1999 CPEO Brownfields List Archive

Date: Tue, 24 Aug 1999 11:06:57 -0700 (PDT)
Reply: cpeo-brownfields
Subject: Re: Request for Advise, Insight, Comment on LocatingWoodBurningPower Plant in Urban Industrial Area

A few additional thoughts based on your response to John's comments:

1.  State of the art on emissions from the stack will depend to some
degree on what's expected from the chipped pallets.  A baghouse is
likely state of the art for particulate emissions, and you should expect
better than 98% removal efficiency.  NOx controls will likely depend on
selective catalytic reduction, although the issue of low NOx burners
should be addressed.  Removal efficiencies have gotten quite high on
SCR, but there are always concerns about ammonia slip and balancing
the reaction.  Metals should be picked up with the particulates in the
baghouse.  Some HAPs will be picked up by the particulates and
deposited in the baghouse.  IF there are other constituents on the pallets,
you may need an oxidizer.  Again removal efficiencies are pretty good. 
The key may be to either test burn some pallets from the expected
sources and see what the emissions are; or to limit the input to clean
pallets so that the emissions are predictable.  The limits will be set in the
air permit.

The issue of construction waste raises additional concern.  There can
be two flavors here -- construction waste consisting of wood scrap; or
construction debris, which consists of wood scrap, demolition materials,
etc.  Either can include plywood and other materials that would have
potential HAPs.  Debris often includes painted or other "finished"
materials, which increases risk of HAP emissions (lead paint residues,
varnish or similar finishes, etc.).     Mixed construction waste may
require that the facility be treated as a waste disposal site rather than
recycling.   It's best to insist on pre-sorted waste.  If you will sort on
the facility at least needs to qualify as a transfer facility, and that
requires more room, normally an enclosed sorting area, and some
arrangement to dispose or transfer unacceptable materials.

Amtrack facilities are notorious for oil contaminated soils and PCB
contamination, as well as potential asbestos and solvent contamination. 
Paving the area ("capping") is a recognized remedy to prevent continued
precipitation inflow from moving the contaminants, but it may or may not
be acceptable as a complete remedy for the site, and there may be
monitoring or other requirements if the contamination has already hit

Neighbors will be concerned about at least the following issues:  truck
traffic to bring waste; what wastes will be tipped and sorted (concerns
about vermin, storage, enclosed areas, etc.); air emissions; remediation
of the underlying site; dust and related controls; noise (from trucks,
grinders or chippers, conveyers, turbines and other equipment), hours of
operation (nobody likes big trucks at very early hours....).

Best regards

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