New Source Performance Standards (NSPS) Subpart AAAA: Revised Materials Separation Plan

Transcription

1 New Source Performance Standards (NSPS) Subpart AAAA: Revised Materials Separation Plan Modification of the South Municipal Waste Combustor Unit at the Perham Resource Recovery Facility Perham, Minnesota Prepared for: PRAIRIE LAKES MUNICIPAL SOLID WASTE AUTHORITY 1115 North Tower Road Fergus Falls, MN Wenck File # Prepared by: WENCK ASSOCIATES, INC Pioneer Creek Center P.O. Box 249 Maple Plain, Minnesota (763) September 2012

2 Table of Contents 1.0 INTRODUCTION Background REQUIREMENTS FOR A MATERIALS SEPARATION PLAN Requirement to Prepare a Materials Separation Plan Elements of the Materials Separation Plan SERVICE AREA Service Area of the Perham Resource Recovery Facility Portions of Service Area Included in the Plan WASTE GENERATION RATE MATERIALS SEPARATION GOALS AND METHODS RESIDUAL WASTE PROJECTION ALTERNATE DISPOSAL METHODS REFERENCES \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx i

3 Table of Contents (Cont.) TABLES Table 4-1: Historical Waste Disposal from Otter Tail, Stearns, Todd, and Wadena Counties (tons per year) Table 4-2: Future Waste Disposal from Otter Tail, Becker, Todd, and Wadena Counties (tons per year) Table 5-1: Materials Separation and Recycling Data for PRRF Service Area (tons in 2010) Table 6-1: PRRF Waste Management Residual Waste (tons per year) Table 7-1: Perham Resource Recovery Facility Waste Management Residual Waste (tons per year) FIGURES Figure 3-1: PRRF Service Area Figure 4-1: Historical Waste Trends Otter Tail, Stearns, Todd, and Wadena Counties Figure 4-2: Projected Future Waste Trends Otter Tail, Becker, Todd, and Wadena Counties Figure 7-1: Projected Future Waste Trends for Proposed Project APPENDICES A B C D E Perham Resource Recovery Facility Industrial Solid Waste Management Plan Becker County Solid Waste Management Ordinance Otter Tail County Solid Waste Ordinance PLMSWA County Draft Solid Waste Ordinance Conference Paper - 15 th North American Waste to Energy Conference in Miami, Florida, in 2007 MSW Contingency Planning Opportunities for Perham Facility Expansion ii

4 1.0 Introduction This Materials Separation Plan (MSP) identifies the goals and approaches for separating certain components of the municipal solid waste (MSW) stream in the Perham service area prior to waste combustion at the Perham Resource Recovery Facility (PRRF), in order to reduce the toxicity and to make separated materials available for recycling. This MSP fulfills the requirements of Title 40 of the Code of Federal Regulations (CFR) Part 60 Subpart AAAA, the New Source Performance Standards (NSPS) for the proposed modification of the South Municipal Waste Combustor Unit (South Unit) at PRRF. 1.1 BACKGROUND The Prairie Lakes Municipal Solid Waste Authority (PLMSWA), a joint powers board made up of Becker, Otter Tail, Todd, and Wadena Counties, operates a waste-to-energy (WTE) facility in Perham, Minnesota. It is part of an integrated solid waste management system that provides comprehensive solid waste services to Becker, Otter Tail, Wadena, and Todd Counties. The solid waste management system at the facility currently consists of: Recycling drop-off center; Mass-burn municipal solid waste combustor that generates steam to sell for local heating systems, and; Ash mono-fill. The counties provide waste-reduction and recycling education programs, recycling centers, demolition landfills, and household hazardous waste drop-off centers and mobile collections as means to manage solid waste in the area. PRRF is located at 201 South 6 th Street, Perham, Otter Tail County, Minnesota. Originally, the Quadrant Waste-to-Energy facility was constructed and began operations in The facility closed in 1998 due to its inability to meet certain air permit emissions requirements, at which point the City of Perham assumed ownership of it. In a joint effort with Otter Tail, Stearns, Todd, \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 1-1

5 and Wadena Counties, and with the support of a state grant, PRRF was reconstructed. With new air emissions control technology, new combustion technology, improved ash handling, and electricity generation capabilities, the facility reopened in Otter Tail County owns the Perham Recycling Redemption Center in the southern corner of the PRRF property. The Recycling Redemption Center accepts glass, plastic bottles, aluminum, tin, magazines, newspaper and phone books, corrugated cardboard, and office paper. PRRF currently operates two Municipal Waste Combustor (MWC) units (the North Unit and the South Unit) that fire MSW. Each unit has a maximum daily capacity of 100 tons per day of waste. However, the hot flue gas from the combustion units are tied together and flows through a single heat recovery boiler (HRB) to generate steam, then continues through air pollution control (APC) equipment. Having one waste heat boiler limits the total waste combustion capacity of both units combined to 116 tons per day (tpd) expressed as an annual average. The steam that is generated during the combustion process is currently sold to Tuffy s Pet Foods, Incorporated (Tuffy s) and to Bongards Creameries (Bongards ). To meet the demand for steam, PRRF also has a natural gas fired auxiliary boiler. There is a steam turbine generator on site to produce electricity, but it is not currently operating because all steam produced is sold to Tuffy s and Bongards. The proposed expansion includes a new HRB and associated APC equipment for the South Unit. The North Unit would remain unchanged and continue to use the existing HRB and APC equipment. By decoupling the flue gas streams, each unit would be able to operate individually with a capacity of 100 tpd. The proposed expansion project also includes adding a Materials Recovery Facility (MRF) at the PRRF. The MRF would presort incoming material in an effort to remove some certain undesirable waste and recyclable components prior to combustion of the remaining material. Undesirable waste and fines, including much of the glass and grit in the MSW, would be separated and removed from the fuel supply. The MRF system would be designed to recover ferrous (magnetic) metal, non-ferrous metals including aluminum, and old corrugated containers. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 1-2

