Please note that some provisions of this approval are shown in strikeout for the sole 

purpose of showing what provisions are not incorporated into the Massachusetts Regional 

Haze State Implementation Plan (SIP). The provisions shown in strikeout are a part of the

approval and are state enforceable. 

This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622 or 1-617-574-6868

MassDEP Website: www.mass.gov/dep

Printed on Recycled Paper

March 14, 2012

Mr. Jairaj Gosine RE: SAUGUS - Metropolitan

Wheelabrator Saugus, Inc. Boston/Northeast Region

100 Salem Turnpike 310 CMR 7.08(2) - Municipal Waste Combustors

Saugus, MA 01906 Application No. MBR-98-ECP-006

Transmittal No. W003302

EMISSION CONTROL PLAN

MODIFIED FINAL APPROVAL

Dear Mr. Gosine:

The Metropolitan Boston/Northeast Regional Office (NERO) of the Department of Environmental Protection, 

Bureau of Waste Prevention (“MassDEP”), has reviewed your request, dated January 9, 2012, to modify the

Municipal Waste Combustor (MWC) Emission Control Plan (ECP) Final Approval issued to you by MassDEP, 

pursuant to 310 CMR 7.08(2), on September 28, 2007. This request included a proposal to modify certain emission 

limits contained in your ECP Final Approval for equipment at your facility located at 100 Salem Turnpike in 

Saugus, Massachusetts.

The purpose of 310 CMR 7.08(2) was to provide emission limitations for the control of certain designated pollutants 

emitted from MWCs, in accordance with the requirements contained in Sections 111(d) and 129 of the Clean Air 

Act. 310 CMR 7.08(2) established requirements for the following: Operating Practices [Carbon Monoxide (CO), 

Flue Gas Temperature, Load Level], Metals [Mercury (Hg), Lead (Pb), Cadmium (Cd)], Particulate Matter (PM), 

Opacity, Organics (Dioxins/Furans), Acid Gases [Sulfur Dioxide (SO2) and Hydrogen Chloride (HCl)], Nitrogen 

Oxides (NOx), and Fugitive Ash Emissions.

Pursuant to 310 CMR 7.08(2)(j)7., MassDEP has modified your ECP Final Approval in order to include additional 

NOx and Hg emission limits and to reduce the PM, Cd, and Pb emission limits contained in the original, September 

28, 2007 ECP Final Approval. The NOx emission limit was proposed in order for the Commonwealth to meet its 

obligation under Section 169A of the Clean Air Act to address regional haze, as described in MassDEP’s Regional 

Haze State Implementation Plan. Monitoring and record keeping for this new NOx emission limit shall commence 

180 days after issuance of this ECP Final Approval. In addition, the Hg, PM, Cd, and Pb emission limits were

proposed to reflect revisions to the federal 40 CFR Part 60, Subpart Cb Emission Guidelines for Existing Large 

Municipal Waste Combustors promulgated on May 10, 2006 and which went into effect for the subject facility on 

May 10, 2011 (40 CFR Part 60.39b(h)).

MassDEP has determined that your submittal is administratively and technically complete and that the proposed 

modifications are in conformance with current air pollution control engineering practices and hereby modifies your
MWC ECP Final Approval as listed below.

In Table 2 of the ECP Final Approval,

a) Include an Oxides of Nitrogen (NOx) limit of 185 ppm by volume at 7% O2 dry basis, 30-day rolling 

average; and,

b) Reduce the Particulate Matter (PM) limit from 27 milligrams per dry standard cubic meter (mg/dscm) at 

7% O2 to 25 mg/dscm at 7% O2; and,

c) Reduce the Cadmium (Cd) limit from 0.040 mg/dscm at 7% O2 to 0.035 mg/dscm at 7% O2; and,

d) Reduce the Lead (Pb) limit from 0.440 mg/dscm at 7% O2 to 0.400 mg/dscm at 7% O2; and,

e) Replace the Mercury (Hg) limit of 0.080 mg/dscm at 7% O2 (during any single quarterly compliance test) 

with a Hg limit of 0.050 mg/dscm or 15% of the potential emission concentration (85% reduction by

weight) and not to exceed 0.080 mg/dscm at 7% O2, whichever is less stringent (during any single quarterly 

compliance test).

