fvrd requirements - burnaby incinerator operational certificate - final

8/13/2019 FVRD Requirements - Burnaby Incinerator Operational Certificate - FINAL

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This document contains the Fraser Valley

Regional Districts comments in response to the

Notice of Intent to Issue Operational Certificate10751 under the provisions of the

Environmental Management Act.

Required Amendments

to the Burnaby

Incinerator Operational

CertificateDecember 20, 2014

Environmental Services DepartmentFraser Valley Regional District


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FVRD RequirementsBurnaby Incinerator Draft Operational Certificate Page | 1

Required Amendments to the BurnabyIncinerator Operational Certificate

Part 1 - Introduction and Overarching Comments

The FVRD has carefully reviewed the Draft Operational Certificate for the Burnaby Incineratorissued November 22, 2013 (dated November 21, 2013). The version received is attached inAppendix 1. Notably, there was no Site Plan A drawing depicting locations of stacks andmonitoring ports included in the Draft Operational Certificate, yet it was referenced in thatdocument. Follow up communication with Chris Allan of Metro Vancouver (November 29, 2013and December 2, 2013) provided a general overview of the facility, as well as a schematic of thefacility. However, this schematic did not include details alluded to in the Draft OperationalCertificate, such as reference numbers for discharges. Thus, we found the Draft OperationalCertificate to be incomplete.

There are a number of comments on the content of the Draft Operational Certificate, detailed inPart 2 of this submission. We assert that several requirements be added to the text of theOperational Certificate, and have displayed the requirements in boxes for ease of reading.These requirements are based on review of international best practice or expertrecommendation, and are referenced in the relevant section.

As indicated, comments and requirements relating to specificsections of the Draft OperationalCertificate follow in Part 2 of this document. The following overarching requirements apply to theoverallOperational Certificate:

There must be an accessible public website to display information pertaining to the operationand 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 monitoringsystems data, stack test data, etc.), as well as other notifications such as maintenancereports, emergency situations, fuel load inspection reports, and other information, as wellas the Operational Certificate itself. The public website must include, at a minimum, all ofthe 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


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Air pollution control devices manufacturers 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 informationb. 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 requirementsof the individual sections) and must remain posted throughout the entire operating life ofthe Burnaby Incinerator. All documents must be posted on the public website for theduration of the operational life of the Burnaby Incinerator. Even if a report becomesoutdated (i.e. the Environmental Management System document that must be updatedannually), it must still be available on the public website as long as the facility is stilloperating.

A overall report on emissions, inspections, maintenance, accidents, and shut downs must beprepared annually, and posted on the public website.

Requirement 2:

a. An annual public report (hereafter called the annual report must be completed andposted 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 specificitems required throughout this submission, including but not limited to those outlined inRequirement 1.

All testing and inspections must be conducted by qualified independent third parties to preventconflict 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 accountable to the BC Ministry of Environment. Maintenance, samplingand audits will be performed on an unscheduled basis, that is they will be unannounced, suchthat the Operational Certificate Holder and Operator cannot specifically prepare for the relevanttest. This type of unannounced auditing and testing is in place in many other facilities andworkplaces (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 thirdparties.

b. All reports on the individual actions (such as maintenance inspections) as well as annualreports summarizing all facility activity, must clearly identify the independent qualifiedthird 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, withoutnotice.

As has been included in the individual requirements detailed in Part 2 of this submission, theconsequences of failing to comply with the conditions of the Operational Certificate are notwritten 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 theCertificate Holder and Operator, such that compliance is ensured.

Requirement 5:The consequences of failing to comply with the conditions of the Operational Certificate must beclearly 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, foodproduct monitoring (particularly for bovine milk) or human biomonitoring in this Draft OperationalCertificate, all of which are critical components of a gold standard monitoring program and havebeen done at various incinerators around the world, as outlined in the Jacques Whitford 2009review.1

Many of the programs were conducted in advance of the facilities initial startup (as was donefor soil and vegetation monitoring at the Burnaby Incinerator), however, many of theinternational examples provided in the Jacques Whitford review did conduct additionalmonitoring 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 wascarried 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

1Jacques Whitford. Final Report: Review of International Best Practices of Environmental Surveillance forEnergy-From-Waste Facilities. 2009. Available from:http://www.metrovancouver.org/services/solidwaste/planning/ReportsforQA/InternationalBestPracticesEnergyfromWasteFacilities.pdf


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been studied elsewhere.2 In the case of the Burnaby Incinerator, it is good that there is somebaseline data on soil and vegetation characteristics before the facility was operational, andnearly 26 years after it has been in place, we require that additional monitoring be conducted todetermine 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 FVRDs overarching comment is that the polluter must demonstrate that they are notadversely affecting human health and the environment. The onus is on the polluter toconduct as much monitoring as possible on as many parameters as possible, todetermine the impact of their facility on the surrounding environment. It is not acceptableto assume that no impact has been had on soil, vegetation, water, food products, orpublic health without rigorous monitoring and evaluation to confirm. The long-termimpacts of the Burnaby Incinerator, in operation since 1988, can and must now beevaluated 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.3The monitoringwas then discontinued. It is not known what impact the facility has on soil and vegetationcurrently, or what the trend over time has been due to this lack of information. At present, soiland vegetation monitoring should be reinstituted, to determine how contaminant levels in soiland 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, particularlysalmon, are an important food source for First Nations and non-First Nations residents of theLower Fraser Valley. Dioxins and furans, pollutants emitted from the incinerator, tend tobioaccumulate, 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 todetermine the extent of this exposure.

