Fvrd Requirements - Burnaby Incinerator Operational Certificate - Final 686224

This document contains the Fraser Valley Regional District’s comments in response to the Notice of Intent to Issue Operational Certificate 10751 under the provisions of the Environmental Management Act.

Required Amendments to the Burnaby Incinerator Operational Certificate December 20, 2014

Environmental Services Department Fraser Valley Regional District

Required Amendments to the Burnaby Incinerator Operational Certificate Part 1 - Introduction and Overarching Comments The FVRD has carefully reviewed the Draft Operational Certificate for the Burnaby Incinerator issued November 22, 2013 (dated November 21, 2013). The version received is attached in Appendix 1. Notably, there was no Site Plan A drawing depicting locations of stacks and monitoring ports included in the Draft Operational Certificate, yet it was referenced in that document. Follow up communication with Chris Allan of Metro Vancouver (November 29, 2013 and December 2, 2013) provided a general overview of the facility, as well as a schematic of the facility. However, this schematic did not include details alluded to in the Draft Operational Certificate, such as reference numbers for discharges. Thus, we found the Draft Operational Certificate to be incomplete. There are a number of comments on the content of the Draft Operational Certificate, detailed in Part 2 of this submission. We assert that several requirements be added to the text of the Operational Certificate, and have displayed the requirements in boxes for ease of reading. These requirements are based on review of international best practice or expert recommendation, and are referenced in the relevant section. As indicated, comments and requirements relating to specific sections of the Draft Operational Certificate follow in Part 2 of this document. The following overarching requirements apply to the overall Operational Certificate: There must be an accessible public website to display information pertaining to the operation and environmental performance of the Burnaby Incinerator. Requirement 1: a. An easily accessible public website (hereafter called “the public website” must be created to report on all emissions data collected (continuous emissions monitoring systems data, stack test data, etc.), as well as other notifications such as maintenance reports, emergency situations, fuel load inspection reports, and other information, as well as the Operational Certificate itself. The public website must include, at a minimum, all of the specific items required in this submission, including but not limited to:  Soil monitoring program annual report  Water monitoring program annual report  Vegetation monitoring program annual report  Food monitoring program annual report  Fauna monitoring program annual report  Human biomonitoring program annual report  Real-time continuous emissions monitoring systems (CEMS) and temperature data  Quality Assurance/Quality Control (QA/QC) procedures for CEMS data  Annual review of CEMS technology  Notification of response limits being reached (CEMS) and action plan  Stack sampling results  Notification of stack sampling exceedance and action plan FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Air pollution control devices – manufacturer’s specifications Air pollution control devices – maintenance and inspection reports Air pollution control devices – best available technology review for particulate matter and other emissions  Emergency generator information – type of generator, hours used per year and reason, emissions characteristics  Description and quantity of water conditioners used annually  Weekly fuel load inspection reports  Laboratory analytical results for fuel loads  Standards for fuel loads (both bulk substances and analytical standards)  Notification of discharge beyond the property boundary  Process modification notice  All inspection and maintenance reports  Remedial action reports for maintenance deficiencies  Biannual complete facility inspection by a Waste to Energy Expert – audit report  Emergency situation notification and remedial action reports  Ash reporting – analytical test results, summary of quantity of fly ash and bottom ash disposed of at specified facilities  Fuel use reporting (number and mass of loads incinerated on a weekly, monthly, annual basis)  Operational data – startups, shut downs, period of upset and hours of each activity per boiler  MSW and natural gas fuel consumption  Environmental Management System document  Emergency Response Plan document  Review of secondary combustion zone temperature requirements for destroying trace organics  Overall annual report summarizing all of this information b. All information posted to the public website must be done in a timely manner (requirements for each type of information are given in the comments and requirements of the individual sections) and must remain posted throughout the entire operating life of the Burnaby Incinerator. All documents must be posted on the public website for the duration of the operational life of the Burnaby Incinerator. Even if a report becomes outdated (i.e. the Environmental Management System document that must be updated annually), it must still be available on the public website as long as the facility is still operating. A overall report on emissions, inspections, maintenance, accidents, and shut downs must be prepared annually, and posted on the public website. Requirement 2: a. An annual public report (hereafter called “the annual report” must be completed and posted on the public website by March 31 of the year following the report year. b. The annual emissions summary report must include, at a minimum, all of the specific items required throughout this submission, including but not limited to those outlined in Requirement 1. All testing and inspections must be conducted by qualified independent third parties to prevent conflict of interest when assessing and reporting information. Independent third parties are not

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simply third parties hired by the Operational Certificate Holder or Burnaby Incinerator Operator; they are hired by and able to the BC Ministry of Environment. Maintenance, sampling and audits will be performed on an unscheduled basis, that is they will be unannounced, such that the Operational Certificate Holder and Operator cannot specifically prepare for the relevant test. This type of unannounced auditing and testing is in place in many other facilities and workplaces (such as restaurants, which can be inspected at any time) to ensure compliance at all times with the applicable regulations. Requirement 3: a. All stack tests, fuel load inspections, maintenance inspections, and any other specific items outlined in this submission must be conducted by qualified and independent third parties. b. All reports on the individual actions (such as maintenance inspections) as well as annual reports summarizing all facility activity, must clearly identify the independent qualified third party, and must clearly demonstrate how they are qualified to perform the work. Requirement 4: Audits, including for any of the work conducted by qualified independent third parties, such as stack testers, maintenance workers, inspectors, etc. may be conducted at any time, without notice. As has been included in the individual requirements detailed in Part 2 of this submission, the consequences of failing to comply with the conditions of the Operational Certificate are not written in the Draft Operational Certificate, and must be before it can be implemented. Further, these consequences must be meaningful and represent significant financial penalties to the Certificate Holder and Operator, such that compliance is ensured. Requirement 5: The consequences of failing to comply with the conditions of the Operational Certificate must be clearly written within each section of the Operational Certificate, and must be significant to ensure compliance. There are no provisions for soil monitoring, water monitoring, vegetation monitoring, food product monitoring (particularly for bovine milk) or human biomonitoring in this Draft Operational Certificate, all of which are critical components of a gold standard monitoring program and have been done at various incinerators around the world, as outlined in the Jacques Whitford 2009 review.1 Many of the programs were conducted in advance of the facilities’ initial startup (as was done for soil and vegetation monitoring at the Burnaby Incinerator), however, many of the international examples provided in the Jacques Whitford review did conduct additional monitoring many years or decades after facilities started operating. As an example, an air and soil sampling study conducted in Italy near three municipal solid waste (MSW) incinerators was carried out more than twenty-five years after some of the facilities started operating, underscoring that soil sampling after an incinerator has been in place for quite some time has

1

Jacques Whitford. Final Report: Review of International Best Practices of Environmental Surveillance for Energy-From-Waste Facilities. 2009. Available from: http://www.metrovancouver.org/services/solidwaste/planning/ReportsforQA/InternationalBestPracticesEn ergyfromWasteFacilities.pdf FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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been studied elsewhere.2 In the case of the Burnaby Incinerator, it is good that there is some baseline data on soil and vegetation characteristics before the facility was operational, and nearly 26 years after it has been in place, we require that additional monitoring be conducted to determine how contaminants in soil, water, vegetation, and food have changed over time. We also request that a human biomonitoring framework be developed and carried out, as has been done for other facilities around the world. The FVRD’s overarching comment is that the polluter must demonstrate that they are not adversely affecting human health and the environment. The onus is on the polluter to conduct as much monitoring as possible on as many parameters as possible, to determine the impact of their facility on the surrounding environment. It is not acceptable to assume that no impact has been had on soil, vegetation, water, food products, or public health without rigorous monitoring and evaluation to confirm. The long-term impacts of the Burnaby Incinerator, in operation since 1988, can and must now be evaluated in a detailed manner. Soil and vegetation testing was conducted around the Burnaby Incinerator from 1987 (before the facility became operational) to 1990, two years after it became operational.3 The monitoring was then discontinued. It is not known what impact the facility has on soil and vegetation currently, or what the trend over time has been due to this lack of information. At present, soil and vegetation monitoring should be reinstituted, to determine how contaminant levels in soil and vegetation now compare to those before the incinerator was in operation. A great deal of food is grown within Metro Vancouver, in regions such as Richmond and Delta, and in the Fraser Valley, downwind of Metro Vancouver. Further, many types of fish, particularly salmon, are an important food source for First Nations and non-First Nations residents of the Lower Fraser Valley. Dioxins and furans, pollutants emitted from the incinerator, tend to bioaccumulate, and a major exposure route for people is crops, dairy products, meat, and fish. No testing on food products produced in the region has been done to determine if these pollutants are found in elevated concentrations in the food we are eating, and must be done to determine the extent of this exposure.

2

Caserini S, Cernuschi S, Giugliano M, Grosso M, Lonati G, Mattaini P. Air and soil dioxin levels at three sites in Itality in proximity to MSW incineration plants. Chemosphere. 2004;54(9);1279-87. 3 Greater Vancouver Regional District. Burnaby Incinerator: Summary of Soil and Vegetation Monitoring Data. 1992. Available from: http://www.metrovancouver.org/services/solidwaste/planning/ReportsforQA/BurnabyIncineratorSummaryo fMonitoringData.pdf FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Requirement 6: a. A comprehensive soil monitoring program must be developed and carried out starting in 2014, and repeated on an annual basis. b. The soil monitoring program must be carried out by a qualified independent third party. c. The soil monitoring program should incorporate elements detailed in the “Green Book”4 developed in 1986 for the Burnaby Incinerator, as well as best practice outlined in the Jacques Whitford 2009 review. This includes, but is not limited to: soil chemistry parameters in the surface soil horizon (0-5 cm depth, 5-10cm depth), mid-soil (10-25 cm depth), and bottom soil (25-60 cm depth). Dustfall must also be measured. d. At a minimum, the following soil chemistry parameters must be monitored in accordance with the previous Burnaby Incinerator soil and vegetation monitoring program, and in accordance with vegetation monitoring programs around other facilities: arsenic, beryllium, cium, chromium, lead, mercury, manganese, nickel, selenium, thallium, vanadium, fluoride, sulphur, polychlorinated biphenyls (PCBs), polyaromatic hydrocarbons (PAHs), and dioxins and furans. e. Annual reporting must be included in the overall annual report and posted on the public website. f. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Requirement 7: a. A comprehensive water quality monitoring program (groundwater and surface water) must be developed and carried out starting in 2014, and repeated on an annual basis. The environmental surveillance program, including water quality monitoring, in Portugal such as at the LIPOR II incinerator, can be reviewed for precedent. b. Annual reporting must be included in the overall annual report and posted on the public website. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. Requirement 8: a. A comprehensive vegetation and crop-monitoring program must be developed and carried out starting in 2014, and repeated on an annual basis. b. The vegetation monitoring program should incorporate elements detailed in the “Green Book”4 developed in 1986 for the Burnaby Incinerator. This includes, but is not limited to: leaf tissue chemistry, root tissue chemistry, fruit tissue chemistry, forage metals, forage fluoride, premature demolition, leaf chlorosis, leaf necrosis. c. At a minimum, the following parameters must be monitored in accordance with the previous Burnaby Incinerator soil and vegetation monitoring program, and in accordance with vegetation monitoring programs around other facilities: arsenic, beryllium, cium, chromium, lead, mercury, manganese, nickel, selenium, thallium, vanadium, fluoride, sulphur, PCBs, PAHs, and dioxins and furans. d. Annual reporting must be included in the overall annual report and posted on the public website. e. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. 4

