National Biosolids Partnership (NBP) Webcast. Compliance and Testing Requirements to Meet the Sewage Sludge Incineration (SSI) MACT Standards Part 2

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1 WELCOMING REMARKS National Biosolids Partnership (NBP) Webcast Compliance and Testing Requirements to Meet the Sewage Sludge Incineration (SSI) MACT Standards Part 2 July 25, 2012 Sam Hadeed Biosolids Program Manager Water Environment Federation National Biosolids Partnership Alexandria, VA WEF Residuals & Biosolids Committee Staff Liaison shadeed@wef.org 2 NBP s Commitment to Excellence in Biosolids Management NBP - WEF Resources to Navigate Biosolids Management Starting in January 2010, NBP began offering a series of no charge quarterly webcasts devoted to general biosolids management and technical topics of interest to water quality and biosolids professionals: Carbon Footprint Implications from Biosolids Management Practices Advances in Solids Reduction Processes Combined Heat and Power Generation Opportunities at Wastewater Treatment Facilities Charting the Future of Biosolids Management: Forum - Findings on Trends and Drivers Implementing the New SSI MACT Standards Issues and Challenges Ahead Terminal Island Renewable Energy LA s Biosolids Slurry and Brine Injection Project Renewable Green Energy from Biosolids POTW Case Studies to Achieve Net Energy Production When Opportunity Knocks, How Can Municipalities and POTWs Partner with the Biofuels Industry Thermal Hydrolysis Comes to America: DC Water s Blue Plains Digestion Project 1.75 Professional Development Hours for this webcast To download PDH Form visit: Web Page and E-Newsletter - Biosolids Access Water Knowledge Channel WEF 2013 Residuals and Biosolids Specialty Conference May 5-8 Abstracts Due: August 1, 2012 Nashville, TN WEFTEC 2012 September 29-October 3, 2012 New Orleans, Louisiana 4 1

2 Alexandria, VA Sanitation Authority City of Santa Rosa, CA Public Utilities City of Wyoming, MI Clean Water Plant Central Davis County, UT Sewer District Columbus, GA Water Works DC Water New England Organic Hawk Ridge Composting Facility Water Environment Services of Clackamas County, OR East Bay Municipal Utility District - Oakland, CA Butler County, OH DES City of Albany, OR Wastewater Treatment Plant City of Chattanooga, TN DPW City of Fort Worth, TX Water Dept City of Grand Rapids, MI Greater Moncton Sewerage Commission, Canada Camden County, NJ Municipal Utility District Renewable Water Resources Greenville, SC NBP EMS Certified Agencies (34) A key component of the NBP program is the EMS and third-party audit program. The following agencies/organizations have achieved the prestigious NBP EMS certification: King County, WA Div. WW Treatment Louisville & Jefferson Co. KY Metro Sewer District Madison, WI Metropolitan Sewerage District Metro Denver, CO WW Reclamation District Metro Water Reclamation Dist. of Greater Chicago, IL Orange County, CA Sanitation District Orange County, FL Utilities Resource Management Inc., NH Kent County, DE Regional WTF Encina Wastewater Authority Carlsbad, CA City of Raleigh, NC Public Utilities Department City of Mankato, MN City of Los Angeles, CA Dept of Public Works City of Lawrence, KS Dept. of Utilities Lewiston-Auburn, ME WPA City of Richmond, VA Public Utilities Dept. Knoxville Utilities Board, TN Today s Webcast Compliance and Testing Requirements to Meet the Sewage Sludge Incineration (SSI) MACT Standards Part 2 Participants Will: Get an overview of the SSI MACT rule and compliance requirements Learn about the timelines for meeting the requirements Learn about the testing required for current and future multiple hearth and fluidized bed incineration units Learn about the next steps agencies need to take to comply with the March 21, 2016 implementation deadline Learn what others are finding TODAY S SPEAKERS Amy Hambrick Environmental Scientist Fuels and Incineration Group US EPA Office of Air Quality Planning & Standards Research Triangle Park, NC Overview of Compliance Requirements for Implementing the SSI MACT Rulemaking TODAY S SPEAKERS Robert Dominak President Friar Consultant, Inc. Parma, OH Testing and Achieving Compliance Robert.dominak@gmail.com hambrick.amy@epa.gov 7 8 2

