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To:

Members, Affiliates, & Air Quality Committee

From:

National Office

Date:

December 4, 1998

Subject:

EPA Proposed MACT Standard

Reference:

RA 98-23

ACTION PLEASE BY: ACTION PLEASE BY: JANUARY 8, 1998

EPA's Office of Air and Radiation released a proposed rule, "National Emission Standards for Hazardous Air Pollutants (NESHAP): Publicly Owned Treatment Plants," in the Federal Register on December 1. Under the proposal, EPA will not impose new maximum achievable control technology (MACT) standards on existing POTWs, as the wastewater treatment portion has not been deemed as major sources of hazardous air pollutants (HAPs). EPA is seeking through the proposal, however, information on emissions and controls for wastewater collection systems, as well as the uses of pretreatment to reduce emissions. The proposal reflects a significant and successful long-term effort on AMSA's part to work with the EPA to accurately characterize air pollution emissions from publicly owned treatment works (POTWs).

As noted in the proposed rule, EPA's conclusions were based largely on data that were furnished by AMSA. AMSA has been working closely with the EPA Office of Air and Radiation for six years during the development of its NESHAP rulemaking. During this time, the Association has provided assistance to EPA by identifying, gathering and assessing available information about POTW emissions, and has arranged for agency site visits and provided technical review of emissions data. Two AMSA surveys - one on volatilization of liquid compounds and another on components of waste stream compounds - were deemed by EPA "as the primary basis for the agency's conclusions thus far regarding HAP emissions from POTW treatment plants." Under the MACT standard, POTWs would have required to install costly and impractical covers up to the primary treatment units or covers vented to control devices.

Throughout the agency's NESHAP initiative, AMSA has presented data that effectively demonstrates that the majority of existing POTWs are not major sources of HAPs as defined by the Clean Air Act, and thus should not be subject to MACT standards. In consideration of this data, AMSA had used wastewater estimation models to estimate that less than five of its member agencies would be considered as potential major sources of HAP, and thus subject to EPA's MACT standards.

In promulgating NESHAP's proposed maximum achievable control technology (MACT) standards, EPA determined that existing POTWs should not be covered by the new standards in large part because evaluating the effectiveness of the new controls would be impractical. While existing POTWs are not covered by the standards, the proposal does impose MACT standards on new, or reconstructed, POTWs deemed to be major sources of HAPs. MACT standards would also be imposed on existing or new POTWs that treat specific industrial waste streams from an industrial user trying to comply with another national emission standard.

EPA is soliciting specific comments on the following aspects of the proposal:

    (1) The use of the WATER8 model for determination of emissions from wastewater treatment processes (see attached AMSA issue paper on WATER8);

    (2) Wastewater Collection Systems:

    1. Quantitative data on the design and operation of wastewater collection systems;
    2. Scientifically supported data on the measurement or estimation of emissions from wastewater collection systems;
    3. Information on industry trends to reduce or eliminate HAP emissions; and
    4. Any other information relevant to the assessment of POTW collection system HAP emissions.

    (3) Pretreatment Program Effectiveness:

    1. The effectiveness of pretreatment program implementation in reducing overall HAP loading to POTWs (including wastewater collection systems);
    2. The effectiveness of pretreatment in reducing emissions of HAPs from POTWs (including collection systems);
    3. The cost of implementing and operating an effective pretreatment system;
    4. Observed trends in industrial HAP discharges via wastewater; and
    5. Any other information relevant in the assessment of POTW HAP emissions as they are affected by pretreatment programs.

In its continuing work with EPA on development of the MACT standards, AMSA's Air Quality Committee recently completed a thorough review of a revised emissions testing model to determine whether the modifications are accurately predictive of actual wastewater utility air emissions. The committee received Technical Action Fund assistance from the AMSA Board of Directors to conduct the review of EPA's latest version of its WATER8 emissions model. The committee also used TAF funding to prepare source testing protocols for submission to EPA to allow direct emissions testing by POTWs for determining major source status, as a default mechanism for emissions modeling.

Public comments are due back to EPA by January 15, 1999. AMSA members need to submit review comments to the National Office no later than January 8. Members are encouraged to email their comments to Sam Hadeed at shadeed@amsa-cleanwater.org ; comments can also be mailed or FAXed to 202/ 833-4657. The Association extends its appreciation and thanks to members of the Air Quality Committee, and committee co-chairs, Edward Torres, environmental manager for the County Sanitation Districts of Orange County, Calif.; and Prakasam B. Tata, manager of technical services of the Metropolitan Water Reclamation District of Greater Chicago, Ill., and Greg Adams, engineering department assistant head with the County Sanitation District of Los Angeles County for their continued efforts to work with EPA on the development of Clean Air Act rules that may affect POTW operations.

ATTACHMENTS: