Document N837637bKOwy64G6xbDbDQVy

DATE: UNITED STATES ENV1RONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604 OCT 1 6 2019 SUBJECT: FROM: CLEAN AIR ACT INSPECTION REPORT Covanta Indianapolis, Inc., Indianapolis, Indiana Charles Hall, Environmental Engineer c__)+Jj AECAB (MN/OH) THRU: Brian Dickens, Section Chief AECAB (MN/OH) TO: File, Covanta Indianapolis, Inc., Indianapolis, Indiana BASIC INFORMATION Facility Name: Covanta Indianapolis, Inc. Facility Location: 2320 South Harding Street, Indianapolis, Indiana Date of Inspection: 24 September 2019 EPA Inspector: 1. Charles Hall, Environmental Engineer Other Attendees: 1. George Drew, Regional Environmental Manager 2. Jeffrey Hom, Facility Manager (closing conference only) 3. Austin Jarvis, Enviromnental Specialist Contact Email Address: ajarvis@covanta.com Purpose of Inspection: inspection of three large municipal waste combustors Facility Type: large municipal waste combustor Regulations Central to Inspection: Indiana's Clean Air Act Section 11 l(d) Plan for Existing Large Municipal Waste Combustors and the definition of modification in Section 129 of the Clean Air Act. Arrival Time: 1330 hrs EDT Departure Time: 1600 hrs EDT 1 of 4 Inspection Type: ISi Unannounced Inspection Announced Inspection l8l Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from Drew and Jarvis unless otherwise noted. Process Description: Municipal solid waste is unloaded from packer trucks into a solid waste pit. Covanta fills the feed hopper to one of the three 726-ton per day mass bum waterwall municipal waste combustion (MWC) units at the Facility. Each MWC unit has a steam load operating limit of 212,000 pounds of steam per hour. The air pollution control train for each MWC unit consists of a spray dryer absorber that injects a lime slurry into the stream of combustion gases, an activated carbon injection system, a fabric filter, and a selective non-catalytic reduction unit. Each pulse jet fabric filter has ten compartments with 270 PTFE riton-coated bags. Each MWC unit is equipped with continuous emission monitors (CEM) for carbon monoxide, nitrogen oxides, oxygen, and sulfur dioxide and a continuous opacity monitor (COM). Covanta also installed in-line backup CEMs and COMs. Each MWC unit is equipped with a liquid direct injection (LDI) system with which Covanta feeds: I, Ink wash, latex paint wash, fermentation broth, and solid waste landfill leachate; 2, Water soluble oil-based coolants and metal working fluids that do not meet the definition of used oil; or 3, Rinsate from empty non-hazardous Federal Insecticide, Fw1gicide, and Rodenticide Act pesticide containers. Each MWC unit is equipped with two 140 million British thermal unit per hour natural gas-fired burners used for start-up, shutdown, and flame stabilization. Construction of each MWC unit commenced in 1988. Staff Interview: The interview focused on the subject of modification. Drew noted that Covanta has analyzed whether it has modified the MWC units at other Covanta-owned facilities. The availability of documents for the original construction and the subsequent replacement of major components is one difficulty that Covanta has found in its analyses of some of the Covanta-owned MWCs in EPA 's Region I. Drew acknowledged that Covanta replaces each superheater every 2 to 3 years while other major components have service lives of 15 to 20 years. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: During the inspection, the inspector collected the following emission and operating data summarized in Tables I and 2: 2of4 Table I. Summary of Carbon Monoxide (CO), Opacity, Oxides of Nitrogen (NOx) and Sulfur Dioxide (SO,) Emission Data Pollutant Limit 1 2 3 CO (4-hour block average) 100 nnmV 17 51 21 Onacitv (6-minute average) 10% 0 0 0 NOx (24-hour block average) 205 nnmV 161 167 126 SO2 (24-hour geometric average) 29 ppmV or 9 2 7 20% of potential 88.9% 99.6% 96.6% em1ss10ns Table 2. Summary of Operating Parameter Limit Data OneratinP Parameter Limit 1 Steam Load 212.0 !<lbs/hr 194.5 klbs/hr Sorbent Feed Rate 26 lbs/hr 26 lbs/hr Carbon Feed Rate 18.0 lbs/hr 20.0 lbs/hr Inlet Temperature 329F 305F 2 177.3 klbs/hr 26 lbs/hr 20.0 lbs/hr 306F "_, 193.3 klbs/hr 26 lbs/hr 20.0 lbs/hr 304F Photos and/or Videos: were not taken during this inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW Covanta provided a summary of the 2018 performance tests for cadmium, dioxin/furan, hydrogen chloride, lead. mercury and particulate matter. Table 3 summarizes the results of the 2018 performance tests. Table 3. Summary of2018 Performance Tests. 2018 Performance Pollutant Unit of Measure Test Avera es Ul U2 U3 Cadmium g/dscm @ 7% 02 1.57 0 39 0.64 Dioxin/Furan1 ng TEQ/dscm@ 7% O, NT NT 0.78 Hydroven Chloride ppmV@7%O, 1.41 3.8 3.64 Lead g/dscm @ 7% 02 12.20 3.60 5.50 Mercurv g/dscm @ 7% O, 0.48 0.50 0.44 Particulate Matter mg/dscm @ 7% 02 9.82 2.85 6.44 Emission Standards in 40 C.F.R. Part 60 Subpart Cb Subpart Eb 35 10 30 13 29 25 400 140 50 50 25 20 CLOSING CONFERENCE Requested Documents: Diagram of each MWC Unit and monitoring locations; 1 NT= Not tested this year due to alternating test schedule. 3 of 4  Copy of the refresher training manual's table of contents; and Results of the most recent performance tests for D/F, Cd, Pb, Hg, opacity PM, CO, HCJ, and fugitive emissions from ash handling. Concerns: The primary concern is whether Covanta has modified, as defined in Section l 2.9(2:)(3),, anv of the MWC units at the Facil.itv since EPA_ nromuhrated the Standards of Performance for Large Municipal Waste Combustors for Which Construction is Commenced After September 20, 1994 or for Which Modification or Reconstruction is Commenced After June 19, 1996, 40 C.F.R. Part 60, Subpart Eb. SIGNATURES Lead Inspector: Section Chief: ,1 n-i~. ,_. ,_ I\ r1 -~~\~ .J~ -J= ~ ~/t-i)J-l-;l- - - - - - Date: ~v.I~i,<{)Yt=,:iv"-I'lif--\',=-'--.J..u""-ko----'--'-./1.4-'-------- Date: l -;;. QJ:..-k '2. 0 l C\ Id/l(fi; I!Cf 4 of 4