6 2.0 Requirements for a Materials Separation Plan The US EPA imposes New Source Performance Standards (NSPS) on new Municipal Waste Combustor (MWC) units. For the PRRF, the applicable standard is Subpart AAAA Standards of Performance for Small Municipal Waste Combustion Units for Which Construction is Commenced After August 30, 1999 or for Which Modification or Reconstruction is Commenced After June 6, 2001 (US EPA, Dec 6, 2000). Subpart AAAA specifies the air-pollutant emission limits which will apply to the modified South Unit at PRRF. Another requirement of the NSPS is to prepare a Materials Separation Plan for the South Unit. This document comprises the required Materials Separation Plan. 2.1 REQUIREMENT TO PREPARE A MATERIALS SEPARATION PLAN In the standard cited above, the US EPA prescribes the requirements for preparation of a Materials Separation Plan, and the process for public review of the plan. Regarding the purpose and content of the Materials Separation Plan, the standard cited above states the following: The Plan --- identifies a goal and an approach for separating certain components of municipal solid waste for a given service area prior to waste combustion and making them available for recycling ( ). A materials separation plan may include such elements as dropoff facilities, buy-back or deposit-return incentives, programs for curbside pickup, and centralized systems for mechanical separation ( (b)) Your materials separation plan may include different goals or approaches for different subareas in the service area ( (c)) Your materials separation plan may exclude materials separation activities for certain subareas or, if warranted, the entire service area ( (d)). The standard also details a specific process that must be followed in order to ensure opportunity for public review and comment on the Materials Separation Plan. The steps of that process are summarized below: \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 2-1

7 Prepare a Draft Materials Separation Plan. Make Draft Plan available for public review. Hold public meeting on the Draft Plan to enable public comment. Prepare written responses to any public comments. Prepare a Revised Materials Separation Plan, considering the public comments. Discuss Revised Materials Separation Plan at a public meeting. Prepare written responses to any public comments. Prepare a Final Materials Separation Plan, considering the public comments. Submit Final Plan to US EPA (or the delegated authority for this standard). 2.2 ELEMENTS OF THE MATERIALS SEPARATION PLAN The required elements of a Materials Separation Plan are outlined in the NSPS regulation cited above. Accordingly, the sections that follow collectively comprise the Materials Separation Plan prepared for the proposed South Unit modifications. The elements of the plan discussed in these sections are as follows: The service area for the PRRF. The amount of waste collected in the service area. The goals for types of materials and amounts to be separated. The methods for materials separation. The amount of residual waste for disposal. The alternate methods for disposal of residual waste. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 2-2

8 3.0 Service Area 3.1 SERVICE AREA OF THE PERHAM RESOURCE RECOVERY FACILITY The service area of the PRRF is defined by the members of the joint powers board that comprise the PLMSWA. Currently, the service area consists of Becker, Otter Tail, Todd, and Wadena Counties. The proposed expansion of PRRF and modification to the South Unit is in response to increased waste availability in the service area, continued demand for steam generated by the facility, and future MSW demands from the PLMSWA counties. The service area is shown in Figure 3-1. Specifically, the service area includes all residential, commercial, and institutional generators of MSW located within each county. 3.2 PORTIONS OF SERVICE AREA INCLUDED IN THE PLAN PLMSWA manages the policies and operations for solid waste management within its political jurisdiction as per the PRRF Industrial Solid Waste Management Plan, which can be found in Appendix A. Additionally, two of the counties have their own existing Solid Waste Management Ordinances. A draft Solid Waste Management Ordinance has been prepared by the four counties and will likely be adopted and implemented in late The Becker County Solid Waste Management Ordinance can be found in Appendix B. The Otter Tail County Solid Waste Ordinance can be found in Appendix C. The Draft Solid Waste Ordinance can be found in Appendix D. Since PRRF is owned by the PLMSWA, the service area of PRRF includes Becker, Otter Tail, Todd, and Wadena Counties. This MSP addresses the goals and approaches for separating certain components of the MSW stream for the counties as described in the PRRF Solid Waste Management Plan, county ordinances, and through the services provided by each county. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 3-1