3 TODAY S SPEAKERS James Welp, PE, BCEE Vice-President Black & Veatch WEF RBC Vice Chair Cincinnati, OH Next Steps and What Others are Finding Amy Hambrick Fuels & Incineration Group Office of Air Quality Planning & Standards USEPA Contact: hambrick.amy@epa.gov (919) welpje@bv.com 9 10 This document & presentation do not establish any new requirements and is not binding or enforceable. It does not constitute final agency action under Clean Air Act section 307(b)(1), 42 U.S.C. 7607(b)(1). Rather, it summarizes existing regulations & applicable compliance dates, provides guidance to applicable facilities, and provides guidance to States pertaining to State Plan development under Section 129 of the Clean Air Act as amended in For full regulatory text and compliance requirements, please refer to 40 CFR part 60 subpart LLLL & MMMM. Specific compliance questions or applicability concerns should be directed to your State and Regional air program office. Other Solid Waste Incinerators (OSWI) 2005 OSWI finalized No limits for SSI units 2006 EPA receives Petitions for Reconsideration Petitioners request that certain categories, including SSI be regulated 2007 Reconsideration Review No additional amendments are to the 2005 final OSWI rule This litigation is currently being held in abeyance 2007 CISWI Definitions Rule Vacated and Remanded The Court held that ANY unit combusting ANY solid waste MUST be regulated under section 129 of the CAA NRDC v. EPA; 489 F. 3d. at Non-hazardous secondary material is defined under the Resource Conservation and Recovery Act (RCRA) March 21, 2011, EPA promulgates 5 sister rules for incinerators, boilers, and NHSM Non-Hazardous Secondary Material Definition (NHSM) Sewage Sludge that is incinerated is defined as a NHSM waste SSI is a subcategory, captured under OSWI

4 40 CFR Part 503 Subpart E (CWA) Standards for the Use and Disposal of Sewage Sludge Incineration 40 CFR Part 61 Subpart C (CAA) National Emission Standard for Beryllium 40 CFR Part 61 Subpart E (CAA) National Emission Standard for Mercury CAA Section 129 Authority 129(A)(1)(a): for NHSM [waste] incineration units 111(b) & 129(a): NSPS 111(d) & 129(d): EG 129(a)(2): Technology based 129(a)(5): 5 year review & 129(h)(3): Ample margin safety NSPS 129(f)(1): NSPS Directly enforceable Ability to subcategorize by size, class, type Beyond the Floor EG 129(b)(2): State Plan 129(b)(3): Federal Plan (40 CFR Part 62) Ability to subcategorize by size, class, type Beyond the Floor Pollutants Regulated Cadmium (Cd) Lead (Pb) Mercury (Hg) Nitrogen Oxides (NOx) Sulfur Dioxides (SO2) Dioxin/Furans (D/F) Carbon Monoxide (CO) Particulate Matter (PM) Monitoring Process parameters Testing Initial Compliance Annual/CEMS or reduced testing do to good performance Recording Keeping & Reporting Annual Deviation Qualified Operator Status Title V Continuous Compliance Maintain emissions limits Annual APCD inspection Hydrogen Chloride 40 CFR Part 60 Subpart O (CAA) Standards of Performance for Sewage Treatment Plants (HCl) 40 CFR Part 60 Subpart LLLL (CAA) New Source Performance Standards (NSPS) for Sewage Sludge Incineration Units CAA 129 Statutory Exemptions Permit under Section 3005 of the Solid Waste Disposal Act Materials recovery facilities (+ primary and secondary smelters) for the primary 40 CFR Part 60 Subpart MMMM (CAA) Emission Guidelines (EG) and Compliance Times for Existing Sewage Sludge Incineration Units Q: My incineration unit recovers energy. Are there any exemptions from CAA 129 (SSI or other rules)? purpose of recovering metals Qualifying small power production facilities Qualifying cogeneration facilities Air curtain incinerators burning clean wood/yard waste and comply with opacity limitations to be established by rule 40 CFR part [RCRA] procedures for identification of non-hazardous secondary materials that are solid wastes when used as fuels or ingredients in combustion units [legitimacy criteria] Statute Large MWC Small MWC HMIWI CISWI OSWI Large MWC >250 tpd (includes MSW air curtain incinerators) CAA Section 129 Small MWC >11 tbd </= 250 tpd (includes MSW air curtain incinerators) NSPS (40 CFR Part 60) HMIWI Small Medium Large CISWI Incinerators ERU-Solid ERU-Liquid Waste Kilns Small Remote EG (40 CFR Part 60) OSWI IWI VSMWC (<35 tpd; includes MSW and IWI air curtain incinerators) Federal Plan (40 CFR Part 62) SSI Multiple Hearth Fluidized Bed LLLL [new units] Directly enforceable MMMM [existing units] State or Federal plan Large MWC Eb & Ea Cb & Ca FFFF Small MWC AAAA BBBB - HMIWI Ec Ce HHH CISWI CCCC DDDD III OSWI EEEE FFFF - SSI LLLL MMMM