2Caserini S, Cernuschi S, Giugliano M, Grosso M, Lonati G, Mattaini P. Air and soil dioxin levels at threesites in Itality in proximity to MSW incineration plants. Chemosphere. 2004;54(9);1279-87.3Greater Vancouver Regional District. Burnaby Incinerator: Summary of Soil and Vegetation MonitoringData. 1992. Available from:http://www.metrovancouver.org/services/solidwaste/planning/ReportsforQA/BurnabyIncineratorSummaryofMonitoringData.pdf


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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 Book4

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 chemistryparameters in the surface soil horizon (0-5 cm depth, 5-10cm depth), mid-soil (10-25 cmdepth), 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 accordancewith the previous Burnaby Incinerator soil and vegetation monitoring program, and inaccordance with vegetation monitoring programs around other facilities: arsenic,beryllium, cadmium, chromium, lead, mercury, manganese, nickel, selenium, thallium,vanadium, fluoride, sulphur, polychlorinated biphenyls (PCBs), polyaromatichydrocarbons (PAHs), and dioxins and furans.

e. Annual reporting must be included in the overall annual report and posted on the publicwebsite.

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 Portugalsuch 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 publicwebsite.

c. The consequences of failing to comply with the requirements must be specified in theOperational 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

Book4developed in 1986 for the Burnaby Incinerator. This includes, but is not limited to:leaf tissue chemistry, root tissue chemistry, fruit tissue chemistry, forage metals, foragefluoride, premature demolition, leaf chlorosis, leaf necrosis.

c. At a minimum, the following parameters must be monitored in accordance with theprevious Burnaby Incinerator soil and vegetation monitoring program, and in accordancewith vegetation monitoring programs around other facilities: arsenic, beryllium, cadmium,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 publicwebsite.

e. The consequences of failing to comply with the requirements must be specified in theOperational Certificate.

4Khare et al. Assessment and Recommendations on Emission and Monitoring Requirements for GreaterVancouver Regional District Incinerator Located in Burnaby. 1986.


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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 in2014, and repeated on an annual basis.

b. At a minimum, the following parameters must be measured in milk and meat produced inthe Lower Fraser Valley, to be consistent with the soil and vegetation monitoring

program: arsenic, beryllium, cadmium, 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 publicwebsite.

d. The consequences of failing to comply with the requirements must be specified in theOperational 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 surveillanceprogram, including wildlife and fish tissue monitoring, at the Swan Hills Treatment Centrecan be reviewed for precedent.5

b. Annual reporting must be included in the overall annual report and posted on the publicwebsite.


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 andcarried 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 BurnabyIncinerator, as well as a control group should be tested for the following parameters, at aminimum: dioxins and furans, PCBs, PAHs, metals (antimony, arsenic, beryllium,cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, selenium,thallium, tin, vanadium, and zinc) and any metabolites. There are many precedentreports referenced in the Jacques Whitford 2009 review.

c. Annual reporting must be included in the overall annual report and posted on the publicwebsite.


5Alberta Health and Wellness. Swan Hills Treatment Centre: Long-term follow-up healthassessment program (1997-2002) . 2004. Available from: http://www.health.alberta.ca/documents/Swan-Hills-Report-2004.pdf


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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 theBurnaby Incinerator are listed below. Information quoted directly from the Draft OperationalCertificate 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 withthe section, including: there are many parameters that should be measured that are missingfrom the list, and most if not all of those parameters can and must be measured by ContinuousEmissions Monitoring Systems (CEMS).6As is highlighted in Section 3.3 Discharge Monitoringfor Subsection 1.1 in the Draft Operational Certificate, many of the parameters on the list thatare currently measured by manual stack testing and proposed to continue that way, aremeasured only once per year, or some up to three times per year. Testing is conducted on ascheduled basis during normal operating conditions, when everything is functioning properly.This provides a very brief snapshot into the overall annual emissions. Where technology existsto monitor emissions continuously, it must be done.

The fact that manual stack testing is only conducted once per year for many of thecontaminants most concerning to human health, including dioxins, furans, chlorobenzenes,chlorophenols, polychlorinated biphenyls, and polycyclic aromatic hydrocarbons is trulyalarming. 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 averageconcentrations? In this monitoring scheme, there is no way to determine when peak emissionsoccur, how frequently they occur, and how high they are when there is one measurement doneper year.