Khare et al. Assessment and Recommendations on Emission and Monitoring Requirements for Greater Vancouver Regional District Incinerator Located in Burnaby. 1986. FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Requirement 9: a. A food monitoring program on, at minimum bovine milk and farmed meat (including but not limited to: poultry, pork, beef, lamb) must be developed and carried out starting in 2014, and repeated on an annual basis. b. At a minimum, the following parameters must be measured in milk and meat produced in the Lower Fraser Valley, to be consistent with the soil and vegetation monitoring program: arsenic, beryllium, cium, chromium, lead, mercury, manganese, nickel, selenium, thallium, vanadium, fluoride, sulphur, PCBs, PAHs, and dioxins and furans. c. Annual reporting must be included in the overall annual report and posted on the public website. d. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Requirement 10: a. A fauna monitoring program for fish and wildlife must be developed and carried out starting in 2014, and repeated on an annual basis. The environmental surveillance program, including wildlife and fish tissue monitoring, at the Swan Hills Treatment Centre can be reviewed for precedent.5 b. Annual reporting must be included in the overall annual report and posted on the public website. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Requirement 11: a. A human biomonitoring program must be developed and carried out starting in 2014, and repeated on an annual basis. The monitoring program should be developed and carried out in conjunction with health agencies (such as the Fraser Health Authority). b. Blood, urine, breast milk, and hair samples from residents living near the Burnaby Incinerator, as well as a control group should be tested for the following parameters, at a minimum: dioxins and furans, PCBs, PAHs, metals (antimony, arsenic, beryllium, cium, chromium, cobalt, copper, lead, manganese, mercury, nickel, selenium, thallium, tin, vanadium, and zinc) and any metabolites. There are many precedent reports referenced in the Jacques Whitford 2009 review. c. Annual reporting must be included in the overall annual report and posted on the public website. d. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

5

Alberta Health and Wellness. Swan Hills Treatment Centre: Long-term follow-up health assessment program (1997-2002) . 2004. Available from: http://www.health.alberta.ca/documents/SwanHills-Report-2004.pdf FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Part 2 - Specific Comments on the Draft Operational Certificate Comments and requirements on specific sections of the Draft Operational Certificate for the Burnaby Incinerator are listed below. Information quoted directly from the Draft Operational Certificate is distinguished by quotation marks and is in italics. Subsection 1.1 Mass Burn Incinerators/Boilers Subsection 1.1.3 discusses the characteristics of discharge. There are a number of issues with the section, including: there are many parameters that should be measured that are missing from the list, and most if not all of those parameters can and must be measured by Continuous Emissions Monitoring Systems (CEMS).6 As is highlighted in Section 3.3 – Discharge Monitoring for Subsection 1.1 in the Draft Operational Certificate, many of the parameters on the list that are currently measured by manual stack testing and proposed to continue that way, are measured only once per year, or some up to three times per year. Testing is conducted on a scheduled basis during normal operating conditions, when everything is functioning properly. This provides a very brief snapshot into the overall annual emissions. Where technology exists to monitor emissions continuously, it must be done. The fact that manual stack testing is only conducted once per year for many of the contaminants most concerning to human health, including dioxins, furans, chlorobenzenes, chlorophenols, polychlorinated biphenyls, and polycyclic aromatic hydrocarbons is truly alarming. How do Metro Vancouver and the people of Metro Vancouver and Fraser Valley (which share an airshed with this facility) know that these measurements represent average concentrations? In this monitoring scheme, there is no way to determine when peak emissions occur, how frequently they occur, and how high they are when there is one measurement done per year. Stack tests are presently conducted three times per year for total particulate matter (TPM), trace metals (including cium and mercury), total hydrocarbons, hydrogen chloride (HCl), hydrogen fluoride (HF), sulphur dioxide (SO2) and nitrous oxide (N2O), which also gives a very blurry snapshot into the emissions patterns of these pollutants. There is no way of knowing whether these sparse measurements represent average, low or high concentrations, because there is simply not enough data collected to compare. What will the emission levels be the other 362+ days in the year? It is not likely these spot measurements are representative of annual emissions considering the variability of waste which feeds the incinerator. People are exposed to emissions on an ongoing basis and to fluctuating levels of contaminants, not just to the quantity emitted on the day of a pre-advised stack test. In addition, incineration creates emissions containing many unidentified chemical compounds of unknown toxicity, which are not monitored or regulated. It is imperative that CEMS monitoring data is posted during all operating periods, especially startup, shut down, and upset periods. These are times when emissions are likely to be significantly different than during normal operation, most likely considerably higher. One study conducted by the United States Environmental Protection Agency found that emissions of PCDD/F (dioxins and furans) during startup, shut down, and other upset conditions, was one to two orders of magnitude greater than during normal operations (ten to one hundred times 6

United States Environmental Protection Agency. Environmental Technology Verification Program. 2013. Available from: http://www.epa.gov/etv/vrvs.html#amsca FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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greater).7 Without continuous monitoring during these periods, we do now know if a similar pattern is occurring at the Burnaby facility. CEMS data must be posted on the public website in real time. Quality Assurance/Quality Control procedures for the data shall be conducted in accordance with a documented method acceptable to the Director, and posted on the public website. CEMS data shall undergo QA/QC within seven days of measurement. Total particulate matter (TPM) is listed in Section 1.1.3, but PM10 and PM2.5 must to be included as well. These are parameters that the Burnaby Incinerator reports to Environment Canada’s National Pollutant Release Inventory (NPRI) each year.8 The 2012 reporter comments in the NPRI submission for PM10 and PM2.5 state, “Changes in estimation methods is due to a change in results (concentration levels) from the latest manual stack tests.” which suggests that the Operator is testing for these parameters already, they are just not currently required in their Operational Certificate and are therefore not reported to the BC Ministry of Environment. There is an incredible volume of peer-reviewed literate on the adverse health effects of PM10, PM2.5 and smaller particles, and as those two fractions have ambient air quality standards in BC9, it is necessary that PM10 and PM2.5 are added to section 1.1.3 of the Operational Certificate. It is not sufficient to monitor only TPM, as larger particles dominate the concentration measured by mass, yet it is the smaller particles (PM10 and PM2.5) are the ones that travel deeper into the respiratory tract, and have a more significant health impact. The BC Ministry of Environment must also propose discharge limits for PM10 and PM2.5 from the Burnaby Incinerator. Ultrafine particles (UFP), those with an aerodynamic diameter less than 1 or 0.1 µm (depending on which definition you look at), while not regulated currently, should also be measured for informational purposes. This monitoring will be useful when potentially determining future emission limits of this size fraction. There are a number of metals that are referenced as being measured by other municipal solid waste incinerators around the world as noted in the Stantec 2011 and Jacques Whitford 2009 review which are not included in the Burnaby Incinerator’s Draft Operational Certificate, a clear indication that facility is not following best practice. These additional metals include: antimony, beryllium, cobalt, copper, manganese, nickel, selenium, tellurium, thallium, tin, vanadium, and zinc. The Burnaby Incinerator’s own soil and vegetation monitoring program summary from 1992 also measured selenium in soil and vegetation, so it should be measured in air as well. Carbon dioxide and methane, as greenhouse gases causing climate change, must be measured. Technology exists to measure these substances in real time and therefore to get accurate measurements of actual emissions, instead of estimating emissions using calculations and assumptions at the end of the year for NPRI reporting. Further, some of the emissions limits proposed in the Draft Operational Certificate for the substances that are there are not in line with the most stringent standards in the world. The Ministry of Environment’s own commissioned review, conducted by Stantec in 2011 states that NOX emissions limits in Austria and Sweden are 70 mg/dscm, whereas the number listed in the 7

Gullett B, Touati A, Oudejans L, Ryan S, Tabor D. Transient PCDD and PCDF Concentrations in an MWC. Organohalogen Compounds. 2006:68;143-6. 8 Greater Vancouver Sewerage and Drainage District: Metro Vancouver Waste to Energy Facility. National Pollutant Release Inventory. 2013. Available from: http://ec.gc.ca/inrp-npri/donneesdata/index.cfm?do=facility_substance_summary&lang=en&opt_npri_id=0000000362&opt_report_year=20 11#cac 9 BC Ministry of Environment. British Columbia Ambient Air Quality Objectives. 2013. Available from: http://www.bcairquality.ca/reports/pdfs/aqotable.pdf FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Draft Operational Certificate is 350 mg/dscm changing to 190 mg/dscm on December 31, 2014. It is evident that a comprehensive review of worldwide emissions limits is required, or at least that the strictest limits included in the review that exists are actually used. Careful scrutiny of emissions limits for all substances currently listed on the discharge table in Section 1.1.3 and all new substances listed in Requirement 12 is required. Temperature in the secondary combustion zone should also be continuously monitored and posted on the public website in real time. Finally, there are a number of additional parameters that can and should be measured by CEMS technology. Although there is not a precedent set for monitoring these parameters at other incineration facilities, the technology exists to measure these substances and the FVRD expects these to be routinely monitored or regularly quantified, to determine what amount is being emitted. As the Stantec 2011 review report quoted, the Province of British Columbia’s Strategic Plan 2010/11 – 2012/13 includes this as one of its five great goals for a golden decade: “Lead the world in sustainable environmental management, with the best air and water quality, and the best fisheries management, bar none.”10 These substances should be measured so that it is known what their emissions are, as at the current time, there is no information on their emissions despite the Burnaby Incinerator being in operation since 1988. To be in line with achieving the best air and water quality in the world, emissions from polluters must be measured as comprehensively as possible. It is acknowledged that some of these parameters are covered by other groupings of parameters (i.e. total volatile organic compounds are covered by total organic compounds, benzene is a volatile organic compound, etc.), but the more measurements that are collected, the more information on the emissions from this facility will be available. Requirement 12: a. The following parameters must be added to the discharge monitoring table:  Antimony  Beryllium  Cobalt  Copper  Manganese  Nickel  Selenium  Thallium  Tin  Vanadium  Zinc  Carbon Dioxide (CO2)  Methane (CH4)  PM10  PM2.5 b. A comprehensive review on emissions limits for substances already listed on the Draft Operational Certificate under Section 1.1.3 and those listed above in Requirement 12 must be completed by the Ministry of Environment. Emissions limits for all of these substances must be determined by the Ministry, and must be equal to, or more strict 10

Province of British Columbia. Strategic Plan 2010/11-2012/13. http://www.bcbudget.gov.bc.ca/2010/stplan/2010_Strategic_Plan.pdf FVRD Requirements Burnaby Incinerator Draft Operational Certificate

2010.