5 Which SSI units are affected? SSI units located at wastewater treatment facilities that are designed to treat domestic sewage sludge. Q: What if another type of unit not located at a wastewater treatment facility designed to treat domestic SS, combusts SS (e.g. Cement Kiln)? The other type of unit would be subject to another 129 standard (e.g. waste burning kilns are subject to CISWI) CFR: & What is an SSI unit? An SSI unit is an enclosed device using controlled flame combustion that burns sewage sludge for the purpose of reducing the volume of the sewage sludge by removing combustible matter. An SSI unit includes the following: Sewage sludge feed system, auxiliary fuel feed system, grate system, flue gas system, waste heat recovery equipment, and bottom ash system. All ash handling systems connected to the bottom ash handling system. Q: Are the air pollution control devices considered part of the SSI unit? No CFR: & Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR States and U.S. protectorates (tribes) with one or more SSI units constructed on or before October 14, 2010 must submit a state plan or Not Applicable Not Applicable tribal plan to EPA by March 21, 2012 States and tribes with no SSI units constructed on or before October 14, 2010 must submit a negative declaration letter in place of the state Not Applicable Not Applicable plan. If EPA has not approved a state or tribal plan by March 21, 2013, a Federal plan developed by EPA will apply to SSI units in that state until a Not Applicable Not Applicable state plan has been approved. Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Compliance with the emission guidelines & After this subpart goes into effect on , is required 3 years from date of state plan September 21, 2011 units that commenced , approval or March 21, 2016 if no construction after October 14, 2010 or & state/tribal plan has been approved (i.e., commenced modification after September (e) the Federal plan applies to the SSI unit). 21, 2011 must comply with the emission limits and standards within 60 days after the unit reaches the feed rate at which it will operate or 180 days after initial startup (whichever is first.) For compliance schedules that extend more than 1 year following the effective date of state plan approval, state plans must include dates for enforceable increments of progress Not Applicable Not Applicable It depends The state or EPA would follow their enforcement response policy as A state or tribe may meet its obligation by submitting a written request for delegation of the Federal plan Not Applicable Not Applicable Q: What if a SSI unit cannot meet the requirements by the compliance date? appropriate. Self Disclosure Policy- Work with your implementing authority to determine appropriate actions to come into compliance. This list will be published in the future SSI Q: Has my state submitted a State Plan? Federal Plan proposal and final rule. In the mean time, give your state a call

