lbs N2O per ton of MSW combusted and 0.012 lbs of methane per ton of MSW combusted.
Per the General Guidance, Minnesota specific emission factors for Xcel Energy were used for the off-site electric generation calculation in the inventory.
The existing fuel use limit for the HERC is 365,000 tons of MSW per year and the HERC reached that limit in 2006, 2007, and 2008. Therefore, 365,000 tons per year will be the baseline for the GHG inventory. The proposed fuel use limit would be 442,380 tons per year and is the basis for future GHG emissions.
Table 12 - CO2e Emissions Summary Emission Emission Sources Factor Baseline1 Future Difference Tons Tons Scope 1 Sources CO2e CO2e Tons CO2 Ton CO2/ton 365,000 442,380 MSW Combustion 0.386 MSW tons MSW 140,890 tons MSW 170,759 29,869 Lbs N2O/ton 365,000 442,380 MSW Combustion 0.019 MSW tons MSW 1043 tons MSW 1252 209 Lbs methane/ton 365,000 442,380 MSW Combustion 0.012 MSW tons MSW 55 tons MSW 65 10 44,679 Natural Gas Use 115.99 lb CO2/MMBTU MMBtu 2,591 54,062 3,135 544 Total Scope 1 144,579 175,211 30,632 Scope 2 Sources Purchased 2,931 2,931 2 Electricity 1281.7 lb CO2/MWH MWH 1,878 MWH 1,878 0 Total Scope 1 and 2 146,457 177,089 30,632 Biogenic Source Ton CO2/ton 365,000 442,380 Scope 0.694 MSW Tons MSW 253,310 tons MSW 307,011 53,701 1 The baseline for natural gas and purchased power is 2009 because the facility used more natural gas and purchased more power in 2009 than in 2007 or 2008. 2 The emission factor for Xcel Energy was used for purchased power because the HERC is located within Xcel Energy production territory.
Life Cycle Analysis
The proposed change would result in an approximate increase in anthropogenic CO2e emissions from the stacks at HERC of 30,632 tons of CO2e. However, the net effect of the proposed change will be a reduction in CO2e. This is because the additional MSW that would be burned at the HERC will have been diverted from landfills. According to the EPA's study on greenhouse gases associated with solid waste management practices (Solid Waste Management and Greenhouse Gases, A Life-Cycle Assessment of Emissions and Sinks, 2006,) a waste- to-energy plant such as the HERC avoids the emission of greenhouse gases in three different ways:
1. Generating electricity from solid waste reduces the need to generate electricity in conventional power plants that use fossil fuels such as coal and oil. This creates a net reduction of greenhouse gas emissions. 2. At HERC, metal that would otherwise have been buried in a landfill is separated and recycled. Using recycled metal is more energy efficient than mining virgin materials for the production of new metals such as steel. This results in significant energy savings and additional avoidance of greenhouse gas emissions.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 32 Worksheet 3. HERC reduces the amount of MSW sent to landfills. MSW in landfills creates methane, and although some of this methane could be collected and used to generate electricity, some of it would be emitted to the atmosphere.
In addition, HERC avoids CO2e emissions by replacing fossil fuel combusted by the downtown Minneapolis heating and cooling system. HERC provided 101 million pounds of steam to the downtown system in 2009. Based on 1 pound of steam being produced by 1 cubic foot of natural gas (CF), 100 CF = 1 therm, and 1 therm = 11.7 pounds of CO2e, the steam provided to the downtown system in 2009 offset approximately 5,900 tons of CO2e. The life cycle analysis considers both the anthropogenic CO2e generated by the HERC plus the anthropogenic CO2e that would be produced by the alternative methods of generating power and disposing of the MSW in landfills. Thus, the amount of anthropogenic CO2e emitted by HERC offsets the CO2e that would be emitted to produce an equivalent amount of electric power and the amount of methane that would be generated by MSW decomposition in landfills. Table 13 summarizes the annual amount of CO2e that is avoided for the current and future cases.
Table 13 – Summary of Lifecycle Greenhouse Gas Emissions Emission Current CO Future CO Net Emissions 2e 2e Factor Throughput tons/year Throughput tons/year Fossil CO e Emitted ton CO /ton 2 0.396 2e 365,000 144,579 442,380 175,230 by HERC MSW Avoided Landfill ton CO /ton -0.84 2e 365,000 -306,600 442,380 -371,599 Methane as CO2e MSW GHGs Avoided from Ferrous ton CO /ton Recovery and -0.06 2e 365,000 -22,377 442,380 -27,121 MSW Avoided Transportation Fossil CO Avoided ton 2e -0.34 190,188 -64,664 190,188 -64,664 by HERC Power CO2e/MWH Lost LFGTE Grid ton CO /ton 0.10 2e 365,000 36,500 442,380 44,238 CO2 Avoidance MSW ton CO /ton Steam Use Offset -0.06 2e 365,000 -22,377 442,380 -27,121 MSW
Total CO2e -234,939 -271,037 Notes & Assumptions: - HERC had net electricity production of 190,188 MWH in 2009. For the purposes of the lifecycle analysis, the assumption was made that HERC would achieve electric production rates similar to 2009 after removal of the fuel use limit. HERC produced 224,074 MWH in 2007 and 218,546 MWH in 2008.
- Avoided grid emissions are based MPCA General Guidance data for Xcel Energy of 1281.7 lbs CO2 / MWh - Landfill gas collection efficiencies vary over time. In fact, at the beginning and end of the life of MSW placed in a landfill, there is typically no collection. An integrated landfill gas collection efficiency of 45% is calculated using the first order decay model, and assumes a collection efficiency of 75% after final cap and system installation. - 10% Soil oxidation in landfills assumed - Assumes that the landfill avoided methane corresponds to landfill gas collection mechanisms used at Elk River landfill = 100% LFGTE.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 33 Worksheet As shown in Table 13, operation of the HERC at the design capacity will reduce overall CO2e emissions by approximately 271,000 tons per year and increase the avoided CO2e.emissions by approximately 36,100 tons CO2e per year.
The GHG mitigation potential of energy from waste (EfW) is widely recognized by the United Nations Framework Convention on Climate Change, the European Union and the European Environmental Agency, the Global Roundtable on Climate Change convened by Columbia University’s Earth Institute, and the U.S. Conference of Mayors.
In fact, the Nobel Prize winning Intergovernmental Panel on Climate Change (“IPCC”) identifies EfW as a key GHG mitigation technology for the waste sector.1 EfW facilities in developing countries are eligible to generate tradable GHG credits under an approved Clean Development Mechanism (CDM) methodology. A recent paper coauthored by EPA and North Carolina State researchers demonstrated the value of EfW over landfilling from both a GHG and energy perspective.2 The World Economic Forum at their 2009 meeting in Davos, Switzerland, identifies EfW as one of eight renewable technologies likely to make a meaningful contribution to a future low-carbon energy system.3 Finally, the Lee County, Florida Resource Recovery Facility recent capital expansion was the first to generate carbon offset credits in North America through the Voluntary Carbon Standard.
Ambient Air Quality
The Clean Air Act required the USEPA to set National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment if present in sufficient concentrations. NAAQS include two types of air quality standards. Primary standards protect the public, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards protect public welfare, including protection against decreased visibility, damage to animals, crops, vegetation, and buildings. USEPA has established and Minnesota has adopted NAAQS for seven principal pollutants, which are called “criteria pollutants”, as defined in Table 13. In addition to the NAAQS, Minnesota has adopted State Ambient Air Quality Standards (MAAQS). Table 14 provides a summary of the MAAQS.
Areas that meet the air quality standards for the criteria pollutants are designated as being in attainment. Areas that do not meet the air quality standard for one or more of the criteria pollutants may be subject to the formal rule-making process and designated as being in nonattainment for that standard. The determination regarding whether an area is in attainment is made by the MPCA using a combination of monitoring for pollutants at multiple locations and computer based modeling. The results of the AAQS designation is reported to and reviewed by the USEPA regularly. The MPCA also prepares and submits a report on AAQ to the Legislature each year.
The State of Minnesota and Hennepin County are in attainment for all criteria air pollutants. Since HERC has been present and operating in Minnesota since 1989, the emissions from HERC have been included in the monitored background concentrations in Minneapolis and Hennepin County used to make the attainment determination.
As part of the original 1986 Environmental Impact Statement prepared for HERC, an ambient air quality modeling analysis was completed. That modeling analysis determined that the emissions from the HERC
1 IPCC, Climate Change 2007: Synthesis Report. Contribution of Work Groups I, II, and III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 pp. 2 Kaplan, P.O, J. DeCarolis, and S. Thorneloe, 2009, Is it better to burn or bury waste for clean electricity generation? Environ. Sci. Technology 43 (6) pp1711-1717 3 World Economic Forum. Green Investing: Towards a Clean Energy Infrastructure. January 2009. http://www.weforum.org/pdf/climate/Green.pdf
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 34 Worksheet will not cause or significantly contribute to an excursion of the NAAQS or MAAQS that were in effect at that time.
As part of this EAW, Covanta completed an ambient air quality analysis. The modeling analysis was completed using the project future potential to emit for the HERC. Covanta used the most recent version of the computer modeling software and followed MPCA guidance on ambient air quality modeling. Table 15 shows the results of that modeling analysis, confirming that HERC does not cause or contribute to excursion of any NAAQS or MAAQS. That is, for all criteria pollutants, the analysis shows that ambient air concentrations associated with emissions of HERC plus contribution from background sources are below the NAAQS and MAAQS. For this comparison calculations were made at the total facility burning MSW at the maximum rate of 1,212 tpd, 365 days per year. Given that this comparison was made for the points of highest modeled concentrations, the contribution of HERC to ambient concentrations of criteria pollutants at all other locations would be less. Table 14 - National Ambient Air Quality Standards Pollutant Primary Standards Averaging Times Secondary Standards Carbon Monoxide 9 ppm (10 mg/m3) 8-hour(1) None 35 ppm (40 mg/m3) 1-hour(1) None Lead 1.5 µg/m3(2) Quarterly Average Same as Primary Nitrogen Dioxide 0.053 ppm (100 µg/m3) Annual (Arithmetic Mean) Same as Primary Nitrogen Dioxide(9) 100 ppb (188 µg/m3) 1-hour None 3 (3) PM10 150 µg/m 24-hour Same as Primary 3 (4) PM2.5 15.0 µg/m Annual (Arithmetic Mean) Same as Primary 35 µg/m3 24-hour(5) Same as Primary Ozone 0.075 ppm (2008 std) 8-hour(6) Same as Primary 0.08 ppm (1997 std) 8-hour (7) Same as Primary 0.12 ppm 1-hour(8) Same as Primary (Applies only in limited areas) Sulfur Oxides 0.075 ppm 1-hour 0.5 ppm (1300 µg/m3)
Table obtained from USEPA, 2009a. (1) Not to be exceeded more than once per year. (2) Final rule signed October 15, 2008. (3) Not to be exceeded more than once per year on average over 3 years. (4) To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 µg/m3. (5) To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 µg/m3 (effective December 17, 2006). (6) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm. (effective May 27, 2008) (7) (a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard—and the implementation rules for that standard—will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (8) (a) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is < 1. (b) As of June 15, 2005 EPA revoked the 1-hour ozone standard in all areas except the 8-hour ozone nonattainment Early Action Compact (EAC) Areas. (9) T th he 1-hours NO2 standard is based on the three year average of the 98 percentile of the annual distribution of the daily hourly maximum 1-hour concentrations.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 35 Worksheet Table 15 – Minnesota Ambient Air Quality Standards
Pollutant/Air Primary Standard Secondary Standard Remarks Contaminant
Hydrogen Sulfide 0.05 ppm by volume 1/2 hour average not to be exceeded over 2 times per year (70.0 micrograms per cubic meter) 0.03 ppm by volume 1/2 hour average not to be exceeded over 2 times in any 5 (42.0 micrograms per consecutive days cubic meter)
Ozone 0.08 ppm by volume same as primary daily maximum 8 hour average; the standard is attained when the (235 micrograms per standard average of the annual fourth-highest daily maximum 8-hour average cubic meter) ozone concentration is less than or equal to the standard
Carbon Monoxide 9 ppm by volume (10 same as primary maximum 8 hour concentration not to be exceeded more than once milligrams per cubic standard per year meter) 30 ppm by volume (35 same as primary maximum 1 hour concentration not to be exceeded more than once milligrams per cubic standard per year meter)
Sulfur Dioxide 80 micrograms per cubic 60 micrograms per cubic maximum annual arithmetic mean meter (0.03 ppm by meter (0.02 ppm by volume) volume) 365 micrograms per same as primary maximum 24 hour concentration not to be exceeded more than once cubic meter (0.14 ppm standard per year by volume) 915 micrograms per maximum 3 hour concentration not to be exceeded more than once cubic meter (0.35 ppm per year in Air Quality Control Regions 127, 129, 130, and 132 by volume) 1300 micrograms per maximum 3 hour concentration not to be exceeded more than once cubic meter (0.5 ppm by per year in Air Quality Control Regions 128, 131, and 133 volume) 1300 micrograms per maximum 3 hour concentration not to be exceeded more than once cubic meter (0.5 ppm by per year volume) 1300 micrograms per maximum 1 hour concentration not to be exceeded more than once cubic meter (0.5 ppm by per year volume)
75 micrograms per cubic 60 micrograms per cubic Particulate Matter maximum annual geometric mean meter meter 260 micrograms per 150 micrograms per maximum 24 hour concentration not to be exceeded more than once cubic meter cubic meter per year
Nitrogen Dioxide 0.05 ppm by volume same as primary maximum annual arithmetic mean (100 micrograms per standard cubic meter)
Lead 1.5 micrograms per same as primary maximum arithmetic mean averaged over a calendar quarter cubic meter standard
PM-10 150 micrograms per same as primary maximum 24-hour average concentration; the standard is attained cubic meter standard when the expected number of days per calendar year exceeding the value of the standard is equal to or less than one 50 micrograms per cubic same as primary annual arithmetic mean; the standard is attained when the expected meter standard annual arithmetic mean concentration is less than or equal to the value of the standard
PM-2.5 65 micrograms per cubic same as primary 24-hour average concentration; the standard is attained when the meter standard 98th percentile 24-hour concentration is less than or equal to the standard 15.0 micrograms per same as primary annual arithmetic mean; the standard is attained when the annual cubic meter standard arithmetic mean concentration is less than or equal to the standard
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 36 Worksheet Table 16 – Summary of Ambient Air Quality Modeling Analysis Impact based on Max TOTAL Averaging NAAQS SIL Background Percent of 5-year Max. Pollutant Impacts Impacts Period (µg/m3) (µg/m3) (µg/m3) NAAQS (unless otherwise (µg/m3) (µg/m3) noted): 1hr 40000 2,000 120.20 3565.00 3685.20 9.2% H1H CO 8 hr 10000 500 32.53 2760.00 2792.53 27.9% H1H 98% (with Paired 1hr(1) 188 - 85.29 - 125.09 66.5% Hourly NO2 Background) annual 100 1 5.79 17.00 22.79 22.8% H1H 24 hr 150 5 18.31 47.00 65.31 43.5% H2Hc PM10 annual 50 1 3.38 27.00 30.38 60.8% H1H 24 hr 35 1.2 8.55 26.00 34.55 98.7% 5-yr H1H Avg. PM2.5 annual 15 0.3 1.05 10.00 11.05 73.6% H1H 1 hr 196 - 49.29 110.00 159.29 81.3% H1H 3 hr 1300 25 22.35 86.00 108.35 8.3% H1H SO2 24 hr 365 5 8.88 34.00 42.88 11.7% H1H annual 80 1 0.56 5.00 5.56 7.0% H1H (1) 1-hr NO2 PVMRM runs using MPCA O3 and background NO2 with 10% in-stack thermal conversion
Risk Assessment
MPCA’s Air Emissions Risk Analysis (AERA) process was followed to provide a health review of changes in annual permitted emissions associated with the proposed removal of the fuel use limit. An AERA estimates cancer and non-cancer risks to human health following guidelines developed by the MPCA (http://www.pca.state.mn.us/air/aera.html), in consultation with the Minnesota Department of Health (MDH), which in most part are consistent with EPA guidance. The guidelines are that the increased individual lifetime cancer risk due to exposure to carcinogenic chemicals emitted from a facility, should be less than 1 in 100,000 (10-5 ) and that non-carcinogenic hazard index should be less than 1. In the context of the proposed revision to the HERC Air Emission Permit, these guidelines apply to the change in annual emissions associated with the proposed action. If the increase in emissions result in estimated risks in excess of these levels, according to the AERA process, MPCA staff would need to evaluate whether further refinement of the analysis, modifications to the facility, or stricter air emissions limits, are warranted.
Covanta screened risks using the AERA process and in consultation with MPCA conducted a more refined analysis following U.S. EPA’s Human Health Risk Assessment Protocol (HHRAP). HHRAP, which was developed by EPA in permitting hazardous waste combustors is widely accepted and used to evaluate human health risks associated with municipal waste combustion in Minnesota and throughout the U.S. The EPA risk assessment model was applied to estimate potential cancer risks and non-cancer hazard indices for people living in the surrounding community. This analysis screened a large number of pollutants using the MPCA’s Risk Assessment Screening Spreadsheet (RASS) which provides a highly conservative evaluation of risk, to identify the 15 toxic air pollutants referred to as chemicals of potential concern (COPC) to be included in the HHRAP assessment. COPCs include acrolein, arsenic, benzo(a)pyrene, cadmium, chromium VI, dibenz(a,h)anthracene, H2SO4, HCl, lead, manganese, mercury, nickel, nitrobenzene, n- nitroso-di-n-propylamine, and dioxin/furan. NO2 was added to the list of COPC at the request of the MPCA.
The HHRAP analysis is a comprehensive assessment that addresses a wide variety of exposure routes that are pertinent to Hennepin County. Using a refined EPA dispersion model (AERMOD), the analysis applies
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 37 Worksheet representative meteorological data to evaluate concentrations of COPCs in the ambient air, at elevated locations such as high rise apartments and roof top gardens (e.g flag pole receptors) and the deposition to the ground surface. Conservative methods are then applied to estimate the concentration in the soil, surface water and eventually fish, home-grown vegetables as farm-raised animals, cow’s milk and eggs that people consume.
For the fish ingestion pathway the non-cancer risk is mostly associated with mercury. At the direction of MPCA, the risk associated with mercury through this pathway was independently evaluated using the Mercury Risk Estimation Method (MMREM) spreadsheet developed by MPCA. The MMREM hazard index for mercury was then added to the HHRAP hazard index (excluding the fish pathway for mercury) to estimate the combined non-cancer hazard index for all COPCs and exposure routes.
Three categories of people living near the HERC were evaluated; 1) a resident who lives in a low-rise or high-rise building and eats local produce from his backyard garden and eats eggs from chickens husbanded at his residence; 2) a farmer who lives at the nearest agricultural area and lives off his produce and livestock; 3) a subsidence fisher who lives at a low-rise residential location and for dietary protein relies on fish caught from local water bodies and 4) a recreational fisher who occasionally eats locally caught fish. Due to their size and nearby locations relative to the HERC, four lakes, Lake Calhoun, Lake of the Isles, Crystal Lake, and Wirth Lake, were evaluated for the recreational and subsidence fisher. The recreational fisher was assumed to fish only at his or her favorite lake, whereas, in accordance to MPCA guidance a subsidence fisher would catch fish from all four lakes.
The following analyses were conducted and summarized in Tables 17 and 18.
Table 17 includes: x Chronic cancer risks and non-cancer hazard indices from current actual emissions based on 2007- 2009 stack testing; x Chronic cancer risks and non-cancer hazard indices from the projected total HERC PTE
Table 18 includes: x Acute non-cancer hazard indices from current actual emissions based on 2007-2009 stack testing; x Acute non-cancer hazard indices from the projected total HERC PTE.
The MPCA significant risk thresholds are 1 x 10-5 for lifetime cancer risk and 1.0 for both the long-term and acute non-cancer hazard indices. The results in these tables indicate that risks associated with proposed future permitted emissions for all model receptor types are below MPCA risk thresholds and that for actual emissions the modeled risks are very low in comparison to these thresholds. This analysis confirms that HERC does not and will not contribute to community health risk.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 38 Worksheet Table 17 – Summary of Long-Term Risk
EmissionsCase ProposedPermittedEmissions ActualEmissions(3) Cancer Hazard ReceptorType(1) CancerRisk HazardIndex Risk Index residentadult 1.2EͲ06 0.20 4.3EͲ07 0.18 Resident residentchild 3.2EͲ07 0.20 9.4EͲ08 0.18 farmeradult 4.8EͲ06 0.02 2.9EͲ07 0.01 Farmer farmerchild 1.0EͲ06 0.02 6.1EͲ08 0.01 RecreationalFisheratLake fisheradult 1.1EͲ06 0.19 2.1EͲ07 0.08 Calhoun fisherchild 2.9EͲ07 0.20 5.2EͲ08 0.08 RecreationalFisherat fisheradult 2.2EͲ06 0.42 2.7EͲ07 0.10 CrystalLake fisherchild 4.5EͲ07 0.43 6.1EͲ08 0.10 RecreationalFisheratLake fisheradult 1.3EͲ06 0.24 2.2EͲ07 0.08 oftheIsles fisherchild 3.2EͲ07 0.25 5.4EͲ08 0.08 RecreationalFisheratLake fisheradult 1.8EͲ06 0.27 2.8EͲ07 0.09 Wirth fisherchild 4.0EͲ07 0.28 6.2EͲ08 0.09 fisheradult 3.5EͲ06 0.98 3.1EͲ07 0.17 SubsistenceFisher(2) fisherchild 6.1EͲ07 0.98 6.6EͲ08 0.17
(1)"Resident"receptortyperepresentsthehighestriskamongresidentslivinginlowͲrisebuildings(groundͲlevelreceptors)andhigh risebuildings(flagpolereceptors).ThehighestresidentialriskinthetablecorrespondstoahighͲrisebuilding.Allothertypesof receptorswereassumedtoliveinlowͲrisebuildings. (2)PerMPCAguidance,theriskforthesubsistencefisherbasedontheaverageconcentrationoverallwatershedsandwaterbodies (3)Basedonaverageof2007Ͳ2009stacktests Table 18 - Summary of Acute Inhalation Risk based on Maximum Modeled 1-hour Concentration
Proposed Actual Receptor Permitted Emissions Emissions Resident(HighRiseDwelling) 0.39 0.27 Resident(LowRiseDwelling) 0.10 0.07 Farmer 0.03 0.02
For lead, per MPCA guidance, a supplemental analysis was conducted to evaluate the maximum contribution of inhaled lead and lead deposited onto soil to blood lead level in children associated with long- term HERC emissions using the USEPA Integrated Exposure Uptake Biokinetic Model (IEUBK). A blood lead level exceeding 10 ug/dL is deemed to be significant. The results of this assessment for the resident with the highest modeled concentrations provided in Table 19, indicates that the contribution from HERC to children’s blood lead levels is insignificant.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 39 Worksheet Table 19 – IEUBK Modeled Incremental Blood Lead Levels
Modeled Long- Modeled Pb Soil Incremental Term Pb Air Neighborhood Area Concentration Blood Hg In Comment Concentration (mg/kg) Children (ug/dL) (ug/m3) Proposed Permitted 1.64E-04 1.64E-04 2.90E-03 Below Emissions threshold Actual Emissions 6.74E-07 6.74E-07 1.19E-05 Below Threshold
In addition to the incremental assessments of HERC emissions, per MPCA guidance, the cumulative hazard index and cancer risk associated with inhalation of urban air pollution in the Minneapolis area was also evaluated. Table 19 shows that according to the upper 95% estimate of 2006 to 2008 ambient measurements of selected toxic air pollutants reported by MPCA, the existing Minneapolis urban-average chronic hazard index is about 1.2, the individual lifetime cancer risk is about 4.4 x 10-5 and acute hazard index is about 0.5. If these background inhalation risks are assumed to be representative for locations of maximum modeled inhalation risk from HERC the total future cumulative risk inhalation risk can be computed by adding the maximum modeled risks to these background levels. This method is conservative because MPCA’s computed background risk estimates already include the actual contribution from HERC emissions. The maximum modeled inhalation risk corresponds to high rise apartment. The results of this conservative analysis are provided in Table 20.
Table 20 - Cumulative Inhalation Risk 95th Maximum Percentile Cumulative Proposed Risk Index Urban Inhalation Permitted Background Risk Risk Risk Cancer Risk x 100,000 4.38 0.10 4.48 Chronic Hazard Index 1.17 0.20 1.37 Acute Hazard Index 0.51 0.35 0.86
24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during operation? Yes No
If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.)
The proposed modification will not result in any physical or operational change at the HERC. Therefore, no change in the generation of odors, noise, or dust would occur.
