Onondaga County Resource Recovery Facility Title V Renewal Draft Permit
Fact Sheet, Statement of Basis, Draft Permit and Complete Notice
All major facilities as defined by the federal Clean Air Act must obtain Title V operating permits. The Onondaga County Resource Recovery Facility (OCRRF) is a major facility under the Clean Air Act; it was issued its initial Title V operating permit on March 24, 2003. That permit is now up for renewal.
Background and History
The Onondaga County Resource Recovery Facility (OCRRF) is a 990 ton per day waste-to-energy facility that operates 24 hours per day 365 days per year. The OCRRF consists of three independent mass burn combustors with boilers, each with a design capacity of 330 tons per day. Refuse is delivered to the OCRRF in standard packer trucks and transfer vehicles for combustion at temperatures exceeding 1800 degrees Farenheight. Refuse is reduced by approximately 90% in volume in the combustion process. The ash residue is disposed of at a landfill. Heat energy generated in the combustion process is utilized to produce electricity in a 39.5 megawatt turbine generator. This electricity provides power to the OCRRF and the excess is sold to a power reseller or broker. Auxiliary burners using natural gas are utilized during periods of startup, shutdown and at other times when the minimum combustion zone temperatures would not otherwise be met.
Air pollution control includes dry scrubbers for acid gas control, fabric filters for particulate removal, a selective non-catalytic reduction system for nitrogen oxide control and a carbon injection system for mercury control.
What's in the Draft Permit
Except for the items discussed below, the existing limits for the plant remain the same. Continuous monitoring of certain pollutants and operating parameters such as operating temperatures will continue. The facility is required to conduct annual compliance stack testing for several contaminants. All stack testing must be conducted using a DEC-approved test protocol and the annual stack test report must be received by the DEC within 120 days of completion of testing. The facility must also continue to submit Title V semi-annual monitoring reports and annual compliance reports to the DEC.
A certified or provisionally-certified shift supervisor or chief facility operator must be on site during all times of operation. All personnel involved in the operation of the facility must receive annual training relevant to their job duties at the plant. This includes, but is not limited to, chief facility operators, shift supervisors, control room operators, ash handlers, maintenance personnel and crane/load handlers. The facility must maintain and update a facility operating manual detailing specifics of operation of the facility
Modifications to the Draft Permit
In 2002 the mercury concentration emission limit for OCCRF was reduced from 80 ug/dscm (dry standard cubic meter) to 28 ug/dscm when DEC adopted lower mercury limits throughout the state. The draft permit includes a corresponding decrease in the mercury mass emission limit (from 0.0182 to 0.004 lb/hr).
Zinc emissions are not regulated under Federal incinerator rules; however, DEC regulates zinc emissions from the OCRRF. The draft permit requires the collection of additional stack test data for zinc emissions and a recalculation of the zinc emission limit based on the additional data obtained. At no time will zinc emissions be allowed to exceed the level used in OCRRF's Health Risk Assessment.
The draft permit clarifies that the limit for particulate matter less than 10 microns in size, commonly referred to as "PM-10 Emissions," is based solely on filterable emissions; condensable particulate matter is not counted towards the permit limit. However, the permit requires that condensable PM-10 be sampled annually and that a total PM-10 emission limit be established at the end of the permit term.
The draft permit discontinues the requirement for continuous ammonia stack monitoring at the OCRRF. Ammonia emissions at the facility have been well below the maximum limit of 50 ppm. Annual stack testing for ammonia emission will still be required. Also, additional monitoring and reporting requirements governing the operation of the ammonia injection system have been added to the draft permit. These requirements will continue to ensure proper operation of the ammonia injection system, which reduces emissions of nitrogen oxides from the facility.
Recent amendments to the Federal emission guideline standard for incineration facilities have been incorporated into the draft permit where such revisions yield additional or more restrictive requirements or standards. For the OCRRF, current permit limits are as or more stringent than the revised Federal rule with the exception of sulfur dioxide, which has been reduced in the draft permit to the federal standard (from 30 to 29 ppm).
Public Comment Period
This permit will undergo a 30-day public comment period which ends on June 26, 2009 or thirty days after the publication date of the notice of complete application in the newspaper, whichever is later. Written comments should be directed to Joanne L. March at NYSDEC, Division of Environmental Permits, 615 Erie Blvd. West, Syracuse, NY 13204; or firstname.lastname@example.org. The draft permit can be accessed at the link below or one may contact the DEC Region 7 Office in Syracuse, 615 Erie Blvd. West, Syracuse, NY, 13204.
All comments received during the 30-day public comment period beginning on May 25, 2009 will be reviewed. In addition, the DEC will evaluate the permit renewal application and the comments received on it to determine whether to hold a public hearing. After completion of the public review process, the DEC will draft a Responsiveness Summary to all comments received and will forward a Proposed Title V Permit reflecting public comments received to the Environmental Protection Agency (EPA) for a 45 day EPA review period. After receipt of EPA review, or after the 45 day period ends, the DEC will make a final determination and issue a final Renewal Title V operating permit based on EPA's review.