Action Please By: June 30, 1997
To: Members & Subscribers From: National Office Date: June 4, 1997 Re: RA 97-12 Survey of Combustion Devices at POTWS
EPA is presently developing regulations to control emissions of Hazardous Air Pollutants (HAPs) and criteria pollutants from a variety of combustion sources as required by Sections 111, 112, and 129 of the Clean Air Act (CAA). The combustion source categories include:
Industrial Boilers
Commercial/Industrial Boilers
Process Heaters
Stationary Internal Combustion Engines
Stationary Gas Turbines
Industrial/Commercial Solid Waste Incinerators
Other Solid Waste Combustion
The CAA requires regulations for all of the categories to be promulgated by November 2000. To accomplish this goal, the EPA has established an Industrial Combustion Coordinated Rulemaking (ICCR) process and has invited various stakeholders to participate in developing a unified set of Federal air emissions regulations. AMSA, through its Air Quality Committee, is participating on behalf of POTWs in the ICCR process. This participation is crucial to ensure that the regulations and emission standards which are promulgated reflect the operations of the various combustion devices burning digester gases in use at POTWs. Other stakeholders in the ICCR process do adequately represent the interests of entities that burn fuels such as natural gas, diesel, etc.
An important step in the rulemaking process is the collection of information and data pertaining to the combustion devices of interest. Since data for combustion devices that burn digester gas is very limited, AMSA is soliciting information from its membership by June 30, 1997, through the enclosed questionnaire. Sludge incineration is not part of the ICCR Rulemaking process and information on these units is not being requested as part of this survey.
The questionnaire is divided into three parts:
Part I - General Facility Information: One Form is to be completed for the entire facility.
Part II - Combustion Device Information: This part is divided into four subgroups.
A) Boilers
B) Stationary Reciprocating Internal Combustion Engines
C) Combustion Turbines
D) Digester Gas Burner (Flare)
Complete one form for each boiler, internal combustion engine, gas turbine, and/or flare burning digester gas at your facility.
Part III - Economics: Complete one form for each combustion device for which a Part II form has been completed.
Please provide the attached questionnaire to the appropriate individual(s) in your agency to complete the information requested. If you are unable to respond to an item as stated, please provide any information you believe may be related. Use additional copies of the questionnaire forms, if necessary. If a facility has multiple identical combustion devices for which all of the Part II form information is the same, it is acceptable to complete only one Part II form and indicate all combustion devices to which it applies under "Combustion Device ID No."
Please return the completed questionnaire to:
Sam Hadeed
Director, Regulatory Affairs & Technical Services
Association of Metropolitan Sewerage Agencies
1000 Connecticut Avenue, NW, Suite 410
Washington, DC 20036-5302
telephone: 202/833-4655
Due to the short time frame and fast moving pace of the rulemaking, it is requested that you return the completed questionnaire to AMSA's National Office by June 30, 1997.
The results of the survey will be compiled by an engineering consulting firm, Malcolm Pirnie, White Plains, NY, retained by AMSA, and analyzed by AMSA's Air Quality Committee and the consultant. Depending upon the availability of data and the duration of the rulemaking, AMSA may recommend that source testing of representative combustion units burning digester gas be performed in order to obtain accurate emissions and control efficiency information to provide to EPA. We will keep the membership abreast of this need and any future developments.
Please feel free to contact Sam Hadeed, AMSA, at 202-833-4655, if you have any questions. Thank you for your time and efforts.
ATTACHMENT: ICCR Survey of Combustion Devices at POTWS (please call AMSA's National Office at 202/833-AMSA for a copy of this document.