6 Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR All SSI units subject to a state or Federal plan All SSI units subject to the NSPS are required to implementing the emission guidelines are apply for and obtain a title V operating permit. required to apply for and obtain a title V operating permit. Unless a unit is subject to an earlier title V permit (a) Unless a new unit is subject to an earlier title V (a) application deadline (for example, a unit subject to this subpart may be part of a major source that has already triggered title V requirements), the title V permit application must be submitted on or before the earliest date specified in 1 through 3 below: permit application deadline (for example, a unit subject to this subpart may be part of a major source that has already triggered title V requirements), the title V permit application must be submitted on or before one of the dates 1.) 12 months after the effective date of any specified in options 1 or 2 below: 1.) If operation commenced by March 21, 2011, applicable EPA approved state or tribal plan. 2.) 12 months after the effective date of any applicable Federal plan; or 3.) March 21, 2014 title V application must be submitted by March 21, ) If operation commenced after March 21, 2011, title V applications must be submitted within 12 months of commencing operation. If the SSI unit is subject to another title V permit (b) If the SSI unit is subject to another title V permit (b) application deadline triggered by some other application deadline triggered by some other requirement besides the emission guidelines, requirement besides the NSPS, then the 12 month then the 12 month timeframe for filing a title V timeframe for filing a title V permit application is permit application is triggered by the requirement triggered by the requirement which first causes which first causes the unit to be subject to title V the unit to be subject to title V (i.e., the earliest (i.e., the earliest application deadline date that application deadline date that applies to the unit). applies to the unit). Q: Are all CAA 129 units required to obtain a Title V permit? Yes CAA 129(e) Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Initial operator training and qualification Initial operator training and qualification must be completed by the later of the must be completed by the later of the following three dates: following two dates: 1.) The compliance date, 1.) 6 months after the unit startup or, 2.) 6 months after the unit startup or, 2.) The date before employee assumes 3.) 6 months after an employee assumes responsibility of operating or supervising responsibility of operating or supervising operation of the unit operation of the unit. Maintaining operator qualification requires Maintaining operator qualification requires an annual refresher course or review an annual refresher course or review including coverage of the following topics: including coverage of the following topics: 1.) Update of regulations 1.) Update of regulations 2.) Proper incinerator operation procedures 2.) Proper incinerator operation procedures 3.) Inspection and maintenance 3.) Inspection and maintenance 4.) Prevention of malfunctions or 4.) Prevention of malfunctions or conditions conditions leading to malfunction leading to malfunction 5.) Discussion of operating problems 5.) Discussion of operating problems encountered by attendees encountered by attendees Renewal of lapsed operator qualification Renewal of lapsed operator qualification requires one of two methods: requires one of two methods: 1.) For lapse less than 3 years, completion 1.) For lapse less than 3 years, completion of of annual refresher course is required annual refresher course is required 2.) For lapse of 3 years or more, initial 2.) For lapse of 3 years or more, initial qualification training must be repeated qualification training must be repeated Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Initial operator training must be obtained through a state approved program or by completing a training course that includes the following topics: 1.) Environmental concerns, including emission types, 2.) Basic combustion principles, including products of combustion, 3.) Operation of specific type of incinerator to be used by operator, 4.) Combustion controls and monitoring, Initial operator training must be obtained through a state approved program or by completing a training course that includes the following topics: 1.) Environmental concerns, including emission types, 2.) Basic combustion principles, including products of combustion, 3.) Operation of specific type of incinerator to be used by operator, 4.) Combustion controls and monitoring, 5.) Operation of air pollution control equipment and factors affecting performance, 6.) Inspection and maintenance of the incinerator and related control device, 7.) Actions to prevent malfunctions or prevent conditions that may lead to malfunctions, 8.) Bottom and fly ash characteristics and handling procedures, 9.) Applicable Federal, State and local regulations, including Occupational Safety and Health Administration standards, 10.) Pollution prevention. In order to complete qualification an operator must pass an examination designed and administered by a state approved program and receive written material covering the training course topics. Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Initial APCD inspection must be conducted Initial APCD inspection must be conducted by the compliance date under the approved by the earlier of two dates: state/tribal plan, or by March 21, 2016 if no 1.) Within 60 days after APCD installation or, state/tribal plan has been approved. 2.) Within 180 days after startup of the SSI unit. For new APCD installed after final Not Applicable Not compliance date, inspection must be Applicable conducted within 60 days of installation. APCD repairs (if necessary) following & APCD repairs (if necessary) following & inspection must be completed within inspection must be completed within operating days unless written approval operating days unless written approval establishing another date is obtained from establishing another date is obtained from the Administration. the Administration. Annual APCD inspections must be Annual APCD inspections must be conducted conducted no later than 12 months no later than 12 months following the following the previous inspection. (APCD previous inspection. (APCD repair schedule repair schedule same as above.) same as above. ) APCD inspection must include: (c) APCD inspection must include: (c) 1.) Inspection of APCD for proper operation, 1.) Inspection of APCD for proper operation, 2.) General observation of equipment to 2.) General observation of equipment to assure it is well maintained and in good assure it is well maintained and in good operating condition. operating condition