Odors
The primary potential sources of odors at the HERC are the MSW trucks arriving at the site and tipping floor operations. The HCDES began daily odor monitoring at the HERC Site and in the surrounding neighborhood in March 2004, in order to determine the potential for the HERC to affect the proposed ballpark site. Other odor sources in the neighborhood were also identified and evaluated. St. Croix Sensory, Inc., an odor testing and training company, was hired to train the HCDES monitoring team in recognized procedures for conducting field evaluations of ambient odors.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 40 Worksheet A monitoring route was established with monitoring points on the HERC property, at the perimeter of the property, and in the neighborhoods around the HERC property. Initially the route consisted of 17 points. As the monitoring program matured some points where HERC odors were never detected or which became inaccessible because of construction were discontinued. When possible, new points were added to replace inaccessible points. Between 2004 and 2009 a total of 26 monitoring points were used at one time or another. Seven points were on the property, ten points were located around the perimeter of the property, and nine points were located in the surrounding neighborhoods. Figure 10 displays the 26 HERC odor monitoring point locations.
Odor monitoring was conducted weekdays from April to November of each year from 2004 through 2009. The data collected included the type of odor detected and the strength of the odor. An olfactometer, a portable odor measuring device, was used to quantify odors. For the purpose of our analyses, data collected between April 26 and November 30 of each year at the monitoring points 200, 205, 210, 212, 215, 217, 220, 230, 240, 250 located around the perimeter of the ballpark site was reviewed. All perimeter monitoring points were not always accessible due to ballpark and light rail construction in the area.
The strength of the detected odors decreased after the 2004 monitoring period and in 2005 to 2009 were barely detectable using the field olfactometer.
In comparison, neighborhood odors such as sewer smells and car and diesel exhaust were frequently more prevalent and intense than odors from the HERC.
The HCDES continues to monitor odors on a daily basis on weekdays from April to November. Current odor control techniques include:
x In 2009 traffic patterns into and out of the tipping hall were changed. Trucks used to enter the tipping hall through a south facing door and exit through one of two east facing doors. When the entrance door and an exit door were open at the same time a wind tunnel effect could be created, drawing air out of the tipping hall. The two existing east facing exit doors were eliminated. A new entrance door has been installed on the south side of the building and the existing south facing door is now used as the exit. Trucks now both enter and exit on the south side of the tipping hall. Sealing the two former truck exit doors and demolishing their associated roadways on the east side of the tipping hall (nearest ballpark) and subsequently utilizing the former entrance door on the south side of the tipping hall as the single new exit door; x High speed doors on the entrance and exit; x Use of the existing under-fire air fans to maintain a negative pressure in the tipping hall; x Use of a vapor phase odor neutralization system that was installed and operated during 2009; x Keeping roadways swept and clean of debris from the trucks; x Construction of an interior wall and air lock door at the entrance to the tipping hall
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 41 Worksheet Noise
The HERC is located in a highly urbanized area where both traffic and other noise sources are currently present. The primary noise sources at the HERC are the cooling tower fans, pollution control equipment fans and trucks entering the site. Traffic noise is generated by a high number of vehicles traveling both on nearby city streets as well as on Interstate entrances, exits and roadways. Free flow traffic conditions create the highest daytime noise levels (generally between 9:00 a.m. to 4:00 p.m.), while the nighttime peak traffic time period is generally from 6:00 a.m. to 7:00 a.m. Other sources include noise generated by freight trains traveling on the Burlington Northern & Santa Fe (BNSF) Railway line, which is located parallel to I-394 through the area. The BNSF Railway line carries approximately 14 to 20 trains per day, some of which are unit trains of substantial length. The mechanical equipment (e.g., air conditioners and ventilation equipment) associated with the many buildings in and surrounding the HERC also produce substantial noise when in operation.
Noise Monitoring Existing noise levels were monitored at two sites, NSA 1 and NSA 3, during the fall of 2006, near the HERC. The sites were chosen to represent areas of current and future residential land uses. Receptor site NSA 3 is located directly south of the HERC Site along 7th Street N. These two monitoring locations are depicted in Figure 11.
Daytime and nighttime noise levels were monitored. Daytime noise levels were monitored from 2:00 p.m. to 4:00 p.m. Nighttime noise levels were measured during the nighttime peak traffic time period (generally from 6:00 to 7:00 a.m.), when free-flow traffic conditions create the highest noise levels just prior to the morning rush hour.
A trained noise monitoring technician was present for each monitoring session to ensure correct operation of the instrumentation. Table 21 summarizes the monitoring data for NSA 1 and NSA3.
Table 21- Summary of 2006 Noise Monitoring Data Location Daytime Results dBA Nighttime Results dBA NSA1 68 64 NSA3 62 64
The monitored L10 daytime noise levels ranged from 62 to 68 dBA (L10), whereas the monitored L10 nighttime noise levels ranged from 64 to 66 dBA (L10). L10 is the sound level in dBA that is exceeded 10 % of the time during a one-hour survey (The Minnesota Urban Ballpark Federal Environmental Impact Statement, June 4, 2007).
The Noise Area Classification (NAC) standards established in Minn. R. ch. 7030.0050 assigns standards according to land use activities (Table 22).
Table 22 - MPCA Noise Area Classification Standards Day (7 am-10 pm) Night (10 pm – 7 am) L50 L10 L50 L10 1 (Residential) 60 65 50 55
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 42 Worksheet 2 (Commercial) 65 70 65 70 3 (Industrial) 75 80 75 80
In 2007, Covanta completed a noise analysis of their scrubber system. Based on that noise analysis, Covanta modified the enclosure system around the scrubber conveyors to reduce the noise levels both on-site and off-site. The scrubber enclosure modification reduced on-site noise levels but did not reduce off-site noise levels significantly due to the predominance of other noise sources off-site.
The MPCA maximum allowable noise levels for residential land are exceeded under current conditions due to noise generated by the numerous sources of noise in this urban area described above. As shown on Figure 11, NSA1 is located several blocks from HERC and had higher monitored noise levels than NSA3 which is immediately adjacent to HERC. Based on these results, the proposed modification will not negatively affect these noise levels.
Dust HERC does not have any significant sources of fugitive dust. All roads and parking areas are paved. All unpaved areas on-site are landscaped. All process operations, including waste and ash handling, are conducted inside the buildings. Strict policies and procedures, as detailed in HERC Fugitive Emission Control Plan, are in place to minimize generation of fugitive dust.
25. Nearby resources. Are any of the following resources on or in proximity to the site?
a. Archaeological, historical, or architectural resources? Yes No b. Prime or unique farmlands or land within an agricultural preserve? Yes No c. Designated parks, recreation areas, or trails? Yes No d. Scenic views and vistas? Yes No e. Other unique resources? Yes No
If yes, describe the resource and identify any project-related impacts on the resources. Describe any measures to minimize or avoid adverse impacts.
25a. Archaeological, Historical, or Architectural Resources
The Minneapolis Warehouse Historic District (Warehouse District) is located to the northeast of the HERC on the other side of 5th Street North. The Warehouse District is comprised of late nineteenth and early twentieth century three- to ten-story brick and stone warehouse structures. These warehouses originally served the railroad lines traversing the north side of the Minneapolis downtown between 2nd Avenue North and 5th Avenue North, and a rail yard that occupied the area many decades ago. The Warehouse District is listed on the National Register of Historic Places (NRHP) and is also designated by the City of Minneapolis as a Heritage Preservation District, although with slightly different boundaries (Figure 12). The Warehouse District today has an entertainment focus, particularly along 1st Avenue North and the adjacent side streets where a number of bars, restaurants, and clubs have located in the lower floors. The upper floors of these buildings are occupied by offices or are used for storage. At the edges of the district furthest from downtown, warehouses have also been converted to residential use. There will be no impact to the Warehouse District due to the proposed modification.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 43 Worksheet 25c. Designated parks, recreation areas, or trails The Cedar Lake Bike Trail currently ends immediately west of the Target Field. Hennepin County has plans to re-route the Trail to run under the Target Field promenade. The proposed modification will not impact the Trail or potential future plans to re-route the trail.
25e. Other Unique Resources Target Field, the new baseball stadium for the Minnesota Twins, has been constructed immediately adjacent to HERC to the southeast. The relationship and impacts of HERC on the stadium were analyzed in FEIS. The FEIS did not identify any mitigative measures required for HERC.
26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No
If yes, explain.
No new visual impacts will occur as a result of removal of the fuel use limit. Current visual impacts include a water vapor plume from the HERC cooling towers and exhaust stacks during cold weather, the buildings and stacks of the HERC. The proposed modification will not change the existing facility or operations. The HERC would operate more days per year and will operate both MSW combustors more hours per year. However, since the water vapor plume is only visible during low temperature conditions and the HERC normally operates through the winter months to provide steam heat to their customers, no increase in the number of days with a visible water vapor plume is expected.
Because of its size and height, the primary structure in the area is the new Target Field. Secondary visual impacts come from the 6th street parking garage, Target Center, and the office towers and buildings in the Warehouse District.
27. Compatibility with plans and land use regulations. Is the project subject to an adopted local comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? Yes No
If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain.
The proposed project will not change the existing facility. Therefore, no change to land use would occur. Covanta is identified in the City of Minneapolis Planning Department Downtown East / North Loop Master Plan, Adopted October 2003 (Master Plan). Covanta is located within Development Precinct 12: Municipal Service. The Master Plan states that:
Development Precinct 12: Municipal Service Given the investment made to locate major institutional uses in this precinct (The Hennepin Energy Recovery Center and the Metro Transit facility) major redevelopment in this precinct is not likely or recommended. However, in keeping with the proposal put forth in the Hennepin County Station Area Plan, the berm along North 5th Street and Sixth Avenue North could be redeveloped with a band of medium-density, mixed use development that houses commercial or government offices and,
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 44 Worksheet perhaps, low-impact light industrial development. Wrapping the site with active uses would help to create a buffer between the Energy Resource Center and the developing neighborhoods to the north and east.
In 2009 and 2010, the City of Minneapolis Department of Community Planning & Economic Development prepared The Draft North Loop Small Area Plan which is officially an update to the Downtown East/North Loop Master Plan, adopted by the City in 2003, and builds upon the policy direction of The Minneapolis Plan for Sustainable Growth, the City’s comprehensive plan. It is meant to articulate a vision for the neighborhood based on existing City policy and input from community stakeholders – both public and private - throughout the planning process. The Small Area Plan was needed due to the large number of changes that had occurred in the North Loop since 2003, including development of Target Field, the Light Rail transit hub, and the Northstar Commuter Line.
The Small Area Plan notes that the Municipal Service district (Precinct 12) has been expanded to include the proposed Heywood II Metro Transit bus layover and maintenance facility on the Ragstock site along 10th Avenue North between 7th and 5th Streets North. Because the majority of sites in this district are publicly-owned, major redevelopment is not likely. Opportunities exist, however, to better utilize the public sites with a transition over time to co-location of public services for a higher utilization of these Downtown sites. If public uses are required to expand, preference is for a creative use of land area by such methods as decked parking or office space over existing buildings before use of additional land is explored. Any new or expanded public facility should adhere to site plan review standards with an emphasis on ground-floor views in and out of the building. They should also make improvements over time to site and building design by incorporating more landscaping and reducing the amount of pavement or hardscape. Any new buildings along 10th Avenue North/Oak Lake Avenue North should include pedestrian-oriented design features and recognize other plan recommendations to use this street as an improved connection through the neighborhood. (Draft North Loop Small Area Plan, City of Minneapolis, March 2010)
Continued operation of HERC is compatible with the land uses identified in the Master Plan and the Small Area Plan. No conflict will occur as a result of the proposed Project.
28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? Yes No
If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.)
The proposed modification will not require any construction or physical changes to existing infrastructure or public services.
29. Cumulative potential effects. Minn. R. 4410.1700, subp. 7, item B requires that the RGU consider the “cumulative potential effects of related or anticipated future projects” when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects. (Such future projects would be those that are actually planned or for which a basis of expectation has been laid.) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form).
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 45 Worksheet Three other projects have been completed that have a potential cumulative impact in the proposed project area, 1) Development of Target Field, 2) Development of the light rail hub adjacent to the facility, and 3) Development of the Northstar Commuter Rail line.
The Target Field was developed between 2007 and 2010. As of March 2010, Target Field has been completed. A FEIS was completed for the construction and operation of Target Field. Since construction of Target Field has been completed, no ongoing cumulative effects remain from construction activities. Significant issues identified during the FEIS related to operation of Target Field were traffic, parking, transit, and pedestrian issues.
The proposed project would increase traffic on 6th Street by less than a 0.6% compared to 2007 traffic levels. New traffic for events at Target Field is predicted to be up to 11,300 additional vehicles for a weekday afternoon game and up to 13,600 additional vehicles for a weekday evening game. With no more than an additional 14 truck per day, the proposed project will not result in a significant increase in traffic and will not exacerbate the traffic issues associated with either daytime or nighttime events at Target Field.
The development of the transit hub and the Northstar commuter line are expected to help alleviate traffic issues in the area. Thus, they are not expected to have an adverse cumulative effect.
The proposed project will not have any impact on parking, transit or pedestrian issues.
30. Other Potential Environmental Impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation.
No other potential adverse environmental impacts are anticipated.
31. Summary of issues. (Do not complete this section if the EAW is being done for EIS scoping; instead, address relevant issues in the Draft Scoping Decision Document, which must accompany the EAW.) List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions.
Air Quality
The PTE and actual emissions for HERC will change as a result of the proposed modification. The proposed PTE for NOX will decrease from 881 tpy to 550 tpy due to the planned installation of a selective non-catalytic reduction (SNCR) system at HERC. Hennepin County and Covanta have committed to the SNCR system installation to achieve this reduction. The proposed annual PTE for mercury will decrease from 0.126 tpy to 0.0314 tpy.
The PTE for PM, PM10, lead, cadmium and Total MWC Metals will decrease. This is because of a revision of the Federal New Source Performance Standard (NSPS) for Municipal Waste Combustors 40 CFR 60, Subpart Cb. The HERC is currently meeting the NSPS Subpart Cb limits and is proposing to incorporate those emission limits in the revised Air Emission permit for the HERC. The PTE for CO and HCl, will increase because of a change in the maximum exhaust flow rate as determined through performance testing completed during 2007, 20087 and 2009. The PTE for VOC and SO2 will remain unchanged.
Because HERC routinely operates at its maximum design capacity, the daily actual emissions from the HERC will not change. However, because the HERC would operate above the existing 1,000 tpd average (365,000 tpy) fuel use limit, the annual actual emissions would increase for some regulated pollutants.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 46 Worksheet Direct GHG emissions will increase from Covanta due to the increase in fuel use. However, the offset in anthropogenic GHG emissions due to electric and steam production from MSW and diversion of MSW from landfills will further reduce GHG emissions by 43,196 tons/year from -325,474 tons CO2e per year to -368,474 tons CO2e per year.
Covanta has completed a risk analysis for the proposed fuel use limit removal. The incremental increase in cancer risk and the hazard index due to the removal of the fuel use limit are well below the thresholds set by the MPCA. Additionally, the risk from the HERC if it operated at its PTE are also below the thresholds set by the MPCA for all persons and resources.
Noise
The MPCA maximum allowable noise levels for residential land are exceeded at monitoring locations under current conditions due to noise generated by the numerous sources of noise in this urban area. As shown on Figure 11, NSA1 is located several blocks from HERC and had higher monitored noise levels than NSA3 which is immediately adjacent to HERC. The noise levels in the area are largely due to other existing sources and the proposed modification will not negatively affect these noise levels.
Traffic After the permit amendment there will be an increase in the number of transfer trailers hauling MSW to HERC. The vast majority of the additional MSW will be hauled by transfer trailer from the Brooklyn Park Transfer Station. HERC currently receives about 210-220 trucks per day during the week, 60-70 trucks per day on Saturday and 25 trucks on Sunday. The increase in traffic assuming HERC could operate without regard for operations and maintenance considerations would be up to 14 transfer trailers and 2 ash trucks per day.
The principal access routes to HERC will not change. The number of employees at HERC will not change, so employee-related traffic and parking will not be affected by the proposed modification.
The Minnesota Urban Ballpark Final Environmental Impact Statement, June 4, 2007 estimated that traffic increases, due to construction of the Target Field, in the North Loop and Warehouse District area would be up to 11,300 additional vehicles for a weekday afternoon game and up to 13,600 additional vehicles for a weekday evening game.
This is an urban area with street and highways that experience high traffic volumes. As shown on Figure 9, the average daily traffic (ADT) on 6th Street adjacent to the HERC is 8,800 vehicles. The ADT at the intersection of 6th Street and Highway 55 adjacent to the HERC is 10,900 vehicles. The increase in truck traffic going to Covanta would result in a total ADT increase on 6th Street of approximately 0.6%.
Recycling Hennepin County currently recycles or composts approximately 49% of waste generated(this includes waste reduction credits from the State). The County is proposing a 65% recycling and composting target to be achieved by 2015 and is implementing strategies to achieve that target. If that target is achieved and HERC capacity is increased by 77,380 tons per year, almost 170,000 tons of waste generated in the County in 2015 will still require landfilling. Additional processing capacity in addition to HERC will be necessary to achieve zero waste landfilled.
RGU CERTIFICATION
I hereby certify that: x The information contained in this document is accurate and complete to the best of my knowledge.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 47 Worksheet x The EAW describes the complete project; there are no other projects, stages, or components other than those described in this document, which are related to the project as connected actions or phased actions, as defined at Minn. R. 4410.0200, subps. 9b and 60, respectively. x Copies of this EAW are being sent to the entire EQB distribution list.
Name and Title of Signer: Craig Affeldt, Supervisor, Environmental Review Unit St. Paul Office Regional Division
Date:
The format of the Environmental Assessment Worksheet was prepared by the staff of the Environmental Quality Board at the Minnesota Department of Administration, Office of Geographic and Demographic Analysis. For additional information, worksheets or for EAW Guidelines, contact: Environmental Quality Board, 658 Cedar Street, St. Paul, Minnesota, 55155, 651-201-2492, or at their Web site http://www.eqb.state.mn.us.
Hennepin Energy Resource Company Fuel Use Limit Removal Environmental Assessment Hennepin County Minnesota 48 Worksheet Appendix A
Figures
Figure 1 - Site Location in Hennepin County Figure 2 – Site Topographic Map Figure 3 – Site Plan Figure 4 – Project Location Map Figure 5 – Land Use Map Figure 6 – HERC Water Process Flow Diagram Figure 7 – HERC Storm Sewer Connections Figure 8 – HERC Chemical Storage Figure 9 – Traffic Counts Figure10 – HERC Odor Analysis Sampling Site Locations Figure 11 – Noise Monitoring Sites Figure 12 – Warehouse Districts, Minneapolis and National Register Designation 101 Hennepin County Project Location
94
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394 394 94
494 35W
7 121 62 7 41 101 62
35W 5 312 77 169 77 212 02.5 5 10 Miles
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Prepared By: FIGURE 1 SITE LOCATION IN HENNEPIN COUNTY HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA Prepared For: MARCH 2010 10180006.01 47 94
952A
952A
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35W Legend 35W
Site Location 65
0500 1,000 2,000 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse.
Prepared By: FIGURE 2 SITE TOPOGRAPHIC MAP HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA Prepared For: MARCH 2010 10180006.01 952A Unk nown or No Streetname
6th Ave N
952A Hoag Ave N 5th Ave N
Bag House Parking APC Area 5th St N Admin 55 Cooling Bldg Tower Boiler Henn County Bldg Environmental Parking Services Ash Fuel Storage Storage 5th Ave N Ash Loadout Tipping Hall
Ballpark Site
Royalston Ave N
Legend
Fence 3rd Ave N Property Boundary
0100 200 400 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse.
Prepared By: FIGURE 3 SITE PLAN HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 W River Pkwy
11th Ave N
9th Ave N
Napco Ave 8th Ave N
10th Ave N
4th Ave N 1st St N
3rd St N 4th St N 7th Ave N 2nd St N
5th Ave N 8th Ave N Washington Ave N
5th St N
7th St N
Oak Lake Ave 7th Ave N 952A
6th Ave N N
Hoag Ave N 3rd Ave
952A 5th Ave N
3rd St N 2nd Ave N 4th St N
Border Ave N
Royalston Ave N 55 3rd St S 3rd Ave N 1st Ave N
Holden St N 4th St S 6th St N
Unknown or No Streetname 5th St S Lakeside Ave N
Hennepin Ave
Currie Ave N Currie Ave N
8th St N 6th St S 11th St N 9th St N W Chestnut St
Unknown or No Streetname Nicollet Ave S
Legend W Linden St Hawthorne Ave 394 Project8th St S Area
11th St S
City Street 2nd Ave S W Hawthorne Ave 13th St N
9th St S Interstate 12th St N Harmon Pl La Salle Ave S W Laurel Ave I- 94 16th St N US Highway
13th St S
Spruce Pl State Highway 3rd Ave S
15th St N Marquette0 Ave S 250 500 1,000 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Prepared By: FIGURE 4 PROJECT LOCATION MAP HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA Prepared For: MARCH 2010 10180006.01 Legend
Site Location
LAND USE R1-R2 Low Density Residence Districts R3-R4 Medium Density Residence Districts R5-R6 High Density Residence District OR1-OR3 Office Residence Districts C1-C4 Commercial Districts B4 Downtown Districts I1-I3 Industrial Districts
0250 500 1,000 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Zoning provided by the City of Minneapolis GIS Business Services.
Prepared By: FIGURE 5 LAND USE MAP HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 Prepared By: FIGURE 6 HERC WATER PROCESS FLOW DIAGRAM HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 Outfall to Mississippi River 952A
952A
24" 42" 30" 6th Ave N
21"
10" 12" 24" 36" 12"
Bag House Parking APC Area 10"
18" Admin 36" 55 Cooling 12" Bldg Tower 15" Boiler 12" Henn County Environmental Bldg 18" Parking Services Ash 10" Storage Fuel 36" Storage
10" Ash Loadout Tipping Hall 6"
10" 18" 21" 21"
Legend Storm Sewer
Structure
050 100 200 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse.
Prepared By: FIGURE 7 HERC STORM SEWER CONNECTIONS HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 Services
Parking
6th Avenue N Parking Admin Bldg
Turbine H I Hall W A B H J K Bag House Boiler M APC Area C Bldg Tipping Hall Legend L Fuel BULK MATERIAL STORAGE D G Storage A Dolomitic Lime Storage R N B Activated Carbon Storage Ash C Pebble Lime Storage Storage O D Citric Acid Storage E F E Propane Storage Q Q Q T F Gasoline Storage P T G Oxygen and Acetylene Storage T H Caustic and Acid Storage Cooling Q I Demineralized Water Storage Tower T J Chlorine Scavenger Storage K Quench Water Storage S L Boiler Water Chemicals Storage M Municipal Solid Waste Storage N Hydraulic Fluids and Oil Storage U V O Kerosene Storage Ash P Fly Ash Storage Loadout Q Ferrous Material Storage R Diesel Fuel Storage S Cooling Water Chemicals Storage T Oversize Material Storage U Combined Ash Storage V Ammonia Storage W Neutralization Tank - Wastewater From Resin Regeneration Treatment Area
025 50 100 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse.
Prepared By: FIGURE 8 HERC CHEMICAL STORAGE HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 952A 290 10600 8800 6th Ave N
Hoag Ave N
5th Ave N
5th St N
12400 5300
120
5th Ave N
Royalston Ave N
2900
Legend 55 10900 120 HCADT (Heavy Commercial Average Daily Traffic) 1994
8800 AADT (Annual Average Daily Traffic) 2008
Property Boundary 4800
3rd Ave N 0100 200 400 Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Traffic data provided by MnDOT Traffic Volume Program.
Prepared By: FIGURE 9 TRAFFIC COUNTS HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 2nd St N 8th Ave N 350
4th St N 7th Ave N
340 5th Ave N 3rd St N Washington Ave N ve N 355 7th Ave N 7th A 360
Oak Lake Ave 7th St N 5th St N
7th Ave N
952A 6th Ave N240 250 230 Hoag Ave N 140 365
100 220 130 200 3rd Ave N 105 952A 3305th Ave N
Lakeside N Ave 110 205 212 120 2nd Ave N
215 300 217 210 4th St N 4th Ave N
Border Ave N
Royalston Ave N 55
Legend 310 394 3rd Ave N Site Location ve N
1st A Odor Sampling Locations 394 6th St N 320 0100 200 400 Holden St N Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Sampling Locations provided by Hennepin County Department of Environmental Services.