Stack tests are presently conducted three times per year for total particulate matter (TPM), tracemetals (including cadmium and mercury), total hydrocarbons, hydrogen chloride (HCl),hydrogen fluoride (HF), sulphur dioxide (SO2) and nitrous oxide (N2O), which also gives a veryblurry snapshot into the emissions patterns of these pollutants.

There is no way of knowing whether these sparse measurements represent average, low orhigh concentrations, because there is simply not enough data collected to compare. What willthe emission levels be the other 362+ days in the year? It is not likely these spot measurementsare representative of annual emissions considering the variability of waste which feeds theincinerator. People are exposed to emissions on an ongoing basis and to fluctuating levels ofcontaminants, 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 unknowntoxicity, which are not monitored or regulated.

It is imperative that CEMS monitoring data is posted during all operating periods, especiallystartup, shut down, and upset periods. These are times when emissions are likely to besignificantly different than during normal operation, most likely considerably higher. One studyconducted by the United States Environmental Protection Agency found that emissions ofPCDD/F (dioxins and furans) during startup, shut down, and other upset conditions, was one totwo orders of magnitude greater than during normal operations (ten to one hundred times

6United States Environmental Protection Agency. Environmental Technology Verification Program. 2013.Available from: http://www.epa.gov/etv/vrvs.html#amsca


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greater).7 Without continuous monitoring during these periods, we do now know if a similarpattern is occurring at the Burnaby facility.

CEMS data must be posted on the public website in real time. Quality Assurance/QualityControl procedures for the data shall be conducted in accordance with a documented methodacceptable 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 PM10and PM2.5 must to be includedas well. These are parameters that the Burnaby Incinerator reports to Environment CanadasNational Pollutant Release Inventory (NPRI) each year.8 The 2012 reporter comments in theNPRI submission for PM10and PM2.5 state, Changes in estimation methods is due to a changein results (concentration levels) from the latest manual stack tests. which suggests that theOperator is testing for these parameters already, they are just not currently required in theirOperational Certificate and are therefore not reported to the BC Ministry of Environment. Thereis an incredible volume of peer-reviewed literate on the adverse health effects of PM 10, PM2.5and smaller particles, and as those two fractions have ambient air quality standards in BC 9, it isnecessary that PM10and PM2.5are 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 bymass, yet it is the smaller particles (PM10and PM2.5) are the ones that travel deeper into therespiratory tract, and have a more significant health impact. The BC Ministry of Environmentmust also propose discharge limits for PM10and PM2.5 from the Burnaby Incinerator. Ultrafineparticles (UFP), those with an aerodynamic diameter less than 1 or 0.1 m (depending on whichdefinition you look at), while not regulated currently, should also be measured for informationalpurposes. This monitoring will be useful when potentially determining future emission limits ofthis size fraction.

There are a number of metals that are referenced as being measured by other municipal solidwaste incinerators around the world as noted in the Stantec 2011 and Jacques Whitford 2009review which are not included in the Burnaby Incinerators 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, andzinc. The Burnaby Incinerators own soil and vegetation monitoring program summary from1992 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 bemeasured. Technology exists to measure these substances in real time and therefore to getaccurate measurements of actual emissions, instead of estimating emissions using calculationsand assumptions at the end of the year for NPRI reporting.

Further, some of the emissions limits proposed in the Draft Operational Certificate for thesubstances that are there are not in line with the most stringent standards in the world. TheMinistry of Environments own commissioned review, conducted by Stantec in 2011 states that

NOXemissions limits in Austria and Sweden are 70 mg/dscm, whereas the number listed in the7Gullett B, Touati A, Oudejans L, Ryan S, Tabor D. Transient PCDD and PCDF Concentrations in anMWC. Organohalogen Compounds. 2006:68;143-6.8Greater Vancouver Sewerage and Drainage District: Metro Vancouver Waste to Energy Facility.National Pollutant Release Inventory. 2013. Available from: http://ec.gc.ca/inrp-npri/donnees-data/index.cfm?do=facility_substance_summary&lang=en&opt_npri_id=0000000362&opt_report_year=2011#cac9BC Ministry of Environment. British Columbia Ambient Air Quality Objectives. 2013. Available from:http://www.bcairquality.ca/reports/pdfs/aqotable.pdf


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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 leastthat the strictest limits included in the review that exists are actually used. Careful scrutiny ofemissions limits for all substances currently listed on the discharge table in Section 1.1.3 and allnew substances listed in Requirement 12 is required.

Temperature in the secondary combustion zone should also be continuously monitored andposted on the public website in real time.