7 Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Site specific monitoring plans must be submitted (f) Site specific monitoring plans must be submitted (f) to the Administrator according to the to the Administrator according to the requirements in (a) and (b) for approval requirements in (a) and (b) for approval at least 60 days before initial performance at least 60 days before initial performance evaluation of a continuous monitoring system. evaluation of a continuous monitoring system. An ash handling plan must be submitted 60 days (g) An ash handling plan must be submitted 60 days (g) before the initial compliance test date. before the initial compliance test date. An updated monitoring plan must be submitted if (h) An updated monitoring plan must be submitted if (h) there are any changes in monitoring procedures, there are any changes in monitoring procedures, or if there is a process change. or if there is a process change. Monitoring plans involving alternate monitoring Monitoring plans involving alternate monitoring requirements to demonstrate compliance may be requirements to demonstrate compliance may be submitted to the Administrator for approval. submitted to the Administrator for approval. Alternate monitoring plan must be submitted for Alternate monitoring plan must be submitted for approval no later than notification of the initial approval no later than notification of the initial performance test (e) performance test (e) Approval or denial of the alternate monitoring Approval or denial of the alternate monitoring plan will be given to the SSI unit owner/operator plan will be given to the SSI unit owner/operator within 90 days after receipt of original request or within 90 days after receipt of original request or 60 days after receipt of any supplemental 60 days after receipt of any supplemental information, whichever is later. information, whichever is later. You may use the results from a performance test conducted within the 2 previous years that Q: Is it correct that only test data obtained after was conducted under the same conditions and 2014, can be used to demonstrate initial compliance demonstrate compliance with the limits with the Emission Guidelines? provided that no process changes have been since the performance test was conducted. CFR: Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Initial compliance with the emission limits and Initial compliance with the emission limits and standards specified in Tables 2 or 3 of this standards specified in Tables 1 or 2 of this subpart subpart must be demonstrated according to the must be demonstrated according to the requirements in and (a) and (b) requirements in and within 60 by the compliance date under the approved days after unit reaches the feed rate at which it will state/tribal plan, or by March 21, 2016 if no operate or within 180 days after initial startup, state/tribal plan has been approved. whichever comes first (i.e., the compliance date). An annual performance test must be conducted (a) An annual performance test must be conducted (a) calendar months after the previous test or calendar months after the previous test or within 60 days of a process change. within 60 days of a process change. If two consecutive performance tests show that (a) If two consecutive performance tests show that (a) emissions for a pollutant are at or below 75 emissions for a pollutant are at or below 75 percent of the emission limit specified in Table 2 percent of the emission limit specified in Table 1 or 3 of this subpart, then testing for that pollutant or 2 of this subpart, then testing for that pollutant can be conducted every 3rd year, but no more can be conducted every 3rd year, but no more than 37 months after the previous performance than 37 months after the previous performance test. test. Use of a continuous emissions monitoring system Use of a continuous emissions monitoring system (CEMS) or continuous automated sampling system (CEMS) or continuous automated sampling system (CASS) to demonstrate compliance requires (CASS) to demonstrate compliance requires following of the procedures specified in following of the procedures specified in (b)(6). For CEMS that do not yet have a (b)(6). For CEMS that do not yet have a final performance specification (hydrogen (b) final performance specification (hydrogen (b) chloride, dioxins/furans, cadmium, or lead), the chloride, dioxins/furans, cadmium, or lead), the option to use CEMS or CASS takes effect on the option to use CEMS or CASS takes effect on the date a final performance specification applicable date a final performance specification applicable to the monitored pollutant is published in the to the monitored pollutant is published in the Federal Register. Federal Register. Facilities can submit an application to the Q: Are there alternate testing options available? Administrator for alternate monitoring requirements CFR: and Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR The records specified in (a) through (n) The records specified in (a) through (n) must be maintained for 5 years. These records must be maintained for 5 years. These records must be on site in paper copy or must be on site in paper copy or computer readable format that can be printed computer readable format that can be printed upon request, unless the Administrator approves upon request, unless the Administrator approves an alternative format. an alternative format. An Increments of Progress Report must be (a) submitted if compliance will be achieved more than 1 year following the effective date of state Not Applicable Not Applicable plan approval. This report must be submitted no later than 10 business days after the compliance A notification of construction (that includes (a) documentation of the siting analysis specified in & Not Applicable Not ) and notification of initial startup must (b) Applicable be submitted prior to commencing construction and initial startup, respectively. The Initial Compliance Report must be submitted (b) The Initial Compliance Report must be submitted (c) within 60 days after the initial performance test. within 60 days after the initial performance test. The first Annual Compliance Report must be (d) The Annual Compliance Report must be submitted no later than 12 months following previous annual compliance report. Report can (c) submitted no later than 12 months following the submission of the initial compliance report. Subsequent annual compliance reports must be be submitted electronically or in paper copy is postmarked on or before the due date. submitted no more than 12 months after the previous annual compliance report. Report can be submitted electronically or in paper copy is postmarked on or before the due date. Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR A Deviation Report must be submitted if a (d) A Deviation Report must be submitted if a (e) deviation has occurred, according to the (h) deviation has occurred, according to the (i) specifications in (d). The Deviation Report specifications in (e). The Deviation Report must be submitted by August 1 of that year for must be submitted by August 1 of that year for data collected during the first half of the calendar data collected during the first half of the calendar year (January 1 to June 30), and by February 1 of year (January 1 to June 30), and by February 1 of the following year for data collected during the the following year for data collected during the second half of the calendar year (July 1 to second half of the calendar year (July 1 to December 31). Report can be submitted December 31). Report can be submitted electronically or in paper copy is postmarked on electronically or in paper copy is postmarked on or or before the due date. before the due date (e) A Qualified Operator Deviation Report must be submitted if all qualified operators are not accessible to the SSI unit for 2 weeks or more. A Qualified Operator Deviation Report must be submitted if all qualified operators are not accessible to the SSI unit for 2 weeks or more. This (f) This report must be submitted within 10 days of the deviation and be followed by a status report report must be submitted within 10 days of the deviation and be followed by a status report every 4 weeks. every 4 weeks. A report notifying a force majeure must be (g) submitted as soon as possible following the date A report notifying a force majeure must be of a pending or past occurrence of a force submitted as soon as possible following the date majeure is known. A force majeure is an event beyond the control of of a pending or past occurrence of a force majeure is known (f) the facility, such as acts of nature, acts of war or A force majeure is an event beyond the control of terrorism, or equipment failure that prevents the facility, such as acts of nature, acts of war or conducting a performance test within the terrorism, or equipment failure that prevents regulatory timeframe specified by the emission conducting a performance test within the guidelines. regulatory timeframe specified by the NSPS. Notification of intent to conduct a performance (g) Notification of intent to conduct a performance (h) test is due at least 30 days prior to the test is due at least 30 days prior to the performance test. performance test

8 Emission Guidelines (MMMM) CFR New Source Performance Standards (LLLL) CFR Notification of a rescheduled performance test is (g) Notification of a rescheduled performance test is (h) due at least 7 days prior to the date of the due at least 7 days prior to the date of the rescheduled test. rescheduled test. Notification to start or stop use of a continuous (g) Notification to start or stop use of a continuous monitoring system used to demonstrate monitoring system used to demonstrate compliance with an emission limit must be compliance with an emission limit must be (h) Provided to the Administrator 1 month before provided to the Administrator 1 month before starting or stopping use of the continuous starting or stopping use of the continuous monitoring system. monitoring system (i) Beginning January 1, 2012 and within 60 days Beginning January 1, 2012 and within 60 days after completing performance testing as defined after completing performance testing, relative in 63.2, relative accuracy test audit data and accuracy test audit data and performance test performance test must be submitted electronically must be submitted electronically to EPA s Central to EPA s Central Data Exchange by using the (h) Data Exchange by using the Electronic Reporting Electronic Reporting Tool at: Tool at: or other compatible electronic spreadsheet. or other compatible electronic spreadsheet. Annual or semi annual reporting dates may be (i) Annual or semi annual reporting dates may be (j) changed with Administrator agreement. changed with Administrator agreement. Procedures to seek approval for changes to Procedures to seek approval for changes to reporting dates are found in 60.19(c). reporting dates are found in 60.19(c). Copies of the rule and other materials are located at: For more information on this regulation, please call your state or local air pollution control agency or the EPA Regional Office covering your state: For more information on state requirements, please contact your state representative found at the following link: OR Google 40 CFR part 60 ecfr from GPO Access will be in the first few search results Sign up for alerts! EPA s Rulemaking Gateway: Federal Docket System:

9 Amy Hambrick Fuels & Incineration Group Office of Air Quality Planning & Standards USEPA Contact: (919) Testing and Achieving Compliance Robert P. Dominak President Friar Consulting Inc. July 25, How do we determine if our SSIs meet the new limits? Are SSIs at other POTWs meeting the new limits? Review recent air emissions test data - Convert emissions (i.e., ppmvd, mg/dscm, ng/dscm) to 7% oxygen How are those not currently in compliance intending to meet the new limits? What might it cost us to meet the new limits? Conduct new air emissions tests using EPA approved Test Methods. 9