Prepared By: FIGURE 10 HERC ODOR ANALYSIS SAMPLING SITE LOCATIONS HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01 1st St N
10th Ave N
4th St N 4th Ave N 2nd St N 7th Ave N 8th Ave N 8th Ave N NSA 1 Washington Ave N 3rd St N
t v N Ave 7th 7th Ave N 7th St N 7th Ave N 5th St N
Oak Lake Ave 5th Ave N
952A
6th Ave N
Hoag Ave N
3rd Ave N
952A 2nd Ave N 94 5th Ave N
3rd St N NSA 3
4th St N 94 4th Ave N
Royalston Ave N
Border Ave N
55
Legend 4th St S 394 3rd Ave N 1st Ave N Site Location
Lyndale Ave N
Noise Monitoring Receptor Lakeside Ave N Holden St N 6th St N Hennepin Ave 394 0125 250 500 5th St S Feet
Source: Map adapted from information provided by the MnDNR Data Deli and the Minnesota Geographic Data Clearinghouse. Noise Sampling Locations provided by The Minnesota Urban Ballpark Final Environmental Impact Statement.
Prepared By: FIGURE 11 NOISE MONITORING SITES HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA
Prepared For: MARCH 2010 10180006.01
Plymouth Ave N 3rd St N
12th Ave N
E Island Ave
8th Ave N
10th Ave N Washington Ave N Maple Pl
Nicollet St 9th Ave N
8th Ave N
4th Ave N W Island Ave 3rd St N 2nd St N 1st St N Grove St 4th St N
e N
8th Ave N 7th Av
5th Ave N 7th Ave N 5th St N 952A W River Pkwy Hennepin Ave
952A 6th Ave N
3rd Ave N 2nd Ave N
1st St S 5th Ave N
oaso v N Royalston Ave
3 rd St N
4th St N
2nd St S
55
1st Ave N
3rd St S 6th St N 65
Unknown or No Streetname 4th St S
Currie Ave N 8th St N Marquette Ave S 5th St S
Legend 11th St N W Chestnut St 9th St N 6th St SSite Location 394 3rd Ave S
Hennepin Ave 8th St S W Linden St 394 Hawthorne Ave Minneapolis Designation 9th St S National Register Designation 11th St S 65 Ave S
13th St N 12th St N 2nd 0255 510 1,020 Feet Nicollet Ave S Source: Map adapted from information65 provided by the MnDNR La Salle Ave S Harmon Pl Data Deli and the Minnesota Geographic Data Clearinghouse. Designations provided by the City of Minneapolis.
Prepared By: FIGURE 12 WAREHOUSE DISTRICTS, MINNEAPOLIS AND NATIONAL REGISTER DESIGNATION HENNEPIN ENERGY RESOURCE COMPANY FUEL USE INCREASE MINNEAPOLIS, MINNESOTA Prepared For: MARCH 2010 10180006.01 Appendix B
DNR Division of Ecological Resources Correspondence Minnesota Department of Natural Resources Division of Ecological Resources, Box 25 500 Lafayette Road
St. Paul, Minnesota 55155-4025
Phone: (651) 259-5107 Fax: (651) 296-1811 E-mail: [email protected]
April 26, 2010 Correspondence # ERDB 20100644
M. Chris White AECOM Technical Services 161 Cheshire Lane N, Ste. 500 Minneapolis, MN 55441
RE: Natural Heritage information in the vicinity of the proposed Covanta Hennepin Energy Resource Company Fuel Limit Removal EAW, T29N R24W Section 22, Hennapin County
Dear M. White,
As requested, the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project. Based on this query, several rare features have been documented within the search area (for details, please see the enclosed database report). However, given the project details that were provided with the data request form, I do not believe the proposed project will negatively affect any known occurrences of rare features. The Natural Heritage Information System (NHIS), a collection of databases that contains information about Minnesota’s rare natural features, is maintained by the Department of Natural Resources, Division of Ecological Resources. The NHIS is continually updated as new information becomes available, and is the most complete source of data on Minnesota's rare or otherwise significant species, native plant communities, and other natural features. However, the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state. Therefore, ecologically significant features for which we have no records may exist within the project area. The results are enclosed as an Index Report of records in the Rare Features Database, the main database of the NHIS. To control the release of specific location information, which might result in the destruction of a rare feature, the report is copyrighted. The Index Report provides rare feature locations only to the nearest section, and may be reprinted, unaltered, in an environmental review document (e.g., EAW or EIS), municipal natural resource plan, or report compiled by your company for the project listed above. If you wish to reproduce the index report for any other purpose, please contact me to request written permission. This letter does not constitute review or approval by the Department of Natural Resources as a whole. Instead, it identifies issues regarding known occurrences of rare features and potential effects to these rare features. Additional rare features for which we have no data may be present in the project area, or there may be other natural resource concerns associated with the proposed project. For these concerns, please contact your DNR Regional Environmental Assessment Ecologist, Melissa Doperalski at (651-259-5738). Please be aware that additional site assessments or review may be required. Thank you for consulting us on this matter, and for your interest in preserving Minnesota's rare natural resources. An invoice will be mailed to you under separate cover.
Sincerely,
Heidi Cyr Endangered Species Environmental Review Specialist enc. Rare Features Database: Index Report Rare Features Database Reports: An Explanation of Fields
DNR Information: 651-296-6157 ● 1-888-646-6367 ● TTY: 651-296-5484 ● 1-800-657-3929
An Equal Opportunity Employer Who Values Diversity Minnesota Natural Heritage Information System: Rare Features Database Page 1 of 2 Detailed Report of records within 1 mile radius of: Printed April 2010 Data valid for one year ERDB #20100644 - Covanta Hennepin Energy Resource Company T29N R24W Section 22 Hennepin County
Vertebrate Animal Element Name and Occ. #: Falco peregrinus (Peregrine Falcon) #43 EO ID #: 9565
Observed Area: Last Observed Date: 2009 MN Status: Threatened Extent Known?: Y - Confident full extent of EO is known First Observed Date: 1989 Federal Status: No Status Ownership Type: Private individual Last Survey Date: 2009 State Rank: S2B Location Description: Hennepin County, MN Global Rank: G4 T29N R24W S22 EO Rank: E - Verified extant (viability not assessed) Site Name: MINNEAPOLIS 22 Managed Area(s): Survey Site #/Name: Survey Type: Secondary source Surveyor(s): Redig, P., Tordoff, H. (Bud),Fallon, J. General Description: Nest at Multifoods Twoer (currently called City Center). EO Data: Nesting Area. Multifoods Tower. First nesting occurred in 1987. 1987: 1 young fledged. 1988-1990: 4 young fledged. 1991: 3 young fledged. 1992: 4 young fledged. 1993: 3 young fledged. 1994: 3 eggs laid, none hatched. 1995: 4 young fledged. 1996-1997: 3 y oung fledged. 1998: Pair of adults observed at site, no breeding. 1999: 4 young fledged. 2000: 1 young fledged. 2001-2002: 3 young fledged. 2003: 1 young fledged. 2004-2006: 4 young fledged. 2007: 3 young fledged. 2008-2009: 4 young fledged. Element Name and Occ. #: Falco peregrinus (Peregrine Falcon) #67 EO ID #: 26813
Observed Area: Last Observed Date: 2009 MN Status: Threatened Extent Known?: Y - Confident full extent of EO is known First Observed Date: 2000 Federal Status: No Status Ownership Type: Local government Last Survey Date: 2009 State Rank: S2B Location Description: Hennepin County, MN Global Rank: G4 T29N R24W S23, T29N R24W S26 EO Rank: E - Verified extant (viability not assessed) Site Name: MINNEAPOLIS 23 Managed Area(s): Survey Site #/Name: Survey Type: Qualitative ground survey Surveyor(s): Tordoff, H. (Bud),Kowal, E., Hendrickson, B., Fallon, J., Sniegowski, J., Mussel, J. General Description: Birds nesting in a tray in a cubbyhole on the east side of the 5th Street Tower. EO Data: Nesting Area. City Hall. Nest site first used in 2000. 2000: 2 young fledged. 2001: Eggs laid and incubated, but none hatched. 2002: Female bird observed, no eggs laid. 2003: 2 adult birds seen, no evidence of nesting. 2004-2005: 2 young fledged. 2006-2007: 1 young fledged. 2008: 1 chick observed, unknown whether it fledged. 2009: Eggs laid and incubated, but none hatched.
Copyright 2010, Division of Ecological Resources, State of Minnesota DNR - MAY NOT BE REPRINTED OR PUBLISHED WITHOUT PERMISSION Minnesota Natural Heritage Information System: Rare Features Database Page 2 of 2 Detailed Report of records within 1 mile radius of: Printed April 2010 Data valid for one year ERDB #20100644 - Covanta Hennepin Energy Resource Company T29N R24W Section 22 Hennepin County
Element Name and Occ. #: Falco peregrinus (Peregrine Falcon) #82 EO ID #: 31265
Observed Area: Last Observed Date: 2008-07-MID MN Status: Threatened Extent Known?: ? - Uncertain whether full extent of EO is known First Observed Date: 2003 Federal Status: No Status Ownership Type: Private organization Last Survey Date: 2009 State Rank: S2B Location Description: Hennepin County, MN Global Rank: G4 T29N R24W S27 EO Rank: E - Verified extant (viability not assessed) Site Name: Managed Area(s): Survey Site #/Name: Survey Type: Qualitative ground survey Surveyor(s): Weber, J., Kistler, H., Fallon, J. General Description: Nest box on 22nd floor of building on south side. EO Data: Nesting Area. Midwest Plaza. Site first used in 2003. 2003: 7 eggs laid, none hatched. 2004: 5 young fledged. 2005: 9 eggs laid, none hatched. 2006: 8 eggs laid, none hatched. 2007: 2 adults in area, no nesting. 2008: 4 young fledged, 1 killed by car. 20 09: Site not active. Invertebrate Animal Element Name and Occ. #: Ligumia recta (Black Sandshell) #337 EO ID #: 30421
Observed Area: Last Observed Date: 2007-09-26 MN Status: Special Concern Extent Known?: N - Confident full extent of EO is NOT known First Observed Date: 1944 Federal Status: Ownership Type: Unknown Last Survey Date: 2007-09-26 State Rank: S3 Location Description: Anoka, Dakota, Hennepin, Ramsey, [...] County, MN Global Rank: G5 T32N R25W S29, T28N R23W S28, T33N R26W S26, T28N R23W S20, T [...] EO Rank: E - Verified extant (viability not assessed) Site Name: Rum River, Crow River, Minnesota River, Mississippi River, ELK Managed Area(s): RIVER, [...] Survey Site #/Name: Statewide Mussel Survey Site ID 1502, [...] Survey Type: Imagery interpretation/analysis, Qualitative ground survey
Surveyor(s): Dawley, C., Sietman, B., Davis, M., Kelner, D., Ceas, P., Helms, D., Schmidt, K. General Description: Left descending bank of the river was surveyed by snorkel, 3 divers on site. Substrates were sand, gravel and cobble. The river was 0.5-2.5ft deep with runs. Right descending bank of the river was surveyed by snorkel, 3 divers on site. Substrates were silt, sand, gravel, boulder and cobble. The river was 0.5-3ft deep with riffles and runs. Left descending bank and middle of river was surveyed by wading and snorkel, 3 divers on site. Substrates were silt, sand, gravel, cobble and boulder. The river had riffles and runs. EO Data: 2007: 21 live specimens were found. Five specimens were between the ages of one and five years old with lengths ranging from 81 mm to 91 mm. Four specimens were between the ages of six and ten years old with lengths ranging from 120 mm to 129 mm. Dead specimens in subfossil condition were also found. [Ref ID 176073 and 175187] 2004: Eight live individuals were found during Statewide Mussel Survey within the Mississippi River, one was <1-5yrs and 110mm in length, four were 6-10yrs and 110-135mm in len gth, and three were >10yrs and 128-133mm in length. One of these individuals was wet vouchered into collection at the James Ford Bell Museum. One live individual was found during Statewide Mussel Survey within the Crow River, <1-5yrs and 98mm in length. This individual along with 1/2 fresh dead specimen was vouchered into collection at the James Ford Bell Museum. Four additional non-listed live mussel species and one weathered, dead species were found during these surveys, and the presence of rusty crayfish, corbicula and snails was noted. 2000-2003: 234 live specimens found. Weathered dead and Fresh dead specimens found. Four specimens were wet vouchered at the James Ford Bell Museum, U of M. 1998: Negative data. A total of 23 dead specim (truncated...)
Copyright 2010, Division of Ecological Resources, State of Minnesota DNR - MAY NOT BE REPRINTED OR PUBLISHED WITHOUT PERMISSION Minnesota Natural Heritage Information System Page 1 of 1 Printed April 2010 Index Report of records within 1 mile radius of: Data valid for one year ERDB #20100644 - Covanta Hennepin Energy Resource Company T29N R24W Section 22 Hennepin County
Rare Features Database: Federal MN State Global Last Observed EO ID # Element Name and Occurrence Number Status Status Rank Rank Date
Vertebrate Animal Falco peregrinus (Peregrine Falcon) #43 No Status THR S2B G4 2009 9565 T29N R24W S22; Hennepin County
Falco peregrinus (Peregrine Falcon) #67 No Status THR S2B G4 2009 26813 T29N R24W S23, T29N R24W S26; Hennepin County
Falco peregrinus (Peregrine Falcon) #82 No Status THR S2B G4 2008-07-MID 31265 T29N R24W S27; Hennepin County
Invertebrate Animal Ligumia recta (Black Sandshell) #337 SPC S3 G5 2007-09-26 30421 T32N R25W S29, T28N R23W S28, T33N R26W S26, T28N R23W S20, T [...]; Anoka, Dakota, Hennepin, Ramsey, [...] County
Records Printed = 4 Minnesota's endangered species law (Minnesota Statutes, section 84.0895) and associated rules (Minnesota Rules, part 6212.1800 to 6212.2300 and 6134) prohibit the taking of threatened or endangered species without a permit. For plants, taking includes digging or destroying. For animals, taking includes pursuing, capturing, or killing.
Copyright 2010, Division of Ecological Resources, State of Minnesota DNR The Division of Ecological Resources recently adopted a new database system called Biotics. As a result of this change, the layout and contents of the database reports have been revised. Many of the fields included in the new reports are the same or similar to the previous report fields, however there are several new fields and some of the field definitions have been slightly modified. We recommend that you familiarize yourself with the latest field explanations.
Rare Features Database Reports: An Explanation of Fields
The Rare Features Database (Biotics) is part of the Natural Heritage Information System, and is maintained by the Division of Ecological Resources, Minnesota Department of Natural Resources (DNR).
**Please note that the print-outs are copyrighted and may not be reproduced without permission**
Field Name: [Full (non-abbreviated) field name, if different]. Further explanation of field.
-E- Element Name and Occ #: [Element Name and Occurrence Number]. The Element is the name of the rare feature. For plant and animal species records, this field holds the scientific name followed by the common name in parentheses; for all other elements (such as native plant communities, which have no scientific name) it is solely the element name. Native plant community names correspond to Minnesota’s Native Plant Community Classification (Version 2.0). The Occurrence Number, in combination with the Element Name, uniquely identifies each record. EO Data: [Element Occurrence Data]. For species elements, this field contains data collected on the biology of the Element Occurrence* (EO), including the number of individuals, vigor, habitat, soils, associated species, peculiar characteristics, etc. For native plant community elements, this field is a summary text description of the vegetation of the EO, including structure (strata) and composition (dominant/characteristic species), heterogeneity, successional stage/dynamics, any unique aspects of the community or additional noteworthy species (including animals). Note that this is a new field and it has not been filled out for many of the records that were collected prior to conversion to the new database system. Some of the information meeting the field definition may be found in the General Description field. EO ID#: [Element Occurrence Identification Number]. Unique identifier for each Element Occurrence record. EO Rank: [Element Occurrence Rank]. An evaluation of the quality and condition of an Element Occurrence (EO) from A (highest) to D (lowest). Represents a comparative evaluation of: 1) quality as determined by representativeness of the occurrence especially as compared to EO specifications and including maturity, size, numbers, etc. 2) condition (how much has the site and the EO itself been damaged or altered from its optimal condition and character). 3) viability (the long-term prospects for continued existence of this occurrence - used in ranking species only). EO Ranks are assigned based on recent fieldwork by knowledgeable individuals. Extent Known?: A value that indicates whether the full extent of the Element is known (i.e., it has been determined through field survey) at that location. If null, the value has not been determined. -F- Federal Status: Status of species under the U.S. Endangered Species Act: LE = endangered; LT = threatened; LE,LT = listed endangered in part of its range, listed threatened in another part of its range; LT,PDL = listed threatened, proposed for delisting; C = candidate for listing. If null or “No Status” the species has no federal status. First Observed Date: Date that the Element Occurrence was first reported at the site in format YYYY-MM-DD. A year followed by “Pre” indicates that the observed date was sometime prior to the date listed, but the exact date is unknown.
-G- General Description: General description or word picture of the area where the Element Occurrence (EO) is located (i.e., the physical setting/context surrounding the EO), including a list of adjacent communities. When available, information on surrounding land use may be included. Note that the information tracked in this field is now more narrowly defined than it was in the old database system, and some of the information still in this field more accurately meets the definition of the new EO Data field. We are working to clean up the records so that the information in the two fields corresponds to the current field explanations described herein. Also note that the use of uppercase in sentences in this field is not significant but rather an artifact of transferring data from the old database system to the new system. Global Rank: The global (i.e., range-wide) assessment of the relative rarity or imperilment of the species or community. Ranges from G1 (critically imperiled due to extreme rarity on a world-wide basis) to G5 (demonstrably secure, though perhaps rare in parts of its range). Global ranks are determined by NatureServe, an international network of natural heritage programs and conservation data centers. -L- Last Observed Date: Date that the Element Occurrence was last observed to be extant at the site in format YYYY-MM-DD. Last Survey Date: Date of the most recent field survey for the Element Occurrence, regardless of whether it was found during the visit. If the field is blank, assume the date is the same as the Last Observed Date. Location Description: County or Counties in which the Element Occurrence was documented followed by Township, Range, and Section information (not listed in any particular order). Each unique Township, Range, and Section combination is separated by a comma. In some cases, there are too many Township, Range, and Section combinations to list in the field, in which case, the information will be replaced with, “Legal description is too lengthy to fit in allotted space”. -M- Managed Area(s): Name of the federally, state, locally, or privately managed park, forest, refuge, preserve, etc., containing the occurrence, if any. If this field is blank, the element probably occurs on private land. If "(Statutory Boundary)" occurs after the name of a managed area, the location may be a private inholding within the statutory boundary of a state forest or park. MN Status: [Minnesota Status]. Legal status of plant and animal species under the Minnesota Endangered Species Law: END = endangered; THR = threatened; SPC = special concern; NON = tracked, but no legal status. Native plant communities, geological features, and colonial waterbird nesting sites do not have any legal status under the Endangered Species Law and are represented by a N/A. -N- NPC Classification (v1.5): Native plant community name in Minnesota’s Native Vegetation: A Key to Natural Communities (Version 1.5). This earlier classification has been replaced by Minnesota’s Native Plant Community Classification (Version 2.0). -O- Observed Area: The total area of the Element Occurrence, in acres, which is measured or estimated during fieldwork. If null, the value has not been determined. Ownership Type: Indicates whether the land on which the Element Occurrence was located was publicly or privately owned; for publicly owned land, the agency with management responsibility is listed, if known. -S- Site Name: The name of the site(s) where the Element Occurrence is located. Sites are natural areas of land with boundaries determined and mapped according to biological and ecological considerations. Survey Site #/Name: The name of the survey site, if applicable, where the Element Occurrence is located. Survey sites are sites that provide a geographic framework for recording and storing data, but their boundaries are not based on biological and ecological considerations. Minnesota County Biological Survey site numbers, if applicable, are also listed in this field. Survey Type: Information on the type of survey used to collect information on the Element Occurrence. Surveyor(s): Name(s) of the person(s) that collected survey information on the Element Occurrence. State Rank: Rank that best characterizes the relative rarity or endangerment of the taxon or plant community in Minnesota. The ranks do not represent a legal status. They are used by the Minnesota Department of Natural Resources to set priorities for research, inventory and conservation planning. The state ranks are updated as inventory information becomes available. S1 = Critically imperiled in Minnesota because of extreme rarity or because of some factor(s) making it especially vulnerable to extirpation from the state. S2 = Imperiled in Minnesota because of rarity or because of some factor(s) making it very vulnerable to extirpation from the state. S3 = Vulnerable in Minnesota either because rare or uncommon, or found in a restricted range, or because of other factors making it vulnerable to extirpation. S4 = Apparently secure in Minnesota, usually widespread. S5 = Demonstrably secure in Minnesota, essentially ineradicable under present conditions. SH = Of historical occurrence in the state, perhaps having not been verified in the past 20 years, but suspected to be still extant. An element would become SH without the 20-year delay if the only known occurrences in the state were destroyed or if it had been extensively and unsuccessfully looked for. SNR = Rank not yet assessed. SU = Unable to rank. SX = Presumed extinct in Minnesota. SNA = Rank not applicable. S#S# = Range Rank: a numeric range rank (e.g., S2S3) is used to indicate the range of uncertainty about the exact status of the element. S#B, S#N = Used only for migratory animals, whereby B refers to the breeding population of the element in Minnesota and N refers to the non-breeding population of the element in Minnesota. -V- Vegetation Plot: Code(s) for any vegetation plot data that have been collected within this Element Occurrence (i.e., either Releve Number or the word “RELEVE” indicates that a releve has been collected).
* Element Occurrence – an area of land and/or water in which an Element (i.e., a rare species or community) is, or was, present, and which has practical conservation value for the Element as evidenced by potential continued (or historical) presence and/or regular recurrence at a given location. Specifications for each species determine whether multiple observations should be considered 1 Element Occurrence or 2, based on minimum separation distance and barriers to movement.
Data Security Locations of some rare features must be treated as sensitive information because widespread knowledge of these locations could result in harm to the rare features. For example, wildflowers such as orchids and economically valuable plants such as ginseng are vulnerable to exploitation by collectors; other species, such as bald eagles, are sensitive to disturbance by observers. For this reason, we prefer that publications not identify the precise locations of vulnerable species. We suggest describing the location only to the nearest section. If this is not acceptable for your purposes, please call and discuss this issue with the Endangered Species Environmental Review Coordinator at (651) 259-5109.