9 Figure 3-1: PRRF Service Area \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 3-2

10 4.0 Waste Generation Rate This section provides information on the historical and projected rates of waste generation for the PRRF service area. Figure 4-1 presents historical waste generation data for 2002 through 2010 for Otter Tail, Stearns, Todd, and Wadena Counties, as these counties were sending at least a portion of their waste to PRRF. The average total waste stream over this period was approximately 258,000 tons per annum for these counties. (Source: SCORE Reports) No data are shown before 2002 as PRRF was shut down from 1999 through For purposes of planning the modification to the South Unit, the following assumptions were used to project future waste generation: A conservative growth rate of one percent per annum for Otter Tail, Todd, and Wadena Counties, based on recent MPCA guidance. Stearns County stopped sending waste to PRRF in 2010, while Becker County joined the PLMSWA in mid For , PRRF will continue to combust MSW at levels close to the present capacity, burning up to 116 tpd, or 42,340 tons per year (tpy). After the proposed modification is complete and the MRF is built in May of 2014, all material not removed by the MRF (6% removed as recycling and 10% removed as fines) would be combusted up to the maximum system capacity of 73,000 tpy. The total waste stream generation figures for the period from is presented in Figure 4-2. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 4-1

11 Figure 4-1: Historical Waste Trends Otter Tail, Stearns, Todd, and Wadena Counties \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 4-2

12 Table 4-1: Historical Waste Disposal from Otter Tail, Stearns, Todd, and Wadena Counties (tons per year) Total Waste Recycled 137, , , , , , , ,902 97,106 Total Waste Combusted 79,051 73,877 84,310 82,058 66,989 65,944 64,629 55,577 36,451 Total Waste Combusted - non-prrf 55,645 40,742 51,302 47,926 33,402 29,690 29,775 22,568 1,664 Total Waste Combusted - PRRF 23,406 33,135 33,008 34,132 33,587 36,254 34,854 33,009 34,787 Estimated Waste Disposed On-Site 6,404 6,390 6,193 3,623 3,590 3,381 3,426 3,308 3,308 Total Waste Landfilled 42,261 56,334 40,911 45,226 59,984 62,644 58,920 57,943 77,253 Total MSW 265, , , , , , , , ,118 Note 1. Total waste combusted includes MSW combusted at PRRF and other facilities \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 4-3

13 Figure 4-2: Projected Future Waste Trends Otter Tail, Becker, Todd, and Wadena Counties \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 4-4

14 Table 4-2: Future Waste Disposal from Otter Tail, Becker, Todd, and Wadena Counties (tons per year) Total Waste Recycled 39,336 39,983 40,641 41,311 41,992 42,684 43,363 44,053 44,754 45,467 46,191 Total Waste Combusted 34,787 35,301 35,822 36,351 36,887 37,432 37,982 38,540 39,107 39,609 40,087 Estimated Waste Disposed 2,301 2,299 2,296 2,294 2,292 2,290 2,287 2,285 2,283 2,280 2,278 On-Site Total Waste Landfilled 29,491 33,115 33,768 34,434 35,113 35,804 36,468 37,143 37,830 38,603 39,420 Total MSW 105, , , , , , , , , , , Total Waste Recycled 46,827 47,472 48,127 48,790 49,486 50,077 50,676 51,281 51,894 52,515 Total Waste Combusted 40,214 40,307 40,402 40,498 40,595 40,671 40,748 40,826 40,904 40,984 Estimated Waste Disposed 2,276 2,274 2,271 2,269 2,267 2,264 2,262 2,260 2,258 2,255 On-Site Total Waste Landfilled 40,433 41,496 42,573 43,666 44,818 45,811 46,817 47,835 48,866 49,910 Total MSW 129, , , , , , , , , ,664 Notes: 1. The waste combusted is assumed to be the maximum capacity of the facility when operating at 116 tons per day, or 42,340 tons per year. 2. The recycling rate is assumed to be constant using 2010 data. 3. Waste disposed on-site through burning or other methods is assumed to decline at 0.1% per year. 4. Municipal solid waste generated per capita in each county is assumed to increase at 1% each year. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 4-5

15 5.0 Materials Separation Goals and Methods In this section, the PLMSWA solid waste materials separation/recycling amounts and goals are presented for Waste Reduction, Hazardous Waste Management, Materials Recycling, Yard Waste Composting, Construction and Demolition Debris and Industrial Solid Waste. Also, the methods used by PRRF to accomplish materials separation are summarized. The materials separation methods combine public education efforts, publicly-owned recycling facilities, private recycling services, and initiatives by each county in the service area. The material separation/recycling rate for the PRRF Service Area Counties has increased from 34 percent in 1991 to 44 percent in The State of Minnesota currently has set a materials separation recycling goal of 35 percent. Collectively, Becker, Otter Tail, Todd, and Wadena Counties currently meet and exceed this State goal. Otter Tail County, which includes the city of Perham and the PRRF, has a Solid Waste Ordinance. Goals of the Ordinance include preserving and protecting the environment and supporting the use and reuse of materials, thus reducing total solid waste that must be disposed. To comply with Minnesota Statutes Chapters 115A, 116, and 400, solid waste management in Otter Tail County includes solid waste collection and disposal services, and solid waste transfer facilities as well as providing the services of a full time solid waste educator and comprehensive county-wide recycling collection and processing system. Becker County is committed to waste reduction, education, recycling, yard waste management, proper land disposal, and programs to aid tire recycling, appliance recycling, used oil and oil filter disposal, battery, and other household hazardous waste disposal. The County has a Solid Waste Ordinance to promote health, protect the environment, and preserve the economic land value of Becker County. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-1

