Document ppwm790ENmmRqkrDeD66xx7OD

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY New England Regional Laboratory Laboratory Services and Applied Science Division 11 Technology Drive, North Chelmsford, MA 01863 Report Memorandum Drafted: Finalized: 09/08/2021 09/28/2021 Subject: From: Stack Emission Testing Observations - William Osbahr, Stack Testing Coordinator, /WAO/ Field Services Branch (FSB) Tyler Kotsifas, Stack Testing Coordinator (Trainee), FSB /TLK/ Through: Jerry Keefe, Investigations Team Leader, FSB /JCK/ To: Christine Sansevero, Chief, Air Compliance Section Enforcement and Compliance Assurance Division Facility Information: A. Facility Name: Wakefield Municipal Gas and Light Department B. Facility Location: 443 Salem Street, Wakefield, MA 01880 C. Facility Contact: Dave Polson, Plant Representative (781) 812-8128 # D. ICIS-Air #: MA0000002511903918 Background Information: A. Date of test: 8/19/21 B. US EPA Representative: William Osbahr, Tyler Kotsifas C. Federally Enforceable Requirements Investigated: 40 CFR Part 60 Subpart JJJJ Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not Page 1 of 3 make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Attendees Name William Osbahr Tyler Kotsifas David Caron Justin Coleman Chris Lydon Kurt Bode Role/Title Stack Testing Coordinator Stack Testing Coordinator (Trainee) Stack Tester Project Manager Stack Tester Technician Generator Technician Plant Operator Organization US EPA US EPA Montrose Air Quality Services Montrose Air Quality Services Milton CAT Wakefield Gas and Light Department Background: The purpose of this memorandum is to provide a summary of EPA representatives Mr. Osbahr and Mr. Kotsifas observations during August 19, 2021 emissions test of two spark ignition engines located at the Wakefield Municipal Gas and Light Department (WMGLD). The facility is subject to the emissions requirement under 40 CFR Part 60 Subpart JJJJ. Test Observation Notes: US EPA representatives arrived at the facility at 7:30 am on 8/19/21. The Inspectors presented their credentials and informed Mr. Bode, the plant operator for WMGLD they were there to observe emission testing A list of attendees was recorded which is the same as the one listed above. Mr. Caron of Montrose was the primary sampling system operator, with assistance from Mr. Coleman. Generator 2 Testing Mr. Caron performed a pretest calibration of Montrose's CEM system prior to testing. US EPA representatives observed the results of the initial calibrations. Initial calibrations were observed to be acceptable by US EPA representatives. Subsequent calibrations would be recorded and included in the emissions test report. The first test run took place from 9:15-10:15 am. The second test run took place from 11:10-12:10 pm. The third test run took place from 12:30-1:30 pm. Page 2 of 3 For all three runs, a post run pitot tube leak checks were witnessed by EPA and passed method requirements. Moisture sample train post run leak checks passed, however, not until a final review of the techniques utilized by Mr. Caron could be assessed after the third run. Moisture for the three runs were as follows. Run 1 15.2% Run 2 15.3% Run 3 14.6% Testing operating parameters for the generator were recorded by Mr. Lydon of Milton CAT. Throughout the test period Generator 2 sustained 95-97% full load. Load data was recorded every 12 minutes. Generator 1 Testing Generator 1 could not be tested as the existing stack test port cap was frozen in place. Generator 1 testing will take place without EPA observation at a later date. Testing data for generator 1 will be documented in the final report. Inspectors Osbahr and Kotsifas left the facility at approximately 1:45 pm. Page 3 of 3