Revised 4/2006 Appendix C
Facility Documents
2008 Production Summary 2009 Production Summary HERC Storm Water Pollution Prevention Plan HERC Spill Prevention Control and Countermeasure Plan HERC Biogenic CO2 Sample Results 1/27/2010 - 11:10 AM
COVANTA HENNEPIN ERC, LP Production and Performance Summary - Jan 2008 to Dec 2008
PRODUCTION UNITS Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 Tot/Avg Refuse Received Tons 32,797 29,659 19,903 33,285 34,777 32,780 32,650 30,906 27,477 32,372 29,411 30,781 366,798 Refuse Processed Tons 32,414 30,392 20,642 32,307 34,937 31,489 32,997 31,071 28,249 31,146 31,474 27,900 365,017 Refuse Bypassed Tons 000000000000 0 Supplemental Waste Tons 177 123 106 136 111 153 158 136 118 134 89 113 1,553 Ash Tons 7,647 6,697 4,503 7,646 7,916 7,690 7,161 7,066 6,740 7,424 6,705 7,527 84,724 Ferrous Tons 960 944 651 1,144 1,089 1,036 1,083 969 953 963 981 872 11,644 Steam klbs 227,723 211,548 140,895 221,597 239,222 219,127 226,355 216,163 196,628 220,084 221,940 193,992 2,535,274 Gross Electric MWH 22,859 21,349 13,671 22,664 24,327 21,607 22,007 21,523 18,872 22,320 22,269 18,447 251,915 Net Electric MWH 19,919 18,591 11,819 19,746 21,127 18,871 19,229 18,590 16,197 19,412 19,377 15,668 218,546
UTILITIES UNITS In-plant Power MWH 2,940 2,758 2,197 2,918 3,200 2,736 2,827 2,933 2,794 2,908 2,892 2,779 33,882 Purchased Power MWH 0 0 345 0 0 0 49 0 119 0 0 0 513 Aux Natural Gas kCuFt 1,010 1,531 2,917 1,735 985 1,406 3,276 1,405 1,586 1,694 1,110 2,996 21,651 Make-up kgals 466 426 480 537 366 423 587 363 262 239 274 283 4,708 Make-up % of Steam 1.71 1.68 2.84 2.02 1.28 1.61 2.16 1.40 1.11 0.91 1.03 1.22 1.55 Pebble Lime Tons 358 323 234 369 384 375 343 387 270 383 335 336 4,098 Dolomitic Lime Tons 99 91 52 63 27 55 67 83 75 78 60 71 821 Ammonia klbs 30 11 0 18 8 0 5 0 0 0 0 0 72 Carbon Tons 17 14 9 17 14 11 18 16 11 17 14 16 173
PERFORMANCE UNITS Refuse HHV Btu/lb 5,447 5,411 5,149 5,213 5,103 5,239 5,068 5,205 5,221 5,287 5,349 5,356 5,254 Refuse Processed Ref Tons 33,953 31,625 20,440 32,387 34,285 31,725 32,160 31,101 28,363 31,668 32,376 28,737 368,819 Refuse Processed Ref TPD 1,095 1,091 659 1,080 1,106 1,057 1,037 1,003 945 1,022 1,079 927 1,008 Gross Energy Rec. KWH/Ref Ton 673.2 675.1 668.9 699.8 709.6 681.1 684.3 692.0 665.4 704.8 687.8 641.9 683.0 In-plant Elec. KWH/Ref Ton 86.6 87.2 107.5 90.1 93.3 86.2 87.9 94.3 98.5 91.8 89.3 96.7 91.9
AVAILABILITY UNITS Boiler 1 % 100.0% 89.2% 70.7% 95.3% 91.4% 88.1% 84.3% 80.5% 100.0% 79.8% 97.4% 73.0% 87.4% Boiler 2 % 79.6% 89.5% 39.9% 83.1% 89.5% 92.0% 90.7% 100.0% 62.2% 100.0% 85.7% 93.5% 83.8% Avg. Boiler Availability % 89.8% 89.3% 55.3% 89.2% 90.4% 90.0% 87.5% 90.2% 81.1% 89.9% 91.6% 83.3% 85.6% Boiler 1 Time Online % 100.0% 89.2% 70.7% 95.3% 91.4% 88.1% 84.3% 80.5% 100.0% 79.8% 97.4% 73.0% 87.4% Boiler 2 Time Online % 79.6% 89.5% 39.9% 83.1% 89.5% 92.0% 90.7% 100.0% 62.2% 100.0% 85.7% 93.5% 83.8% Avg. Boiler Time Online % 89.8% 89.3% 55.3% 89.2% 90.4% 90.0% 87.5% 90.2% 81.1% 89.9% 91.6% 83.3% 85.6% Turbine % 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 98.9% 100.0% 94.9% 100.0% 100.0% 100.0% 99.5% Boiler Tube Leak Incidents Count 2 3 2 3 0 1 1 1 0 2 2 0 17
COVANTA - WTE <
COVANTA HENNEPIN ERC, LP Production and Performance Summary - Jan 2009 to Dec 2009
PRODUCTION UNITS Jan-09 Feb-09 Mar-09 Apr-09 May-09 Jun-09 Jul-09 Aug-09 Sep-09 Oct-09 Nov-09 Dec-09 Tot/Avg Refuse Received Tons 33,907 29,286 31,110 27,936 32,113 31,648 34,922 32,371 20,160 14,755 36,485 37,186 361,879 Refuse Processed Tons 35,680 28,567 29,875 29,404 32,488 31,563 33,175 34,452 11,274 22,018 36,764 35,742 361,003 Refuse Bypassed Tons 000000000000 0 Supplemental Waste Tons 121 83 87 102 115 137 122 131 25 103 183 73 1,282 Ash Tons 7,758 6,234 7,292 7,102 7,606 8,118 8,151 7,749 3,584 4,260 8,154 8,686 84,695 Ferrous Tons 1,113 896 960 698 959 1,090 1,095 1,105 337 720 1,103 1,069 11,145 Steam klbs 238,739 200,820 209,831 198,465 229,214 217,276 227,409 225,530 77,992 147,057 246,675 235,657 2,454,665 Steam Exported klbs 1,575 10,455 9,462 9,448 8,427 10,485 13,861 6,118 12,179 9,021 10,885 101,916 Condensate Returned kgals 190 10,116 9,205 9,063 7,252 9,740 1,304 4,858 2,721 5,007 1,305 60,760 Gross Electric MWH 23,122 19,240 19,642 18,510 21,829 20,441 21,036 20,232 5,355 973 25,151 23,243 218,773 Net Electric MWH 20,204 16,731 16,811 16,160 18,938 17,698 18,128 17,347 4,571 827 22,395 20,379 190,188
UTILITIES UNITS In-plant Power MWH 2,947 2,509 2,876 2,503 2,891 2,744 2,908 2,885 1,541 2,090 2,760 2,864 31,516 Purchased Power MWH 29 0 45 152 0 0 0 0 758 1,944 4 0 2,931 Aux Natural Gas kCuFt 2,138 2,326 1,039 3,468 2,953 1,216 3,477 7,216 2,763 9,628 1,657 6,798 44,679 Make-up kgals 227 257 314 322 456 422 316 795 439 426 432 474 4,882 Make-up % of Steam 0.79 1.07 1.25 1.35 1.66 1.62 1.16 2.94 4.69 2.41 1.46 1.68 1.66 Pebble Lime Tons 400 332 326 329 379 373 469 354 153 248 353 360 4,075 Dolomitic Lime Tons 105 63 63 66 49 58 52 49 11 59 63 68 705 Ammonia klbs 000000000000 0 Carbon Tons 15 11 18 12 15 18 12 14 2 19 16 27 179
PERFORMANCE UNITS Refuse HHV Btu/lb 5,155 5,330 5,376 5,075 5,340 5,162 5,412 4,937 5,194 4,814 5,178 5,168 5,185 Refuse Processed Ref Tons 35,372 29,281 30,886 28,697 33,363 31,332 34,528 32,710 11,261 20,384 36,609 35,522 359,943 Refuse Processed Ref TPD 1,141 1,046 996 957 1,076 1,044 1,114 1,055 375 658 1,220 1,146 986 Gross Energy Rec. KWH/Ref Ton 653.7 657.1 635.9 645.0 654.3 652.4 609.2 618.5 475.5 47.7 687.0 654.3 607.8 In-plant Elec. KWH/Ref Ton 83.3 85.7 93.1 87.2 86.7 87.6 84.2 88.2 136.9 102.5 75.4 80.6 87.6
AVAILABILITY UNITS Boiler 1 % 95.9% 88.8% 73.6% 86.3% 86.9% 91.5% 100.0% 87.3% 27.8% 77.4% 92.8% 95.3% 83.7% Boiler 2 % 96.6% 88.1% 94.9% 71.7% 94.3% 86.7% 91.4% 100.0% 38.3% 98.2% 100.0% 98.4% 88.4% Avg. Boiler Availability % 96.3% 88.5% 84.3% 79.0% 90.6% 89.1% 95.7% 93.7% 33.0% 87.8% 96.4% 96.8% 86.0% Boiler 1 Time Online % 95.9% 88.8% 73.6% 86.3% 86.9% 91.5% 100.0% 87.3% 27.8% 45.0% 92.8% 95.3% 80.9% Boiler 2 Time Online % 96.6% 88.1% 94.9% 71.7% 94.3% 86.7% 91.4% 100.0% 38.3% 68.5% 100.0% 98.4% 85.9% Avg. Boiler Time Online % 96.3% 88.5% 84.3% 79.0% 90.6% 89.1% 95.7% 93.7% 33.0% 56.7% 96.4% 96.8% 83.4% Turbine % 98.9% 100.0% 94.8% 90.0% 100.0% 100.0% 100.0% 100.0% 27.5% 5.6% 99.8% 100.0% 84.7% Export Steam Line % 100.0% 93.7% 99.8% 100.0% 80.8% 100.0% 99.1% 100.0% 100.0% 100.0% 100.0% 89.3% Boiler Tube Leak Incidents Count 1 0 1 0 2 0 0 0 0 0 1 1 6
COVANTA - WTE <
REVISED BY:
HENNEPIN ENERGY RESOURCE COMPANY, L.P. 505 SIXTH AVENUE NORTH MINNEAPOLIS, MINNESOTA 55405
REVISION DATE:
DECEMBER 2009 – Rev. 6 CERTIFICATION
This Storm Water Pollution Prevention Plan will be implemented as herein described. I have personally examined and am familiar with the information contained in the Storm Water Pollution Prevention Plan and all attachments, and based on my inquiry of those persons immediately responsible for preparing this plan, I believe that the information is true, accurate, and complete.
Name Date Signature Durwin G. Fitch 12/04/09 Facility Manager
Glenn Schmidt 12/04/09 Chief Engineer
Jeff Johnson 12/04/09 Maintenance Manager
Daniel Fish 12/04/09 Environmental Engineer
STORMWATER POLLUTION PREVENTION PLAN - REVISION HISTORY
Name Signature Date Description of Review/Revisions Thorough rewrite and revision of plan Shannon Forss Feb 2002 Rev 1 Shannon Forss June 2003 Plan Review and Minor Revision – Rev 1 Dan Fish August 2005 Thorough revision of plan – Rev 2 Dan Fish August 2006 Review and update of signature pages and emergency response contacts – Rev 3 Dan Fish Review and update of signature pages November 5, 2007 and emergency response contacts – Rev 4 Dan Fish Plan review and update of signature December 15, 2008 pages – Rev 5 Dan Fish Plan review and update of signature December 4, 2009 pages – Rev 6 TABLE OF CONTENTS
Section 1.0 General Information 1
1.1 Site Description...... 1 1.2 General Facility Operation...... 1 1.3 General Facility Process Flow Diagrams...... 3
Section 2.0 Material Storage and Handling 6
2.1 Raw Materials ...... 6 2.2 By-Products...... 9 2.3 Finished Materials...... 9 2.4 Waste Products...... 10 2.5 Hazardous Wastes...... 10
Section 3.0 Potential Storm Water Pollutants and BMPs 11
3.1 Fly and Bottom Ash...... 11 3.2 Lime, Activated Carbon and Fly Ash ...... 11 3.3 Cooling Water Treatment Chemicals...... 12 3.4 Incidental Litter from MSW Trucks ...... 13 3.5 Anhydrous Ammonia...... 13 3.6 Lime Slurry Grit Container...... 14 3.7 Material Unloading - Turbine Drop...... 14 3.8 Material Unloading - Hydraulic Fluids...... 15 3.9 Material Unloading - Diesel Fuel ...... 16 3.10 Material Unloading – Kerosene...... 17 3.11 Material Unloading - Gasoline and Propane...... 17 3.12 Equipment Maintenance and General Maintenance Activities...... 18 3.13 Equipment and Vehicle Washing...... 18 3.14 Parking Lot and Roadways ...... 18
Section 4.0 Discharge Evaluation 19 TABLE OF CONTENTS (continued)
Section 5.0 Preventive Maintenance Program 20
5.1 Routine Preventive Maintenance ...... 20 5.2 Formal Scheduled Maintenance...... 20 5.3 Unscheduled Outage ...... 21 5.4 Work Order System ...... 21 5.5 Good Housekeeping Practices ...... 21
Section 6.0 Spill Prevention and Response Procedures 22
Section 7.0 Employee Training Program 23
Section 8.0 Plan Implementation and Responsibilities 24
Appendix A
A-1 Site Map A-2 Storm Sewer System A-3 Drainage Areas A-4 Surface Characteristics A-5 Significant Materials Locations 1.0 GENERAL INFORMATION
A National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) permit (MPCA No MN0057525), authorizing discharges of non-contact cooling water and storm water associated with industrial activity was issued to Covanta Hennepin Energy Resource Company, L.P. (CHERC) by the MPCA on October 25, 2004. This permit satisfies the provisions of the Clear Water Act, as amended, 40 CFR 122 and 124, as amended, Minnesota Statues Chapters 115 and 116, as amended and Minnesota Rules Chapter 7001.
Facilities engaged in industrial activity, and meeting the terms and conditions of this permit, are permitted to discharge storm water to the waters of the State of Minnesota. The permit becomes effective on the date of issuance, and shall expire at midnight, five years from the date of issuance.
The primary requirement of this general permit is the development of a Pollution Prevention Plan (Plan). The Plan must be tailored to site specific conditions and designed with the goal of controlling the amount of pollutants in storm water discharged form the site by using "best management practices" (BMPs).
1.1 Site Description
CHERC began commercial operation in October 1989. This facility consists of two 606 tons per day (TPD) combustion units, a 37.5 megawatt capacity turbine-generator, air pollution control equipment and other required ancillary equipment. The facility is capable of converting up to 1212 tons per day of post-recycled municipal solid waste (MSW) into 37.5 megawatts of power and consumes about 4.5 megawatts in the process. The site is located northwest of downtown Minneapolis between Fifth Street North and Seventh Street North and between Sixth Avenue North and existing railroad tracks. This site was formerly occupied by a bus garage, a large parking area, a small abandoned storage building and a railroad spur.
During construction of the Facility, soils on site were found to be contaminated with petroleum products from its former use as a bus garage. During the construction phase, some groundwater was treated with activated carbon for contaminant removal. Soil excavated during construction was used to construct landscape berms onsite. A groundwater pump-out project had been planned but groundwater testing indicated it was not needed.
1.2 General Facility Operation
Solid waste collection and transfer vehicles are weighed upon entering the facility at the incoming scale. Vehicles are weighed upon leaving the facility and the net amount of solid waste delivered is recorded. After weighing, incoming vehicles will proceed to an enclosed tipping area to discharge their load onto the tipping floor or directly into the 7,000-ton storage
Covanta Hennepin Energy Resource Company Page 1 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 bunker. Unacceptable or non-processible wastes such as tires, appliances and items too large for the feed chutes are placed in roll-off containers for recycling or alternate disposal.
One of two overhead cranes lifts the waste from the storage pit into the feed chutes. The crane operator also mixes and stacks the waste in order to maximize available storage and to provide a uniform fuel mixture. Dust and odors within the storage bunker and tipping hall area are controlled by drawing in combustion air from these areas into the boilers and keeping the areas under a slight negative pressure.
Combustion takes place in two waterwall furnaces, each having a design capacity of 606 tons per day of mixed municipal solid waste (MSW) with an average heating value of 5,200 British Thermal Units (BTU's) per pound. Solid waste drops through feed chutes and is moved onto furnace grates by hydraulically operated ram feeders. The MSW moves down through the feed chute onto the grates of the boiler. The high chrome/nickel, cast steel ally grate bars transport the waste through a drying zone, an ignition zone, a combustion zone and into a post-combustion zone.
A demineralization system is used to treat the water used in the boilers. The demineralization system is located in the northeast corner of the furnace/boiler building on the main floor. Day tanks, holding acid and caustic, used for regenerating the resins are located within diked areas on the north side of the furnace/boiler building. Unopened drums containing acid and caustic are located within diked areas in the middle of the furnace/boiler building and east of the maintenance shop. Boiler water treatment chemicals are ordered in 55-gallon barrels. The barrels are stored in a diked area south of the maintenance shop.
As the hot gases move through the boiler sections of the furnace, steam is generated. The steam is then directed to an extracting, condensing turbine-generator to produce electricity. Electricity produced flows to switchgear and on to an electrical transmission lines interconnected to the Xcel Energy distribution system. Exhaust steam from the turbine-generator passes through a water-cooled condenser. The condenser is cooled by a circulating water system using a cooling tower. Tanks holding cooling water treatment chemicals are located within diked areas in the chemical treatment building. Cooling water chemicals are delivered by truck and pumped into the storage tanks.
After leaving the furnaces, the flue gases enter the air pollution control (APC) system consisting of a dry scrubber, carbon injection system, and a fabric filter. The cleaned combustion gases are discharged through separate flues at the stack. The APC area is diked to allow the collection of runoff water which then drains to the settling basin.
Grate siftings, residue from the grates and ash from the boiler/economizer hoppers (termed bottom ash) are conveyed to the ash discharges which contain water to quench the hot ash. Cooled ash settles to the bottom of the discharger and is pushed by a hydraulic ram onto the main ash conveyor. Floor drains within the furnace/boiler building route wastewater to a settling basin located to the north of the furnace/boiler building. Particulates settle out within the basin and the water is pumped to the ash dischargers. The bottom ash is conveyed to a classification building where the ferrous and oversized materials are removed to a temporary storage bin. A front-end loader places the ferrous and oversized materials in containers for eventual transport to a recycler. Fly ash is combined with the remaining bottom ash in the classification building and conveyed to the ash storage building where the combined ash is loaded into trucks for delivery to an ash monofill.
The floor drains on the operating level are connected to the sanitary sewer. Most floor drains in the demineralizer area are connected to the sanitary sewer.
The majority of the roofs of the tipping hall, refuse pit, furnace/boiler area, and turbine/generator area are all equipped with roof drains that connect directly to the storm water drainage system piping some of the roof drains are routed into the facility in an effort to utilize some of the storm water. The storm water piping in turn drains to a City of Minneapolis collector system that runs east to west through the site. There are several storm water manholes located throughout the site that intercept the storm water runoff and route it to the collector system. The storm water collector eventually empties into the Mississippi River.
1.3 General Facility Process Flow Diagrams
General process flow diagrams indicating raw materials utilized, process operations and products generated are provided below. The processes that impact storm water will be discussed in detail in the sections to follow. They are intended to provide a general understanding of the raw materials utilized and the products generated at the facility. BOILER OPERATION - MATERIAL PROCESSING
RAW MATERIALS COMBUSTION PROCESS PRODUCTS x Municipal Solid Waste x 2 Waterwall Furnaces x Fly Ash x Auxiliary Fuel (Natural Gas) x Bottom Ash x Dolomitic Lime (Powder) AIR POLLUTION CONTROL x Air Emissions x Pebble Lime (Powder) x Lime Slurry Scrubbers x Ferrous Materials x Activated Carbon x Carbon Injection Systems x Oversized Materials x Anhydrous Ammonia x Ammonia Injection Systems x Spent Lime Slurry Waste x City Water x Reverse Air Fabric Filters
RECYCLING x Removal of Ferrous Materials x Removal of Oversize Materials
COMBINED ASH pH CONTROL x Dolomitic Lime Addition
BOILER OPERATION - STEAM GENERATION
RAW MATERIALS STEAM GENERATION & RELATED PRODUCTS x City Water COOLING PROCESSES x Spent Boiler Water x Resin x Spent Cooling Water x Acid & Caustic CITY WATER TREATMENT & RESIN x Neutralization Tank x Brine REGENERATION Wastewater x Boiler Water Chemicals x Demineralization Process x Chlorine Scavenger SPENT BOILER WATER TREATMENT
RESIN REGENERATION & WASTEWATER NEUTRALIZATION
Covanta Hennepin Energy Resource Company Page 4 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev.6 NON-CONTACT COOLING WATER PROCESSES
RAW MATERIALS COOLING TOWER PRODUCTS x Spent Boiler Water x Cooling Tower Blowdown x City Water HYDROSTATIC TESTING DURING NPDES/SDS Permit to discharge cooling tower blowdown to the storm x Cooling Tower Chemicals OUTAGES sewer. x Spent Boiler Water from NON-CONTACT COOLING WATER Hydrostatic Tests PROCESSES NPDES/SDS Permit to discharge x Chute Coolers boiler water generated from x Surface Condenser hydrostatic tests to cooling tower. x Seal Steam Condenser x Spent Non-Contact Cooling x Oil Coolers Water
OPERATION AND MAINTENANCE ACTIVITIES & BUILDING UPKEEP
MAINTENANCE & MISC. ACTIVITIES RAW MATERIALS PRODUCTS x Parts Washing x Citric Acid x Spent Citric Acid Solution x Nozzle and Hose Cleaning x Propane x Spent Parts Washing Solution x Forktruck/Lift Operation x Gasoline x Combustion Products from x Front-End Loader Operation x Oxygen & Acetylene Diesel Fuel, Gasoline & x Oil Changing Activities for Various x Hydraulic Fluids and Oil Equipment Located Throughout the Propane x Kerosene x Particulate Emissions from Facility x Diesel Fuel Welding & Torch Cutting x Welding and Cutting Torches x Parts Washing Solvent x Used Hydraulic Fluids x Floor Washing & Facility Upkeep x City Water x Used Oil x Discharger Draining & Facility x Contaminated Storm Water Wastewater Collection System x General Wastewater x Storm Water Collection System
Covanta Hennepin Energy Resource Company Page 5 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 2.0 MATERIAL STORAGE AND HANDLING
The majority of the operations conducted at the facility are inside buildings or totally enclosed conveying systems and do not impact storm water runoff. This section provides a list of significant materials that are handled or stored at the facility that may potentially contact storm water. This section also provides a list of facility areas that significant materials could be exposed to storm water.
2.1 Raw Materials
The table below provides a list of all raw materials stored at the facility, the current storage location, storage container and a brief description of the materials are handled is provided in Table 1.
Raw Material Significant Correspondin Storage Storage Name Material? g Operation Location Container General Handling Operation Chem Treat CT709 YES x Chemicals are piped into the cooling Corrosion Inhibitor (unloading) tower water treatment system. Chem Treat CL4848 x Storage tanks are filled via tanker YES Aboveground, Synthetic Polymer truck. (unloading) INSIDE plastic storage x Facility personnel are present during Chem Treat CL241 YES Cooling tanks with filling operations when ever Defoamer (unloading) Tower concrete possible. Cooling Tower Building containment. x During filling operations, the tanker Water Chem Treat CL215 YES truck is parked in a diked, concrete Biocide Treatment (unloading) area able to contain accidental Chemicals releases. x Contents of shipping containers are Aboveground, pumped into the bulk storage tank. INSIDE plastic storage Chem Treat B-120 YES x Filling operations take place inside Boiler tanks with Chlorine Scavenger (unloading) the facility. Building concrete x Facility personnel conduct the containment. filling operations. x Bulk Steel INSIDE Chem Treat BL1283 YES Storage Tank Boiler Oxygen Scavenger (unloading) inside Concrete Building Containment x Contents of shipping containers are x Bulk Steel pumped into the bulk storage tank. Chem Treat Boiler Water INSIDE YES Storage Tank x Filling operations take place inside B144/144 Treatment Boiler (unloading) inside Concrete the facility. Phosphate Chemicals Building Containment x Facility personnel conduct the x Bulk Steel filling operations. Chem Treat CL-16 INSIDE YES Storage Tank Condensate Polisher Boiler (unloading) inside Concrete Building Containment Resin INSIDE x Bulk Steel x Contents of shipping containers are YES Caustic Soda Regeneration Boiler Storage Tank pumped into the bulk storage tank. (unloading) & Water Building inside Concrete x Filling operations take place inside
Covanta Hennepin Energy Resource Company Page 6 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Raw Material Significant Correspondin Storage Storage Name Material? g Operation Location Container General Handling Operation
INSIDE YES Sulfuric Acid Boiler (unloading) Building
x Bulk Fiberglass x Brine is added manually to the Storage Tank storage tank and mixed with water INSIDE inside Concrete to make a solution. YES Demineralizati Brine Boiler Containment x Filling operations take place inside (unloading) on Process Building x 50 Pound Bags the facility. inside Concrete x Facility personnel conduct the Containment filling operations. x Bulk Steel and Plastic Storage x Filled via bulk trucks using a hose. Tanks inside x Facility personnel are present during Various INSIDE Steel filling operations when ever Oil and Hydraulic YES Equipment Boiler Containment possible. Fluids (unloading) throughout the Building x Temporary Bulk x Bulk truck parks in an outside which Facility Plastic Storage is contained using a concrete floor, Tanks sloping and concrete curbing. containment? x Powder citric acid is mixed with x Bulk Metal water as needed to replenish the Nozzle & INSIDE Storage Tank bulk storage tank. Citric Acid YES Hose Cleaning Scrubber x 50 Pound Bags x Solids that collect on the bottom of (unloading) Powder Operations Building inside Plastic the tank are removed as needed and Container placed in the pit for energy recovery. x Bulk Steel x Filled via bulk trucks using a hose. Storage Tank, x Facility personnel are present during Space Heaters INSIDE Double lined filling operations when ever YES & Kerosene Boiler Steel Storage possible. (unloading) Miscellaneous Building Lank with a x Bulk truck parks in an outside which Equipment leak detection is contained using a concrete floor, system. sloping and concrete curbing. x Filled pneumatically via tanker x Metal Storage trucks. Silo located x Caps to fill port are locked requiring OUTSIDE - inside diked vendors to receive authorization YES Combined Ash Powder Dolomitic Lime cement area from facility personnel prior to (unloading) Treatment APC Area with wastewater conducting filling operations. Near Facility collection x Facility personnel are present during system. filling operations when ever possible.