16 The goals of Todd and Wadena Counties are similar to those of Otter Tail County and are managed in conjunction with the Otter Tail solid waste program. PRRF s materials separation recycling program consists of the following major components: Waste Reduction Hazardous Waste Management Materials Recycling Yard Waste Composting Construction and Demolition Debris Industrial Solid Waste Each of these components is described in more detail below. Waste Reduction Waste reduction and reuse is at the top of the hierarchy in solid waste management established by Minnesota Statute 115A.02 (b). The PLMSWA and the county members of the PLMSWA have education programs to encourage the public to reduce solid waste. County Solid Waste webpages encourage waste reduction by: providing information on ways to reduce waste, hosting the materials exchange network for managing material reuse (and therefore reducing the amount of new materials that need to be purchased), and promotes reusable grocery bags. County programs provide incentives for citizens to reduce waste generation by mandating volume or weight based disposal fees. The Ordinances require that commercial haulers offer volume or weightbased fees for MSW collection as an incentive to reduce MSW production. The transfer stations in the service area charge by volume or weight. This provides a financial incentive to waste generators to reduce their amount of MSW. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-2

17 Hazardous Waste Management All four counties in the PRRF service area provide opportunities for residents to dispose of their household hazardous waste (HHW). The goals of this are to prevent hazardous wastes from entering the MSW stream and to help protect the environment (land, air and water) by advocating proper management of hazardous materials. The hazardous waste programs include education, product exchange, and a regional mobile collection unit. Household Hazardous Waste programs provide residents with a disposal outlet for unusable, unwanted, or hard to get rid of hazardous wastes and materials. Ensuring proper elimination of HHW from the waste stream entering PRRF is important for waste toxicity reduction efforts. The separation and collection of hazardous waste is intended to reduce the volume of problem heavy metals (e.g., lead, cadmium and mercury) and organic compounds entering the waste stream. These hazardous wastes could contribute to toxic air emissions from the facility, higher metals levels in ash, ground water, and surface water, or air contamination from solid waste bypassed to a landfill. The Regional HHW Collection Facility accepts and manages Household Hazardous Waste. The primary focus of the HHW program is to reduce the toxicity of the incoming waste by removing certain materials. The following is a partial list of wastes accepted at the facility: aerosol cans containing product, automotive fluids (e.g., degreasers, antifreeze, and motor oil), cleaners (acids, bases, degreasers, heavy metals), paints and stains (oil and latex), including thinners and removers, pesticides, insecticides, herbicides, wood preservatives, chlorinated and non-chlorinated solvent-based products, mercury products, rechargeable and button batters, pool chemicals, and resins/epoxies/roofing tars. Both the Todd County Transfer Station in Browerville, Minnesota and the Wadena County Transfer Station in Wadena, Minnesota include a household hazardous waste facility that accepts HHW from its residents and will accept the products listed above. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-3

18 Materials Recycling The counties in the PRRF service area all have recycling programs that correspond with the second level in the Minnesota waste management practices hierarchy. Otter Tail County operates the Perham Recycling Redemption Center on the southwest corner of the facility property. Otter Tail also has recycling centers in Fergus Falls and Pelican Rapids which serve to remove recyclables from the waste stream at their source. There are 24 additional recycling canister locations for residents to drop off their glass, plastic, aluminum, tin, magazines and catalogs, newspaper, phone books, corrugated cardboard, and office/compute paper. The Otter Tail County Solid Waste website also provides educational materials about what is recyclable, how to recycle, and tips for recycling in the workplace or classroom. The 2010 Otter Tail County recycling rate is 31 percent. Additionally, Otter Tail County recycles concrete and shingles at its county-owned demolition landfills. Becker County accepts plastic, metal, glass, cardboard, and paper for recycling. There are 47 recycling shed drop-off locations and one central recycling center. Curbside recycling is offered in the city of Detroit Lakes on a weekly basis. Other curbside recycling is provided by individual waste haulers on an as-needed basis. Becker County also works with two municipalities on commingled recycling programs. The Becker County Environmental Services website includes educational information on increasing recycling, how, and where to recycle materials. Materials collected from the Demolition Landfill, such as shingles, clean wood waste, and concrete, are separated and collected for recycling. All cities and townships in Becker County participate in recycling. Per the Becker County Solid Waste Ordinance, all solid waste haulers must provide education and incentives to recycle. More information about Becker County recycling can be found in the Becker County Solid Waste Plan Update. The 2010 Becker County recycling rate is 44 percent. The Todd County Board of Commissioners adopted a resolution on June 21, 2011, to offset the cost of hauling recyclables at residential sites. Recycling collection is provided by licensed waste haulers for all residents in city limits and most residents outside of city limits. Recyclables are hauled to the Todd County Recycling Center in Browerville, Minnesota. This policy is an example of how to increase recycling service at residences. Residents may also bring appliances, auto batteries, electronics, and \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-4