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from:

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than, the strictest standards in the world. As was pointed out earlier, some of the proposed emissions limits (i.e. for NOX) are multiple times higher on the Draft Operational Certificate than at other facilities around the world, as stated in the Stantec 2011 review. c. Ultrafine particles (both PM1 and PM0.1) must be measured, but there does not need to be a discharge limit put in place at present. d. The following parameters should be routinely monitored or quantified in some way:  Acetaldehyde (C2H4O)  Acethylene (C2H2)  Ammonia (NH3)  Benzene (C6H6)  Bromine (Br2)  Carbon disulphide (CS2)  Chlorine (Cl2)  Ethane (C2H6)  Ethanol (C2H6O)  Ethene (C2H4)  Ethylbenzene (C6H5C2H5)  Formaldehyde (HCHO)  Hydrogen bromide (HBr)  Hydrogen cyanide (CHN2)  Hydrogen sulphide (H2S)  Metanol (CH4O)  Naftalene (C10H8)  Nitrous acid (HNO2)  Nitrous oxide (N2O)  Ozone (O3)  Phenol (C6H5OH)  Phosgene (COCl2)  Propane (C3H8)  Sulphur trioxide (SO3)  Toluene (C7H8)  Total hydrocarbons (THC)  Total Volatile Organic Compounds (TVOCs) Further, according to the FVRD’s findings on the United States Environmental Protection Agency Environmental Technology Verification Program website, most, if not all of the parameters outlined in requirement 12 as well as in the Draft Operational Certificate can be measured by CEMS technology of some form. All substances for which CEMS technology exists must be measured by that technology. For any parameter that cannot be measured by CEMS, or if the level of quantification is insufficient, stack testing in accordance with the comments and requirements listed in Section 3.3 must be followed. As part of the annual report, CEMS technology for all parameters measured must be reviewed every year. The Operational Certificate Holder must implement the best available monitoring technology for each measured parameter that exists. As the Site Plan A document provided was incomplete, it is unclear exactly how many discharge stacks there are at the Burnaby Incinerator emitting air contaminants. It is understood there is one main stack with three flues, plus additional discharge sites (activated carbon silo, fly ash

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silo, etc). All discharge ports must be sampled in accordance with the requirements spelled out in this submission, that is, if there is more than one stack emitting discharge into the air, all stacks must have CEMS for all parameters installed, and all stacks must be stack sampled, if that is required for certain parameters.

Requirement 13: a. All of the parameters included in the discharge table in Section 1.1.3 of the Draft Operational Certificate and listed in requirement 12 above must be measured by CEMS technology if it exists, at the finest resolution possible. All data must also calculate a rolling 30-minute average, to be compared with response limits (shown in the able in section 1.1.3), if that resolution is available. If that resolution is not available, the most finely temporally resolved averaging period must be used. Data for all parameters must be available for 97% of the time or more on an annual basis, in accordance with the requirements of the European Commission’s Waste Incineration Directive11 (page 11, point 3 of the Draft Operational Certificate must be amended to 97%). This may require duplication of CEMS to ensure that data completeness requirement is met. To be clear, the following parameters must be monitored by CEMS:  Total particulate matter (TPM)  Opacity  Carbon Monoxide (CO)  Hydrogen chloride (HCl)  Hydrogen fluoride (HF)  Sulphur dioxide (SO2)  Nitrogen oxides (NOx)  Total organic carbon (TOC)  Total dioxins and furans (PCDD/F as TEQ)  Cium  Mercury  Lead  Arsenic  Chromium  Chlorophenols  Chlorobenzenes  Polycyclic aromatic hydrocarbons (PAHs)  Polyclorinated biphenyls (PCBs)  Antimony  Beryllium  Cobalt  Copper  Manganese  Nickel  Selenium  Thallium  Tin  Vanadium 11

Directive 2000/76/EC of the European Parliament and of the Council. 2008. Available from: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2000L0076:20081211:EN:PDF FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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b.

c. d.

e.

 Zinc  Carbon Dioxide (CO2)  Methane (CH4)  PM10  PM2.5  Ultrafine particles (PM1 and PM0.1)  Temperature The following parameters should be measured by CEMS or routinely monitored in some way specified in the Operational Certificate.  Acetaldehyde (C2H4O)  Acethylene (C2H2)  Ammonia (NH3)  Benzene (C6H6)  Bromine (Br2)  Carbon disulphide (CS2)  Chlorine (Cl2)  Ethane (C2H6)  Ethanol (C2H6O)  Ethene (C2H4)  Ethylbenzene (C6H5C2H5)  Formaldehyde (HCHO)  Hydrogen bromide (HBr)  Hydrogen cyanide (CHN2)  Hydrogen sulphide (H2S)  Metanol (CH4O)  Naftalene (C10H8)  Nitrous acid (HNO2)  Nitrous oxide (N2O)  Ozone (O3)  Phenol (C6H5OH)  Phosgene (COCl2)  Propane (C3H8)  Sulphur trioxide (SO3)  Toluene (C7H8)  Total hydrocarbons (THC)  Total Volatile Organic Compounds (TVOCs) All CEMS data must be posted in real time on the public website. Quality Assurance/Quality Control (QA/QC) procedures for the data shall be conducted in accordance with a documented method acceptable to the Director, and posted on the public website. CEMS data shall undergo QA/QC within seven days of measurement. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. Consequences should involve serious financial penalty or facility shut down.

All CEMS devices and procedures must be approved by the Regional Director, such that they are subject to performance, reliability, and maintenance requirements. These should follow those of the United States Environmental Protection Agency or European Commission’s Waste Incineration Directive.

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Requirement 14: a. All CEMS devices and procedures must be authorized by the Director, following guidance of the United States Environmental Protection Agency or European Commission’s Waste Incineration Directive. Details of all systems and approval must be posted on the public website. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. Requirement 15: a. In the overall annual report, a review of the most current CEMS technology must be presented for all substances measured. If improved methods of contaminant measurement are available, those technologies must be adopted those technologies within the next two years. If CEMS technology for substances currently tested for by stack tests or other methods become available, adopt those technologies within the next year. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

On page 2, note 4 of the Draft Operational Certificate states, “Response limits are the threshold requiring the Operational Certificate Holder to take immediate action to bring down the discharge levels to the applicable discharge limits specified in this section…” Documented, immediate action taken must be posted on the public website promptly. A summary of these instances must also be included in the annual report. Requirement 16: a. Actions taken immediately at the time the response limit is reached must be posted in writing on the public website within 12 hours of the response limit being reached and updated as more information becomes available. b. A summary of these instances must also be included in the annual report. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 1.1.4 The section reads, “The Operational Certificate Holder shall ensure that under no circumstances Municipal Solid Waste (MSW) is continued to be fed to an incinerator/boiler when an authorized parameter response limit is exceeded for a period of more than four (4) hours uninterrupted per parameter per unit; moreover the cumulative duration of operation in such conditions over one calendar year shall be less than 60 hours per parameter per unit.”

There must be clear, significant consequences for annual exceedances reaching above 60 hours. It is suggested that a significant financial penalty be applied in such a case. FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Requirement 17: Consequences of failure to comply with Section 1.1.4 must include a significant financial penalty, clearly outlined in the Operational Certificate. What about any substances that are not continuously monitored? What are the consequences of failure to adhere to the emissions limits? Requirement 18: a. Any exceedance from a manual stack test must be fully investigated immediately upon receipt of results and the investigation detailed on the public website, as well as included in the annual report. Once the facility has made changes to achieve compliance, two independent tests conducted by different qualified independent third parties must be completed within 24 hours of facility startup, the analyses rushed, and results reported on the public website. b. Consequences of failure to comply: two consecutive failures per parameter per unit will result in entire facility shut down and remedial changes being made, which must be approved by the Director before the facility can restart. All must be reported on the public website and in the annual report.

Section 1.2.3 The Draft Operational Certificate mentions water conditioning additives for pH and algae growth control as part of the discharge. The types and quantities of these additives used must be reported. Requirement 19: a. The description and quantities of all water conditioning additives used in the facility must be presented in the annual report. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 1.3.3, 1.4.3, 1.5.3 (note: section 1.5.3 is written 1.4.3 a second time in the Draft Operational Certificate) The Draft Operational Certificate reads, “The discharge point shall be equipped with a fully functional particulate matter filter.” How is fully functional defined? To what standard are filters held? The Operator must use the best available control technology, and must annually review best available control technology, and deploy that technology when it is available. Requirement 20: a. A fully functional particulate matter filter is defined as the best available control technology, operating in accordance with the manufacturer’s specifications. b. Maintenance and verification of performance must be conducted in accordance with the

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manufacturer’s instructions, which must be posted on the public website. This must be performed by a qualified independent third party. A summary of the maintenance and inspection must be posted on the public website within seven days of the inspection. c. Annually, a review of best available air pollution control (APC) technology for particulate matter must be conducted. This assessment must be included in the annual monitoring report. The Burnaby Incinerator must implement best available control technology when it comes available, within one year of reporting it in the annual monitoring report. d. Annually, a review of best available APC technology for all other air emissions must be conducted. This assessment must be included in the annual monitoring report. The Burnaby Incinerator must implement best available control technology when it comes available, within one year of reporting it in the annual monitoring report. e. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 1.6.1 and 1.6.2 Regarding the Emergency Power Generator, the Draft Operational certificate states, “The authorized discharge period is 500 hours per annum.” “The characteristics of the discharge shall be equivalent to or better than typical emissions from the type of engine in-place at the facility.”  Requirement 21: a. Emergency generator startup and reason for use must be posted on the website within 12 hours of starting the generator. Number of hours per use must be reported on the public website within two hours of the generator being shut down. Total hours of use must be reported in the annual report. b. The type of generator must also be reported on the public website and in the annual report. Annually, emissions measurements from the generator must be collected and compared with typical emissions from that type of engine based on published emissions factors, to demonstrate that the characteristics of its discharge are better or equivalent to typical emissions from that type of engine. c. These measurements and comparison must be conducted by a qualified independent third party, and the report must be posted on the public website. This information must also be summarized in the annual monitoring report. d. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.1 Authorized Fuels In accordance with Metro Vancouver’s 2010 Integrated Solid Waste and Resource Management document (“A Solid Waste Management Plan for the Greater Vancouver Regional District and Member Municipalities”),12 the overarching goals of Metro Vancouver’s solid waste management are: Goal 1: Minimize waste generation 12 Metro Vancouver. 2010. Integrated Solid Waste and Resource Management - a Solid Waste Management Plan for the Greater Vancouver Regional District and Member Municipalities. Available online: http://www.metrovancouver.org/about/publications/Publications/ISWRMP.pdf

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Goal 2: Maximize reuse, recycling and material recovery Further, the plan includes the 5R hierarchical resource management principles amongst its guiding principles which are: reduce waste at the source, reuse where possible, recycle products at the end of their useful life, recover energy or materials from the waste stream, and manage residuals in an environmentally sound manner. Metro Vancouver must follow these principles, which means maximizing reuse, recycling, and material recovery before recovering energy from the remaining waste. Incineration of reusable, recyclable, and recoverable materials must be prohibited, and clearly stated in the Operational Certificate of the Burnaby Incinerator. The list of authorized fuels in the Draft Operational Certificate should be rewritten to more specifically prohibit incineration of recyclable materials (such as already in place with the term, “non-recyclable wood waste”). The list of authorized fuels must be adhered to, and consequences of non-compliance with this requirement be clear and strict, as it violates the BC Ministry of Environment approved solid waste management plan. In addition to the list of authorized fuels, there should be a list of unauthorized fuels, requirement for frequent independent third party inspection of fuel loads to ensure compliance with the authorized and unauthorized fuel lists, and reporting requirements for these inspections. Non-recyclable EPR material must be listed as an unauthorized fuel because allowing it to be incinerated is a disincentive to improve packaging design. Further, international airline waste and international marine waste must be specified in the authorized fuels list, that is, the specific elements of those types of waste must be outlined. As it is written, those statements are vague and open the possibility that wastes that should not be incinerated will be under those loose . Biosolids, wastewater treatment plant residuals, and pharmaceuticals as banned landfill materials, should also not be combusted in an incinerator. To be clear, MSW combusted in the Burnaby Incinerator must not contain reusable, recyclable, or recoverable material. One option to prevent this is to send all MSW received to a mixed waste material recovery facility to remove all reusable, recyclable, or recoverable material. Requirement 22: The list of authorized fuels in the Operational Certificate should be rewritten as follows: • MSW from residential, industrial/commercial/institutional (ICI), and construction and demolition sources containing no reusable, recyclable, or recoverable materials • Non-anatomical hospital waste • Non-recyclable or non-compostable wood waste • Noxious weeds • Invasive Plants • Drug seizures containing no reusable, recyclable, or recoverable materials • Seized and counterfeit goods containing no reusable, recyclable, or recoverable materials • Casino tokens containing no reusable, recyclable, or recoverable materials  

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The following items were listed as authorized fuels in the Draft Operating Certificate: • International airline waste • International marine waste • Cruise ship waste Details on what exactly constitutes “international airline waste,” “international marine waste” and “cruise ship waste” must be provided. Once those details are provided, they should be placed under either authorized or unauthorized fuels in the Operational Certificate, which list will depend on what the materials are. No reusable, recyclable, or recoverable materials may be included.