Covanta Hennepin Energy Resource Company Page 7 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Raw Material Significant Correspondin Storage Storage Name Material? g Operation Location Container General Handling Operation x Filled pneumatically via tanker x Metal Storage trucks. Silo located x Caps to fill port are locked requiring OUTSIDE - inside diked vendors to receive authorization YES Lime Slurry Powder Pebble Lime cement area from facility personnel prior to (unloading) Scrubber APC Area with wastewater conducting filling operations. Near Facility collection x Facility personnel are present during system. filling operations when ever possible. INSIDE - x Metal Holding x Powder pebble lime is mechanically Lime Slurry Slurry Tank inside Pebble Lime NO mixed with water to make slurry and Scrubber Scrubber Scrubber routed to the scrubber. Building Building x Filled pneumatically via tanker x Metal Storage trucks. Silo located x Caps to fill port are locked requiring OUTSIDE - Mercury inside diked vendors to receive authorization YES Powder Activated Carbon Control cement area from facility personnel prior to (unloading) APC Area Additive with wastewater conducting filling operations. Near Facility collection x Facility personnel are present during system. filling operations when ever possible. OUTSIDE x Metal Cylinders YES Forklifts/ Area North located inside a x Facility personnel fill cylinders at a Propane (stored Forktrucks of Boiler non-flammable nearby gas station. outside) Building steel cabinet. OUTSIDE x Metal Cylinders YES Pumps, Area North located inside a x Facility personnel fill containers at a Gasoline (stored Compressors, of Boiler non-flammable nearby gas station. outside) etc. Building steel cabinet. x Bulk Steel x Filled via bulk trucks using a hose. Storage Tank, x Facility personnel are present during OUTSIDE Double lined filling operations when ever YES Front-End Area North Diesel Fuel Steel Storage possible. (unloading) Loaders of Boiler Lank with a x Bulk truck parks in an outside area Building leak detection which is contained using a concrete system. floor, sloping and concrete curbing. x Filled via bulk trucks using a hose. x Facility personnel are present during OUTSIDE x 20,000 gallon filling operations when ever Anhydrous YES Nitrogen Near Ash pressurized possible. Ammonia (unloading) Oxide Control Storage Blg. tank. x Bulk truck parks in an outside area which is contained using a concrete floor, sloping and concrete curbing. x Serviced by Industrial Services INSIDE x , Steel Parts Washing YES handles the transporting, disposing Parts Washer Maintenance container/parts (handling) and restocking the parts washer Solvent Shop washer. fluid.
Covanta Hennepin Energy Resource Company Page 8 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Raw Material Significant Correspondin Storage Storage Name Material? g Operation Location Container General Handling Operation x 8,000-ton storage pit is made of concrete INSIDE containment, x Garbage hauling trucks and transfer Tipping entire tipping trailers are unloaded directly into the Municipal Solid Fuel for Floor/Storag NO area is enclosed. storage pit or on the floor and Waste Combustion e Pit x 500-ton loadout pushed into the pit with a front-end Loadout area is made of loader. Area concrete containment, entire loadout area is enclosed.
2.2 By-Products
The table below provides a list of all by-products produced/stored at the facility, the current storage location, storage container and a brief description of the materials are handled is provided in Table 2.
Significant Correspondin Storage Storage By-Product Material? g Operation Location Container General Handling Operation x Metal collection container south Ferrous Materials YES of the boiler x Ferrous metal is retrieved building. magnetically from the bottom ash x Metal roll-off and pushed into a temporary 3-sided container Combustion OUTSIDE metal container. located in a By-Product South of the x The temporary container is emptied diked, concrete Contained in boiler as needed into a roll-off container. area that is used MSW building. When the roll-off container is full, Oversize Material YES for storm water the metal is transported to a metal collection. recycling facility where it is x Ferrous and recycled. oversize material is kept separate.
2.3 Finished Materials
Unprocessable materials are segregated prior to pit storage and include tires, appliances, oversized items and hard-to-process or low BTU-containing materials (paper rolls, mattresses, etc.). These items are stored in the loadout area (include the tipping floor building) and routed to the appropriate disposal or recycling facility.
Covanta Hennepin Energy Resource Company Page 9 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 2.4 Waste Products
The table below provides a list of all waste products produced/stored at the facility, the current storage location, storage container and a brief description of the materials are handled is provided in Table 4.
Significant Correspondin Storage Storage Waste Product Material g Operation Location Container General Handling Operation x Fly ash is temporarily stored in the x Fly ash is mechanically routed from fabric filter the hoppers to the fly ash storage hoppers. silo utilizing totally enclosed drag x Fly ash is routed chain conveyors. to an ash x Fly ash is then routed through an ash conditioner, conditioner where is it mixed with Combustion combined with water to increase the moisture By-Product INSIDE bottom ash, and content of the fly ash and minimize Particulate x Fly ash conveyed to the fugitive emissions. Fly Ash YES matter hoppers ash storage x Once conditioned, fly ash is batch collected by x Fly ash silo building until mixed with bottom ash and the fabric loadout. conveyed to the ash building in a filters x Ash storage totally enclosed conveying system. building is x Combined ash is then loaded into totally enclosed. trucks with a front-end loader and Ash is stored on transfer to an ash mono-fill for a concrete floor disposal. The loading operations with concrete take place inside the ash building. containment and sloped floors. x Conveying systems are INSIDE inside buildings x Bottom ash and totally is conveyed enclosed when Combustion from the outside building By-Product x Combined ash is loaded on to furnace, structure. Bottom Ash & Residue transfer trucks with a front-end YES combined x Ash storage Combined Ash Remaining loader. The loading operations take with the fly building is After place inside the ash building. ash and totally enclosed. Combustion sent to the Ash is stored on ash storage a concrete floor building with concrete containment and sloped floors.
2.5 Hazardous Substances
There are no hazardous substances generated at the facility.
Covanta Hennepin Energy Resource Company Page 10 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 3.0 POTENTIAL STORM WATER POLLUTANTS AND BEST MANAGEMENT PRACTICES
Following are materials that have the potential to become storm water pollutants and the best management practices implemented to prevent contamination.
3.1 Bottom and Fly Ash
Bottom ash is the residue left over from the combustion process. Oversized materials and ferrous materials are separated from the bottom ash prior to routing the bottom ash to the ash storage building. The oversized and ferrous material, which may be coated with bottom ash, are stored in outside bins and roll-off containers that are exposed to rainfall. In addition, the wheels of the front-end loader used to load combined ash onto the transfer trailers track combined ash via the wheels in the area.
Best Management Practices Implemented
x The area is inspected on a daily basis and is swept with a street sweeper as needed.
x The front-end loader is cleaned daily to minimize tracking of the ash on the roadways.
x The entire area between the boiler building and the ash storage building has been made impermeable with concrete.
x Concrete curbs and slopes have been installed to capture all storm water runoff in the area that may be contaminated with bottom ash. The sump and drains in the area have been permanently sealed with concrete. During a storm water event, the water collected in this area is pumped to the wastewater basin and reused as needed in the facility.
x Diversion of the uncontaminated runoff form the sump area mitigates the quantity of runoff to be collected. Rain gutters were moved to divert uncontaminated storm water away from the concrete area.
3.2 Lime, Activated Carbon and Fly Ash
The dolomitic lime silo, the pebble lime silo, the activated carbon silo and the fly ash conveyors are exposed to rainfall. Fugitive (air borne) emissions of dolomitic lime, pebble lime activated carbon or fly ash have the potential to enter into the nearby storm water drains during rainfall event.
Covanta Hennepin Energy Resource Company Page 11 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Best Management Practices Implemented
x The storage silos, conveying systems and containment area is inspected on a daily basis.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that dolomitic lime, pebble lime and activated carbon delivery personnel utilize proper procedures to minimize spillage during unloading.
x All unloading connections are kept locked forcing the delivery drivers to obtain clearance from facility personnel prior to unloading.
x Facility personnel witness the delivery operations when ever possible.
x Fabric filter hoppers are never opened (except during outages in which they have to be opened for cleaning).
x The concrete containment dike around the APC area will prevent most of the fugitive emissions from entering the nearby storm drains since the diked area drains into the settling basin.
x The storm water collected in the APC area is routed to a settling basin located in the northeast corner of the boiler building. Particulate matter is settled out using baffles and the waste water is reused in the discharges to create a water seal and cool the bottom ash as it exits the discharges.
x Periodic cleaning of the APC area, daily inspection of the silo enclosures, loading/unloading equipment and fly ash conveyors will spot problems before they become serious.
x The conveying systems to transport lime, activated carbon and fly ash to the areas they are needed have to totally enclosed to prevent contact with storm water.
3.3 Cooling Water Treatment Chemicals
Some of the chemicals used to treat the cooling water are delivered by truck could accidentally spill on the paved area and enter nearby storm water drains. Some of the chemicals are delivered in barrels and could be spilled if dropped or punctured during unloading. Cooling tower chemicals are piped from the storage tank to their designated location in the cooling tower building.
Covanta Hennepin Energy Resource Company Page 12 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Best Management Practices Implemented
x The cooling tower building and surrounding areas are inspected on a daily basis.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that chemical delivery personnel follow proper procedures to minimize spillage during bulk and barrel unloading.
x Facility personnel witness the delivery operations when ever possible.
x A storage locker in the cooling tower building contains spill containment equipment.
x The water treatment chemical holding tanks located in the chemical treatment building have concrete containment berms in case of tank leakage or rupture.
x During unloading, the bulk truck is parked in a contained area with a concrete floor, sloping and concrete curbing. Accidental spills would be contained in this area until they could be cleaned up.
3.4 Incidental Litter from MSW Trucks
Litter from improperly secured tarps on MSW trucks can be washed into storm water drains during rainfall events.
Best Management Practices Implemented
x Roadways and parking areas are inspected daily and swept using a street sweeper as needed.
x Debris is picked up from the landscaped areas on a daily basis.
x Facility policy requires MSW trucks to keep their loads covered and tailgates closed until they are in the enclosed tipping hall. Violators are reported to the Hennepin County authority for enforcement.
3.5 Anhydrous Ammonia
Ammonia is delivered and unloaded as needed. There is a potential for an accidental ammonia spill during unloading. Ammonia is piped into the boiler building from the storage tank.
Covanta Hennepin Energy Resource Company Page 13 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Best Management Practices Implemented
x The ammonia storage tank and containment area are inspected daily.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that ammonia delivery personnel utilize proper procedures to minimize spillage during unloading.
x Facility personnel witness the delivery operations when ever possible.
x The ammonia tank is equipped with secondary containment - concrete floor and concrete walls which can hold the contents of the tank should the tank have a leak.
x A Risk Management Plan was developed for ammonia. The RMP includes routine hazard assessments, inspections of all equipment, personnel training and accidental release scenarios.
3.6 Lime Slurry Grit Container
When the pebble lime is slaked with water, the slurry is routed through a screen to filter out grit and other unwanted debris. The grit is routed to an open top collection container located in the APC area. The collection container is periodically emptied as needed.
Best Management Practices Implemented
x The APC area, including the grit collection container, is inspected daily.
x The open container is located inside a contained area that utilizes a concrete floor, sloping and concrete curb to contain all storm water in the area. The area also has a trench system to collect the storm water and route it to our wastewater basin where the water is reused in the process. Thus any accidental spills of the slurry waste would be collected and routed to the waste basin.
3.7 Material Unloading - Turbine Drop
A number of materials, supplies and chemicals are delivered to the Turbine Drop and then are routed to the appropriate storage area or pumped out into the appropriate bulk storage tank. During unloading, there is a potential for chemicals to be spilled in the Turbine Drop and surrounding area.
Covanta Hennepin Energy Resource Company Page 14 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 Best Management Practices Implemented
x The Turbine Drop area is inspected daily.
x All deliveries are required to check in with facility personnel.
x Ensure that chemical delivery personnel follow proper procedures to minimize spillage during bulk and barrel unloading.
x All chemical deliveries are unloaded with the assistance of facility personnel.
x A large spill kit is located near the door of the turbine drop to contain any spills that may occur during unloading or transferring chemicals.
x Temporary curbing is located near the door of the turbine drop that can be used to prevent any spills from entering a nearby storm sewer drain.
x Once inside the facility, the chemicals are moved to the appropriate storage area with sufficient secondary containment or they are pumped into the appropriate bulk storage containers by facility personnel.
3.8 Material Unloading - Oil and Hydraulic Fluids
Oil and hydraulic fluids are delivered by bulk truck could accidentally spill on the paved area and enter nearby storm water drains. Some of the chemicals are delivered in barrels and could be spilled if dropped or punctured during unloading.
Best Management Practices Implemented
x The bulk oil and hydraulic fluid storage area is inspected on a daily basis.
x The bulk oil and hydraulic fluid storage bulk containers are located inside the facility near the South Drop. Secondary containment has been installed for all bulk storage containers to capture any leaks from the storage tanks.
x Specialty oils are stored inside the facility near the South Drop. Specialty oils are typically stored in 5-gallon pails. Secondary containment has been installed for the specialty oils near the south drop area.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that chemical delivery personnel follow proper procedures to minimize spillage during bulk and barrel unloading.
Covanta Hennepin Energy Resource Company Page 15 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 x Facility personnel witness the delivery operations when ever possible.
x During unloading, the bulk truck is parked in a contained area with a concrete floor, sloping and concrete curbing. Accidental spills would be contained in this area until they could be cleaned up.
x Small containers are used to transport oil where needed. All accidental spills are immediately cleaned up.
x A large, moveable spill kit on a dolly is located near the Turbine Drop to assist with accidental spills if needed.
3.9 Material Unloading - Diesel Fuel
Diesel fuel is unloaded into an aboveground storage tank located outside from a bulk truck. There is a potential for an accidental spill during unloading.
Best Management Practices Implemented
x The diesel storage area is inspected on a daily basis.
x The aboveground storage tank is located outside the facility near the South Drop. The steel storage tank is double lined and is equipped with a leak detector.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that chemical delivery personnel follow proper procedures to minimize spillage during bulk and barrel unloading.
x Facility personnel witness the delivery operations when ever possible.
x During unloading, the bulk truck is parked in a contained area with a concrete floor, sloping and concrete curbing. Accidental spills would be contained in this area until they could be cleaned up.
x During equipment fueling, the front-end loader is parked in a contained area with a concrete floor, sloping and concrete curbing. Accidental spills would be contained in this area until they could be cleaned up.
x A large, moveable spill kit on a dolly is located near the Turbine Drop to assist with accidental spills if needed. In addition, spill materials are also available in storage cabinet in the cooling tower building.
Covanta Hennepin Energy Resource Company Page 16 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 3.10 Material Unloading - Kerosene
Kerosene is unloaded into aboveground storage tanks located outside the facility. There is a potential for an accidental spill during unloading.
Best Management Practices Implemented
x The kerosene storage areas are formally inspected on a daily basis.
x The aboveground storage tank is located outside the facility near the South Drop. The steel storage tank is double lined and is equipped with a leak detector.
x All delivery personnel are required to notify facility personnel when they are onsite and must obtain authorization to unload.
x Ensure that chemical delivery personnel follow proper procedures to minimize spillage during unloading.
x Facility personnel witness the delivery operations when ever possible.
x During unloading, the bulk truck is parked in a contained area with a concrete floor, sloping and concrete curbing. Accidental spills would be contained in this area until they could be cleaned up.
x Spills inside the facility would be generally contained within the building. Any accidental spills are cleaned up immediately. Trenches in the floor would capture large spills and route it to the wastewater basin.
x A large, moveable spill kit on a dolly is located near the Turbine Drop to assist with accidental spills if needed. In addition, spill materials are also available in storage cabinet in the cooling tower building.
x Small safety cans are used to fill various equipment located the facility. Small volumes are used in filling operations to minimize accidental spills. All accidental spills are immediately cleaned up.
3.11 Material Storage - Gasoline and Propane
Gasoline and propane containers are filled at a near by gas station by facility personnel. When filled, they are stored in a flammable storage container located outside, south of the boiler building. Equipment fueling operations are conducted outside or inside depending on the equipment.
x Facility personnel inspect the gasoline and propane storage area on a daily basis.
Covanta Hennepin Energy Resource Company Page 17 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 x Small volume containers are used for easy handling and to minimize spills.
x All equipment fueling takes place in a contained area (either inside the facility or in the area between the Ash Residue Building and the Ash Storage Building).
x Any accidental spills are immediately contained and cleaned up.
3.12 Equipment Maintenance and General Maintenance Activities
Equipment maintenance is conducted inside when ever possible. If equipment maintenance is conducted outside, the following Best Management Practices have been implemented to prevent accidental releases to the storm sewer.
x All equipment maintenance is conducted inside the facility in appropriate areas whenever possible.
x Only authorized personnel can conduct equipment maintenance and must obtain the required clearances before doing so.
x If maintenance is conducted outside, appropriate containment is implemented before conducting maintenance (i.e. temporary dikes, absorbent rags or socks, etc.).
x When the job is completed, all supplies and materials are cleaned up and the area is swept or washed if necessary to prevent storm water contamination.
x If accidental spills occur, they are contained and cleaned up immediately.
3.13 Equipment and Vehicle Washing
Equipment washing is conducted inside when ever possible. If equipment or vehicle washing is conducted outside, the following Best Management Practices have been implemented to prevent accidental releases to the storm sewer.
x Equipment washing can only be conducted in designated areas that are designed to collect the wastewater generated from the washing operations.
x All wastewater generated from equipment washing is either allowed to evaporate in a contained area or routed inside the facility and reused in the ash dischargers.
3.14 Parking Lot and Roadways
Parking lots and roadways are inspected daily and swept with a street sweeper as needed.
Covanta Hennepin Energy Resource Company Page 18 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 4.0 DISCHARGE EVALUATION
All discharge conveyances have been evaluated from the site and it has been determined that no other liquids other than storm water are being discharged from these devices. This was done through knowledge of the site, detailed sanitary sewer diagrams and storm sewer diagrams.
x All drains inside the facility lead to either the wastewater settling basin or the sanitary sewer.
x All facility drains have been evaluated based on knowledge and through review of drain diagrams.
x All wastewater generated is either routed to the wastewater basin and reused, or the sanitary sewer or the cooling tower. The cooling tower blowdown is routed to the storm sewer by NPDES/SDS Permit Number 0057525.
x There are no direct discharges to the storm sewer except for the cooling tower blowdown described above.
x All significant materials have been contained and any areas that are exposed to storm water have been contained. Storm water collected from these areas is routed to the wastewater basin and reused at the facility.
Covanta Hennepin Energy Resource Company Page 19 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 5.0 PREVENTATIVE MAINTENANCE PROGRAM
A formal preventative maintenance program has been implemented that reduces the likelihood of spills that could impact storm water runoff. The Preventative Maintenance Program is run by the Maintenance Manager and consists of four main parts:
x Daily, weekly, monthly, semiannual and annual preventative maintenance activities that are conducted during normal operation of the facility;
x Formal outages in which specific equipment is taken out of service for preventative maintenance or repair;
x Unscheduled outages in which specific equipment is taken out service to prevent failure or for repair; and,
x Work order system for facility personnel to formally document items that need maintenance or repair.
5.1 Routine Preventative Maintenance
A formal preventative maintenance program has been implemented in which daily, weekly, monthly, semiannual and annual preventative maintenance activities are scheduled through a computerized work order system. Maintenance and operations personal receive preventative maintenance work orders daily and turn in the work orders when the job is complete.
Preventative maintenance activities are conducted in all equipment, operations and structures at the facility. They include but are not limited to detailed inspections, oil/fluid changes, routine parts replacement, monitoring gage and instrument readings and instrument calibrations. The preventative maintenance activities range in frequency based on manufacture recommendations and experience with the equipment. The preventative maintenance activities are conducted by both maintenance and operations personnel.
In addition, weekly environmental inspections are conducted specifically to ensure compliance with current permit and regulations. As part of the weekly environmental inspections, informal storm water management devices and Best Management Practices are inspected and reviewed. Formal storm water inspections are conducted every two months are required by our current storm water permit.
5.2 Formal Scheduled Outages
The Preventative Maintenance Program includes four scheduled outages in which major equipment and operations are shut down for repair and maintenance, as well as, scheduled
Covanta Hennepin Energy Resource Company Page 20 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 inspections, checks, calibrations and preventative maintenance to ensure equipment is operating properly. An outage lasts anywhere from four days to two weeks depending on the magnitude of work that needs to be conducted. Scheduled outages are well planned for and numerous contractors are onsite to assist with the equipment inspections, repairs and preventative maintenance. Detail outage reports are generated documenting all repairs and preventative maintenance that occurred during the outage.
5.3 Unscheduled Outages
Unscheduled outages occur when equipment breaks down or equipment is suspect for facility and an inspection is warranted. During an unscheduled outage suspect equipment is thoroughly inspected and repaired as needed. Facility personnel do the majority of the repairs, although outside contractors are called in when necessary. Typically unscheduled outage last one to four days.
5.4 Work Order System
The Preventative Maintenance Program includes a work order in which the control room operators or shift supervisors can document problems that were discovered during daily inspections. Computerized work orders are issued to the maintenance personnel and work orders remain in the system until the work is complete.
5.5 Good Housekeeping Practices
Good housekeeping practices have been developed and implemented regarding material handling and storage throughout the facility and grounds. Facility personnel inspect all operations, material handling and material storage areas on a daily basis, 365 days per year. In addition, an environmental inspection focusing on compliance with regulatory requirements and evidence of actual or threatened releases is conducted weekly and documented. Any findings are discussed formally and corrective actions are determined and implemented in a time manner. Finally, storm water inspections are conducted routinely as required to specifically verify the Best Management Practices are implemented and working properly.
Materials, equipment, and related items are not permitted to be stored outdoors except in designated areas. The facility has also formalized spill response procedures to ensure prompt and appropriate response and control of release situations.
Covanta Hennepin Energy Resource Company Page 21 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 6.0 SPILL PREVENTION AND RESPONSE PROCEDURE
Spill Prevention Control and Counter Measure Plans
A formal Spill Prevention and Counter Measure (SPCC) Plan has been developed to aid to assist personnel in responding to both hazardous chemical and oil spills at the facility.
Appropriate containment and diversionary structures or equipment are provided to prevent discharged hazardous substances from reaching the storm sewer. Both inside and outside, the facility uses containment systems to control accidental releases. In addition, in areas where storm water has the potential to come in contact with significant materials, the storm water is collected, routed inside the reused.
Spill containment kits and temporary dikes for containing and cleaning up small spills are located in designated areas in the facility and cooling tower building. A company that is equipped and licensed to provide emergency response and cleanup would handle large spills.
A copy of the current Spill Prevention and Countermeasure Plans for hazardous materials and oils are available for review and reference.
Covanta Hennepin Energy Resource Company Page 22 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 7.0 EMPLOYEE TRAINING PROGRAM
Affected personnel are required to review the Storm Water Pollution Prevention Plan and Spill Prevention and Countermeasures Plan on an annual basis. A training log has been develop indicating who was trained, the date of the training and approximately the number of hours spent on training.
Beginning in 2005, a formal training session conducted by the Environmental Engineer is given for all affected facility personnel. The annual training is based on the corporate Environmental Awareness Training program and includes topics of storm water best management practices and spill response.
New hires will be trained on the Storm Water Permit and associated storm water pollution prevention plan.
Copies of the training records associated with the Storm Water Pollution Prevention Plan will be kept in the Environmental Engineer's office.
Covanta Hennepin Energy Resource Company Page 23 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 8.0 PLAN IMPLEMENTATION AND RESPONSIBILITIES
The following personnel will be responsible for implementing the Storm Water Pollution Prevention Plan.
Name Position Responsibilities Durwin Fitch Facility Manager x Annually Review Plan x Review Best Management Practices and Update as Necessary x Oversee Preventative Maintenance Program - Specifically Scheduled Outages Glenn Schmidt Chief Engineer x Implement Preventative Maintenance Program (Operations Activities) x Assist with Formal Training Sessions x Address Storm Water Issues x Enforce and ensure BMP's are implemented Jeff Johnson Maintenance Manager x Implement Preventative Maintenance Program (Maintenance Activities) x Oversee and Complete Work Orders x Repair and Implement Structural Best Management Practices as Needed Daniel Fish Environmental x Conduct and Document Storm Water Engineer Inspections during Non-Frozen Conditions x Conduct and Document Environmental Inspections Year-Round x Discuss Issues with Management Team x Document all Corrective Actions associated with Inspection Findings x Document any changes or additions to current BMP's x Review and Update the Storm Water Pollution Prevention Plan Annually x Complete the Annual Storm Water Report and Submit to MPCA by March 31 x Conduct Training for all Affected Employees Shift Supervisors x Enforce and ensure requirements of Storm Water Permit and Pollution Prevention Plan are followed. x Request additional training as needed. x Complete Environmental Event Report for any accidental releases to the environment.