19 fluorescent bulbs directly to the Todd County Transfer Station for recycling. The 2010 Todd County recycling rate is 60 percent. Wadena County has a comingle program to recycle aluminum, tin, steel, corrugated and cereal box-type cardboard, glass, magazines, paper, and plastic. Curbside or centralized recycling pickup is available in all cities and townships. Wadena County also provides compartmentalized recycling containers for six of the major cities and townships. The central transfer station provides recycling services. The Wadena County Solid Waste website provides links to educational sites to increase the amount and ease of recycling for residents. The 2010 Wadena County recycling rate is 52 percent. The State of Minnesota compiles data annually regarding the types and amount of materials that have been separated and recycled for all abatement areas in each county, and determines each county s materials separation recycling percentage. These annual compilations are referred to as SCORE (Select Committee on Recycling and the Environment Reports. The SCORE data used throughout this MSP is based on information from MPCA published SCORE Reports. The most recent SCORE data available is for The materials separation/recycling data for the counties in the PRRF service area for 2010 are presented in Table 5-1 at the end of this section. The proposed modification of PRRF includes the addition of a MRF. The MRF would enable PRRF to remove problem materials from the waste stream such as mercury switches, lead acid batteries and drywall, and also would reduce the amount of recyclable material in the waste combustion stream. The policies already in place in the four service area counties, as well as the addition of the MRF show the PLMSWA s commitment to recycling and removing useful materials from the waste stream before incineration. Yard Waste Composting Yard waste has been banned from landfills and waste-to-energy facilities since County education programs encourage home management of yard waste through back yard composting and mulching. County webpages provide information with resources on how to compost and use compost, as well as how to solve common problems with composting. For residents who elect not to compost in their own \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-5

20 yard, they may bring yard waste to most of the County-owned transfer stations or landfills. Counties have an incentive to increase their yard waste composting because the SCORE report calculates an adjusted recycling rate that includes a credit for yard waste recycling. Construction and Demolition Debris Construction and demolition debris is handled by each county to keep it out of the waste stream that would be sent to PRRF. There are three landfills in Otter Tail County, two landfills in Becker County, one landfill in Todd county and one landfill in Wadena County that accept construction & demolition (C&D) debris. Accepted material includes concrete, masonry and bricks, bituminous concrete, untreated wood, roofing/shingles, insulation, asphalt, conduit, and tree stumps. Certain materials including asbestos, glue, tar, caulking, resins, treated lumber, new construction materials, and household garbage are not accepted at these demolition landfills. Counties allow Permit by Rule demolition for waste generated by the construction or demolition of individual structures to be buried on-site. This is a one-time approval and is only allowed by permit with approval by the appropriate administrator. Industrial Solid Waste The Perham Resource Recovery Facility accepts non-hazardous industrial solid waste in accordance with its Industrial Solid Waste Management Plan (ISWMP). Customers to PRRF include industrial solid waste generators. Before accepting any waste, PRRF screens potential customers to ensure only qualified wastes come to the facility. Customers receive a Non-Hazardous Industrial Solid Waste Incineration Program Description and fill out and return an Application for Incineration of Non- Hazardous Industrial Wastes. The Application identifies the customer; the type of packaging and quantities of waste; provides a written description of the waste and the process that generated it; identifies the physical characteristics of the waste; identifies any special classes of waste such as waste contaminated with used oil or petroleum spill media; communicates any analytical testing requirements \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-6

21 based on the ISWMP; obtains generator knowledge about the waste; and certifies that the waste conforms with the application. Acceptable waste generators are sent a Certificate of Waste Approval and a Scheduling, Packaging, and Transportation Requirements form. To establish whether analytical testing of waste is required, PRRF reviews all available information, including the Application for Incineration, applicable Material Safety Data Sheets (MSDS), and the generator s certification. PRRF manages non-hazardous industrial solid wastes, RCRA-exempt wastes including waste contaminated with used oil and petroleum spill media, and other wastes the facility is authorized by MPCA to incinerate. The waste must meet certain criteria, including that it is combustible, that the combustion of the waste will not release substances which threaten the welfare of employees or the environment, and that the combustion of waste will not release pollutants in excess of emission limits imposed on PRRF. All waste is inspected and should be burned within five days of its arrival at PRRF. Upon combustion, the generator receives a Certificate of Destruction. Industrial solid waste is mixed with municipal solid waste for burning to ensure proper incineration and handling. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-7

