|From:||CHARLES PATRIZIA <CAPATRIZIA@phjw.com>|
|Date:||Tue, 24 Aug 1999 11:06:57 -0700 (PDT)|
|Subject:||Re: Request for Advise, Insight, Comment on LocatingWoodBurningPower Plant in Urban Industrial Area|
Emery: 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 site, 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 groundwater. 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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