10 Pollutant Volume or Duration EPA Test Method No.* PM 0.75 dscm/run 5, 26A, or 29 HCl 26: 200 liters/run 26 or26a 26A: 1 dscm/run CO 1 hour/run 10, 10A, or 10B Dioxins/Furans 1 dscm/run 23 Hg 29: 1dscm/run 29, 30B or ASTM D See 30B for details NOx 1 hour/run 7 or 7E SO 2 6: 200 liters/run 6C: 1 hour/run 6, 6C, or ANSI/AMSE PTC Cd 1 dscm/run 29 Pb 1 dscm/run 29 Fug. Ash Emissions 3 1 hour observation periods 22 * 40 CFR Part 60, Appendix A unless otherwise noted Pollutant Volume or Duration EPA Test Method No.* PM 0.75 dscm/run 5, 26A, or 29 HCl 26: 200 liters/run 26 or26a 26A: 1 dscm/run CO 24-hour block avg. CO-CEMS Dioxins/Furans 3 dscm/run 23 Hg 29: 1dscm/run 29, 30B or ASTM D See 30B for details NOx 1 hour/run 7 or 7E SO 2 6: 200 liters/run 6C: 1 hour/run 6, 6C, or ANSI/AMSE PTC Cd 1 dscm/run 29 (GFAAS or ICP/MS) Pb 1 dscm/run 29 (GFAAS or ICP/MS) Fug. Ash Emissions 3 1 hour observation periods 22 * 40 CFR Part 60, Appendix A unless otherwise noted Pollutant Volume or Duration EPA Test Method No.* PM 1 dscm/run 5, 26A, or 29 HCl 1 dscm/run 26A CO 1 hour/run 10, 10A, or 10B Dioxins/Furans 1 dscm/run 23 Hg 29: 1dscm/run 29, 30B or ASTM D See 30B for details NOx 1 hour/run 7 or 7E SO 2 6: 60 liters/run 6C: 1 hour/run 6, 6C, or ANSI/AMSE PTC Cd 1 dscm 29 (GFAAS or ICP/MS) Pb 1 dscm 29 (GFAAS or ICP/MS) Fug. Ash Emissions 3-1 hour observation periods 22 * 40 CFR Part 60, Appendix A unless otherwise noted Pollutant Volume or Duration EPA Test Method No.* PM 1 dscm/run 5, 26A, or 29 HCl 1 dscm/run 26A CO 24-hour block avg. CO-CEMS Dioxins/Furans 3 dscm/run 23 Hg 29: 3 dscm/run 29, 30B or ASTM D See 30B for details NOx 1 hour/run 7 or 7E SO 2 6: 100 liters/run 6C: 1 hour/run 6, 6C, or ANSI/AMSE PTC Cd 1 dscm 29 (GFAAS or ICP/MS) Pb 3 dscm 29 (GFAAS or ICP/MS) Fug. Ash Emissions 3-1 hour observation periods 22 * 40 CFR Part 60, Appendix A unless otherwise noted 10

11 Items monitored during the air emission tests and when the unit is in service. (Applies to all SSIs): 1. Pressure drop across each wet scrubber 2. Water feed rate for each scrubber 3. ph of water feed for each scrubber 4. Combustion chamber operating temperature or afterburner temperature Additional operational limits for SSIs equipped with: 1. Activated carbon injection systems 2. Fabric filters (Baghouse) 3. Wet electrostatic precipitators Emissions were 1,000 times higher than anticipated Reason - Data was in micrograms, but incorporated into the formula as milligrams. Data not corrected to 7% O 2 PM = 20 12% O 2 7% O 2 = PM x ((20.9-7)/(20.9-%O 2 )) 7% O 2 = 20 mg/dscm x ((20.9-7)/( )) PM = 31 O 2 Incorrect Toxic Equivalency Factors used for Dioxins/Furans See Table 5 of Subpart MMMM or Table 4 of Subpart LLLL for details - Same TEFs for all SSIs 100% compliance - No changes required. Exceeded NOx limit - Investigating operational changes to reduce NOx emissions. Exceeded one or more of the limits - Considering: a. Operational changes. b. Implementing a more stringent pre-treatment program. c. Modifying existing APCDs or installing new APCDs. NOx Emission Reduction Options: 1. Reduce operating and/or afterburning temperatures 2. Install new low NOx burners 3. Improve mixing within the incinerator 4. Inject urea or ammonia into an FBI or its exhaust gas system. (Not yet tested on MHIs.) Cost Estimate = ~$1.5 - $2.0 million/unit 5. Add sodium hydroxide to the scrubber water (MHIs only) Cost Estimate = ~$ $0.30 million/unit 11