22 Table 5-1: Materials Separation and Recycling Data for PRRF Service Area (tons in 2010) Category Item Otter Tail County Becker County Todd County Wadena County Service Area Total Banned Antifreeze Banned Electronics Banned Fluorescent & HID lamps Banned HHW Banned Latex paint Banned Major appliances Banned Used oil Banned Used oil filters Banned Vehicle batteries Banned Waste tires Subtotal 1, ,740 Glass Food & beverage ,605 Subtotal ,605 Metal Aluminum Metal Co-mingled alum/steel/tin Metal Other ferrous & non-ferrous 3, ,456 9,689 Metal Steel/tin cans Subtotal 4, ,606 10,532 Paper Corrugated 1,950 5,477 1,343 1,201 9,971 Paper Magazine/catalog Paper Mixed paper , ,624 Paper Newsprint 816 1, ,035 Paper Office paper Paper Phone book Paper Other paper Subtotal 3,099 7,313 11,417 1,296 23,125 Plastic Film plastic Plastic HDPE Plastic Other plastic Plastic PET Plastic Mixed plastic Subtotal ,185 Other Pallets Other Mattresses & box springs Subtotal Textiles Textiles \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-8

23 Category Item Otter Tail County Becker County Todd County Wadena County Service Area Total Subtotal Total County Recycling Total 9,605 9,645 12,525 7,561 39,336. Yard Waste Composting 2,079 1,345 1, ,445 Credit Waste Reduction Credit 1, ,267 Total Materials Separated for Recycling Total Solid Waste Generated Total Adjusted Recycling Rate 12, ,797 14,443 8,548 48,048 41,57 26,902 23,972 16, , % 44% 60% 52% 44% \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 5-9

24 6.0 Residual Waste Projection "Residual waste", for the purpose of this plan, is defined as the amount of waste remaining after existing waste abatement, separation, and processing efforts have been applied. In the case of the PLMSWA system, processing includes the waste currently being combusted for energy production at the existing PRRF. When Becker County starts sending waste to PRRF, the facility s capacity for processing solid waste would be exceeded, causing excess combustible waste to be sent to a landfill. Once the proposed modification is made to the South Unit and the MRF is in place, however, PRRF would be able to handle all the waste from Otter Tail, Becker, Todd, and Wadena Counties. As seen in Figure 4-2, capacity should last until 2030 based on conservative assumptions. Total waste information is presented in Section 4.0 and data on separated and abated waste is contained in Section 5.0. Residual waste data for the Counties of Otter Tail, Becker, Todd, and Wadena, both historical and projected, is presented in Table 6-1. Residual waste will drop to zero with the proposed project. Residual waste without the project is the waste delivered to PRRF above its current processing capacity of 42,340 tpy, which assumes a "no action" scenario, meaning the PRRF integrated waste management systems operate far into the future with no substantial change other than the growth of the total waste stream. Table 6-1: PRRF Waste Management Residual Waste (tons per year) 2010 actual 2015 projected 2020 projected 2025 projected Total Waste Generated 105, , , ,577 Total Waste Brought to PRRF 48,805 56,748 59,643 62,685 Amount Separated at MRF - 9,080 9,543 10,030 Amount Combusted 41,805 47,668 50,100 52,655 Residual Waste 7, Residual Waste without Project NA 14,408 17,303 20,345 \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 6-1

25 The data presented in Table 6-1 indicates the current amount of total waste generated in the services area far exceeds the current capacity of the integrated waste management system for the service area, resulting in potentially significant landfill disposal of residual waste. When the proposed project is finished; however, the increase in processing capacity would be sufficient to eliminate residual waste until 2030, even accounting for conservative municipal solid waste generation estimates. Additionally, with the expanded capacity, PLMSWA would continue to be able to meet the steam demand from Tuffy s and Bongards. Discussion of the alternatives for management of the residual waste is presented in Section 7.0. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 6-2

26 7.0 Alternate Disposal Methods After the MSW generated in the service area is reduced through public and private waste abatement efforts via reduction, reuse, recycling and composting, the remaining fraction ( residual waste, as defined in the NSPS for purposes of a Materials Separation Plan) must be disposed. The proposed expansion is one way to dispose of the region s solid waste. Other methods of disposal were also considered and are described in this section. Over the course of several years, various discussions regarding the handling of regional solid waste have occurred in the Otter Tail County area. In 2006, Becker, Cass, Clay, and Otter Tail Counties, and the Cities of Fargo, Grand Forks, Moorhead, and West Fargo, in partnership with the MPCA, formed the Red River Valley and Lakes Region Solid Waste Panel. This Panel reviewed the existing conditions of solid waste in the region, including remaining life expectancy of the region s landfills, current quantities of MSW, and handing of MSW. The Panel contracted with a consultant to complete a technical assessment of alternative waste disposal options for the region. In March 2007, this technical assessment, the Alternative Waste Feasibility Study, was completed. This study reviewed a variety of options for handling MSW in the region, including different commercially demonstrated technologies and locations within the region that were feasible for implementation. Some of the options included MSW combustion, landfill with baler, plasma gasification, composting, and hydrolysis. From the study, the Panel narrowed the most feasible alternatives down to a MSW combustor and landfill. The Alternative Waste Feasibility Study provides greater detail on what technology alternatives were considered and background information regarding MSW in the region. If no action is taken, the life expectancy of landfills in the region would be decreased. MSW would continue to need a location for disposal, and therefore decreased landfill life expectancy would require expanding and/or siting new landfill facilities in Minnesota or North Dakota. This \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-1