Requirement 23: a. Include an unauthorized fuels list with the following items on it, in accordance with Metro Vancouver’s own landfill bans, including but not limited to13:  corrugated cardboard  recyclable paper  green waste (kitchen scraps, yard waste, etc.)  containers made from glass, metal, or recyclable plastic (1,2,4,5)  all beverage containers  agricultural waste  asbestos and asbestos-containing material  automobile bodies and parts  batteries, including lead acid batteries  barrels or drums of any size  biomedical waste  dead animals  electronics and electrical products  excrement, waste water treatment plant residuals and screenings, Biosolids  fluorescent lights  gypsum  hazardous waste  hospital office waste  inert fill materials (soil, sod, gravel, concrete, asphalt)  liquids and sludge  mattresses  oil containers (filers, paint products, solvents, flammable liquids)  metal household or commercial appliances  pesticide products  pharmaceuticals  propane tanks  radioactive waste  thermostats  tires  recyclable wood waste  recyclable and non-recyclable EPR material 13

Metro Vancouver. Banned from Landfills. 2013. Available from: http://www.metrovancouver.org/services/solidwaste/disposal/Pages/bannedmaterials.aspx FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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b. Inspections on fuel coming to the facility must conducted by an independent third party on every load coming to the facility to ensure that only authorized fuels are being incinerated, and that unauthorized fuels are not being incinerated. c. A load of fuel shall be determined compliant in composition if it contains items listed as authorized fuel only. The Operational Certificate must specify the percentage of unauthorized material permitted per load (on a mass or volume basis) before it is deemed noncompliant. This percentage should be very small so as to ensure reusable, recyclable, and recoverable material is not incinerated. d. The Burnaby Incinerator must post on its public website a weekly report, summarizing the fuel load inspections, including number of loads, mass of fuel received, and results of inspection. e. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. On page 6 of the Draft Operational certificate, it states “Other non-MSW fuels may be accepted that have received prior approval by the Director. New non-MSW fuels to be used on an ongoing basis are authorized based upon the following criteria: 1. Prior to usage of a new fuel, the Director must receive written notification identifying the proposed material. A report must accompany this notification which shall contain the following: a. Records detailing analyses and written descriptions establishing the composition, source and quality of the proposed fuel. The analyses shall include, but not be limited to, quantitative trace metal composition of the proposed fuel...” First, absolutely no non-MSW fuels must be permitted to be incinerated in this facility. The Burnaby Incinerator was built to be an MSW incinerator. If there is not enough garbage to fuel the facility, or for any other reason new non-MSW fuels are proposed to replace MSW, it must be shut down.

Requirement 24: The section on page 6 of the Draft Operational Certificate on new non-MSW fuels must be removed from the Operational Certificate.

Second, if reporting on the composition, source, quality, and testing for metal content of proposed new fuel is listed in the Draft Operational Certificate, why is this not required for all fuel burned? Garbage is a variable mix, and each load will be different from the last.

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Requirement 25: For all MSW fuel: a. All ‘normal’ MSW fuel loads inspected by a third party for composition (see requirement 23) must be sampled for metal content (at a minimum: antimony, beryllium, cobalt, copper, manganese, nickel, selenium, tellurium, thallium, tin, vanadium, and zinc), chlorine, sulphur, and moisture as well, with 5 samples collected per load. Samples for testing must be collected by a qualified independent third party, and analyzed following methods set out in Section 3.10 and Requirement 43 at an accredited laboratory. Samples must be shipped to the laboratory within 24 hours of collection. Results of the testing must be posted on the public website within two days of receipt of results from the laboratory. b. Results must be compared to standards determined by the Director, and those standards posted on the public website. c. Failure of tests to adhere to the standards will result in the fuel load being denied to the incinerator. d. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.3 Future Recycling or Beneficial Use This section states, “The Director may require an evaluation of the potential to recycle or beneficially use certain residues from the combustion process and recovery of certain reusable resources.” What about before the material is incinerated? As was noted above in the comments under section 2.1, Metro Vancouver’s own solid waste management plan, which has been approved by the BC Ministry of Environment, requires that they first reduce waste, then reuse, recycle, and recover materials, before energy recovery is pursued. Reusing, recycling, recovering materials must be conducted before incineration occurs.

Section 2.4 Byes This section states, “The discharge of air contaminants, as that term is defined in the Environmental Management Act, beyond the property boundary of the facility, which has byed the authorized works, is prohibited unless the approval of the Director is obtained in writing.” In advance of the discharge of air contaminants beyond the property boundary, a public notice must be issued.

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Requirement 26: a. In advance of the discharge of air contaminants beyond the property boundary, a public notice must be issued on the website must be made at least ten days in advance of the discharge, characterizing the discharge, including but not limited to: the types of pollutants being discharged, the quantities of pollutants being discharged, the length of time, and reason for discharge. This notice must remain on the website for the duration of the operational life of the Burnaby Incinerator. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.4 Process Modifications This section states, “The Director shall be notified prior to implementing material changes to any process that adversely affects the quality and/or quantity of the discharge from the facility to a material extent. Despite notification under this section, permitted levels must not be exceeded.” In advance of any process change (that may adversely or beneficially affect the quality or quantity of the discharge), a public notice on the website must be issued. Requirement 27: a. In advance of any process change that may adversely or beneficially affect the quality or quantity of the discharge, a public notice must be issued on the website must be made at least fourteen days in advance of the process change, detailing the change, reason for the change, and anticipated effects on discharge caused by the change. This notice must remain on the website for the duration of the operational life of the Burnaby Incinerator. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.6 Maintenance of Works, Emergency Procedures and Non-Compliance Reporting Subsection 2.6.1 states, “The Operational Certificate Holder shall ensure the authorized works are inspected regularly and maintained in good working order. In the event of an emergency or condition beyond the control of the Operational Certificate Holder which prevents effective operation of the authorized works or leads to unauthorized discharge, the Operational Certificate Holder shall immediately as soon as reasonably practical notify the Regional Manager, Environmental Protection, and take appropriate remedial action for the prevention or mitigation of pollution. The Operational Certificate Holder shall meet all applicable emergency statutory requirements. The Director may reduce or suspend operations to protect the environment until the authorized works have been restored and/or corrective steps have been taken to prevent unauthorized discharges.”

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In this section, who conducts inspections, how often they are conducted (what is the definition of regularly?) and how good working order is defined need to be specified. In the event of an emergency, unauthorized discharge, or similar condition, the Burnaby Incinerator must be shut down immediately and remain that way until the cause is identified and corrective actions taken.

Requirement 28: a. Authorized works must be inspected by qualified independent third parties on an unscheduled basis, at least four times per year, covering all four seasons. Inspection and maintenance reports are to be completed and posted on the public website within seven days of the work. Any noted deficiencies are to be corrected immediately. A posting on the public website outlining remedial action being taken must be posted within seven days of the inspection report being received. “Good working order” is defined as operating in accordance to the manufacturer’s specifications. b. Further, the entire Burnaby Incinerator facility must be inspected by a qualified independent third party waste to energy expert on a biannual basis. The report from this inspection must be posted on the public website within 30 days of the inspection. The report must outline how the inspector is an expert in mass burn waste to energy technology specifically. All recommendations in the maintenance report must be completed in a timely manner, and an action plan posted on the public website within 30 days of the report being released. c. Emergencies or conditions beyond the control of the Operational Certificate Holder which prevents effective operation of the authorized works or leads to unauthorized discharge must result in the Burnaby Incinerator being shut down immediately. The Burnaby Incinerator must remain shut down until the cause is identified and remedial actions have been submitted to and approved by the Director. Upon verification by the Director that remedial measures have been implemented, the facility may startup. d. A notice on the public website must be issued within three hours of emergency condition onset. The report to the Director outlining the cause and remedial measures taken must also be posted on the public website, along with the confirmation by the Director once those actions have been implemented and the facility restarts. e. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. It is suggested that in addition to mandatory shut down of the facility in an emergency, unauthorized discharge, or similar event, that a significant financial penalty be applied for failing to adhere to any of the aforementioned requirements during such an event.

Subsection 2.6.2 states, “During and after the emergency event or condition, the Operational Certificate Holder shall ensure (1) sampling and analysis of discharges which might be non-compliant with the rates or characteristics of discharges as specified in this Operational Certificate and/or applicable statutory requirements is conducted, (2) the probable causes of the non-compliances are investigated and (3) appropriate remedial actions at the authorized works, plant operations or both to prevent pollution or authorized discharges are implemented.”

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Requirement 29: a. All sampling conducted must be in accordance with modified section 1.1.3 and section 3.3 and related sections of the Operational Certificate, and must be reported to the public website in real time, if measured by CEMS. If measured by stack test, it must occur during the emergency event while the facility is being shut down (if time allows), during the startup, and on the day immediately following startup. All analyses must be completed on a rush basis at an accredited laboratory, and results posted on the public website within 24 hours of receipt. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate. Subsection 2.6.3 states, “Within 30 days of the emergency event or condition, the Operational Certificate Holder shall provide a report to Regional Manager, Environmental Protection, describing the sequences of events that led to an emergency event or condition, results of sampling and analysis described above, the root causes of non-compliance, remedial actions implemented and/or planned schedules for potential corrective and preventive action.” This report should also be posted on the public website at the same time as it is submitted to the Regional Manager.