Finally, there are a number of additional parameters that can and should be measured byCEMS technology. Although there is not a precedent set for monitoring these parameters atother incineration facilities, the technology exists to measure these substances and the FVRDexpects these to be routinely monitored or regularly quantified, to determine what amount isbeing emitted. As the Stantec 2011 review report quoted, the Province of British ColumbiasStrategic Plan 2010/11 2012/13 includes this as one of its five great goals for a goldendecade: Lead the world in sustainable environmental management, with the best air and waterquality, and the best fisheries management, bar none.10 These substances should bemeasured 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. Tobe in line with achieving the best air and water quality in the world, emissions from pollutersmust be measured as comprehensively as possible. It is acknowledged that some of theseparameters are covered by other groupings of parameters (i.e. total volatile organic compoundsare covered by total organic compounds, benzene is a volatile organic compound, etc.), but themore measurements that are collected, the more information on the emissions from this facilitywill 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 DraftOperational Certificate under Section 1.1.3 and those listed above in Requirement 12must be completed by the Ministry of Environment. Emissions limits for all of thesesubstances 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. 2010. Available from:http://www.bcbudget.gov.bc.ca/2010/stplan/2010_Strategic_Plan.pdf


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than, the strictest standards in the world. As was pointed out earlier, some of theproposed emissions limits (i.e. for NOX) are multiple times higher on the DraftOperational Certificate than at other facilities around the world, as stated in the Stantec2011 review.

c. Ultrafine particles (both PM1and PM0.1) must be measured, but there does not need tobe 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 FVRDs findings on the United States Environmental ProtectionAgency Environmental Technology Verification Program website, most, if not all of theparameters outlined in requirement 12 as well as in the Draft Operational Certificate can bemeasured by CEMS technology of some form. All substances for which CEMS technologyexists 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 thecomments 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 OperationalCertificate Holder must implement the best available monitoring technology for each measuredparameter that exists.

As the Site Plan A document provided was incomplete, it is unclear exactly how many dischargestacks there are at the Burnaby Incinerator emitting air contaminants. It is understood there isone 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 outin this submission, that is, if there is more than one stack emitting discharge into the air, allstacks must have CEMS for all parameters installed, and all stacks must be stack sampled, ifthat 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 CEMStechnology if it exists, at the finest resolution possible. All data must also calculate arolling 30-minute average, to be compared with response limits (shown in the able insection 1.1.3), if that resolution is available. If that resolution is not available, the mostfinely temporally resolved averaging period must be used. Data for all parameters mustbe available for 97% of the time or more on an annual basis, in accordance with therequirements of the European Commissions Waste Incineration Directive11 (page 11,point 3 of the Draft Operational Certificate must be amended to 97%). This may requireduplication 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) Cadmium Mercury

Lead Arsenic Chromium Chlorophenols Chlorobenzenes Polycyclic aromatic hydrocarbons (PAHs) Polyclorinated biphenyls (PCBs) Antimony Beryllium Cobalt Copper Manganese Nickel Selenium Thallium Tin Vanadium

11Directive 2000/76/EC of the European Parliament and of the Council. 2008. Available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2000L0076:20081211:EN:PDF


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Zinc Carbon Dioxide (CO2) Methane (CH4) PM10 PM2.5

Ultrafine particles (PM1and PM0.1) Temperature

b. The following parameters should be measured by CEMS or routinely monitored in someway 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)

c. All CEMS data must be posted in real time on the public website.d. 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 thepublic website. CEMS data shall undergo QA/QC within seven days of measurement.

e. The consequences of failing to comply with the requirements must be specified in theOperational Certificate. Consequences should involve serious financial penalty or facilityshut down.

All CEMS devices and procedures must be approved by the Regional Director, such that theyare subject to performance, reliability, and maintenance requirements. These should followthose of the United States Environmental Protection Agency or European Commissions WasteIncineration 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 EuropeanCommissions Waste Incineration Directive. Details of all systems and approval must beposted on the public website.

b. The consequences of failing to comply with the requirements must be specified in the


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 contaminantmeasurement are available, those technologies must be adopted those technologieswithin the next two years. If CEMS technology for substances currently tested for bystack tests or other methods become available, adopt those technologies within the nextyear.

b. The consequences of failing to comply with the requirements must be specified in theOperational Certificate.

On page 2, note 4 of the Draft Operational Certificate states,

Response limits are the threshold requiring the Operational Certificate Holder to takeimmediate action to bring down the discharge levels to the applicable discharge limitsspecified in this section

Documented, immediate action taken must be posted on the public website promptly. Asummary 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 andupdated 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


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 anauthorized parameter response limit is exceeded for a period of more than four (4)hours uninterrupted per parameter per unit; moreover the cumulative duration ofoperation in such conditions over one calendar year shall be less than 60 hours perparameter per unit.

There must be clear, significant consequences for annual exceedances reaching above 60hours. It is suggested that a significant financial penalty be applied in such a case.


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Requirement 17:Consequences of failure to comply with Section 1.1.4 must include a significant financialpenalty, 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 includedin the annual report. Once the facility has made changes to achieve compliance, twoindependent tests conducted by different qualified independent third parties must becompleted within 24 hours of facility startup, the analyses rushed, and results reportedon the public website.

b. Consequences of failure to comply: two consecutive failures per parameter per unit willresult in entire facility shut down and remedial changes being made, which must beapproved 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 growthcontrol as part of the discharge. The types and quantities of these additives used must bereported.