27 is a less desirable alternative due to the requirement of finding, permitting, and developing a new landfill site within a feasible hauling distance of the MSW source. Following completion of the Alternative Waste Feasibility Study, some members of the Panel decided to continue handling waste outside of the Red River Valley and Lakes Region partnership. Otter Tail County, along with Becker, Todd, and Wadena Counties, formed the Prairie Lakes Municipal Solid Waste Authority to handle MSW on a more coordinated regional basis. The PLMSWA considered the findings of the Alternative Waste Feasibility Study along with the specific circumstances in their four-county area. There is one operating MSW combustor located in the City of Perham. There is MSW in the region that is currently being hauled outside of the region that could be used at the PRRF if it had more capacity. There is a steam demand from existing customers that could be satisfied through increased processed MSW combustion. Alternative sites for a new MSW combustor were considered to not have significant environmental benefit compared to the Proposed Project, which would use an existing site and make modifications to an existing facility. PLMSWA also considered alternative designs and layouts for the project. These included where to locate the MRF on the existing site, emissions stack placement, haul routes, facility access, and location of existing customers. Additionally, an adjacent parcel to the north would be purchased as part of the Proposed Project. The scale and magnitude of the Proposed Project were determined based on the characteristics of the existing site and the infrastructure in place. Changes in scale or magnitude would not meet the underlying need for or purpose of the Proposed Project. Other solid waste disposal alternatives were also considered when the Fergus Falls Waste-to- Energy plant closed in The City of Perham evaluated a number of alternatives in 2007 to determine the best option with the assumption that the waste would be handled at PRRF. The alternatives considered and basis for decision-making were published as a conference paper entitled MSW Contingency Planning Opportunities for Perham Facility Expansion. This paper was presented and published at the 15 th North American Waste to Energy Conference in Miami, Florida, in 2007 and is included in this MSP in Appendix E. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-2

28 The three options discussed in the paper were the following: 1. Add an additional boiler train. 2. Add a Material Recovery Facility (MRF). 3. Add an additional boiler train and MRF. An economic analysis was performed for the three alternatives that evaluated the current capacity, demand for steam, availability of combustible waste, and evaluating no-build options such as sending the excess waste to the Pope/Douglas Solid Waste Management Facility (Pope/Douglas) or to regional public or private landfills. The economic analysis determined that alternative 3 would result in the highest tipping fee. However, it is the most compatible option with the Minnesota policy for solid waste management, as it includes more recycling, more waste-to-energy, and less landfilling than continuing with the status quo. Option 3 is the preferred option since: 1) Stearns County now sends its waste to Pope/Douglas; and 2) Becker County is part of the PLMSWA agreement and sends its waste to PRRF. The specifications for Option 3 include adding an additional heat recovery boiler and associated air pollution control equipment for the South Unit. The second boiler would allow each unit to operate at its capacity of 100 tpd of waste, for a total capacity of the facility of 200 tpd. Currently, having a single HRB limits the capacity to 116 tpd. Steam demands from the facility are 300,000,000 pounds of steam. To meet demand, since only 200,000,000 pounds of steam can be produced from the current configuration, an auxiliary natural gas boiler is used to provide the additional 100,000,000 pounds of steam. Option 3 increases the expected output of steam from the waste-to-energy portion of the facility to 260,000,000 pounds per year. Based upon the assumption of a 200 tpd capacity for PRRF beginning in May, 2014, Figure 7-1 shows the impact of landfilling projected for the twenty-year planning period. This figure also assumes equivalent replacement of the North Unit when it becomes necessary to maintain MSW processing potential. If the proposed project were not constructed, the scenario from Figure 4-2 showing growth of MSW without increased incineration capacity would be the likely scenario. Waste from the four \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-3

29 counties would end up in landfills in Gwinner or Fargo, North Dakota, or Elk River or Greater Morrison, Minnesota. The benefits of expansion according to the proposed project include responsible waste disposal following the MPCA/EPA hierarchy of disposal options, state and federal recognition for increased renewable energy, reduced use of fossil fuels, reduced greenhouse gas emissions, reduced landfill liability, job creation, and economic stimulation in the area. Alternatives that would not have increased the incineration and steam generation capabilities of PRRF or would not have included a MRF would not have been as beneficial. \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-4

30 160,000 Figure : Projected Future Waste Trends for Proposed for Proposed Project Project Becker, Otter Tail, Todd, and and Wadena Counties Counties , , ,000 80,000 60,000 40,000 20, Municipal Solid Waste (tons) Total MSW MSW directly landfilled MSW directly recycled MSW sent to PRRF MSW recycled at PRRF (5-8%) MSW fines landfilled from PRRF (10%) Other MSW landfilled from PRRF MSW Combusted \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-5