Covanta Hennepin Energy Resource Company Page 24 Storm Water Pollution Prevention Plan 505 6th Avenue North Revision Date: December 2009 Minneapolis, Minnesota 55405 Rev. 6 SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN
(OIL AND PETROLEUM PRODUCTS)
FOR
COVANTA HENNEPIN ENERGY RESOURCE COMPANY, L.P. 505 SIXTH AVENUE NORTH MINNEAPOLIS, MINNESOTA 55405
DATE OF CURRENT PLAN REVIEW/REVISION: DECEMBER 4, 2009 REV. 5
DATE OF P.E. CERTIFICATION: JANUARY 2005
DATE OF INITIAL PLAN REVIEW/REVISION: APRIL 2003 REV. 0
DESIGNATED PERSON ACCOUNTABLE FOR SPILL PREVENTION: DURWIN G. FITCH, FACILITY MANAGER
Uncontrolled Document See S:\SHARE\Plans\SPCC for current authorized version TABLE OF CONTENTS
1.0 APPROVAL AND CERTIFICATIONS Professional Engineer Certification 112.3(d)(1) Technical Amendment Certification and Review 112.5(c) Management Approval and Commitment 112.7
2.0 INTRODUCTION Purpose Scope Implementation Review, Amendment and Certification Deviations from Plan Requirements 112.7(a)(1)&(2)
3.0 GENERAL REQUIREMENTS General Facility Information Facility Operations and Background Receiving Waters/Probable Flow Paths Physical Layout/Description of Facility 112.7(a)(3) Discharge Prediction 112.7(b) Diversionary Structures and Containment 112.7(c) Demonstration of Impracticability for Diversionary Structures or Containment 112.7(d) Inspections and Records 112.7(e) Personnel, Training and Discharge Prevention Procedures 112.7(f) Security 112.7(g) Truck Unloading Operations 112.7(h) Brittle Fracture Evaluation 112.7(i) Conformance with Additional State Requirements 112.7(j) Conformance with General Requirements 112.8(a)
4.0 SPILL PREVENTION AND COUNTERMEASURE PROCEDURES Spill (Discharge) Reporting Procedures 112.7(a)(4) Spill (Discharge) Response Procedures 112.7(a)(5)
5.0 DISCHARGE PREVENTION MEASURES Drainage Control 112.8(b) Bulk Storage Containers 112.8(c) Facility Transfer Operations 112.8(d) Other Sections 112.9, 112.10, 112.11, 112.12, 112.13, 112.14 and 112.15
6.0 SUBSTANTIAL HARM CRITERIA CHECKLIST 112.20(e)
7.0 RECOMMENDED DISCHARGE CONTROL IMPROVEMENTS LIST of FIGURES
FIGURE 1 FACILITY LAYOUT AND SURFACE DRAINAGE DIAGRAM
LIST of TABLES
TABLE 1 OIL AND PETROLEUM PRODUCTS STORAGE TABLE 2 EXISTING CONTAINMENT AND DIVERSIONARY STRUCTURES TABLE 3 CONTACT LIST TABLE 4 SUMMARY OF DISCHARGE CONTROL EQUIPMENT
APPENDICES
APPENDIX 1 SECONDARY CONTAINMENT CALCULATIONS FOR DIKED STORAGE AREAS APPENDIX 2 MONTHLY FACILITY INSPECTION REPORT APPENDIX 3 CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA CHECKLIST APPENDIX 4 NOTIFICATION FORM FOR REPORTABLE SPILL EVENTS 1.0 APPROVAL AND CERTIFICATIONS
1.1 PROFESSIONAL ENGINEER CERTIFICATION [40 CFR 112.3(d)(1)]
I hereby certify that I have visited and examined the Covanta Hennepin Energy Resource Company, L.P. (CHERC) facility located at 505 Sixth Avenue North, Minneapolis, Minnesota, and, being familiar with the relevant provisions for SPCC Plans under the Clean Water Act, attest that this SPCC Plan is in accordance with industry standards, good engineering practices and the requirements of the SPCC regulation (40 CFR 112). The procedures required for inspections and testing have been established and this Plan is adequate for the facility.
SIGNATURE:
NAME (PRINT): Mr. Jeffrey L. Hahn
REGISTRATION NO.: CH 3289
STATE: California
DATE:
1.2 TECHNICAL AMENDMENT CERTIFICATION AND REVIEW [40 CFR 112.5]
In accordance with 40 CFR Part 112.5(b), a review and evaluation of this SPCC Plan is conducted at least once every five years. As a result of this evaluation, if necessary, the SPCC Plan will be amended within six months of the review to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a discharge event from the facility; and if such technology has been field-proven at the time of review.
Pursuant to 40 CFR Part 112.5(c), any technical amendment will be certified by a Professional Engineer (P.E.) within six months after a change in the facility design, construction, operation or maintenance occurs which materially affects the facility’s potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines.
The following page provides documentation of the five-year review or evaluation of the SPCC plan by the professional engineer (or his/her agent). A statement as to whether an amendment to the Plan is required is also included on the review page.
Covanta Hennepin Energy Resource Company Page 1 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 TECHNICAL AMENDMENT CERTIFICATION AND REVIEW PAGE
Is P.E. certification Review Reviewer required Comments (Provide description of Date (Print name) Reviewer’s Signature (Yes/No)? changes/revisions)
1. 03/09/03 S. Forss Yes Initial review and certification
Technical update to the plan to reflect the removal of the existing diesel tanks 2. 12/10/04 D. Fish YES and the installation of a new diesel tank. Administrative update to the plan to 3. 12/10/04 D. Fish NO reflect personnel changes and new monthly inspection forms. Administrative update to the plan to 4. 08/31/06 D. Fish NO reflect personnel changes and annual review. Administrative update to the plan to 5. 10/16/07 D. Fish NO reflect personnel changes and annual review. Administrative update to the plan for 6. 11/17/08 D. Fish NO annual review.
Administrative update to the plan for 7. 12/04/09 D. Fish NO annual review.
8.
Covanta Hennepin Energy Resource Company Page 2 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 1.3 MANAGEMENT APPROVAL AND COMMITMENT [40 CFR 112.7]
This Spill Prevention, Control, and Countermeasure (SPCC) Plan will be implemented as herein described. I have personally examined and am familiar with the information contained in the SPCC Plan and all attachments, and I believe that the information is true, accurate, and complete.
Name Date Signature Durwin G. Fitch 12/04/09 Facility Manager
Glenn Schmidt 12/04/09 Chief Engineer
Jeff Johnson 12/04/09 Maintenance Supervisor
Daniel Fish 12/04/09 Environmental Specialist
Covanta Hennepin Energy Resource Company Page 3 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 2.0 INTRODUCTION
This Spill Prevention Control and Countermeasure (SPCC) Plan has been prepared in accordance with 40 Code of Federal Regulations (CFR) Part 112-Oil Pollution Prevention. The SPCC Plan is required for non-transportation onshore facilities that:
1. Store, use or consume oil and oil products with an aggregate aboveground storage capacity in excess of 1,320 gallons total; or, 2. A completely buried (underground) storage capacity in excess of 42,000 gallons, which is not subject to 40 CFR 280 or 281; and, 3. Should a discharge occur, the discharged oil and oil products could reasonably be expected to discharge into or upon the navigable waters or adjoining shorelines of the United States.
For the purposes of calculating the threshold storage capacity, only containers of oil with a storage capacity of 55 gallons or greater are counted toward the aggregate aboveground storage capacity. The threshold applies to storage capacity contained in operating equipment as well as the storage capacity contained in containers.
Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish or marine mammal in origin; vegetable oils, including oils from seeds, nuts, fruits or kernels; and other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes (other than dredged spoil).
2.1 PURPOSE
The purpose of the SPCC Plan is to prevent the discharge of oil and oil products into or upon the navigable waters or adjoining shorelines of the United States by identifying potential discharges, establishing equipment, and procedures to prevent the occurrence of a discharge and to provide immediate response and notification should a discharge occur.
2.2 SCOPE
This Plan addresses three basic functions:
1. The practices devoted to the prevention of oil discharges; 2. The plan of containment should a discharge occur; and, 3. The plan for removal and disposal of discharged material.
Please note that in each section of this document, the federal requirements are enclosed within a box prior to the facility’s description of the mechanisms in place for ensuring compliance with each requirement.
Covanta Hennepin Energy Resource Company Page 4 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 2.3 IMPLEMENTATION
The personnel at the Covanta Hennepin Energy Resource Company, L.P. (CHERC) facility will implement the SPCC Plan. Contractors and delivery staff can have a significant impact on the prevention of discharges. The facility will take reasonable measures to direct contractors and delivery staff to operate in a manner consistent with this Plan.
2.4 REVIEW, AMENDMENT, AND CERTIFICATION
USEPA Review and Amendment [40 CFR 112.4]
The SPCC Plan is not required to be filed with the USEPA; however, a copy is retained at the facility and is available onsite for review by the USEPA or appropriate state agencies during normal working hours.
Whenever there has been a discharge (spilling, leaking, pumping, pouring, emitting, emptying or dumping of oil outside of piping, equipment or containment) of more than 1,000 gallons in a single discharge, or more than 42 gallons of oil discharged in each of two discharges occurring within any 12-month period, a discharge report will be submitted to the USEPA and the Minnesota Pollution Control Agency within 60 days of the discharge. The report should contain the information listed in Section 4.1.
Upon receipt and review of the report information, the Regional Administrator or state agency may require the Plan to be amended.
Facility Review and Amendment [40 CFR 112.5]
Review. The SPCC Plan will be reviewed and evaluated by facility personnel at least once every five years.
Amendment. The SPCC Plan will be amended whenever there is a significant change in facility design, construction, operation, or maintenance, which affects the facility's potential to discharge oil. Specific changes that require an SPCC Plan amendment include:
x Commission or decommission of containers; x Replacement, reconstruction, or movement of containers; x Reconstruction, replacement, or installation of piping systems; x Construction or demolition that may alter secondary containment structures; x Changes in products or services; and, x Revision of standard operation or maintenance procedures at the facility.
Covanta Hennepin Energy Resource Company Page 5 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 If changes are required to provide more effective prevention and control, the SPCC Plan will be amended and implemented within six months of the review. All amendments will be implemented as soon as possible, but no later than six months after changes have occurred.
Certification [40 CFR 112.5(c)]
Technical amendments to the Plan will be reviewed and certified by a Registered Professional Engineer or his/her agent, who has examined the facility and is familiar with the requirements of 40 CFR 112. The “Technical Amendment Certification and Review Page” form is found in Section 1.0, Approvals, and Certifications. Administrative changes, such as changes to phone numbers, personnel names, etc. do not need to be certified by a registered Professional Engineer.
2.5 DEVIATIONS FROM PLAN REQUIREMENTS [40 CFR 112.7(a)(1) and (2)]
(1) Include a discussion of your facility’s conformance with the requirements listed in this part (i.e., 112.7). (2) Comply with all applicable requirements listed in this part. Your plan may deviate from the requirements in paragraphs (g), (h)(2) and (3), and (i) of this section, and the requirements of Subpart B and C of this part, except for the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8 (c)(11), 112.9(c)(2), 112.10(c), 112.12 (c)(2), 112.12(c)(11), 112.13(c)(2) and 112.14(c), where applicable to a specific facility, if you provide equivalent environmental protection by some other means of spill prevention, control or countermeasure. Where your plan does not conform to the applicable requirements in paragraphs (g), (h)(2), (h)(3) or (i) or the requirements of Subpart B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8 (c)(11), 112.9(c)(2), 112.10(c), 112.12 (c)(2), 112.12(c)(11), 112.13(c)(2) and 112.14(c), you must state the reasons for nonconformance in the Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. If the Regional Administrator determines that the measures described in your Plan do not provide equivalent environmental protection, he may require you to amend your Plan, following the procedures in §112.4(d) and (e).
The facility is in conformance with all of the general requirements of 112.7, and the specific requirements of 112.8. Alternate means of environmental protection have not been provided, since the facility conforms to the requirements specified in the regulation.
3.0 GENERAL REQUIREMENTS [40 CFR 112.7]
Covanta Hennepin Energy Resource Company Page 6 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 3.1 GENERAL FACILITY INFORMATION
Facility Owner: Hennepin County Department of Environmental Services Address and 417 North Fifth Street, Minneapolis Minnesota 55401 Phone Number
Facility Operator: Covanta Hennepin Energy Resource Company, L.P. Address and 505 6th Avenue North, Minneapolis, Minnesota Phone Number
Name Title Phone Number 612-332-9422 Durwin G. Fitch Facility Manager 612-790-7316 612-332-9424 Glenn Schmidt Chief Engineer 612-916-0170 Maintenance 612-332-9425 Facility Contacts: Jeff Johnson Supervisor 612-750-1186 612-332-9423 John Sigmond Business Manager 612-508-3099 Environmental 612-332-9428 Dan Fish Compliance 612-508-0116 Specialist
3.2 FACILITY OPERATIONS AND BACKGROUND
The Covanta Hennepin Energy Resource Company (CHERC) Facility is a 1212- ton per day refuse-fired electric generating facility. The facility has operated continuously since it began commercial operation in 1989. This facility consists of two, 606-ton per day refuse-fired boilers, and a 38.5-megawatt capacity turbine- generator, along with ancillary equipment. The facility converts municipal solid waste into electricity, which is sold to Xcel Energy.
3.3 RECEIVING WATERS/PROBABLE FLOW PATHS
The facility is located in downtown Minneapolis. The site drains into various storm sewers located on the site. Storm water will flow offsite through the several storm drains located around the site. The storm water collector pipe enters the CHERC site on the eastern boundary. Storm water collected in the southeast quadrant of the site empties into the interceptor east of the tipping hall exit doors. The collector continues around the north half of the site collecting storm water discharge at several locations in the north half of the site. Storm water from the southwest quadrant of the site empties into the collector near the facility entrance. The storm water collector exits the site near the facility entrance in the northwest quadrant eventually flowing into the Mississippi River.
Covanta Hennepin Energy Resource Company Page 7 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 A number of areas have been sealed or contained. Storm water that has come in contact with contaminants is captured in these areas is routed to the wastewater basin and reused inside the facility.
3.4 PHYSICAL LAYOUT/DESCRIPTION OF FACILITY [40 CFR 112.7(a)(3)]
Describe in your Plan the physical layout of the facility, and include a facility diagram, which must mark the location and contents of each container. The facility diagram must include completely buried tanks that are otherwise exempted from the requirements of this part under §112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes. You must also address in your Plan: (i) The type of oil in each container and its storage capacity; (ii) Discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.) (iii) Discharge or drainage controls, such as secondary containment around containers and other structures, equipment and procedures for the control of a discharge; (iv) Countermeasures for discharge discovery, response, and cleanup (both the facility’s capability and those that may be required of a contractor; (v) Methods of disposal of recovered materials in accordance with applicable legal requirements; and (vi) Contact list and phone numbers for the facility response coordinator, National Response Center, clean up contractors with whom you have an agreement for response, and all appropriate Federal, State and local agencies who must be contacted in case of a discharge as described in §112.1(b).
The facility consists of the main boiler building, ferrous recovery area, ash residue area, maintenance shop, air pollution control (APC) area, continuous emission monitoring system (CEMS) shelter, cooling tower building, ash storage building, tipping floor and storage pit, loadout bay and the administration building.
A facility diagram, indicating the location and contents of each container is presented as Figure 1. Oil-filled electrical and operating equipment having capacities greater than 55-gallons are also shown in Figure 1, for informational purposes. Containers that hold less than 55-gallons of oil product are not shown on the diagram. Additionally, there are no completely buried containers of oil in service. A summary of the types of oils used at the facility and related storage information is presented in Table 1.
Covanta Hennepin Energy Resource Company Page 8 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Table 1 Oil and Petroleum Products Storage
Type of Oil Storage Storage Stored Container Capacity Hydraulic Oil AST: Plastic Bulk Storage Container with Steel 200 Gallons (13M) Containment (Inside Facility) Hydraulic Oil AST: Steel Storage Container with Steel 800 Gallons (DTE25) Containment (Inside Facility) Lubricating Oil AST: Plastic Bulk Storage Container with Steel 200 Gallons (Delvac 1230) Containment (Inside Facility) Turbine 55-Gallon Steel Drums with Plastic Containment (~4 Lubricating Oil ~220 Gallons drums) (Inside Facility) (DTE797) AST: Double Walled, Steel Storage Container Kerosene 470 Gallons (Outside Facility) AST: Double Walled, Steel Storage Container Diesel Fuel 1000 Gallons (Outside Facility) 55-gallon or 30-gallons Steel Drums with Plastic Specialty Oils ~220 Gallons Containment (~4 drums) (Inside Facility) 55-gallon or 30-gallons with Steel Containment (~4 Specialty Oils ~220 Gallons drums) (Inside Facility) Compressor Oils 55-gallons Steel Drums (~4 drums) (Inside Facility) ~220 Gallons Oil Filled Transformer (CHERC) with Concrete Insulating Oil 307 Gallons Containment (Outside Facility) Oil Filled Transformer (CHERC) with Concrete Insulating Oil 307 Gallons Containment (Outside Facility) Oil Filled Transformer (Hennepin County) (Outside Insulating Oil 3,730 Gallons Facility) Lubricating Oil Turbine Oil Reservoir with Concrete Containment 1575 Gallons (DTE797) (Inside Facility) Hydraulic Oil Hydraulic Skid with Steel Containment (Inside 132 Gallons (DTE25) Facility) Hydraulic Oil Hydraulic Skid with Steel Containment (Inside 132 Gallons (DTE25) Facility) TOTAL 9,733 Notes: (1) Containers that hold less than 55-gallons of oil are not included in the total quantity of oil stored.
Covanta Hennepin Energy Resource Company Page 9 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 3.5 DISCHARGE PREDICTION [40 CFR 112.7(b)]
Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure.
There is a reasonable potential for reportable discharges from the oil and oil product containers.
13M Hydraulic Oil Bulk Storage Container – 200 Gallons DTE-25 Hydraulic Oil Bulk Storage Container – 800 Gallons Delvac 1230 Lubricating Oil Bulk Storage Container – 200 Gallons
Hydraulic and lubricating oils are stored in bulk storage containers on the ground floor of the boiler building, near the south drop. A steel containment area surrounds the bulk storage area and can contain 520 gallons of oil accounting for the displaced volume from the containers inside the containment area. The types of failures for these containers include a leak in the container, filling operations and dispensing operations. In the case of a container leak or releases generated from dispensing operations, the oil would be contained in the steel containment designed to capture leaks from the oil storage area. In the event the containment cannot contain the quantity of oil released, the oil would be released onto the floor of the boiler building. The trench system would collect and route the oil to the wastewater basin where it would be contained. In the event that the trench system was full and could not route the oil to the wastewater basin, the oil may flow towards the south drop and ultimately outside of the building through an overhead door. The area directly outside the south drop overhead door has been designed to capture storm water utilizing concrete, sloping and curbing. Thus, any oil that is routed outside the building would be contained and cleaned up accordingly. Similarly, any accidental releases from filling or dispensing operations would be routed to the wastewater basin or contained in the concrete area near the south drop. The bulk truck parks in the concrete area during filling, thus any accidental releases from the bulk fill truck would be captured in the concrete containment area and contained until it could be cleaned up. Oil is typically dispensed into the 5-gallon pails or 55-gallon drums when needed. Only trained personnel are authorized to dispense and use oil.
DTE-797 Lubricating Oil (Turbine Drop)
Lubricating oil for the turbine is stored in 55-gallon drums located near the turbine on the ground floor of the boiler building. This oil is also used as a lubricant for the induced draft fan hydraulic drives. “Pallet containment” is used as a secondary containment mechanism and can hold up to 66 gallons of oil. The types of failures for this container include a leak in the container, filling operations
Covanta Hennepin Energy Resource Company Page 10 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 and dispensing operations. In the case of a container leak, the oil would be contained in the pallet containment. Excess oil would then be released inside the boiler building and would flow towards the wastewater basin or into a sanitary sewer drain near the water heaters. If the oil is routed into the sanitary sewer drain, it will pass through an oil separator prior to being discharged to the city sewer system and ultimately to a wastewater treatment plant. If the oil flowed outside the building through the turbine drop, it will collect in a concrete area and could be cleaned up. The storm water drains near the turbine drop have been protected with concrete curbing such that accidental releases of oil or other chemicals could not enter the storm water system. Similarly, accidental releases from filling or dispensing operations would be routed to the wastewater basin, the sanitary sewer would pool outside near the turbine drop. Oil is delivered in 55- gallons drums that are unloaded through the turbine drop. Oil is typically dispensed into a 55-gallon or smaller containers when needed. Only trained personnel are authorized to dispense and use oil.
Kerosene Bulk Storage Container (South Drop/Ash Residue Area)
Kerosene is used as a fuel for portable space heaters and other miscellaneous equipment. A bulk kerosene container is stored in the ash residue area (outside). The kerosene container is a steel, double-walled container. The container is equipped with a leak detection system, which enables the inspector to determine if any material has leaked into the secondary containment. The types of failures that could occur for this container include a leak in the inside container, or from filing or dispensing operations. A leak in the container would be discharged to the outside container, which surrounds the entire tank and there would be no release to the environment. If kerosene were released during filling or dispensing operations, the kerosene would be released into the the area directly outside of the south drop overhead door (ash residue area). This area has been designed as a secondary containment to capture storm water utilizing appropriately sloping concrete and curbing. Thus, any kerosene that is released during filling or dispensing operations would be contained and cleaned up accordingly. The bulk fill truck parks in the ash residue area during filling, thus any accidental releases would be captured and contained until it could be cleaned up. Kerosene is typically dispensed into small metal containers on an as needed basis. Only trained personnel are authorized to dispense and use kerosene.
Covanta Hennepin Energy Resource Company Page 11 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Diesel Fuel Bulk Storage Containers (South Drop/Ash Residue Area)
Diesel fuel is stored in a bulk container in the ash residue area (outside). Diesel fuel is used primarily as fuel for the front end loaders. The diesel container is a steel, double-walled container. The container is equipped with a leak detection system, which enables the inspector to determine if any material has leaked into the secondary containment. The types of failures that could occur for this container include a leak in the inside container, or from filing or dispensing operations. A leak in the container would be discharged to the outside container, which surrounds the entire tank and there would be no release to the environment. If diesel fuel were released during filling or dispensing operations, the diesel fuel would be released onto the floor of the ash residue area. The ash residue area has been designed as a secondary containment to capture storm water utilizing appropriately sloping concrete and curbing. Thus, any diesel fuel that is accidentally released in the ash residue area would be contained and cleaned up accordingly. The bulk fill truck parks in the concrete area during filling, thus any accidental releases would be captured and contained until it could be cleaned up. Diesel fuel is typically dispensed directly into the front end loaders as needed. Only trained personnel are authorized to dispense and use diesel fuel.
Specialty Oils (South Drop)
Small quantities of specialty oils are needed for some of the equipment that is operated onsite. Specialty oils are stored in 55-gallon steel drums near the South Drop with steel containment capable of holding 279 gallons or in the South Drop with “pallet containment” capable of hold 68 gallons. In the case of a container leak, the oil would be contained in the steel containment or the plastic pallet containment. In the event the containment cannot hold the quantity of oil released, the oil would be released onto the floor of the boiler building or onto the floor of the south drop. In the boiler building, the trench system would collect and route the oil to the wastewater basin. In the event that the trench system was full or in the event the pallet containment was full, the oil may flow towards the south drop and ultimately outside of the building through an overhead door. The area directly outside of the south drop overhead door has been designed to capture storm water utilizing appropriately sloping concrete and curbing. Thus, any oil that is routed outside the building would be contained and cleaned up accordingly. Similarly, any accidental releases from filling or dispensing operations would be routed to the wastewater basin or contained in the concrete area near the south drop. Specialty oils are delivered in 55 gallon drums to the South Drop. Specialty oils are typically dispensed from the 55-gallon drums when needed. Only trained personnel are authorized to dispense and use specialty oils.
Covanta Hennepin Energy Resource Company Page 12 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Compressor Oil (Operating Level)
Compressor oil is stored on the operating level and used in one of three compressors. Air compressor oil is stored in 55-gallon steel drums with “pallet containment” capable of holding 66 gallons of oil. In the case of a container leak, the oil would be contained in the pallet containment. In the event the containment cannot hold the quantity of oil released, the oil would be released onto the operating floor and would most likely be discharged through a floor drain to the sanitary sewer. If the oil is routed into the sanitary sewer drain, it will pass through an oil separator prior to being discharged to the city sewer system and ultimately to a wastewater treatment plant. Specialty oils are delivered in 55-gallon drums to the Turbine Drop and are routed to the designated storage area.
3.6 DIVERSIONARY STRUCTURES AND CONTAINMENT [40 CFR 112.7(c)]
Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in §112.1(b). The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe will not escape the containment before cleanup occurs. At a minimum, you must use one of the following prevention systems or its equivalent: [(1) For onshore facilities:] i) Dikes, berms or retaining walls sufficiently impervious to contain oil; ii) Curbing; iii) Culverting, gutters or other drainage systems; iv) Weirs, booms or other barriers; v) Spill diversion ponds; vi) Retention ponds; and vii) Sorbent materials.
Existing containment and diversion structures for each container are listed on Table 2.