Requirement 19:a. The description and quantities of all water conditioning additives used in the facility must

be presented in the annual report.


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 thebest 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 manufacturers specifications.b. Maintenance and verification of performance must be conducted in accordance with the


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manufacturers instructions, which must be posted on the public website. This must beperformed by a qualified independent third party. A summary of the maintenance andinspection 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 particulatematter must be conducted. This assessment must be included in the annual monitoringreport. 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. TheBurnaby Incinerator must implement best available control technology when it comesavailable, within one year of reporting it in the annual monitoring report.


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 typicalemissions 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 thepublic website within two hours of the generator being shut down. Total hours of usemust be reported in the annual report.

b. The type of generator must also be reported on the public website and in the annualreport. Annually, emissions measurements from the generator must be collected and

compared with typical emissions from that type of engine based on published emissionsfactors, to demonstrate that the characteristics of its discharge are better or equivalent totypical emissions from that type of engine.

c. These measurements and comparison must be conducted by a qualified independentthird party, and the report must be posted on the public website. This information mustalso be summarized in the annual monitoring report.


Section 2.1 Authorized Fuels

In accordance with Metro Vancouvers 2010 Integrated Solid Waste and Resource Managementdocument (A Solid Waste Management Plan for the Greater Vancouver Regional District andMember Municipalities),12the overarching goals of Metro Vancouvers solid waste managementare:

Goal 1: Minimize waste generation

12Metro Vancouver. 2010. Integrated Solid Waste and Resource Management - a Solid Waste Management Plan forthe 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 itsguiding principles which are: reduce waste at the source, reuse where possible, recycleproducts at the end of their useful life, recover energy or materials from the waste stream, andmanage residuals in an environmentally sound manner.

Metro Vancouver must follow these principles, which means maximizing reuse, recycling, andmaterial recovery before recovering energy from the remaining waste. Incineration of reusable,recyclable, and recoverable materials must be prohibited, and clearly stated in the OperationalCertificate of the Burnaby Incinerator. The list of authorized fuels in the Draft OperationalCertificate 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 authorizedfuels must be adhered to, and consequences of non-compliance with this requirement be clearand 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 compliancewith 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 beincinerated is a disincentive to improve packaging design. Further, international airline wasteand international marine waste must be specified in the authorized fuels list, that is, the specificelements of those types of waste must be outlined. As it is written, those statements are vagueand open the possibility that wastes that should not be incinerated will be under those looseterms. Biosolids, wastewater treatment plant residuals, and pharmaceuticals as banned landfillmaterials, 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 recoverablematerial.

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 demolitionsources 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 placedunder either authorized or unauthorized fuels in the Operational Certificate, which list willdepend on what the materials are. No reusable, recyclable, or recoverable materials may beincluded.

Requirement 23:a. Include an unauthorized fuels list with the following items on it, in accordance with Metro

Vancouvers 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

13Metro Vancouver. Banned from Landfills. 2013. Available from:http://www.metrovancouver.org/services/solidwaste/disposal/Pages/bannedmaterials.aspx


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b. Inspections on fuel coming to the facility must conducted by an independent third partyon every load coming to the facility to ensure that only authorized fuels are beingincinerated, and that unauthorized fuels are not being incinerated.

c. A load of fuel shall be determined compliant in composition if it contains items listed asauthorized fuel only. The Operational Certificate must specify the percentage ofunauthorized 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, summarizingthe fuel load inspections, including number of loads, mass of fuel received, and results ofinspection.


On page 6 of the Draft Operational certificate, it states

Other non-MSW fuels may be accepted that have received prior approval by theDirector.

New non-MSW fuels to be used on an ongoing basis are authorized based upon thefollowing criteria:

1. Prior to usage of a new fuel, the Director must receive written notificationidentifying the proposed material. A report must accompany this notificationwhich shall contain the following:a. Records detailing analyses and written descriptions establishing thecomposition, 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. TheBurnaby Incinerator was built to be an MSW incinerator. If there is not enough garbage to fuelthe 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 beremoved from the Operational Certificate.

Second, if reporting on the composition, source, quality, and testing for metal content ofproposed new fuel is listed in the Draft Operational Certificate, why is this not required for allfuel 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 requirement23) 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 followingmethods 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 thetesting must be posted on the public website within two days of receipt of results fromthe laboratory.

b. Results must be compared to standards determined by the Director, and thosestandards posted on the public website.

c. Failure of tests to adhere to the standards will result in the fuel load being denied to theincinerator.


Section 2.3 Future Recycling or Benefic ial Use

This section states,

The Director may require an evaluation of the potential to recycle or beneficially usecertain residues from the combustion process and recovery of certain reusableresources.