31 Table 7-1: Perham Resource Recovery Facility Waste Management Residual Waste (tons per year) Total MSW 105, , , , , , , , , ,631 Per capita MSW (tons/person/year) Population 128, , , , , , , , , ,084 MSW directly landfilled 9,210 6,394 7,376 8,375 5,792 6,264 6,711 7,169 7,638 8,119 MSW directly recycled 47,900 48,697 49,508 50,333 51,172 52,026 52,864 53,715 54,580 55,460 MSW sent to PRRF 48,805 52,586 52,586 52,586 56,186 56,748 57,315 57,888 58,467 59,052 MSW recycled at PRRF (5-8%) ,371 3,405 3,439 3,473 3,508 3,543 MSW fines landfilled from PRRF (10%) ,619 5,675 5,732 5,789 5,847 5,905 Other MSW landfilled from PRRF 7,000 10,246 10,246 10, MSW Combusted 41,805 42,340 42,340 42,340 47,196 47,668 48,145 48,626 49,113 49, Total MSW 124, , , , , , , , , ,208 Per capita MSW (tons/person/year) Population 136, , , , , , , , , ,852 MSW directly landfilled 8,611 8,963 9,322 9,689 10,063 10,482 10,746 11,015 11,289 11,568 MSW directly recycled 56,354 57,137 57,931 58,736 59,552 60,411 61,146 61,891 62,646 63,409 MSW sent to PRRF 59,643 60,239 60,841 61,450 62,064 62,685 63,312 63,945 64,584 65,230 MSW recycled at PRRF (5-8%) 3,579 3,614 3,650 3,687 3,724 3,761 3,799 3,837 3,875 3,914 MSW fines landfilled from PRRF (10%) 5,964 6,024 6,084 6,145 6,206 6,268 6,331 6,394 6,458 6,523 Other MSW landfilled from PRRF MSW Combusted 50,100 50,601 51,107 51,618 52,134 52,655 53,182 53,714 54,251 54,793 Notes 1. Assume all combustible waste currently sent straight to the landfill goes to PRRF instead beginning in 2014 when capacity increases. 2. Assume recycling rate consistent with Becker, Otter Tail, Todd, and Wadena 2009 recycling rate. 3. Maximum processing capacity at PRRF after the modification is tpy. 4. Municipal solid waste generated per capita is assumed to increase by one percent per year. Population growth rates are based on the June 2007 Minnesota State Demographic Report, "Minnesota Population Projections " \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 7-6

32 8.0 References 1. Becker County, Solid Waste Management Ordinance of Becker County. November Becker County, Solid Waste Plan Update, Becker County, Minnesota. 3. Becker County Department of Environmental Services. Accessed October 17, City of Perham, Traeger, David; Clark, Matt; Louiseau, Robert. MSW Contingency Planning Opportunities for Perham Facility Expansion. 15th North American Waste to Energy Conference, May 21-23, 2007, Miami, Florida. NAWTEC Minnesota OEA, Report on 2009 SCORE Programs, Minnesota Office of Environmental Assistance (OEA), St. Paul, Minnesota, December 2010, and similar SCORE reports for 2002 to Otter Tail County Solid Waste Transfer Stations US EPA, Municipal Waste Combustion: Background Information Document for Promulgated Standards and Guidelines Public Comments and Responses, EPA-453/R , October Otter Tail County Solid Waste Ordinance, October 23, Todd County Solid Waste Fee Schedule. Accessed October 17, Psihos & Associates, Industrial Solid Waste Management Program: Perham Resource Recovery Facility. January US EPA, New Source Performance Standards for New Small Municipal Waste Combustion Units; Final Rule, 40 CFR 60, Subpart AAAA, published in the Federal Register, V65, No. 235, December 6, Wadena County Household Hazardous Waste. Accessed October 17, \\francis\vol1\2415\03\05 NSPS Compliance\Materials_Separation_Plan\Revised MSP\Revised Materials Separation Plan.docx 8-1

33 Appendix A Perham Resource Recovery Facility Industrial Solid Waste Management Plan

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111 Appendix B Becker County Solid Waste Management Ordinance

112 SOLID WASTE MANAGEMENT ORDINANCE OF BECKER COUNTY November 13, 2001

113 SOLID WASTE MANAGEMENT ORDINANCE OF BECKER COUNTY Table of Contents Sectio Title n 1 Purposes and Authorization 1 Subdivision 1 Purpose 1 Subdivision 2 Authorization 1 2 Title 1 3 Jurisdiction, Scope, Interpretation and Severability Subdivision 1 Jurisdiction 2 Subdivision 2 Scope 2 Subdivision 3 Interpretation 2 Subdivision 4 Severability 2 4 Rules and Definitions 2 Subdivision 1 Rules 2 Subdivision 2 Definitions 3 5 General Provisions 8 Subdivision 1 Disposal 8 Subdivision 2 License 8 Subdivision 3 Performance 10 Bond Subdivision 4 Insurance 10 6 Solid Waste Administrator 10 7 Solid Waste Storage 11 8 Collection and Transportation of Solid Waste Page 2 12