Requirement 30: a. This report should also be posted on the public website at the same time as it is submitted to the Regional Manager. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.8 Ash Handling This section states, “Fly ash shall be disposed at an appropriate permitted facility. Bottom ash shall be disposed at an appropriate permitted facility or beneficially used, as authorized by the Director. Prior to disposal or authorized beneficial use, recoverable materials, such as ferrous metal pieces, may be removed.” The term “appropriate permitted facility” must be defined to include the hazardous waste. The volume of ash disposed of at such facilities must be reported each year in the public annual report. As per Requirements 22 and 23, no unauthorized fuels, no reusable, recyclable, or recoverable materials may be incinerated. Ferrous metal pieces should be moved from the fuel before it is burned. Bottom ash must also be disposed at an appropriate permitted hazardous waste facility. As has been reported in Metro Vancouver staff reports and in the news recently, both fly ash and bottom ash have failed toxicity characteristic leaching procedure (TCLP) tests with cium

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exceedances over the past year or so.14 This highlights that the facility has recently had a number of failures to meet provincial standards, and that these products are hazardous and must be disposed of at a hazardous waste facility.

Requirement 31: a. The section should be rewritten to read, “Fly ash and bottom ash shall be disposed at an appropriate permitted facility for hazardous waste.” b. The results of TCLP tests for every load of fly ash and bottom ash must be published on the public website and summarized in the annual report. The quantity of fly ash and bottom ash disposed of, and location of disposal, must be reported on the public website on a monthly basis, and summarized in the annual report. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.9

Plans - Works

This section reads, “Plans and specifications of the works authorized in Sections 1.1, 1.2, 1.3, 1.4, 1.5, and 1.6 shall be submitted to the Director upon request. For any material modifications to the authorized works, a qualified professional must certify that the works have been constructed in accordance with the certified design before discharge commences.”

Requirement 32: a. All plans and specifications of the works authorized in the Operational Certificate must be posted on the public website. For any material modifications to the authorized works, plans and certification by an independent third party qualified professional must be posted on the public website at least fourteen days in advance of the modifications being implemented. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 2.11 Environmental Management System

Requirement 33: a. The annually updated Environmental Management System must be posted on the public website by December 31 of each year. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

14

Metro Vancouver. Technical Bulletin: Waste-to-Energy Facility Fly Ash Management. October 31, 2012.

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Section 2.12 Emergency Response Plan

Requirement 34: a. The annually updated Environmental Management System must be posted on the public website by December 31 of each year. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.1

MSW Fuel and Ash Monitoring

Subsection 3.1.1 requires estimated or measured weight of fuels (MSW and natural gas) burned per day, month, and year to be calculated. This information must be posted on the public website.

Requirement 35: a. Daily MSW and natural gas fuel consumption must be posted on the public website within 24 hours of the end of the day being reported, monthly consumption within 48 hours of the end of the month, and yearly consumption by January 15 of the following year. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Subsections 3.1.2, 3.1.3, and 3.1.4 detail fly ash and bottom ash reporting and allude to fly ash and bottom ash management plans coming into place March 31, 2014 and June 30, 2014 respectively. In accordance with the comments and requirements under Section 2.3, all of these records must be displayed on the public website.

Requirement 36: a. Fly ash and bottom ash management plans must be posted on the public website. b. Bulk weight and percentage moisture content of treated fly ash and treated bottom ash must be reported on a monthly on the public website. The quantities of each type of ash disposed at these facilities, and the identification of the facilities must be posted on the public website on a monthly basis. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

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Section 3.2

Spill Reporting

A spill report must also be posted on the public website within 24 hours of a spill. Requirement 37: a. A spill to the environment, defined in the Spill Reporting Regulation must be reported in accordance with that regulation to the public website within 24 hours of the spill. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.3 Discharge Monitoring for Subsection 1.1 Section 3.3 should be included in subsection 1.1 for clarity. Comments pertaining to section 3.3 have been included with the comments for subsection 1.1.

Section 3.5

Emission Control Device Record Keeping

Performance records on emission control devices must be posted on the public website, and summarized in the annual report.

Requirement 38: a. Performance records on all emission control devices must be posted on the public website on a quarterly basis and summarized in the annual report. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.6

Secondary Combustion Zone Temperature Monitoring Requirements

The continuous temperature measurement record in the secondary combustion zone must be posted on the public website. The percentage of time (during operation, where startup, shut down, and upset conditions are considered in operation) when the temperature is at or above 800ºC must be presented annually on the public website and in the annual report. Further, a number of sources have indicated that higher temperatures are needed to destroy trace organics. For example, the Supplementary “Green Book”15 produced for the Burnaby Incinerator in 1986 reads on page 4 of ‘Organics’, “Another field study (8)16 comparing operating temperatures found that a higher, (1140°C versus 1000°C) secondary combustion chamber temperature significantly reduced the PCDD and PCDF emission concentrations.”

15

Khare et al. Supplementary to the report on Emission and Monitoring Requirements for Greater Vancouver Regional District Incinerator Located in Burnaby. 1986. 16 The National Incinerator Testing and Evaluation Program: Two Stage Combustion (Prince Edward Island). 1985.Environment Canada Report EPS 3/UP/l, Ottawa, Canada. 85 p. FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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The Operational Certificate Holder must conduct a review of best practice secondary combustion temperatures for destroying the most trace organics. If findings reveal that the temperature should be above 800°C to destroy more of the trace organics, it must be required to reach that higher temperature. Further, it is understood that a tertiary air combustion chamber may be installed in the facility. Comment on temperature requirements in this case must be discussed in the Operational Certificate.

Requirement 39: a. Continuous temperature measurements will be posted to the public website in real-time at the finest resolution the instrument can measure. Continuous temperature measurements will be made and recorded during all times of operation of the facility, including normal operation, start up, shut down, or upset periods. b. QA/QC on the data shall be conducted in accordance with a documented method acceptable to the Director, and posted on the public website, within one week of the data measurement. c. The percentage of time during operation when the temperature is 800ºC or above must be presented on the public website at the end of each calendar year (by January 15 of the following year) and in the annual monitoring report. d. A qualified independent third party must conduct a review of best practice secondary combustion temperatures for destroying the most trace organics, which must be completed and posted on the public website by December 31, 2014. If findings reveal that the temperature should be above 800°C to destroy more of the trace organics, it must be required to reach that higher temperature. e. Comments on temperature requirements in a potential tertiary combustion chamber in the facility must be provided in the Operational Certificate. f. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.7

Start Up or Shut Down Period

As detailed in length in the comments of section 1.1.3, it is imperative that emissions are monitored and publicly reported during start up, show down, and upset periods, as these times may represent periods where the highest emissions are occurring. Residents of Metro Vancouver and the Fraser Valley are exposed to all emissions, all the time, not just when they are monitored, so it is critical that the monitoring requirements accurately reflect the range of emissions during all different times of operation, seasons, etc. Representatives of the FVRD took a tour of the Burnaby Incinerator on September 11, 2013. Attendees were told on that tour by Chris Allan of Metro Vancouver that the facility was typically shut down about 45 days per year. This could represent a substantial number or percentage of operational time per year when the facility is in start up, shut down, or upset conditions. The number of operational hours the facility has per year (defined as number of hours the facility is operating normally, is undergoing start up, is undergoing shut down, or is experiencing upset conditions) and percentage of those operating hours that are start up, shut down, or upset must be reported.

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Requirement 40: a. Report on the public website and annual monitoring report number of operational hours, percentage of hours per year in start up, shut down, or upset conditions. b. Maintain internal temperature of 800ºC or higher as determined by the review of best practice during start up, shut down, upset conditions. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.8

Modification of Monitoring Requirements and/or Treatment Works

The Director may alter the monitoring requirements, but they can only become stricter (the emissions limits go down or the frequency of monitoring increase). Any alteration of monitoring requirements must be posted on the public website at least one month before they are to take effect.

Requirement 41: a. Modification of monitoring requirements and/or treatment works must be given notice on the public website at least 30 days before the proposed changes will take effect. b. Monitoring requirements can only become more strict (the emissions limits go down or the frequency of monitoring increase

Section 3.9

Sampling Location and Techniques

This section reads, “Sampling shall be done under actual operating conditions when the Operational Certificate Holder is able to properly document that these conditions represent a period of normal operation.” As was detailed in section 1.1.3, where the technology for CEMS exists to measure the parameters monitored in the Operational Certificate, that technology must be used to measure those pollutants in real time. CEMS must be in place on all stacks emitting pollutants. Monitoring must be conducted during all operations, including but not limited to normal operations, start up, shut down, and upset conditions. In the case that a parameter cannot be measured by CEMS (where the technology does not exist), stack tests must be conducted. Stack tests must be conducted on all stacks emitting air pollutants. The requirements for stack testing must be made more rigorous.

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Requirement 42: a. This section should be rewritten as, Sampling must be done under all actual operating conditions when the Operational Certificate Holder is able to properly document that these conditions represent normal operating conditions, startup conditions, shut down conditions, or upset conditions. b. In the event, and only in the event that CEMS technology does not exist for a parameter being measured (see section 1.1.3), stack tests must be conducted. c. Stack tests must be conducted a minimum of six times per year for all substances. This must cover all four seasons, and at least one startup, one shutdown, and one normal operating condition period for each parameter at each stack. Further, at least one of the tests per parameter per year must have two independent qualified third parties measuring the same parameter, to see if they obtain the same results. d. Any samples collected during stack testing must be submitted to a qualified independent third party laboratory, accredited for the analyses to be done, within 24 hours of collection. Results of the stack testing can be obtained on the laboratory’s normal turnaround time for the test. Results of the stack testing must be posted on the public website within 48 hours of receipt from the laboratory. e. All stack testing results must be included in the annual report. f. The consequences of failing to comply with the requirements must be specified in the Operational Certificate, and must represent significant financial penalties. As has been detailed many times already, it is imperative that comprehensive emissions monitoring data is available for the Burnaby Incinerator, and these requirements for any stack testing needed followed. There must be a strong disincentive for failing to comply with these requirements.

Section 3.10

Sampling and Analytical Procedures

Analyses of samples must be conducted by a qualified third party laboratory. The laboratory must be accredited by a recognized organization for each test it conducts, if accreditation exists. This section reads, “Sampling is to be carried out in accordance with the procedures described in the "British Columbia Field Sampling Manual for Continuous Monitoring and the Collection of Air, Air-Emission, Water, Wastewater, Soil, Sediment, and Biological Samples, 2003 Edition", or most recent edition, or by suitable alternative procedures as authorized by the Director. Analyses are to be carried out in accordance with procedures described in the most recent edition of the "British Columbia Laboratory Manual for the Analysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient Air Samples”, or by suitable alternative procedures as authorized by the Director.” The actual method of sampling and analysis for all parameters must be disclosed on the public website (even if it is in accordance with the "British Columbia Laboratory Manual for the Analysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient Air Samples”), and especially if it is an alternate method authorized by the Director.

FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Requirement 43: a. Analyses of samples must be conducted by a qualified third party laboratory. The laboratory must be accredited by a recognized organization for each test it conducts, if accreditation exists. Sampling and analysis reports must be posted on the public website, along with proof they were conducted by qualified third parties, and that accredited laboratories were used, where applicable. b. The actual method of sampling and analysis for all parameters must be disclosed on the public website (even if it is in accordance with the "British Columbia Laboratory Manual for the Analysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient Air Samples”). c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Section 3.11

Reporting Requirements

Subsection 3.11.1 Internet Posting of Section 3.3 Daily CEMS Data All reporting requirements should match requirements listed in sections 1.1.3 and 3.3. CEMS data must be posted in real time, and must undergo Quality Assurance/Quality Control (QA/QC) verification (methods acceptable to the Director, and must be posted on the public website) within seven days of measurement. In the event that additional time is needed to perform QA/QC verification, a notice indicating that can be posted on the website. Comments on exceedances, outlining possible reasons and remedial actions taken (section 1.1.3 and 3.3) must be posted within 24 hours of the exceedance, and updated as more information comes available. See comments and requirements under section 1.1.3 for more details and requirements on reporting.