What about before the material is incinerated? As was noted above in the comments undersection 2.1, Metro Vancouvers own solid waste management plan, which has been approvedby the BC Ministry of Environment, requires that they first reduce waste, then reuse, recycle,

and recover materials, before energy recovery is pursued. Reusing, recycling, recoveringmaterials mustbe conducted beforeincineration occurs.

Section 2.4 Bypasses


The discharge of air contaminants, as that term is defined in the EnvironmentalManagement Act, beyond the property boundary of the facility, which has bypassed theauthorized 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 noticemust 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 thedischarge, characterizing the discharge, including but not limited to: the types ofpollutants being discharged, the quantities of pollutants being discharged, the length oftime, 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


Section 2.4 Process Modifications


The Director shall be notified prior to implementing material changes to any processthat adversely affects the quality and/or quantity of the discharge from the facility to amaterial 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 orquantity 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 madeat least fourteen days in advance of the process change, detailing the change, reasonfor the change, and anticipated effects on discharge caused by the change. This noticemust remain on the website for the duration of the operational life of the BurnabyIncinerator.


Section 2.6 Maintenance of Works, Emergency Procedures and Non-ComplianceReporting

Subsection 2.6.1 states,

The Operational Certificate Holder shall ensure the authorized works are inspectedregularly and maintained in good working order. In the event of an emergency orcondition beyond the control of the Operational Certificate Holder which prevents

effective operation of the authorized works or leads to unauthorized discharge, theOperational Certificate Holder shall immediately as soon as reasonably practical notifythe Regional Manager, Environmental Protection, and take appropriate remedial actionfor the prevention or mitigation of pollution. The Operational Certificate Holder shall meetall applicable emergency statutory requirements. The Director may reduce or suspendoperations to protect the environment until the authorized works have been restoredand/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 ofregularly?) and how good working order is defined need to be specified. In the event of anemergency, unauthorized discharge, or similar condition, the Burnaby Incinerator must be shutdown 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. Inspectionand maintenance reports are to be completed and posted on the public website withinseven days of the work. Any noted deficiencies are to be corrected immediately. Aposting on the public website outlining remedial action being taken must be postedwithin seven days of the inspection report being received. Good working order isdefined as operating in accordance to the manufacturers specifications.

b. Further, the entire Burnaby Incinerator facility must be inspected by a qualifiedindependent third party waste to energy expert on a biannual basis. The report fromthis 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 becompleted in a timely manner, and an action plan posted on the public website within30 days of the report being released.

c. Emergencies or conditions beyond the control of the Operational Certificate Holderwhich prevents effective operation of the authorized works or leads to unauthorizeddischarge must result in the Burnaby Incinerator being shut down immediately. TheBurnaby Incinerator must remain shut down until the cause is identified and remedialactions have been submitted to and approved by the Director. Upon verification by theDirector that remedial measures have been implemented, the facility may startup.

d. A notice on the public website must be issued within three hours of emergencycondition onset. The report to the Director outlining the cause and remedial measurestaken 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 thefacility in an emergency, unauthorized discharge, or similar event, that a significantfinancial penalty be applied for failing to adhere to any of the aforementionedrequirements during such an event.


During and after the emergency event or condition, the Operational Certificate Holdershall ensure (1) sampling and analysis of discharges which might be non-compliant with

the rates or characteristics of discharges as specified in this Operational Certificateand/or applicable statutory requirements is conducted, (2) the probable causes of thenon-compliances are investigated and (3) appropriate remedial actions at the authorizedworks, plant operations or both to prevent pollution or authorized discharges areimplemented.


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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 thepublic website in real time, if measured by CEMS. If measured by stack test, it mustoccur 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 becompleted on a rush basis at an accredited laboratory, and results posted on the publicwebsite within 24 hours of receipt.



Within 30 days of the emergency event or condition, the Operational Certificate Holdershall provide a report to Regional Manager, Environmental Protection, describing thesequences of events that led to an emergency event or condition, results of samplingand 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 tothe 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


Section 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, asauthorized by the Director. Prior to disposal or authorized beneficial use, recoverablematerials, such as ferrous metal pieces, may be removed.

The term appropriate permitted facility must be defined to include the terms hazardous waste.

The volume of ash disposed of at such facilities must be reported each year in the public annualreport. As per Requirements 22 and 23, no unauthorized fuels, no reusable, recyclable, orrecoverable materials may be incinerated. Ferrous metal pieces should be moved from the fuelbefore it is burned.

Bottom ash must also be disposed at an appropriate permitted hazardous waste facility. As hasbeen reported in Metro Vancouver staff reports and in the news recently, both fly ash andbottom ash have failed toxicity characteristic leaching procedure (TCLP) tests with cadmium


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exceedances over the past year or so.14 This highlights that the facility has recently had anumber of failures to meet provincial standards, and that these products are hazardous andmust 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 forhazardous waste.

b. The results of TCLP tests for every load of fly ash and bottom ash must be published onthe public website and summarized in the annual report. The quantity of fly ash andbottom ash disposed of, and location of disposal, must be reported on the public websiteon a monthly basis, and summarized in the annual report.