12 Reducing PM and PM based Cd, Pb & Hg Emissions 1. Increase scrubber water flow rate and pressure drop 2. Install a new multi-stage venturi scrubbing system. Cost Estimate = ~$ $1.75 million/unit 3. Install a new wet electrostatic precipitator Cost Estimate = ~$2.5 - $3.0 million/unit Reducing HCl and SO 2 Emissions 1. Increase scrubber water flow rate 2. Add sodium hydroxide to the scrubber Cost Estimate = ~$ $0.30 million/unit Reducing CO Emissions 1. Increase exhaust gas temperature. 2. Install an internal afterburner, if there is room. 3. Install a new external afterburner. Cost Estimate = ~$3.0 - $4.0 million/unit Note: All three options will increase NOx emissions. Reducing Dioxins/Furans Emissions 1. Install an activated carbon adsorption system Cost Estimate = ~$ million/unit Reducing Hg Emissions 1. Source Control: Implement a mandatory dental amalgam separator program. This action has reduced Hg emissions by as much as 50%. 2. Install an activated carbon adsorption system Cost Estimate = ~$ million/unit See WERF s 2009 Report titled Minimizing Mercury Emissions from Biosolids Incinerators Bob Dominak Friar Consulting Inc Friar Drive Parma, OH Phone: Robert.Dominak@gmail.com 12

13 Conduct Air Emissions Testing ASAP to determine whether or not your SSIs are in compliance. James E. Welp Vice President Black & Veatch July 25, 2012 If your incinerators do not meet all of the limits, see if reductions can be achieve through operational changes. If operational changes don t achieve compliance, start investigating modifications to your existing air pollution control system or the installation of new equipment. Apply for a new or modified Title V permit no later than March 21, Retest your incinerators after March 21, This data can be used to demonstrate initial compliance for the March 21, 2016 compliance deadline. Continue working with your Plant operating personnel and others on ways to reduce emissions from your incinerators. Analysis of Recent Tests or Baseline testing of existing SSIs using MACT protocols Cost analysis to determine if you are an existing source 13

14 Most would consider they are an Existing source. Ones that are close to modified status have replaced feed system with pumps, changed ash system, or added heat recovery. Many of the costs are considered maintenance replacement. Included in modification Feed system and grate system Incinerator capacity, burner, or ID fan change Ash and conveyance system Waste heat recovery equipment Not included in modification Air pollution control equipment Maintenance, repair, or replacement in kind Need to bring original costs and improvments to current $ using Engineering News Record Construction Cost Index Example $10M (1972) ~ $44M (2012) Multiplier varies by Region Retest How much confidence do you have in one test to make a decision Data analysis to determine if operational controls or additional emission control equipment is needed Preliminary engineering to develop feasible arrangement and costs Feed quantity issues not enough solids on test day for unit to be at 85% Testing time issues several have not done the testing for the same length of time/volume as prescribed in test methods Varies between new and existing MHIs and FBIs 3 test runs required for each pollutant CEMs converter issues SS or molybdenum probes for NOx 14

15 CO is in compliance NOx is marginal for most MHIs SOx reading are typically in compliance with a few units having very high readings Cd and Pb are issues related to age of scrubber Hg limit is low and problematic for several FBIs HCl exceeded limits on several tests check units CCD/CDF has limited test data exceeded for at least one MHI We have not found an MHI or FBI that has met New or Modified criteria steam turbine generator costs do not count towards the modification threshold. WEF recommends EPA reconsider sludge variability for new units Control Mechanism(s) Combustion Controls (T and O2 control, afterburner) Water/ Chemical (NaOH) Advanced Scrubber Equipment (multi venturi or WESP) Carbon Bed or Injection Pollutants CO, CDD/CDF, and NOx HCl and SOx Cd, Pb, and PM CDD/CDF and Hg Planning Time Frame Compliance by March 2016 required Regulations could change in 5 years but EPA track record has been changes every 10 years May want to consider modified criteria if planning is more than 10 years Space for new equipment is limited in existing buildings Training program for combustion controls is recommended Consider new SSI Consider energy recovery 15

16 Baseline Testing should be complete Cost Analysis should be complete Develop Plan to move forward Additional Testing to confirm operation and add confirm for compliance James E. Welp Vice President Black & Veatch July 25, Compliance and Testing Requirements to Meet the Sewage Sludge Incineration MACT Standards Part 2 Q & A Session FTP Site for PDH Form and Power Point Slides 16