Requirement 44: a. All reporting requirements must match the other comments and requirements outlined in this submission. Data must be posted in real time. b. Comments on exceedances of CEMS data, including possible reasons and remedial actions taken must be posted within 24 hours of the exceedance, and updated are more information comes available. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

Subsection 3.11.2

Monthly Monitoring Data Reporting

All monthly monitoring data reporting submitted to the Regional Manager, Environmental Protection, must be posted on the public website as well, at the time of submission. “Each monthly data submission shall include a statement outlining the number of exceedances of permit discharge limits; the number and duration of exceedances of the ½ hr response limits, and comments on remedial measures taken in each case; up to date cumulative duration of any ½ hr response limit exceedances for the calendar year; FVRD Requirements Burnaby Incinerator Draft Operational Certificate

Page | 29

the number of occasions the one-hour average secondary combustion chamber temperature dropped below 800°C during periods of normal operation, the minimum temperature reached in each case, and the corrective action taken; and the CEMS availability factor expressed as a percentage of plant operating hours, causes, and corrective action(s) taken to address exceedances that occurred during the reporting period. The dates of the exceedances and action(s) taken shall be clearly identified in the data submission. Should no exceedances have occurred over the reporting period, a statement to that effect must be included.”

Requirement 45: a. All monthly monitoring data reports must be posted on the public website at the same time as they are submitted to the Regional Manager, Environmental Protection. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

3.11.3

CEMS Maintenance, Calibration and Audit Reporting

This section states, “The Operational Certificate Holder shall maintain for a minimum of two years and make available upon request the performance range, specifications and calibration data for each CEMS; the availability of each CEMS (expressed as a percent of facility operating hours); maintenance and calibration work performed on the CEMS as well as results of any independent audit performed during the preceding month.” Instead, the Operational Certificate Holder shall maintain the performance range, specifications and calibration data for each CEMS; the availability of each CEMS for the entire duration of the operational life of the Burnaby Incinerator. All of this information must be posted on the public website. Requirement 46: a. All records pertaining to each CEMS (performance range, specifications, calibration data, availability expressed as a percentage of facility operating hours, including start up, shut down, and upset hours; maintenance and calibration) must be posted on the public website, and remain there for the duration of the operational life of the facility. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

3.11.4

Source Testing Reporting

See comments on sections 1.1.3, 3.3, and 3.9.

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3.11.5

Record Keeping Requirements

This section states, “Maintain all emission testing results, data of analysis, reports, continuous emission results (1/2 hour and 24 hour averages) and calibration records for continuous monitors required under Sections 3.1, 3.3, and 3.6 for a minimum of two years and make available upon request.” All records must be kept for the duration of the operating life of the Burnaby Incinerator, and must be posted on the public website.

Requirement 47: a. All records, pertaining but not limited to emission testing results, data analysis, reports, CEMS results, calibration records, maintenance records, etc. listed under Sections 3.1, 3.3 and 3.6 must be kept for the duration of the operating life of the Burnaby Incinerator, and must be posted on the public website. b. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

3.11.6

Annual Monitoring Report

Comments and requirements on the annual monitoring report are provided throughout this submission, and first addressed in Requirement 2. It must be posted on the public website by March 31 of the following year.

Requirement 48: a. All comments and requirements listed in this document pertaining to the annual report must be adhered to. Requirement 1 and 2 provide a non-exhaustive list of items that must be in the annual report. b. The annual report must be posted on the public website by March 31 of the year following the report year. c. The consequences of failing to comply with the requirements must be specified in the Operational Certificate.

FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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Appendix 1

FVRD Requirements Burnaby Incinerator Draft Operational Certificate

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ENVIRONMENTAL PROTECTION NOTICE NOTICE OF INTENT TO ISSUE OPERATIONAL CERTIFICATE 107051 UNDER THE PROVISIONS OF THE ENVIRONMENTAL MANAGEMENT ACT Take notice that the Director intends, a minimum of 30 days after the date of this publication, to issue Operational Certificate 107051 to the Greater Vancouver Sewerage and Drainage District (Metro Vancouver) for the existing Metro Vancouver Waste-to-Energy Facility located at 5150 Riverbend Drive, Burnaby, British Columbia. Environmental discharges for this facility are authorized by Metro Vancouver’s approved Integrated Solid Waste and Resource Management Plan, and the of draft Operational Certificate 107051 meet or exceed environmental requirements contained in this Plan. Copies of the draft Operational Certificate 107051 are available at Metro Vancouver, Solid Waste Services, 4330 Kingsway, Burnaby, British Columbia during normal business hours or can be requested by sending an email to [email protected] to the attention of the Regional Manager, Environmental Protection within 30 days of the date of this publication.

DRAFT November 21, 2013 1. AUTHORIZED DISCHARGES 1.1

Mass Burn Incinerators/Boilers This section applies to the discharge of air contaminants for three (3) identical Mass Burn Incinerators/Boilers from a common stack (with three individual flues) identified as “stack” on Site Plan A. The site reference number for this discharge is XXXXX. 1.1.1

The maximum rate of discharge for the three combined incinerator units is 72 dry cubic metres per second (m3/s).

1.1.2

The authorized discharge period is continuous.

1.1.3

The characteristics of the discharge shall be equivalent to or better than: Discharge (3) Limits

Preliminary Discharge (2)(3) Limits

Parameter Total Particulate (9) Matter Opacity

(1)

Units

mg/dscm %

Response (4) Limits

24-hr (5) Average -

4-hr (6) Average -

1-hr Average -

24-hr (5) Average -

Approved Test (7) Method 9

1/2-hr (8) Average -

-

-

5

-

-

5

-

50

-

100

(10)

10

-

60

Carbon Monoxide (CO)

mg/dscm

-

55

Hydrogen Chloride (HCl)

mg/dscm

-

-

55

Hydrogen Fluoride (HF)

mg/dscm

-

-

-

-

1.0

-

Sulphur Dioxide (SO2)

mg/dscm

200

-

-

50

-

190

Nitrogen Oxides (NOx)

mg/dscm

350

-

-

190

-

350

Total Organic Carbon (TOC)

mg/dscm

-

-

Manual Stack Test limit of (11) 40

10

-

20

Total Dioxins and Furans (as PCDD/F (12) TEQ) Cium (Cd)

ng/dscm

-

-

-

-

0.08

-

µg/dscm

-

-

-

-

7

Page 1 of 15

DRAFT November 21, 2013 Mercury (Hg)

(13)

µg/dscm

-

-

-

-

20

-

Sum of Lead (Pb), Arsenic (As), Chromium (Cr) Chlorophenols

µg/dscm

-

-

-

-

64

-

µg/dscm

-

-

-

-

1

-

Chlorobenzenes

µg/dscm

-

-

-

-

1

-

Polycyclic Aromatic Hydrocarbons (PAHs) Polychlorinated Biphenyls (PCBs)

µg/dscm

-

-

-

-

5

-

µg/dscm

-

-

-

-

1

-

1. 2.

3. 4.

5. 6. 7. 8. 9. 10. 11. 12. 13.

dscm = dry standard cubic metre, corrected to 11% oxygen Preliminary Discharge Limits shall apply until and including the following dates, at which point the Discharge Limits and Response Limits shall apply: a. Opacity – December 31, 2015 b. CO – December 31, 2014 (Discharge Limit) and December 31, 2015 (Response Limit) c. HCl – December 31, 2019 (Discharge and Response Limits) d. SO2 – December 31, 2019 (Discharge and Response Limits) e. NOx – December 31, 2014 (Discharge Limit) and December 31, 2015 (Response Limit) f. TOC – December 31, 2015 (Discharge and Response Limits) Discharge limits are the criteria for compliance determination of each discharge parameter listed in the column, subject to Note 2 above. Response limits are the threshold requiring the Operational Certificate Holder to take immediate action to bring down the discharge levels to the applicable discharge limits specified in this section. The response limits are expressed as ½ hr (block) average values measured by approved continuous emission monitors. The Operational Certificate Holder is required to demonstrate the response action(s) implemented by record keeping. Daily average values, calculated as the arithmetic average of valid continuous emissions monitoring system (CEMS) data. Calculated as the arithmetic average of 4 hrs of data from a CEMS. Determined by a test method approved by the Director. A single manual stack test result is the average of a minimum of three (3) test runs. Calculated as the arithmetic average of ½ hr block of data from a CEMS. Total particulate matter (filterable portion only) is determined by EPA Test Method 5 or an alternative method approved by the Director. Continuous monitoring of SO2 shall be used as a surrogate for emission monitoring of acid gases, such as HCl and HF. Monitored as total hydrocarbons (measured as methane). PCDD (polychlorinated dibenzo-p-dioxins) & PCDF (polychlorinated dibenzofurans) shall be expressed in dioxin toxicity equivalent value (dioxin TEQ) as defined in the Hazardous Waste Regulation. Mercury determined by EPA Test Method 29 or an alternative method approved by the Director.

1.1.4

The Operational Certificate Holder shall ensure that under no circumstances Municipal Solid Waste (MSW) is continued to be fed to an incinerator/boiler when an authorized parameter response limit is exceeded for a period of more than four (4) hours uninterrupted per parameter per unit; moreover the cumulative duration of operation in such conditions over one calendar year shall be less than 60 hours per parameter per unit. Page 2 of 15

DRAFT November 21, 2013

1.2

1.1.5

The authorized works are refuse bunker, three (3) mass burn incinerators/boilers each equipped with an independent fuel feed chute, integrated furnace/boiler, Covanta Low NOx System, selective non-catalytic NOx reduction system, lime scrubber, activated carbon injection system and three (3) baghouses, fans, heaters, ash handling and treatment systems, turbo generator, air cooled condenser, a common stack (with three individual flues) and related appurtenances approximately located as shown on Site Plan A.

1.1.6

The authorized works must be complete and in operation while discharging. It is understood that the Covanta Low NOx System will be commissioned in 2014.

1.1.7

The location of the facilities from which the discharge originates is Legal Land Description: LOT 1, DISTRICT LOT 167, GROUP 1, NEW WESTMINSTER DISTRICT, PLAN 72187

1.1.8

The location of the point of discharge is Parcel Identifier: XXXX

Closed-Circuit Cooling Tower This section applies to the discharge of air from a multi-cell Closed Circuit Cooling Tower as shown on attached Site Plan A. The site reference number for this discharge is XXXX.

1.3

1.2.1

The maximum rate of discharge is 70 m3/s.

1.2.2

The authorized discharge period is continuous.

1.2.3

The characteristics of the discharge shall include water vapour and mist containing dissolved minerals naturally present in water and water conditioning additives for pH and algae growth control.

1.2.4

The authorized works are a closed-circuit cooling tower, exhaust vents and related appurtenances approximately located as shown on Site Plan A.

1.2.5

The location of the facilities from which the discharge originates and the point of discharge is the same as Section 1.1.7 above.