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, and1.6 shall be submitted to the Director upon request. For any material modifications to theauthorized works, a qualified professional must certify that the works have beenconstructed in accordance with the certified design before discharge commences.

Requirement 32:

a. All plans and specifications of the works authorized in the Operational Certificate mustbe posted on the public website. For any material modifications to the authorized works,plans and certification by an independent third party qualified professional must beposted on the public website at least fourteen days in advance of the modifications beingimplemented.


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


14Metro 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


Section 3.1 MSW Fuel and Ash Monitoring

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

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 48hours of the end of the month, and yearly consumption by January 15 of the followingyear.


Subsections 3.1.2, 3.1.3, and 3.1.4 detail fly ash and bottom ash reporting and allude to fly ashand bottom ash management plans coming into place March 31, 2014 and June 30, 2014respectively. 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 ashdisposed at these facilities, and the identification of the facilities must be posted on thepublic website on a monthly basis.



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Section 3.2 Spill Report ing

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


Section 3.3 Discharge Monitor ing fo r Subsection 1.1

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

Section 3.5 Emission Contro l Device Record Keeping

Performance records on emission control devices must be posted on the public website, andsummarized 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


Section 3.6 Secondary Combustion Zone Temperature Monitor ing Requirements

The continuous temperature measurement record in the secondary combustion zone must beposted on the public website. The percentage of time (during operation, where startup, shutdown, and upset conditions are considered in operation) when the temperature is at or above800C 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 destroytrace organics. For example, the Supplementary Green Book15 produced for the BurnabyIncinerator in 1986 reads on page 4 of Organics,

Another field study (8)16comparing operating temperatures found that a higher, (1140C

versus 1000C) secondary combustion chamber temperature significantly reduced thePCDD and PCDF emission concentrations.

15Khare et al. Supplementary to the report on Emission and Monitoring Requirements for GreaterVancouver Regional District Incinerator Located in Burnaby. 1986.16The National Incinerator Testing and Evaluation Program: Two Stage Combustion (Prince EdwardIsland). 1985.Environment Canada Report EPS 3/UP/l, Ottawa, Canada. 85 p.


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The Operational Certificate Holder must conduct a review of best practice secondarycombustion temperatures for destroying the most trace organics. If findings reveal that thetemperature should be above 800C to destroy more of the trace organics, it must be requiredto 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 OperationalCertificate.

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 temperaturemeasurements 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 methodacceptable to the Director, and posted on the public website, within one week of the datameasurement.

c. The percentage of time during operation when the temperature is 800C or above mustbe presented on the public website at the end of each calendar year (by January 15 ofthe following year) and in the annual monitoring report.

d. A qualified independent third party must conduct a review of best practice secondarycombustion temperatures for destroying the most trace organics, which must becompleted and posted on the public website by December 31, 2014. If findings revealthat the temperature should be above 800C to destroy more of the trace organics, itmust be required to reach that higher temperature.

e. Comments on temperature requirements in a potential tertiary combustion chamber inthe facility must be provided in the Operational Certificate.

f. The consequences of failing to comply with the requirements must be specified in theOperational 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 aremonitored and publicly reported during start up, show down, and upset periods, as these timesmay represent periods where the highest emissions are occurring. Residents of MetroVancouver and the Fraser Valley are exposed to all emissions, all the time, not just when theyare monitored, so it is critical that the monitoring requirements accurately reflect the range ofemissions 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 typicallyshut down about 45 days per year. This could represent a substantial number or percentage ofoperational time per year when the facility is in start up, shut down, or upset conditions. Thenumber of operational hours the facility has per year (defined as number of hours the facility isoperating normally, is undergoing start up, is undergoing shut down, or is experiencing upsetconditions) and percentage of those operating hours that are start up, shut down, or upset mustbe 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 800C 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


Section 3.8 Modification of Monitoring Requirements and/or Treatment Works

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

Requirement 41:

a. Modification of monitoring requirements and/or treatment works must be given notice onthe 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 orthe frequency of monitoring increase

Section 3.9 Sampling Location and Techniques

This section reads,

Sampling shall be done under actual operating conditions when the OperationalCertificate 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 theparameters monitored in the Operational Certificate, that technology must be used to measurethose pollutants in real time. CEMS must be in place on all stacks emitting pollutants. Monitoringmust 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 notexist), stack tests must be conducted. Stack tests must be conducted on all stacks emitting airpollutants. 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 CertificateHolder is able to properly document that these conditions represent normal operatingconditions, 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 parameterbeing 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. Thismust cover all four seasons, and at least one startup, one shutdown, and one normaloperating condition period for each parameter at each stack. Further, at least one of thetests per parameter per year must have two independent qualified third partiesmeasuring the same parameter, to see if they obtain the same results.

d. Any samples collected during stack testing must be submitted to a qualified independentthird party laboratory, accredited for the analyses to be done, within 24 hours ofcollection. Results of the stack testing can be obtained on the laboratorys normalturnaround 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 beendetailed many times already, it is imperative that comprehensive emissions monitoringdata is available for the Burnaby Incinerator, and these requirements for any stacktesting needed followed. There must be a strong disincentive for failing to comply withthese requirements.