Covanta Hennepin Energy Resource Company Page 13 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Table 2 Existing Containment and Diversion Structures Applicable Containers (1)
Secondary Type of Containment Type of Oil Storage Storage Secondary Volume Stored Container Capacity Containment (gallons) Hydraulic Oil Plastic Bulk Storage 200 Gallons (13M) Tank Common Steel Hydraulic Oil Steel Storage Tank 800 Gallons Containment 520 (2) (DTE25) Area Lubricating Oil Plastic Bulk Storage 200 Gallons (Delvac 1230) Tank Turbine 55-Gallon Steel Plastic Pallet Lubricating Oil Drums ~220 Gallons 66 gallons Containment (DTE797) (~4 drums) Double walled Steel Storage (steel) with leak Kerosene 470 Gallons 485 gallons Container detection system. Double walled Steel Storage (steel) with leak Diesel Fuel 1000 Gallons 1100 gal Container detection system. Plastic, 55-gallon Steel portable drum Specialty Oils ~220 Gallons 68 gallons Drums (~4 drums) containment. Spill kit. 55-gallon Steel Steel Specialty Oils ~220 Gallons 279 gallons Drums (~4 drums) containment. Air Plastic, 55-gallon Steel Compressor ~210 Gallons portable drum 66 gallons Drums (~4 drums) Oil containment. (1) Only applicable containers are reflected in Table 2. Secondary containment calculations associated with process equipment is provided in Attachment 1. (2) Although the steel secondary containment cannot contain the discharge of the largest tank, contingencies are in place that would contain any excess oil released from the secondary containment. Specifically, the oil would be routed through the trench system and into the waste water basin or through the south drop and into the ash residue area which has the capacity to contain in excess of 23,000 gallons.
Covanta Hennepin Energy Resource Company Page 14 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 3.7 DEMONSTRATION OF IMPRACTICABILITY FOR DIVERSIONARY STRUCTURES OR CONTAINMENT [40 CFR 112.7(d)]
If you determine that the installation of any of the structures or pieces of equipment listed in paragraphs (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8 (c)(11), 112.9(c)(2), 112.10(c), 112.12 (c)(2), 112.12(c)(11), 112.13(c)(2) and 112.14(c) to prevent discharge as described in §112.1(b) from any onshore or offshore facility is not practical, you must clearly explain in your Plan why such measures are not practicable; for bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping; and, unless you have submitted a response plan under §112.20, provide in your Plan, the following: (1) An oil spill contingency plan following the provisions of part 109 of this chapter. (2) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.
The facility employs the use of appropriate secondary containment and equipment for discharge control.
The facility’s process equipment that is not considered to be oil storage devices includes the following: the turbine lube oil reservoir, two oil-filled transformers owned by CHERC, one oil-filled transformer owned by Hennepin County, two hydraulic skids associated with the grates, feeders and the ash dischargers and two hydraulic drives associated with the induced draft fans. The facility’s process equipment does have secondary containment with the exception of the Hennepin County-owned transformer and the two hydraulic drives associated with the induced draft fans. However, secondary containment is not required, since this equipment is not classified as oil storage containers. In addition, the hydraulic skids, the turbine reservoir, and the hydraulic drives associated with the induced draft fans have an alarm system that will alert operators if the oil level is low and there is a potential leak in the system.
3.8 INSPECTIONS AND RECORDS [40 CFR 112.7(e)]
Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for the purposes of this paragraph.
Covanta Hennepin Energy Resource Company Page 15 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Oil storage containers and drum storage areas are visually inspected on a daily basis by facility operators for signs of leaks or discharges, damage, or improper operation (only findings are documented). In addition, drum storage areas and the oil storage containers are formally inspected on a monthly basis by the Environmental Compliance Specialist (documented). Findings are documented using the Inspection Report form found in Appendix 2, discussed and resolved with management personnel. Copies of these inspection forms are maintained in a file located in the Environmental Compliance Specialist’s office. Additional confirmation of structural integrity of aboveground storage tanks is described in Section 5.2. Records of integrity testing are also maintained at the same file location.
3.9 PERSONNEL, TRAINING, and DISCHARGE PREVENTION PROCEDURES [40 CFR 112.7(f)]
Personnel Instructions [40 CFR 112.7(f)(1)]
At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules and regulations; general facility operations; and the contents of the SPCC Plan.
Affected personnel that handle oil are trained for successful implementation of this Plan. Personnel are instructed in the operation and maintenance of equipment to minimize the discharge of oils. Personnel are also trained on proper procedures for containment and clean up of small discharges and leaks, as well as discharge response procedures, the contents of this Plan, and other applicable pollution control laws, rules, and regulations. Personnel are trained or review this plan annually.
The annual training will include a briefing of any known discharges; failures, malfunctioning components or any recently developed precautionary measures. The person providing the briefing and the person that receives the briefing will certify that the briefing was conducted.
Designated Person Accountable for Discharge Prevention [40 CFR 112.7(f)(2)]
Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.
The Facility Manager is the designated person responsible for discharge prevention at the facility.
Covanta Hennepin Energy Resource Company Page 16 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Discharge Prevention Briefings [40 CFR 112.7(f)(3)]
Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in §112.1(b) or failures, malfunctioning components, or any recently developed precautionary measures.
Briefings are conducted in conjunction with the annual SPCC Plan training as discussed above.
3.10 SECURITY [40 CFR 112.7(g)(1-5)]
Fencing [40 CFR 112.7(g)(1)]
Fully fence each facility handling, processing, or storing oil, and lock and/or guard entrance gates when the facility is not in production or is unattended.
CHERC has installed a seven-foot high chain link fence that surrounds the entire facility and its operations. All gates are monitored via video camera or kept locked during non-business hours in which vehicles or people can enter/exit facility grounds. All incoming vehicles must either have a required entrance code or must check in with the control room operator before gaining access to the site.
Locked Flow Valves [40 CFR 112.7(g)(2)]
Ensure that the master flow and drain valves and any other valves permitting direct outward flow of the container’s contents to the surface have adequate security measures so that they remain in the closed position when in non-operating or non-standby status.
The facility‘s on-site oil storage devices are not equipped with master flow valves or drains that would allow the direct outward flow of containers contents to the surface, thus this section is not applicable.
Valves on bulk storage containers are “fail-close” valves. The drain valves located on process equipment are capped with bull plugs. During scheduled outages, all equipment that is not in use is locked out through the lockout/tagout program.
Locked Starter Controls [40 CFR 112.7(g)(3)]
Lock the starter control on each oil pump in the "off" position and locate it at a site accessible only to authorized personnel when the pump is in a non-operating or non-standby status.
One bulk storage container (DTE-25 located near the South Drop) has a permanently mounted pneumatic pump. The pump is located on top of the
Covanta Hennepin Energy Resource Company Page 17 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 container and the air is disconnected from the pump when not in use. The remaining bulk storage containers do not have permanently mounted pumps. If a pump is needed, it would be manually hooked up to the container and then disconnected after use.
Secure Capping of Loading/Unloading Connections [40 CFR 112.7(g)(4)]
Securely cap or blank-flange the loading/unloading connections of oil pipelines or facility piping when not in service or when in standby service for an extended time. This security practice also applies to piping that is emptied of liquid content either by draining or by inert gas pressure.
The facility does not have any oil pipelines from on-site storage devices or facility piping other than that associated with direct process equipment as described above. Fill lines associated with the bulk storage containers are capped when not in use. All drain valves associated with the process equipment are capped.
Adequate Lighting to Detect Discharges [40 CFR 112.7(g)(5)]
Provide facility lighting commensurate with the type and location of the facility that will assist in the: (i) Discovery of discharges occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.) and (ii) prevention of discharges occurring through acts of vandalism.
All areas of the plant are adequately lighted, and enclosed by the fencing described previously. The facility is normally in operation and is manned 24- hours per day, seven days per week.
3.11 TRUCK UNLOADING OPERATIONS [40 CFR 112.7(h)(1-3)]
Adequate Secondary Containment for Vehicles [40 CFR 112.7(h)(1)]
Where loading/unloading area drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading and unloading areas. You must design any containment system to hold at least maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility.
As outlined in Appendix A of 40 CFR 112, this requirement is not applicable when a commercial self-unloading vehicle enters our site and unloads to our tank. The requirements for the tank truck are governed by the Department of Transportation. All tank fill connections are either located within a containment area. The area in the vicinity of the mobile equipment refueling station is curbed/graded such that any appreciable spill will be contained such that the spill can be effectively cleaned-up prior to draining off site. All filling/refueling activities are manned by the vendor for the full duration of the operation.
Covanta Hennepin Energy Resource Company Page 18 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Warning Barrier System for Vehicles [40 CFR 112.7(h)(2)]
Provide an interlocked warning light or physical barrier system, warning signs, wheel chocks, or vehicle break interlock system in loading/unloading areas to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines.
Fuel oil delivery truck wheels will be chocked prior to unloading operations and removed after the delivery hose has been disconnected and just prior to departure.
Vehicles Examined for Drainage Outlets Before Leaving [40 CFR 112.7(h)(3)]
Prior to filling and departure of any tank car or tank truck, closely inspect the lowermost drain and all outlets of such vehicles, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit.
The bulk storage containers are filled from tank trucks as needed. The vendor has been instructed on the requirements of this Plan and must be present at all times during filling operations. Vehicles will be inspected by the vendor for leaks prior to departing the facility.
Facility personnel are present whenever possible to ensure proper unloading procedures are used and to verify the vendor is present at all times during filling operations.
3.12 BRITTLE FRACTURE EVALUATION [40 CFR 112.7(i)]
If a field-constructed aboveground container undergoes a repair, alteration, reconstruction or change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary take appropriate action.
There are no field-constructed storage tanks at the facility.
3.13 CONFORMANCE WITH ADDITIONAL STATE REQUIREMENTS [40 CFR 112.7(j)]
In addition to the minimal prevention standards listed under §112.7, include in your Plan, a complete discussion of conformance with the applicable requirements and other effective discharge prevention and containment procedures listed in this part or any applicable more stringent State rules, regulations and guidelines.
All spills greater than five gallons must be reported to the Minnesota Duty Officer. This includes any spills outdoors, even spills that occur inside containment areas,
Covanta Hennepin Energy Resource Company Page 19 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 areas, spills entering storm or sanitary sewer systems, spills with the potential to directly impact the environmental or human health – even if thought to be adequately contained.
All aboveground storage tanks (ASTs) greater than 110 gallons must be registered with the Minnesota Pollution Control Agency.
3.14 CONFORMANCE WITH GENERAL REQUIREMENTS [40 CFR 112.8(a)]
The general requirements (40 CFR Part 112.7) for the SPCC plan under the regulation have been met.
4.0 SPILL PREVENTION AND COUNTERMEASURE PROCEDURES
Spill prevention and control structures, such as containment structures, are present in oil storage areas at the facility to contain most discharges that could occur. The likelihood of a release is minimized by routine inspections, preventive operating practices such as good maintenance, security measures, and personnel training. However, should a release occur, a protocol has been established to notify appropriate plant management and regulatory agencies, and to respond to such discharges. Reporting and response procedures are outlined in the sections that follow.
4.1 SPILL (DISCHARGE) REPORTING PROCEDURES [40 CFR 112.7(a)(4)]
Unless you have submitted a response plan under §112.20, provide information and procedures in your Plan to enable a person reporting a discharge as described in §112.1(b) to relate information on the exact address or location and phone number of the facility; the date and time of the discharge; the type of material discharged; estimates of the quantity discharged as described in §112.1(b); the source of the discharge; a description of all affected media; the cause of the discharge; any damages or injuries caused by the discharge; actions being taken to stop, remove and mitigate the effects of the discharge; whether an evacuation may be needed and the names of the individuals and/or organizations who have also been contacted.
The facility is not required to submit a response plan under 112.20; therefore, the following section provides information and procedures for a person reporting a discharge to the appropriate agencies. A description of the “Discharge Response Organization,” as well as reporting and recordkeeping requirements is found in the following paragraphs.
DISCHARGE RESPONSE ORGANIZATION
The Discharge Response Coordinator is in charge of all discharge response activities and has the authority and training to mobilize the appropriate personnel and equipment in the event of a discharge. The Environmental Compliance Specialist will assume the role of the Discharge Response Coordinator. Upon discovery of a discharge, the plant employee(s) will immediately notify the Shift
Covanta Hennepin Energy Resource Company Page 20 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Supervisor. The Shift Supervisor will then call the Discharge Response Coordinator. If the Discharge Response Coordinator is not available, the on-call manager (Facility Manager, Chief Engineer, or Maintenance Manager) will be contacted, and become the alternate Discharge Response Coordinator.
If necessary, the Discharge Response Coordinator (or alternate) will provide immediate notification and follow-up written reports to the appropriate federal, state, and local agencies.
If there is an immediate or actual emergency, the Discharge Response Coordinator has the full authority needed to complete the activities listed in this Plan.
The Discharge Response Coordinator will be familiar with aspects of the SPCC Plan, which include the following:
x Reporting and response procedures;
x Facility operation and activities;
x Location and characteristics of petroleum products at the facility; and
x Location of discharge response equipment.
The Discharge Response Coordinator(s) will either be at the facility or on-call with the responsibility of coordinating the response measures.
Notification Requirements
x If a discharge poses a threat to human health and/or the environment, the Discharge Response Coordinator will notify the police, fire department or medical assistance, as needed.
x If any discharge reaches navigable water or the Sanitary Sewer System, the Discharge Response Coordinator will notify the following agencies, Covanta personnel and clean-up contractors as described in Table 3.
Table 3 Contact List
Agencies to be contacted in the event of a discharge Federal USEPA National Response Center (800) 424-8802 State Minnesota Duty Officer 651-649-5451 800-422-0798
Covanta Hennepin Energy Resource Company Page 21 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Metropolitan Council Environmental 651-602-4727 Services, Karalynn Marr Local Sheriff 911 Police 911 Fire Department 911 Cleanup Contractor(s) Bay West Environmental, 651-291-0456 St. Paul, Minnesota 800-279-0456 WCEC 763-571-4944 (office) Fridley, Minnesota 888-544-9481 952-980-3247 (all page) Covanta Personnel Work Phone Number Home Phone Number Daniel Fish 612-332-9428 612-508-0116 Durwin Fitch 612-332-9422 612-790-7316 Glenn Schmidt 612-332-9424 612-916-0170 Jeff Johnson 612-332-9425 612-750-1186
Contact the above corporate personnel until at least one person is contacted.
x Facility Management must be notified in all instances. Facility management will then notify the Minnesota Duty Officer and/or the Metropolitan Council Environmental Services.
x The Minnesota Duty Officer must be notified if discharged oil reaches the sanitary sewer or storm water system.
x As required by the Minnesota Pollution Control Agency, any discharge of five gallons or more outside the facility buildings must be reported to the Minnesota Duty Officer even if it does not reach a sanitary or storm water system.
x The National Response Center must be notified if a harmful quantity of oil reaches a sanitary sewer or storm water system. A harmful quantity is defined by the United States Environmental Protection Agency (USEPA) in 40 CFR 110 and 112, as a discharge which violates applicable water quality standards and/or one which causes a sheen, film, or discoloration of the water surface or adjoining shorelines. It also includes a discharge that may cause a sludge or emulsion to be deposited beneath the water surface or upon adjoining shorelines.
The Shift Supervisor will prepare the following information and provide it to the Discharge Response Coordinator before reporting a discharge:
x Exact facility name, address and phone number of the facility; x Date and time of the discharge; x Type of material discharged; x An estimate of the quantity of material discharged;
Covanta Hennepin Energy Resource Company Page 22 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 x The source of the discharge; x A description of all affected media; x The cause of the discharge; x Any damages or injuries caused by the discharge; x Any actions being taken to stop, remove and mitigate the effects of the discharge; x Whether evacuation is necessary; and x Names of individuals/organizations who have also been contacted.
Reports
A follow-up written report will be submitted to the USEPA and the Minnesota Pollution Control Agency within 60 days if a single discharge exceeds 1,000 gallons or the facility discharges oil in quantities greater than 42 gallons in each of two spill events within a twelve-month period. At a minimum, the written report will contain the following information:
1) Facility Name; 2) Owner/Operator’s Name; 3) Facility Location; 4) Name and address of registered agent of the owner, if any; 5) Maximum facility storage or handling capacity and normal daily throughput; 6) Corrective actions and countermeasures taken, including repairs or replacements; 7) Facility description, including maps, flow diagrams and topographical maps; 8) Cause(s) of such discharge(s), including a failure analysis of the system or subsystem in which failure occurred; 9) Additional preventive measures taken to minimize the possibility of reoccurrence; 10) Any other information required by the Regional Administrator.
Records
The Discharge Response Coordinator will keep a record of activities during the discharge event including the quantity of oil discharged, recovered, and disposed, a general assessment of environmental damage, and any other notable events, which may occur during the discharge and subsequent response activities. Upon completion of all activities, the Discharge Response Coordinator will complete an Environmental Incident Report Form (Appendix 4) and prepare a summary of the incident for entry into the SPCC Plan. Copies of the completed Incident Report Form will be submitted to the Environmental Compliance Specialist and maintained in facility central files.
Covanta Hennepin Energy Resource Company Page 23 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 4.2 SPILL (DISCHARGE) RESPONSE PROCEDURES [40 CFR 112.7(a)(5)]
Unless you have submitted a response plan under §112.20, organize portions of the Plan describing procedures you will use when a discharge occurs in a way that will make them readily usable in an emergency, and include appropriate supporting material as appendices.
In the event of a discharge, the following procedures will be followed
Response Procedures
x The employee(s) discovering the discharge will immediately stop work and, if appropriate, turn off any equipment in the affected area.
x The employee(s) will report the discharge to the Shift Supervisor or Control Room and evacuate to a safe area, if necessary.
x The Shift Supervisor will contact the Discharge Response Coordinator. If the Primary Coordinator is not available, an alternate will be contacted (in the order listed in Table 3).
x If the Discharge Response Coordinator or alternate is not available (nights, weekends, holidays), the Shift Supervisor will assume the role of the Discharge Response Coordinator.
x The Discharge Response Coordinator will designate an assistant, if necessary.
x The Discharge Response Coordinator or designee will proceed to the discharge area and set up a perimeter. If necessary, assistance from the outside agencies will be requested.
x Upon arrival, the Discharge Response Coordinator will assess the nature and extent of the release and the potential threat to human health and/or the environment.
x As necessary, the Discharge Response Coordinator will evacuate personnel, notify local authorities (911), and advise if area control or evacuation of the surrounding area is recommended or if medical assistance is required.
x The Shift Supervisor will take immediate action to control the discharge and to contain it within the Facility property line. A summary of discharge control equipment is found in Table 4.
x Should outside assistance be required to control the discharge, the Discharge Response Coordinator will contact the local fire department (911).
Covanta Hennepin Energy Resource Company Page 24 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Table 4 Summary of Discharge Control Equipment
The following equipment is maintained and can be used to contain and control discharges or leaks.
NUMBER EQUIPMENT LOCATION 20 Portable radios Assigned to Personnel on Shift 9 plus the Telephone Control Room Telephones Shift Supervisor Office located in the Crane Administration Maintenance Shop Building Supervisor Cell Phone Ice Box (Maintenance) 480 Room Scale House CEMS Shelter Administrative Offices NONE Public address system Floor Dry Absorbents Operation Floor – West End By Tool Crib Warehouse Absorbent Socks Warehouse Cooling Tower Spill Kit Turbine Drop Tipping Floor 2 Spill control kits Turbine Drop Tipping Floor Shovels ~20 Rakes and Shovels Various Locations Rakes ~4 Spares in Tool Crib 3 Front-end loader Ash House Ash Residue Area Tipping Floor 1 Skidster Ground Floor 1 Fork Lift Ground Floor 2 Portable pumps (Gas) Operation Floor (tool crib) Ground Floor 2 Portable pumps (Electric) Operation Floor (tool crib) Warehouse
x Should the discharge reach the storm sewer inlets, the Discharge Response Coordinator will authorize further action to stop the migration of the discharge. The Minnesota Duty Office is required to be notified of all releases to the storm sewer.
x Upon containment and control of the release, the Discharge Response Coordinator will direct the clean-up of the area.
x To the extent feasible, the discharge material will be recovered, reclaimed or
Covanta Hennepin Energy Resource Company Page 25 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 properly disposed. Materials such as absorbents and contaminated soil and water will be disposed of at an appropriate facility.
x The Discharge Response Coordinator or their alternate is also responsible for fulfilling the notification and recording requirements specified in Section 4.1, and Follow-up Actions listed below.
Follow-up Actions
x Return all response equipment and materials to their proper location and status.
x Review the discharge event, determine the cause of the release and take actions to prevent a recurrence under similar circumstances.
x Complete an Incident Report and submit to the Environmental Compliance Specialist.
5.0 DISCHARGE PREVENTION MEASURES
5.1 DRAINAGE CONTROL [112.8(b)]
Drainage from Diked Storage Areas [112.8(b)(1)]
Restrain drainage from diked storage areas by valves to prevent a discharge into the drainage system or facility effluent treatment system, except where facility systems are designed to control such discharge. You may empty diked areas by pumps or ejectors; however, you must manually activate these pumps or ejectors and must inspect the condition of the accumulation before starting, to ensure no oil will be discharged.
The ash residue area does not contain any valves. A manually activated pump pumps any water collected in this area into the facility for reuse. There are no drains or valves in this area – the only method to remove the water collected is through evaporation or a manually activated pump.
The storm sewer near the Turbine Drop has been closed off from the concrete roadway with curbing to prevent an oil release from entering the storm sewer. With the curbing in place, this area would serve as a collection point where oil would pool until it could be cleaned up. However, there are no valves in place to drain the area. The only method to remove water or a discharge that collected in this area is through evaporation or a manually activated pump.
Covanta Hennepin Energy Resource Company Page 26 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Valves Used on Diked Storage Areas [112.8(b)(2)]
Use valves of manual, open-and-closed design, for the drainage of diked areas. You may not use flapper-type drain valves to drain diked areas. If your facility drainage drains directly into a watercourse and not into an on-site wastewater treatment plant, you must inspect and may drain uncontaminated retained storm water, as provided in paragraphs (c)(3)(ii), (iii) and (iv) of this section (i.e., during drainage, the bypass valve should be opened and resealed under responsible supervision. Adequate records of such events should also be kept).
As indicated above, there are no valves on the diked areas. All storm water collected in the diked areas is manually pumped inside the facility or routed inside the facility via the trench system and reused.
Plant Drainage Systems from Undiked Areas [112.8(b)(3)]
Design facility drainage systems from undiked areas with a potential for a discharge (such as where piping is located outside containment walls or where tank truck discharges may occur outside the loading area) to flow into ponds, lagoons or catchment basins designed to retain oil or return it to the facility. You must not locate catchment basins in areas subject to periodic flooding.
All loading areas or filling areas (South Drop, Ash Residue Area, and the Turbine Drop) potentially exposed to oil releases are diked or designed to contain any oil released in these areas. In addition, storm water collected in these areas is pumped into the facility and reused to ensure the containment capacity of these areas is maintained.
Final Discharge of Drainage (Diversion Systems) [112.8(b)(4)]
If facility drainage is not engineered as in paragraph (b)(3) of this section, equip the final discharge of all ditches inside the facility with a diversion system that would, in the event of an uncontrolled discharge, retain oil in the facility.
Diked areas are not drained. This section is not applicable.
Facility Drainage Systems and Equipment [112.8(b)(5)]
Where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed, provide two "lift" pumps and permanently install at least one of the pumps. Whatever techniques you use, you must engineer facility drainage systems to prevent a discharge as described in §112.1(b) in case there is an equipment failure or human error at the facility.
Diked areas are not drained. This section is not applicable.
5.2 BULK STORAGE CONTAINERS [40 CFR 112.7(8)(c)]
Covanta Hennepin Energy Resource Company Page 27 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Container Compatibility with Contents [112.8(c)(1)]
Not use a container for the storage of oil unless its material and construction are compatible with the material stored and conditions of storage such as pressure and temperature.
Bulk storage containers, listed in Table 1, are constructed of appropriate materials for the storage contents and conditions of storage.
Diked Area Construction and Containment Volumes [112.8(c)(2)]
Construct all bulk storage container installations so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond.
Secondary containment is provided for bulk storage containers as listed on Table 1. The containment provided for each storage container or group of containers has sufficient volume to contain the volume of the largest in the group of containers. Regarding the 800-gallon container stored in the South Drop, the steel containment can hold up to 520 gallons. Any additional oil that is released would spill onto the floor and be routed to either the wastewater basin through the floor trenches or potentially through the South Drop in into the concrete containment area adjacent to the South Drop. In either case, the oil would be contained and could be cleanup accordingly. Secondary containment calculations for diked storage areas are provided as Appendix 1.
Diked Area, Inspection, and Drainage of Rainwater [112.8(c)(3)]
Not allow drainage of uncontaminated rainwater from the diked area into a storm drain or discharge of an effluent into an open water course, lake, or pond, bypassing the facility treatment system unless you: (i) Normally keep the bypass valve sealed closed. (ii) Inspect the retained rainwater to ensure that its presence will not cause a discharge as described in §112.1(b); (iii) Open the bypass valve and reseal it following drainage under responsible supervision. (iv) Keep adequate records of such events, for example any records required under permits issued in accordance with §§122.41(j)(2) and 122.41(m)(3) of this chapter.