Lime Silo This section applies to the discharge of air from a Lime Silo as shown on attached Site Plan A. The site reference number for this discharge is XXXX. 1.3.1

The maximum rate of discharge is 1.0 m3/s.

1.3.2

The authorized discharge period is intermittent. Page 3 of 15

DRAFT November 21, 2013

1.4

1.3.3

The discharge point shall be equipped with a fully functional particulate matter filter.

1.3.4

The authorized works are a lime silo, a baghouse and related appurtenances approximately located as shown on Site Plan A.

1.3.5

The authorized works must be complete and in operation while discharging.

1.3.6

The location of the facilities from which the discharge originates and the point of discharge is the same as Section 1.1.7 above.

Activated Carbon Silo This section applies to the discharge of air from an Activated Carbon Silo as shown on attached Site Plan A. The site reference number for this discharge is XXXX.

1.5

1.4.1

The maximum rate of discharge is 1.0 m3/s.

1.4.2

The authorized discharge period is intermittent.

1.4.3

The discharge point shall be equipped with a fully functional particulate matter filter.

1.4.4

The authorized works are an activated carbon silo, a baghouse and related appurtenances approximately located as shown on Site Plan A.

1.4.5

The authorized works must be complete and in operation while discharging.

1.4.6

The location of the facilities from which the discharge originates and the point of discharge is the same as Section 1.1.7 above.

Fly Ash Silo This section applies to the discharge of air from a Fly Ash Silo as shown on attached Site Plan A. The site reference number for this discharge is XXXX. 1.4.1

The maximum rate of discharge is 2.0 m3/s.

1.4.2

The authorized discharge period is continuous.

1.4.3

The discharge point shall be equipped with a fully functional particulate matter filter.

1.4.4

The authorized works are a fly ash silo, exhaust vents and related appurtenances approximately located as shown on Site Plan A. Page 4 of 15

DRAFT November 21, 2013

1.6

1.4.5

The authorized works must be complete and in operation while discharging.

1.4.6

The location of the facilities from which the discharge originates and the point of discharge is the same as Section 1.1.7 above.

Emergency Power Generator This section applies to the discharge of air from an Emergency (Standby) Power Generator as shown on attached Site Plan A. The site reference number for this discharge is XXXX. 1.6.1

The authorized discharge period is 500 hours per annum.

1.6.2

The characteristics of the discharge shall be equivalent to or better than typical emissions from the type of engine in-place at the facility.

1.6.3

The authorized works are Emergency Power Generator and related appurtenances approximately located as shown on Site Plan A.

1.6.4

The authorized works must be complete and in operation while discharging.

1.6.5

The location of the facilities from which the discharge originates and the point of discharge is the same as Section 1.1.7 above.

2. GENERAL REQUIREMENTS 2.1

Authorized Fuels The authorized fuels for the Mass Burn Incinerators/Boilers are (a) MSW and (b) other wastes approved by the Director. Natural gas may be used as an auxiliary fuel during start up, shut down and flame stabilization. Wastes that are approved and authorized for use as fuel are as follows: • • • • • • • • • • •

MSW from residential, industrial/commercial/institutional (ICI), and construction and demolition sources International airline waste International marine waste Cruise ship waste Non-recyclable wood waste Non-recyclable Extended Producer Responsibility (EPR) material Non-anatomical hospital waste Waste Water Treatment Plant residuals Biosolids Noxious weeds Invasive Plants Page 5 of 15

DRAFT November 21, 2013 • • • •

Drug seizures Pharmaceuticals Seized and counterfeit goods Casino tokens

Other non-MSW fuels may be accepted that have received prior approval by the Director. New non-MSW fuels to be used on an ongoing basis are authorized based upon the following criteria: 1. Prior to usage of a new fuel, the Director must receive written notification identifying the proposed material. A report must accompany this notification which shall contain the following: a. Records detailing analyses and written descriptions establishing the composition, source and quality of the proposed fuel. The analyses shall include, but not be limited to, quantitative trace metal composition of the proposed fuel. b. Proposed feed rate of the fuel shall be expressed as a percentage of the total raw material feed to the incinerators. The proposed feed rate of the fuel shall be expressed as a percentage of the total heat value to the incinerators. 2. Conduct a demonstration trial utilizing the proposed fuel at the maximum proposed feed rate. The demonstration trial must meet the following requirements: a. Site storage and handling of the proposed fuel shall be conducted in such a manner so as to effectively control fugitive emissions. b. Maximum duration of 96 hours. Records detailing the proposed fuel usage times and dates shall be maintained and made available for inspection. c. Records detailing feed rates, quantity and quality of all fuel sources utilized during the demonstration trial shall be maintained and made available for inspection for a period of two (2) years. d. Emissions monitoring shall be conducted to determine the concentration of the parameters listed in Section 1.1.3. The Operational Certificate Holder shall provide the Ministry with a minimum of three business days advance notice before any of the emission testing is carried out. All field data and calculations collected for the testing conducted must be submitted to the Director. These submissions shall include the feed rates for all fuel sources utilized at the time of testing. The results of emissions monitoring shall be submitted to the director a minimum of five business days prior to the routine usage of the proposed fuel. 3. New fuels that have met the requirements above and demonstrated compliance with all and conditions of this Operational Certificate are authorized for use.

Page 6 of 15

DRAFT November 21, 2013 2.2

Municipal Solid Waste (MSW) Fuel Handling, Storage and Disposal Subject to the other provisions of this Operational Certificate, MSW fuel shall be protected against weather elements and prevented from releasing leachate, odour or fugitive dust emissions that amount to pollution, as that term is defined in the Environmental Management Act, to the receiving environment beyond the property boundary of the facility during unloading, storage and disposal. The Operational Certificate Holder shall implement necessary housekeeping procedures to eliminate sources and potential sources of attraction for vermin and vectors. MSW fuel delivered to the facility by truck shall be discharged directly into the refuse bunker. MSW loads delivered to the facility by truck may be periodically discharged onto a dedicated paved area adjacent to the refuse bunker to facilitate MSW load inspections and waste audits, provided all other Section 2.2 conditions are satisfied. Unloading and storage of bulk MSW delivered by trucks shall be managed in an area with appropriate ventilation and odour control. The maximum MSW fuel storage capacity at the site shall be dictated by the capacity of the refuse bunker. All stored MSW fuel must be entirely contained within the refuse bunker.

2.3

Future Recycling or Beneficial Use The Director may require an evaluation of the potential to recycle or beneficially use certain residues from the combustion process and recovery of certain reusable resources.

2.4

Byes The discharge of air contaminants, as that term is defined in the Environmental Management Act, beyond the property boundary of the facility, which has byed the authorized works, is prohibited unless the approval of the Director is obtained in writing.

2.5

Process Modifications The Director shall be notified prior to implementing material changes to any process that adversely affects the quality and/or quantity of the discharge from the facility to a material extent. Despite notification under this section, permitted levels must not be exceeded.

2.6

Maintenance of Works, Emergency Procedures and Non-Compliance Reporting In a manner acceptable to the Director, the Operational Certificate Holder shall ensure the following are conducted: Page 7 of 15

DRAFT November 21, 2013

2.7

2.6.1

The Operational Certificate Holder shall ensure the authorized works are inspected regularly and maintained in good working order. In the event of an emergency or condition beyond the control of the Operational Certificate Holder which prevents effective operation of the authorized works or leads to unauthorized discharge, the Operational Certificate Holder shall immediately as soon as reasonably practical notify the Regional Manager, Environmental Protection, and take appropriate remedial action for the prevention or mitigation of pollution. The Operational Certificate Holder shall meet all applicable emergency statutory requirements. The Director may reduce or suspend operations to protect the environment until the authorized works have been restored and/or corrective steps have been taken to prevent unauthorized discharges.

2.6.2

During and after the emergency event or condition, the Operational Certificate Holder shall ensure (1) sampling and analysis of discharges which might be noncompliant with the rates or characteristics of discharges as specified in this Operational Certificate and/or applicable statutory requirements is conducted, (2) the probable causes of the non-compliances are investigated and (3) appropriate remedial actions at the authorized works, plant operations or both to prevent pollution or authorized discharges are implemented.

2.6.3

Within 30 days of the emergency event or condition, the Operational Certificate Holder shall provide a report to Regional Manager, Environmental Protection, describing the sequences of events that led to an emergency event or condition, results of sampling and analysis described above, the root causes of noncompliance, remedial actions implemented and/or planned schedules for potential corrective and preventive action.

Odour Control Should the facility emit odours to an extent that amount to pollution, as that term is defined in the Environmental Management Act, beyond the property boundary of the facility, the Director may require the facility to implement measures to reduce such odour to an extent that the odour does not amount to pollution.

2.8

Ash Handling Fly ash shall be disposed at an appropriate permitted facility. Bottom ash shall be disposed at an appropriate permitted facility or beneficially used, as authorized by the Director. Prior to disposal or authorized beneficial use, recoverable materials, such as ferrous metal pieces, may be removed.

2.9

Plans - Works Plans and specifications of the works authorized in Sections 1.1, 1.2, 1.3, 1.4, 1.5, and 1.6 shall be submitted to the Director upon request. For any material modifications to the Page 8 of 15

DRAFT November 21, 2013 authorized works, a qualified professional must certify that the works have been constructed in accordance with the certified design before discharge commences. 2.10 Standard Conditions For the istration of this Operational Certificate all gaseous volumes shall be converted to standard conditions of 293.15 K and 101.325 kPa with zero percent moisture and 11% oxygen. 2.11 Environmental Management System The Operational Certificate Holder shall ensure that an Environmental Management System (EMS) or equivalent (e.g., ISO 14001) is implemented to ensure compliance with the discharge requirements through the use of the effective operating procedures, training and maintenance practices. This system shall include, operating the equipment within its designed capabilities, preventing occurrences of abnormal operating conditions in all areas of the facility, enhancing the capabilities to manage or mitigate/correct such abnormal operating conditions for the protection of the environment and human health. The Operational Certificate Holder shall ensure the EMS is updated annually and available for inspection or submission upon request. 2.12 Emergency Response Plan The Operational Certificate Holder shall ensure that an Emergency Response Plan that describes the procedures to be taken to prevent or mitigate any spills, unauthorized discharge of contaminants to the air or deposit of deleterious substance to the receiving environment is maintained. The Emergency Response Plan shall be immediately implemented if there is a discharge/deposit, or any risk of a discharge/deposit, of a deleterious substance to the receiving environment. The Operational Certificate Holder shall ensure that the Emergency Response Plan is updated annually and kept available for inspection. 3. MONITORING AND REPORTING REQUIREMENTS 3.1

MSW Fuel and Ash Monitoring In a manner acceptable to the Director, the Operational Certificate Holder shall ensure the following are monitored and recorded: 3.1.1

Record estimated or measured weight of fuels (MSW and natural gas) burned per day (back calculated MSW from steam rate and reconciled with truck scale data at the month end), per month (by truck scale) and year.

3.1.2

Record estimated bulk weight (and estimated % moisture) of treated bottom ash and treated fly ash destined for disposal or beneficial use per month and year. Page 9 of 15

DRAFT November 21, 2013 3.1.3

Approved fly ash management requirements will be in place by March 31, 2014. Prior to final approval of the requirements for managing fly ash, fly ash monitoring will be performed in accordance with the methods approved by the Director. The approved fly ash management requirements may be reviewed from time to time at the discretion of the Director.