Section 3.10 Sampling and Analyti cal Procedures

Analyses of samples must be conducted by a qualified third party laboratory. The laboratorymust 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 "BritishColumbia Field Sampling Manual for Continuous Monitoring and the Collection of Air,Air-Emission, Water, Wastewater, Soil, Sediment, and Biological Samples, 2003Edition", or most recent edition, or by suitable alternative procedures as authorized bythe 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 bysuitable alternative procedures as authorized by the Director.

The actual method of sampling and analysis for all parameters must be disclosed on the publicwebsite (even if it is in accordance with the "British Columbia Laboratory Manual for theAnalysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient AirSamples), and especially if it is an alternate method authorized by the Director.


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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 accreditationexists. Sampling and analysis reports must be posted on the public website, along withproof they were conducted by qualified third parties, and that accredited laboratories wereused, where applicable.

b. The actual method of sampling and analysis for all parameters must be disclosed on thepublic website (even if it is in accordance with the "British Columbia Laboratory Manual forthe Analysis of Water, Wastewater, Sediment, Biological Materials and Discrete Ambient AirSamples).


Section 3.11 Report ing 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. CEMSdata 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 performQA/QC verification, a notice indicating that can be posted on the website.

Comments on exceedances, outlining possible reasons and remedial actions taken (section1.1.3 and 3.3) must be posted within 24 hours of the exceedance, and updated as moreinformation comes available.

See comments and requirements under section 1.1.3 for more details and requirements onreporting.

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 moreinformation comes available.


Subsection 3.11.2 Monthly Monitoring Data Reporting

All monthly monitoring data reporting submitted to the Regional Manager, EnvironmentalProtection, 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 ofexceedances of permit discharge limits; the number and duration of exceedances of the hr response limits, and comments on remedial measures taken in each case; up todate cumulative duration of any hr response limit exceedances for the calendar year;


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the number of occasions the one-hour average secondary combustion chambertemperature dropped below 800C during periods of normal operation, the minimumtemperature reached in each case, and the corrective action taken; and the CEMSavailability factor expressed as a percentage of plant operating hours, causes, andcorrective action(s) taken to address exceedances that occurred during the reportingperiod.

The dates of the exceedances and action(s) taken shall be clearly identified in the datasubmission. Should no exceedances have occurred over the reporting period, astatement 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


3.11.3 CEMS Maintenance, Calibration and Audi t Report ing


The Operational Certificate Holder shall maintain for a minimum of two years and makeavailable upon request the performance range, specifications and calibration data foreach CEMS; the availability of each CEMS (expressed as a percent of facility operatinghours); maintenance and calibration work performed on the CEMS as well as results ofany 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 theoperational life of the Burnaby Incinerator. All of this information must be posted on the publicwebsite.

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 publicwebsite, and remain there for the duration of the operational life of the facility.


3.11.4 Source Testing Report ing

See comments on sections 1.1.3, 3.3, and 3.9.


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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 monitorsrequired under Sections 3.1, 3.3, and 3.6 for a minimum of two years and makeavailable upon request.

All records must be kept for the duration of the operating life of the Burnaby Incinerator, andmust 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


3.11.6 Annual Monitor ing Report

Comments and requirements on the annual monitoring report are provided throughout thissubmission, and first addressed in Requirement 2. It must be posted on the public website byMarch 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 thatmust be in the annual report.

b. The annual report must be posted on the public website by March 31 of the yearfollowing the report year.



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Appendix 1


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ENVIRONMENTAL PROTECTION NOTICENOTICE OF INTENT TO ISSUE OPERATIONAL CERTIFICATE 107051 UNDER THE PROVISIONS OF TH

ENVIRONMENTAL MANAGEMENT ACT

Take notice that the Director intends, a minimum of 30 days after the date of this publication, to issue Operatio

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 Vancouvers approved Integrated Solid Waste

and Resource Management Plan, and the terms 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 em

to [email protected] with the subject line WTEF OC Request.

Any comments regarding the draft Operational Certificate 107051 must be sent to the Regional Manager,

Environmental Protection at #200-10470 152 Street, Surrey, British Columbia, V3R 0Y3, or emailed to

[email protected] to the attention of the Regional Manager, Environmental Protection within

30 days of the date of this publication.


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DRAFT

November 21, 2013

Page 1 of 15

1. AUTHORIZED DISCHARGES

1.1 Mass Burn Incinerators/Boilers

This section applies to the discharge of air conta

fvrd requirements - burnaby incinerator operational certificate - final

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