In the first sentence of Table 2, Note 4, delete the phrase “Based on the current NOx limit of 205 ppm by volume at 

7% O2 dry basis,”. Furthermore, add Notes 6 and 7 to Table 2.

As such, MassDEP replaces Pages 4 and 5 of your September 28, 2007 ECP Final Approval with the two (2) pages 

attached hereto. All other requirements as contained in your September 28, 2007 ECP Final Approval shall remain 

in full force and effect.

MassDEP issued a Proposed Modification to your ECP Final Approval on January 25, 2012. Pursuant to 310 CMR 

7.08(2)(j)7., public notice of this proposed modified ECP Final Approval was published in accordance with M.G.L. c. 

30A in the Lynn Daily Item on February 3, 2012 and in the Saugus Advertiser on February 9, 2012, followed by a 30-

day public comment period. As such, the public comment period ended on March 12, 2012. During the public 

comment period, no comments were received.

MassDEP has determined that the filing of an Environmental Notification Form (ENF) with the Secretary of Energy &

Environmental Affairs, for air quality control purposes, was not required prior to this action by MassDEP. 

Notwithstanding this determination, the Massachusetts Environmental Policy Act (MEPA) and Regulation 301 CMR 

11.00 Section 11.04, provide certain "Fail Safe Provisions" which allow the Secretary to require the filing of an ENF 

and/or Environmental Impact Report at a later time. The facility submitted an ENF on February 2, 1998 solely because 

the project could have triggered the review threshold for financing by a public agency [310 CMR 11.24(4)(a)1.]. On 

March 13, 1998, the Executive Office of Environmental Affairs issued a Certificate allowing for the emission control 

project to proceed without the need to prepare an Environmental Impact Report. The Certificate stated, “the project will 

have significant air quality benefits; other environmental impacts should prove minor; and the review of the ENF has 

served adequately to disclose impacts/benefits and mitigation.”

Please be advised that this Approval does not negate the responsibility of the facility to comply with this or any other 

applicable federal, state, or local regulations now or in the future. Nor does this Approval imply compliance with any 

applicable federal, state or local regulations now or in the future.

Should you have any questions concerning this Approval, please contact Cosmo Buttaro by telephone at (978) 694-

3281, or in writing at the following address: Department of Environmental Protection (MassDEP), 205B Lowell 

Street, Wilmington, Massachusetts 01887.
Sincerely,

Cosmo Buttaro James E. Belsky

Environmental Engineer Permit Chief

Bureau of Waste Prevention

cc: Town Hall, 298 Central Street, Saugus, MA 01906

Board of Health, Town Hall, Saugus, MA 01906

Fire Headquarters, 27 Hamilton Street, Saugus, MA 01906

Metropolitan Area Planning Council, 60 Temple Place, Boston, MA 02111

United States Environmental Protection Agency (USEPA) – New England Regional Office, 5 Post Office 

Square, Suite 100, Mail Code OEP05-2, Boston, Massachusetts 02109-3912, Attn: Manager – Air Permits 

Program

MassDEP/Boston: Yi Tian (E-Copy)

MassDEP/NERO: Marc Altobelli (E-Copy & Hard Copy), Mary Persky (Hard Copy), Cosmo Buttaro
APPLICABLE REQUIREMENTS

A. EMISSION LIMITS AND RESTRICTIONS

The facility is subject to the emission limits/restrictions as contained in Table 2 below:

Table 2 +

EU# RESTRICTION/ 

OPERATING 

PRACTICES

POLLUTANT EMISSION LIMIT/STANDARD 5 APPLICABLE 

REGULATION 

AND/OR APPROVAL 

NUMBER

EU1, 

EU2 PM Control Device Inlet 

Temperature:

< 17C (30F) above 

maximum demonstrated 

PM control device inlet 

temperature, calculated in 

4-hour block arithmetic 

averages, measured during 

the most recent 

dioxin/furan compliance 

test in which compliance 

is achieved 3

310 CMR 7.08(2)(f)2.

SO2 < 29 ppm by volume at 7% O2 dry basis or 75% 

reduction by weight or volume, whichever is less 

stringent (24-hour geometric mean)

40 CFR 60.33b(a)

310 CMR 7.08(2)(f)2.

PM < 25 mg/dscm at 7% O2

1, 6

NOx < 205 ppm by volume at 7% O2 dry basis

(24-hour daily arithmetic average)

310 CMR 7.08(2)(f)3.

< 185 ppm by volume at 7% O2 dry basis

(30-day rolling average) 7

40 CFR Part 51.308(e)

+ Table 2 Notes:

3 No person subject to 310 CMR 7.08(2) shall:

1. cause, suffer, allow or permit a municipal waste combustor unit to operate at a load level (based 

on steam flow) greater than 110 percent of the maximum demonstrated municipal waste 

combustor unit load calculated in 4-hour block arithmetic averages, measured during the most 

recent dioxin/furan compliance test in which compliance is achieved; and 

2. cause, suffer, allow or permit a municipal waste combustor unit to operate at a temperature, 

measured at the PM control device inlet, exceeding 17C (30F) above the maximum 

demonstrated PM control device temperature, calculated in 4-hour block arithmetic averages, 

measured during the most recent dioxin/furan compliance test in which compliance is achieved.

During any nine-month dioxin/furan compliance test and the 2 weeks preceding each ninemonth dioxin/furan compliance test, municipal waste combustor unit load limit and PM control 

device temperature limitations are not applicable.

Municipal waste combustor unit load limit and PM control device temperature limitations may 

be waived, if prior approval is granted by MassDEP, for the purposes of evaluating system 
performance, testing new technology or control technologies, diagnostic testing, or related 

activities for the purpose of improving facility performance provided that there is an 

improvement in controlling air pollution, or advancing the state-of-the-art for controlling facility 

emissions.

5 Emission limits/standards in Table 2 and under 310 CMR 7.08 apply at all times except during periods of 

start-up, shutdown or malfunction as defined in 40 CFR Part 60, Subpart Eb, 60.58b, as amended.

6 The 310 CMR 7.08(2)(f)2. limits of 27 mg/dscm at 7% O2 are less restrictive than the listed Table 2 

emission limits of 25 mg/dscm at 7% O2 for PM, respectively (40 CFR 60.33b(a)).

7 Monitoring and record keeping for the NOxlimit of 185 ppm by volume at 7% O2 dry basis (30-day 

rolling average) shall commence 180 days after issuance of this ECP Final Approval. NOx Continuous 

Emissions Monitoring Systems installed and operated in accordance with 310 CMR 7.08(2)(g) shall be 

used to demonstrate compliance with said limit. Record keeping, including the 30-day rolling averages, 

shall be in accordance with 310 CMR 7.08(2)(h), as applicable. Reporting, including deviations from 

said limit, shall be in accordance with 310 CMR 7.08(2)(i).

+ Table 2 Key:

EU# = Emission Unit Number

mg/dscm = milligram per dry standard cubic meter

ng/dscm = nanogram per dry standard cubic meter

ppm = parts per million

Cd = Cadmium

Pb = Lead

HCl = Hydrogen Chloride

Dioxin/Furan = tetra- through octa- chlorinated dibenzo-p-dioxins and dibenzofurans

PM = Particulate Matter

SO2 = Sulfur Dioxide

CO = Carbon Monoxide

NOx = Nitrogen Oxides

Hg = Mercury

NH3 = Ammonia

O2 = Oxygen

% = percent