3.1.4

An approved Bottom Ash Management Plan, detailing bottom ash monitoring requirements, will be in place by June 30, 2014. Prior to final approval of the Bottom Ash Management Plan, bottom ash monitoring will be performed in accordance with the methods approved by the Director. The approved Bottom Ash Management Plan may be reviewed from time to time at the discretion of the Director.

3.2

Spill Reporting All spills to the environment (as defined in the Spill Reporting Regulation) shall be reported immediately in accordance with the Spill Reporting Regulation. Notification shall be via the Provincial Emergency Program at 1-800-663-3456.

3.3

Discharge Monitoring for Subsection 1.1 The Operational Certificate Holder shall ensure the discharge is monitored as follows: Parameter for Stack XXXX Rate of Discharge2, m3/s Total Particulate Matter, mg/m3 Opacity3, % Oxygen6, % of dry air Carbon Monoxide (CO) , mg/m3 Hydrogen Chloride (HCl), mg/m3 Hydrogen Fluoride (HF), mg/m3 Sulphur Dioxide (SO2), mg/m3 Nitrogen Oxides (NOx), mg/m3 Total Organic Compounds (TOC), mg/m3 PCDD & PCDF TEQ, pg/ m3 Total Mercury, mg/m3

Sampling and Analysis Frequency1 Continuous & Three times per year Three times per year Continuous3,4 & retain records by minute for inspections Continuous3,4 & record ½ hr average values for concentration adjustments Continuous3,4 & record ½ hr and daily average values Continuous3,4 & record ½ hr and daily average values Three times per year Continuous3,4 & record ½ hr and daily average values Continuous3,4 & record ½ hr and daily average values Continuous3,4 & record ½ hr and daily average values Annually5 Three times per year Page 10 of 15

DRAFT November 21, 2013 Polychlorinated Biphenyls (PCBs), mg/m3 Chlorophenols, mg/m3 Chlorobenzene, mg/m3 Lead, mg/m3 Arsenic, mg/m3 Cium, mg/m3 Chromium, mg/m3 Polycyclic Aromatic Hydrocarbons (PAH) , mg/m3 1.

2. 3.

4.

5.

3.5

Annually5 Annually5 Annually5 Three times per year Three times per year Three times per year Three times per year Annually5

For those parameters with continuous monitoring requirements, compliance with Section 1.1 discharge requirements shall be verified with continuous monitoring data (with a QA/QC program satisfactory to the Director) collected during normal operating periods, excluding start up and shut down periods described in Section 3.7. Other than instrument errors, all collected data issible under a QA/QC program must be recorded and reported. The Director may amend the above monitoring requirements when the Operational Certificate Holder is able to demonstrate to the Director that an alternative compliance monitoring method/requirement is equal to or better than the above requirements. The rate of flue gas discharge shall be adjusted to dry standard conditions. The rate of flue gas discharge shall be reported as daily average values, calculated as the arithmetic average of valid CEMS data. The required data capture rate for (CEMS) specified above shall be 90% of the operating hours per quarter and 95% of the operating hours per annum. The monthly CEMS compliance data report shall include % up time for CEMS. The statistic shall be extended to annual reports. The CEMS data (½ hour and 24 hour averages) for the above parameters shall include maximum, minimum and average for the day, month and year and % of time out of compliance. The specified CEMS data may not be available for all parameters prior to December 31, 2015. Monitoring conducted once per year on one incinerator/boiler.

Emission Control Device Record Keeping The Operational Certificate Holder shall ensure performance records are maintained for all emission control devices in conjunction with manufacturer specifications. The emission control devices include Section 1.1 Covanta Low NOx System, selective noncatalytic NOx reduction system, lime scrubbers, activated carbon injection system. The records shall include frequency and duration of any period when an emission control device is not fully operational, along with appropriate description of each malfunction, as well as the corrective measure(s) taken in each case.

3.6

Secondary Combustion Zone Temperature Monitoring Requirements In a manner acceptable to the Director, the Operational Certificate Holder shall ensure the secondary combustion zone temperature is monitored/recorded continuously (or equivalent surrogate temperature) expressed in degrees Celsius measured at a suitable Page 11 of 15

DRAFT November 21, 2013 location in the secondary combustion zone of the incinerator. The minimum one-hour average secondary combustion zone temperature shall be 800°C while unburned MSW is present in the combustion chamber during periods of normal operation. 3.7

Start Up or Shut Down Period The start up or shut down period for the boilers shall be no more than five (5) hours each. During this period, emission data recorded by CEMS shall be excluded from regulatory emission calculations. Start up periods shall exclude times when the auxiliary burners are in service but waste has not yet been introduced into the boiler. The start up period shall commence when the feed chute damper is open and waste is charged to the stoker. After the start up period, all the air emission discharge requirements specified in Section 1.1 are applicable even during periods when fuel feed rates are being adjusted for any reasons other than start up or shut down. Auxiliary burner(s) shall be used during start-up, shutdown, upset conditions, and at any other times as necessary to maintain the secondary combustion zone temperature. The shut down period will commence when the feed chute damper is closed and waste is no longer being charged to the stoker. The Director may alter or exclude CEMS emission data based upon a review of discharge data and actual start up and shut down operations of the facility boilers.

3.8

Modification of Monitoring Requirements and/or Treatment Works Based on monitoring results and any other pertinent information obtained in connection with the discharges, the Director may alter the monitoring requirements, and/or require the Operational Certificate Holder to take additional measures and/or provide additional treatment works to reduce the impact on the environment and human health from discharges to the receiving environment.

3.9

Sampling Location and Techniques All sampling locations, techniques, and equipment shall be acceptable to the Director. Sampling and monitoring data, including the rate of discharge, shall be accompanied by process data relevant to the operation of the source of the emissions and the performance of the pollution abatement equipment involved in the testing. Sampling shall be done under actual operating conditions when the Operational Certificate Holder is able to properly document that these conditions represent a period of normal operation. The following parameters must be reported for the test period: a) Boiler steam production from fuels expressed as kg/h or kJ/h. b) Boiler secondary combustion zone temperature or an appropriate surrogate expressed in degrees Celsius. c) The estimated rates of fuels as-fired into the boiler during each compliance test Page 12 of 15

DRAFT November 21, 2013 period. 3.10 Sampling and Analytical Procedures Sampling is to be carried out in accordance with the procedures described in the "British Columbia Field Sampling Manual for Continuous Monitoring and the Collection of Air, AirEmission, Water, Wastewater, Soil, Sediment, and Biological Samples, 2003 Edition", or most recent edition, or by suitable alternative procedures as authorized by the Director. Analyses are to be carried out in accordance with procedures described in the most recent edition of the "British Columbia Laboratory Manual for the Analysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient Air Samples”, or by suitable alternative procedures as authorized by the Director. Copies of the above manuals may be purchased from the Queen's Printer Publications Centre, P. O. Box 9452, Stn. Prov. Gov't. Victoria, British Columbia, V8W 9V7 (1-800-6636105 or (250) 387-6409) or via the internet at www.crownpub.bc.ca. A copy of the manual is also available for review at all Environmental Protection offices. 3.11 Reporting Requirements 3.11.1 Internet Posting of Section 3.3 Daily CEMS Data The Operational Certificate Holder shall post verified daily CEMS emissions concentration data that have been confirmed to be accurate by a QA/QC program approved by the Director, on an internet website as soon as reasonably practicable. The emissions concentration data shall be presented in 24 hour averages as required under Section 3.3. Comments on any exceedances of the discharge limits and remedial actions implemented shall be posted as soon as practicable, as required. 3.11.2 Monthly Monitoring Data Reporting The Operational Certificate Holder shall submit to the Regional Manager, Environmental Protection, once each month, the results of the monitoring program specified in Sections 3.1, 3.3, and 3.6, as applicable. The Director may require that data be submitted in electronic format suitable for entry into the Ministry of Environment computer database. The information shall be submitted within 45 days following the month in which the data was collected. Each monthly data submission shall include a statement outlining the number of exceedances of permit discharge limits; the number and duration of exceedances of the ½ hr response limits, and comments on remedial measures taken in each case; up to date cumulative duration of any ½ hr response limit exceedances for the calendar year; the number of occasions the one-hour average secondary combustion chamber temperature dropped below 800°C during periods of normal operation, the minimum temperature reached in each case, and the corrective Page 13 of 15

DRAFT November 21, 2013 action taken; and the CEMS availability factor expressed as a percentage of plant operating hours, causes, and corrective action(s) taken to address exceedances that occurred during the reporting period. The dates of the exceedances and action(s) taken shall be clearly identified in the data submission. Should no exceedances have occurred over the reporting period, a statement to that effect must be included. 3.11.3 CEMS Maintenance, Calibration and Audit Reporting The Operational Certificate Holder shall maintain for a minimum of two years and make available upon request the performance range, specifications and calibration data for each CEMS; the availability of each CEMS (expressed as a percent of facility operating hours); maintenance and calibration work performed on the CEMS as well as results of any independent audit performed during the preceding month. Within 30 days of the Operational Certificate Holder receiving notice of a Ministry audit of continuous emissions, which alleges that there was a non-compliance with the emissions requirements, the Operational Certificate Holder will respond to the audit and allegation. 3.11.4 Source Testing Reporting The Operational Certificate Holder shall submit a report in electronic format to the Regional Manager, Environmental Protection, within 60 days of the completion of the actual source testing, with the exception of testing for chlorophenols, chlorobenzenes, polycyclic aromatic hydrocarbons, hydrocarbons, polychlorinated biphenyls, and/or total dioxins and furans, in which case source testing results shall be submitted within 90 days of the actual source testing. 3.11.5 Record Keeping Requirements Maintain all emission testing results, data of analysis, reports, continuous emission results (1/2 hour and 24 hour averages) and calibration records for continuous monitors required under Sections 3.1, 3.3, and 3.6 for a minimum of two years and make available upon request. 3.11.6 Annual Monitoring Report The Operational Certificate Holder shall submit an annual summary report for the monitoring conducted in the preceding calendar year to the Regional Manager, Environmental Protection, by March 31 of each year. The Annual Report shall include an executive summary, review and interpretation of monitoring data for the preceding calendar year and provide graphical analysis with suitable interpretation of any trends relative to discharge limits and all applicable Page 14 of 15

DRAFT November 21, 2013 federal and Province of BC guidelines, evaluation of authorized works and monitoring programs, conclusions, recommendations and any proposed changes to the monitoring program or the facility. Specific issues identified for reporting include, but are not limited to: a) The quantities of MSW fuel shipments received and processed at the site. b) An overview of the plant performance describing boiler availability, period(s) and cause(s) of any non-availability; the status of operation and maintenance of various pieces of equipment,; the estimated weight of fly ash and bottom ash and/or other residue(s) generated and their processing and disposal method or beneficial uses; general housekeeping practices; incidents of emission control equipment malfunction; and emission limits exceedance summary. c) Summary of emergencies/spills, the response measures implemented, and any incidents of emission control work byes. d) An implementation schedule for any alterations to the authorized works. e) Operation, performance and maintenance of emission control devices and CEMS including availability factor expressed as percentage of plant operating hours. f) Summary of any complaints received from of the public and associated responses with reference to the facility’s EMS, and incidents of exceedances or emergency conditions at the facility.

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