Storm water collected in diked areas (ash residue area and the APC area) is routed back into the facility via pumps or trenches and reused in the ash dischargers.
Covanta Hennepin Energy Resource Company Page 28 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Corrosion Protection of Buried Metallic Storage Tanks [112.8(c)(4)]
Protect any completely buried metallic storage tank installed on or after January 10, 1974 from corrosion by coatings or cathodic protection compatible with local soil conditions. You must regularly leak test such completely buried metallic storage tanks.
There are no buried tanks for the storage of oil at the facility; therefore, this section is not applicable.
Corrosion Protection of Partially Buried Metallic Tanks [112.8(c)(5)]
Not use partially buried metallic or bunkered metallic tanks for the storage of oil, unless you protect the buried section of the tank from corrosion. You must protect partially buried and bunkered tanks from corrosion by coatings or cathodic protection compatible with local soil conditions.
There are no partially buried tanks for the storage of oil at the facility; therefore, this section is not applicable.
Periodic Integrity Testing of Aboveground Containers [112.8(c)(6)]
Test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skid-mounted, elevated, or partially buried.). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing. You must keep comparison records and you must also inspect the container’s supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices will suffice for the purposes of this paragraph.
Integrity testing is required for bulk storage containers. The following paragraphs describe the testing program that is applicable to the Facility’s bulk storage containers.
The double-walled diesel fuel tank (equipped with a leak detection system), the DTE-25 metal container and the double-walled kerosene tank (equipped with a leak detection system) for which there is little or no contact with the ground, pose minimal risk of internal corrosion and failure. As such, these tanks will receive random UT testing on a five-year interval and will be visually inspected at least on a monthly basis. 55-gallon drums and plastic containers/totes will be visually inspected at least monthly, but no integrity testing will be performed.
Electrical, operating and manufacturing equipment (such as transformers, turbine hydraulic oil reservoirs, stoker hydraulic oil reservoirs, etc.) are not bulk storage
Covanta Hennepin Energy Resource Company Page 29 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 containers, and as such are not subject to integrity test requirements. However, visual inspection of these types of equipment will be conducted at least monthly.
Control of Leakage through Internal Heating Coils [112.8(c)(7)]
Control leakage through defective internal heating coils by monitoring the steam return and exhaust lines for contamination from internal heating coils that discharge into an open watercourse, or pass the steam return or exhaust lines through a settling tank, skimmer, or other separation or retention system.
There are no oil storage containers that use internal heating coils at the facility; therefore, this section is not applicable.
Good Engineering Practice – Alarm Systems [112.8(c)(8)]
Engineer or update each container installation in accordance with good engineering practices to avoid discharges. You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid-level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauge and the pumping station. (iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation.
Currently two types of bulk storage containers are utilized at the facility. The first type is a semi-transparent plastic in which the level of the oil can be visually inspected with the naked eye. The second type of container is steel which is either double walled (kerosene/diesel) with a level detector or is single walled (DTE-25) with a sight glass. The levels on both tanks can be determined visually. Thus direct vision gauges are utilized as the method to prevent discharges. The bulk trucks that deliver diesel fuel and kerosene are equipped with a high liquid-level cutoff device and thus once the tanks are full, the filling operations cease.
The equipment that continuously uses oil (turbine, hydraulic skids and the hydraulic drives associated with induced draft fans) are equipped with low level alarms to alert the control room of the situation.
Observation of Wastewater Treatment Facilities for Oil-Contaminated Discharges [112.8(c)(9)]
Covanta Hennepin Energy Resource Company Page 30 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Observe effluent treatment facilities frequently enough to detect possible system upsets that could cause a discharge as described in §112.1(b).
Wastewater from miscellaneous washing operations and a limited number of floor drains is discharged to the sanitary sewer. Prior to discharge, the wastewater passes through an oil/water separator. The oil level in the oil/water separator is monitored via a direct vision gauge. The oil residue is pumped out as needed. Twice per year samples are collected from the discharge to the sanitary sewer and are analyzed for a host of parameters, including oil and grease.
Visible Oil Leak Corrections from Container Seams and Gaskets [112.8(c)(10)]
Promptly correct visible discharges which result in a loss of oil from the container, including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts. You must promptly remove any accumulated oil in diked areas.
As part of the monthly aboveground piping inspection and during routine facility walkdowns, any leaks from seams, gaskets, pumps, rivets or bolts will be identified and promptly corrected. Any accumulated oil will be collected and properly disposed as soon as it is identified.
Appropriate Positioning of Mobile or Portable Oil Storage Containers [112.8(c)(11)]
Position or locate mobile or portable oil storage containers to prevent a discharge as described in §112.1(b). You must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation.
Secondary containment is provided for all mobile or portable oil containers. Specialty oils are stored near the South Drop inside a stationary steel secondary containment or portable pallet containment devices. Similarly the lubricating oil for the air compressors is stored inside plastic pallet containment on the operating floor. All portable oil containers are required to be stored in designated areas with secondary containment when not in use.
5.3 FACILITY TRANSFER OPERATIONS [40 CFR 112.8(d)]
Buried Piping Installation Protection and Examination [40 CFR 112.8(d)(1)]
Covanta Hennepin Energy Resource Company Page 31 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Provide buried piping that is installed or replaced on or after August 16, 2002, with a protective wrapping and coating. You must also cathodically protect such buried piping installations or otherwise satisfy the corrosion protection standards for piping in 40 CFR Part 280 or a State program approved under Part 281. If a section of buried line is exposed for any reason, you must carefully inspect it for deterioration. If you find corrosion damage, you must undertake additional examination and corrective action as indicated by the magnitude of the damage.
Buried piping is not used for the transfer of oil products; therefore, this section is not applicable.
Terminal Connections [40 CFR 112.8(d)(2)]
Cap or blank-flange the terminal connection at the transfer point and mark it as to origin when piping is not in service or is in standby service for an extended time.
The facility does not have “not-in-service” or standby service terminal connections; therefore, this section is not applicable.
Pipe Supports Design [40 CFR 112.8(d)(3)]
Properly design pipe supports to minimize abrasion and corrosion and allow for expansion and contraction.
Piping supports are required to transfer oil associated with our hydraulic system. All piping is located inside the facility and was properly designed pursuant to applicable codes at the time of construction.
Aboveground Valve and Piping Examination [40 CFR 112.8(d)(4)]
Regularly inspect all aboveground valves, piping and appurtenances. During the inspection you must assess the general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. You must also conduct integrity and leak testing of buried piping at the time of installation, modification, construction, relocation, or replacement.
Aboveground piping and valves will be visually inspected at least monthly to confirm system integrity. In addition to identifying any leaks from piping, joints, or valves, observations will include determination of interference with other piping and equipment, excessive vibration, deflection or sag, and the general condition of supports, hangers, and guides. The proper position of system valves will also be confirmed. Any anomalies will be promptly corrected.
Aboveground Piping Protection from Vehicular Traffic [40 CFR 112.8(d)(5)]
Covanta Hennepin Energy Resource Company Page 32 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Warn all vehicles entering the facility to be sure that no vehicle will endanger aboveground piping or other oil transfer operations.
There is no aboveground piping that is impacted by vehicular traffic. This section is not applicable to this facility.
5.4 OTHER SECTIONS [40 CFR 112.9, 112.10, 112.11, 112.12, 112.13, 112.14 and 112.15]
These sections are not applicable to this facility.
6.0 SUBSTANTIAL HARM CRITERIA CHECKLIST 112.20(e)
Section 112.20(e) of the facility response plan regulation requires that all facilities regulated by the Oil Pollution Prevention regulation (40 CFR 112), conduct an initial screening to determine whether they are required to develop a facility response plan. The criteria in this checklist can be found in 40 CFR 112.20(f)(1).
The federal regulations provide an “Applicability of Substantial Harm Criteria Checklist” in 40 CFR 112.20(f)(1). These requirements have been placed in a checklist format. This checklist and an associated certification are found in Appendix 3 of this SPCC Plan. Based upon the completion of this checklist, it has been found that the facility is not required to prepare a facility response plan pursuant to 112.20(e).
7.0 RECOMMENDED DISCHARGE CONTROL IMPROVEMENTS
Covanta Hennepin Energy Resource Company Page 33 of 34 SPCC Plan 505 6th Avenue North REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 APPENDIX 1
SECONDARY CONTAINMENT CALCULATIONS FOR DIKED STORAGE AREAS
Total Container/ Container Length Width Height Diameter Volume Volume Volume Containment Name Location Measurements (inches) (inches) (inches) (inches) (cu. Inches) (gallons) Quantity (gallons) Outside 48.00 32.00 73.00 - 112,128.00 485.40 - 485.4 Near (double walled) Kerosene South Drop Inside Measurements Not Available, 470 Stamped on Container 470.00 - 470.0
Top Portion 330.00 34.50 6.00 - 68,310.00 295.71 - 295.7
Bottom Portion 330.00 34.00 6.00 - 67,320.00 291.43 - 291.4 Near Bulk Oil Container 1 South Drop Elevated, Insignificant Displacement 0.00 - 0.0 Containment Displacement Indoors Container 2 Elevated, Insignificant Displacement 0.00 - 0.0 Displacement Container 3 84.50 30.50 6.00 15,463.50 66.94 - (66.9) Displacement TOTAL 520.2
Container 1 Plastic Cylinder: 200 Gallons Stamped on Container 200.00 - 200.0
Near Container 2 Plastic Cylinder: 200 Gallons Stamped on Container 200.00 - 200.0 Bulk Oil South Drop Containers Indoors Outside Metal Square Container: Container Labeled 800 Gallons 800.00 - 800.0 Measurements Container 3 84.50 72.50 30.50 - 186,850.63 808.88 - 808.9
Covanta Hennepin Energy Resource Company APPENDIX 1 SPCC Plan 505 6th Avenue North Page 1 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 SECONDARY CONTAINMENT CALCULATIONS FOR DIKED STORAGE AREAS (continued)
Total Volume Container/ Container Length Width Height Diameter Volume Volume (gallons) Containment Name Location Measurements (inches) (inches) (inches) (inches) (cu. Inches) (gallons) Quantity Diesel Fuel Outside Near South Drop 120.00 46.00 46.00 - 253,920.00 1,100.0 - 1,100.0 Containers and (double walled) Containment Inside Name Plate: 1000 gallons 1000.00 - 1000.0
TOTAL 100.0 Steel Containment - 144.00 36.25 6.00 - 31,320.00 135.58 - 135.6 Near Top Portion Specialty Oils South Drop Steel Containment - 144.00 36.25 7.00 - 36,540.00 158.18 - 158.2 Containment Indoors Bottom Portion Displacement - - 6.00 12.00 678.24 2.94 5.00 (14.7)
TOTAL 279.1 Pallet Containment Specialty Oils South Drop 105.00 28.00 6.00 - 17,640.00 76.36 - 68.7 (See Note 2) Turbine Oil Crane Drop Pallet Containment Total Volume Per New Pig Specification Sticker: 66 Gallons 66.00 - 66.0
Compressor Oils Ops. Floor Pallet Containment Total Volume Per New Pig Specification Sticker: 66 Gallons 66.00 - 66.0
Outdoors Equipment Name Plate: 307 Gallons 307.00 - 307.0 Transformer 1 Outdoors Containment 186.00 144.00 4.00 - 107,136.00 463.79 - 463.8 HERC Outdoors Displacement 117.50 55.50 4.00 - 26,085.00 112.92 - (112.9)
TOTAL CONTAINMENT 350.9
Covanta Hennepin Energy Resource Company APPENDIX 1 SPCC Plan 505 6th Avenue North Page 2 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 SECONDARY CONTAINMENT CALCULATIONS FOR DIKED STORAGE AREAS (continued)
Total Container/ Container Length Width Height Diameter Volume Volume Volume Containment Name Location Measurements (inches) (inches) (inches) (inches) (cu. Inches) (gallons) Quantity (gallons) Outdoors Equipment Name Plate: 307 Gallons 307.00 - 307.0 Transformer 2 Outdoors Containment 180.00 144.00 4.00 - 103,680.00 448.83 - 448.8 HERC Outdoors Displacement 52.75 117.50 4.00 - 24,792.50 107.33 - (107.3)
TOTAL CONTAINMENT 341.5
Transformer 3 Outdoors Equipment Volume obtained from Xcel Energy 2,780.00 - 2,780.0 Hennepin County Outdoors No Containment 0.0
TOTAL CONTAINMENT 0.0
Crane Drop Equipment Volume obtained from Equipment Specifications 1,575.00 - 1,575.0
Turbine Reservoir Crane Drop Containment 163.50 144.00 11.00 - 258,984.00 1,121.14 - 1,121.1
Crane Drop Displacement 131.50 121.50 11.00 - 175,749.75 760.82 - (760.8)
TOTAL CONTAINMENT 360.3
Equipment Volume obtained from Equipment Specifications 132.00 - 132.0
Hydraulic Skid 1 Containment 56.00 84.00 2.75 - 12,936.00 56.00 - 56.0
Displacement Equipment Elevated, Assumed 10% Displacement 5.60 - (5.6)
TOTAL CONTAINMENT 50.4
Covanta Hennepin Energy Resource Company APPENDIX 1 SPCC Plan 505 6th Avenue North Page 3 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 SECONDARY CONTAINMENT CALCULATIONS FOR DIKED STORAGE AREAS (continued)
Total Container/ Container Length Width Height Diameter Volume Volume Volume Containment Name Location Measurements (inches) (inches) (inches) (inches) (cu. Inches) (gallons) Quantity (gallons) Equipment Volume obtained from Equipment Specifications 132.00 - 132.0
Hydraulic Skid 2 Containment 56.00 84.00 2.75 - 12,936.00 56.00 - 56.0
Displacement Equipment Elevated, Assumed 10% Displacement 5.60 - (5.6)
TOTAL CONTAINMENT 50.4
Covanta Hennepin Energy Resource Company APPENDIX 1 SPCC Plan 505 6th Avenue North Page 4 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 APPENDIX 2
MONTHLY FACILITY INSPECTION REPORT
This form is part of the weekly inspection form. At a minimum, this information is documented on a monthly basis. A final copy is placed in the SPCC documentation for compliance purposes. Findings are addressed monthly at the shift supervisors meetings. The facility manager, chief engineer, maintenance supervisor, business manager and the shift supervisors are given a copy of the environmental improvement list which summarizes all findings.
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Covanta Hennepin Energy Resource Company Appendix 2 SPCC Plan 505 6th Avenue North Page 1 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 +\GUDXOLFVNLGFRQWDLQPHQW +\GUDXOLFVNLGFRQWDLQPHQW 6DWHOOLWH$FFXPXODWLRQ$UHDV 2,/ 2SHUDWLRQV)ORRU8QLW 2SHUDWLRQV)ORRU8QLW 9LEUDWLQJ&RQYH\RU 7XUELQH5HVHUYRLU$UHD )HHGHU(QFORVXUHV
Covanta Hennepin Energy Resource Company Appendix 2 SPCC Plan 505 6th Avenue North Page 2 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Monthly Facility Inspection Report for Aboveground Storage Containers
Gauge Platform and Quadrant #1 ______
+
Covanta Hennepin Energy Resource Company Appendix 2 SPCC Plan 505 6th Avenue North Page 3 of 4 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 APPENDIX 3
CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA CHECKLIST
Section 112.20(e) of the facility response plan regulation requires that all facilities regulated by the Oil Pollution Prevention regulation (40 CFR 112), conduct an initial screening to determine whether they are required to develop a facility response plan. The criteria in this checklist can be found in 40 CFR 112.20(f)(1). Facilities should include this form with their SPCC plan.
Covanta Hennepin Energy Resource Company Appendix 3 SPCC Plan 505 6th Avenue North Page 1 of 2 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Certification of the Applicability of the Substantial Harm Criteria Facility Name: Covanta Hennepin Energy Resource Company, L.P. Facility Address: 505 6th Avenue North, Minneapolis, Minnesota 55405
Yes No 1. Does the facility transfer oil over water to or from vessels, and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? x 2. Does the facility have a total oil storage capacity greater than or equal to one million gallons, and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient x freeboard to allow for precipitation within any aboveground oil storage tank area? 3. Does the facility have a total oil storage capacity greater than or equal to one million gallons, and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula {1}) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, x see Appendices I, II, and III to DOC/NOAA’s "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (see Title 40 Part 112 Appendix E to this part, section 13, for availability) and the applicable Area Contingency Plan. 4. Does the facility have a total oil storage capacity greater than or equal to one million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula {1}) such that a x discharge from the facility would shut down a public drinking water intake {2}? 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil discharge in an amount x greater than or equal to 10,000 gallons within the last 5 years? Notes: {1} If a comparable formula is used documentation of the reliability and analytical soundness of the comparable formula must be attached to this form. {2} For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c).
CERTIFICATION
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete.
Name (please type or print) Durwin G. Fitch Signature
Title Facility Manager Date January 13, 2005
Covanta Hennepin Energy Resource Company Appendix 3 SPCC Plan 505 6th Avenue North Page 2 of 2 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 APPENDIX 4 NOTIFICATION FORM FOR REPORTABLE SPILL EVENTS
The Discharge Response Coordinator will complete the Incident Report attached for all reportable spills. The form will be completed prior to reporting the incident.
Covanta Hennepin Energy Resource Company Appendix 4 SPCC Plan 505 6th Avenue North Page 1 of 3 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 INCIDENT REPORT *****ATTACH SHEETS AS NECESSARY*****
NDPES/SDS Permits/MCES Permit/SPCC Requirements For: All reportable Releases: Releases of oil and prohibited materials outside the facility (contained or uncontained), to the storm sewer or to the sanitary sewer.
Covanta Hennepin Energy Resource Company 505 Sixth Avenue North Facility Information Minneapolis, Minnesota 55405 (612) 333-7303
Date and Time of the Event:
Event Description (Describe what caused the event and the source of the release):
Material Released:
Quantity Discharged:
Location of Release and all Affected Areas (Receiving Waters, Drains, etc.)
List of injuries and/or damage caused by the event:
Steps taken to reduce any adverse impact resulting from the event:
Covanta Hennepin Energy Resource Company Appendix 4 SPCC Plan 505 6th Avenue North Page 2 of 3 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 INCIDENT REPORT (continued) *****ATTACH SHEETS AS NECESSARY*****
Covanta Hennepin Energy Resource Company 505 Sixth Avenue North Facility Information Minneapolis, Minnesota 55405 (612) 333-7303 Date and Time of the Event:
Was the MPCA notified? Date, Time, Person Contacted
Indicate what information was provided to the MPCA.
Was the MN Duty Officer notified?
Date, Time, Person Contacted
Indicate what information was provided to the Duty Officer.
Was any other agency notified? Date, Time, Person Contacted
Indicate what information was provided.
Were any samples collected? Date, Time, Type, Quantity
Were any samples collected? Date, Time, Type, Quantity
Person Completing Report:
¾ NOTIFY ON-CALL MANAGER AND ENVIRONMENTAL COMPLIANCE SPECIALIST IMMEDIATELY OF NON-PERMITTED DISCHARGES (AFTER CONTAINMENT IS ACHIEVED).
Covanta Hennepin Energy Resource Company Appendix 4 SPCC Plan 505 6th Avenue North Page 3 of 3 REVISION DATE: 12/04/09 Minneapolis, MN 55405 REV. 5 Sample Received @ Biogenic Sample Date Lab Facility Region Sample # Beta # Composition Great 15-May-07 Hennepin Lakes Covanta Hennepin #1-Minnesota 230675 70.0% Great 15-May-07 Hennepin Lakes Covanta Hennepin #2-Minnesota 230676 71.0% Great 12-Jun-07 19-Jun-07 Hennepin Lakes 6/12/07 09:00-11:00 hours-Bag 1-Hennepin 231765 64.0% Great 12-Jun-07 19-Jun-07 Hennepin Lakes 6/12/07 09:00-11:00 hours-Bag2-Hennepin 231766 68.0% Great 10-Sep-07 14-Sep-07 Hennepin Lakes 9/10/07 09:00-15:00-HENNEPIN (MINNEAPOLIS)-A 234876 65.0% Great 10-Sep-07 14-Sep-07 Hennepin Lakes 9/10/07 09:00-15:00-HENNEPIN (MINNEAPOLIS)-B 234877 64.0% Great 24-Sep-07 25-Sep-07 Hennepin Lakes BAG A-9/24/07 10:00-15:30 HRS-HENNEPIN 235162 62.0% Great 24-Sep-07 25-Sep-07 Hennepin Lakes BAG B-9/24/07 10:00-15:30 HRS-HENNEPIN 235163 64.0% Great 10-Dec-07 13-Dec-07 Hennepin Lakes 12/10/07 10:00-15:30 hours-Hennepin 238747 65.0% Great 10-Dec-07 13-Dec-07 Hennepin Lakes 12/10/07 10:00-15:30 hours (1)-Hennepin 238748 62.0% Great 27-Mar-08 02-Apr-08 Hennepin Lakes HENNEPIN 3/27/08,0800-1430; 1-MINNEAPOLIS 243091 61.0% Great 27-Mar-08 02-Apr-08 Hennepin Lakes HENNEPIN 3/27/08,0800-1430; 2-MINNEAPOLIS 243092 65.0% Great 7-Apr-08 23-Apr-08 Hennepin Lakes Bag #1: 4/7/08 09:00- 4/10/08 14:30 hours: Hennepin 243844 63.0% Great 14-Jul-08 23-Apr-08 Hennepin Lakes Bag #2: 4/14/08 11:15- 4/17/08 15:00 hours: Hennepin 243845 63.0% Great 6-Aug-08 12-Aug-08 Hennepin Lakes Bag #1 8/4/08 09:00-8/6/08 8:30 Minneapolis 247862 62.0% Great 8-Aug-08 12-Aug-08 Hennepin Lakes Bag #2 8/6/08 10:15-8/8/08 09:00 Minneapolis 247863 62.0% Great 3-Oct-08 15-Oct-08 Hennepin Lakes Bag #1: 10/2/08 09:00-10/3/08 08:30-Minneapolis 250451 65.0% Sample Received @ Biogenic Sample Date Lab Facility Region Sample # Beta # Composition Great 7-Oct-08 15-Oct-08 Hennepin Lakes Bag #2: 10/6/08 08:00-10/7/08 09:00-Minneapolis 250452 66.0% Great 21-Oct-08 24-Oct-08 Hennepin Lakes BAG#1: 10/20/08 08:00-10/21/08 07:30-MINNEAPOLIS 250884 66.0% Great 22-Oct-08 24-Oct-08 Hennepin Lakes BAG#2: 10/21/08 08:00-10/22/08 07:30-MINNEAPOLIS 250885 63.0% Great 18-Nov-08 21-Nov-08 Hennepin Lakes Bag#1: 11/17/08 08:00-11/18/08 08:30 MINNEAPOLIS 252199 60.9% Great 16-Dec-08 19-Dec-08 Hennepin Lakes BAG#1 12/15/08 08:00-12/16/08 08:30-MINNEAPOLIS 253594 64.7% Great 17-Dec-08 19-Dec-08 Hennepin Lakes BAG#2 12/16/08 09:00-12/17/08 09:30- MINNEAPOLIS 253595 63.3% Great 12-Mar-09 18-Mar-09 Hennepin Lakes Hennepin: Bag#1: 3/11/09 08:00-3/12/09 08:30 hours 257341 63% Great 13-Mar-09 18-Mar-09 Hennepin Lakes Hennepin: Bag#2: 3/12/09 09:00-3/13/09 09:30 hours 257342 63% Great 24-Jun-09 29-Jun-09 Hennepin Lakes HENNEPIN-BAG#1: 6/23/09 08:00-6/24/09 08:30 hours 261390 65% Great 25-Jun-09 29-Jun-09 Hennepin Lakes HENNEPIN-BAG #2: 6/24/09 09:00-6/25/09 09:30 hours 261391 62% Great 2-Sep-09 17-Sep-09 Hennepin Lakes Hennepin: Bag#1: 9/1/09 08:00-9/2/09 08:30 hours 264607 64% Great 3-Sep-09 17-Sep-09 Hennepin Lakes Hennepin: Bag #2: 9/2/09 09:00-9/3/09 09:30 hours 264608 66% Great 12-Nov-09 17-Nov-09 Hennepin Lakes Hennepin: Bag #1 11/11/09 08:00 - 11/12/09 08:30 hours 268938 64% Great 13-Nov-09 17-Nov-09 Hennepin Lakes Hennepin: Bag #2 11/12/09 09:00 - 11/13/09 09:30 hours 268939 65% Great 11-Mar-10 22-Mar-10 Hennepin Lakes HENNEPIN: Bag#2: 03/10/10 09:00-03/11/10 09:30 277295 65 % Great 10-Mar-10 22-Mar-10 Hennepin Lakes HENNEPIN: Bag#1: 03/09/10 08:00-03/10/10 08:30 277294 Damaged Bag Average 64.3%