AMSA Regulatory Alert (RA 04-13)

To: Members
From: National Office
Date: May 19, 2004
Subject: AMSA/WERF 2004 THC/CO-CEMS SURVEY
Reference: RA 04-13

Action Please By:
June 15, 2004

Given the problems that some publicly owned treatment works (POTWs) are encountering with their Total Hydrocarbon (THC) / Carbon Monoxide (CO) - Continuous Emissions Monitoring Systems (CEMS) and the differing interpretations of the 40 CFR Part 503 requirements concerning THC/CO-CEMS, the Association of Metropolitan Sewerage Agencies (AMSA) and the Water Environment Research Foundation (WERF) are conducting a joint survey to collect information on the following:

• Current THC/CO emissions from biosolids incinerators;
• Extent of the operation and maintenance (O&M) problems being encountered with THC/CO-CEMS;
• Cost to purchase, install, operate and maintain the THC/CO-CEMS; and
• State and local THC/CO-CEMS requirements.

The information gathered from this survey will shed light on the extent of the problems POTWs are facing with their TCC/CO-CEMS and will help frame AMSA’s advocacy efforts with the U.S. Environmental Protection Agency (EPA), and state and local permitting authorities.

To accomplish this, AMSA requests that its members who incinerate part or all of their biosolids complete this survey by June 15, 2004.

Background
On February 19, 1993, EPA published in the Federal Register its new “Standards for the Use or Disposal of Sewage Sludge (40 CFR Part 503).” These standards required that the THC concentration in the exhaust gases for all biosolids or sewage sludge incinerators not exceed 100 parts per million (ppm) – as propane – corrected to zero percent moisture and seven percent oxygen, on a monthly average basis. This rule also required POTWs that practice incineration to install an instrument that measures and records the THC concentrations in the biosolids incinerator exit gas.

In 1994, the Part 503 Regulation was modified to allow POTWs that practice incineration to monitor CO as an alternative to THC. The alternative CO limit was set at 100 ppm, corrected to zero percent moisture and seven percent oxygen, on a monthly average basis.

Over the past few years, a substantial number of POTWs that practice incineration have encountered major problems with their THC/CO-CEMS. A number of POTWs have replaced their existing systems after less than seven years of service, some have encountered extensive O&M problems, while others have received additional or more stringent THC/CO-CEMS requirements from their state and/or local permitting authorities.

Survey Instructions
Responses from this survey will only be viewed by a few members of AMSA’s working group. The data contained within the surveys will be summarized both on a national basis and an EPA Regional basis, before it is presented to EPA, AMSA members, and WERF subscribers. Neither the name nor location of your Agency will be made public without your written consent.

The online survey is available on the CleanWater Central website (http://www.cleanwatercentral.org). To login:

• Click on “Enter private subscribers’ area”;
• Enter your AMSA user ID and password;
• Click on “Surveys” on the menu bar at the top of the screen;
• Select the THC/CO-CEMS Survey and follow the directions.

For purposes of this survey, we request that one survey be completed for your wastewater treatment agency as a whole, covering all of your facilities that practice incineration.

The survey, which contains twenty-six (26) questions, is divided into the following seven (7) sections:

1. Responder/Responding Agency Information
2. THC/CO-CEMS Construction Cost Data
3. Plant & Process Background Information
4. THC/CO Performance Information
5. THC/CO-CEMS Regulatory Information
6. THC/CO-CEMS Design and Maintenance Information
7. Follow-up Questions and Contact

The system will save your responses as you go through the survey and you can logoff and come back later to complete, add to, or change your responses. There is a PDF version of the survey available for download also on the CleanWater Central site so you can review all the questions in advance of completing the online form. For those wastewater treatment agencies that are unable to complete the survey online, please contact the individuals listed below to obtain a hard copy or an e-mailed electronic version of the survey.

Again, it is requested that all surveys be completed by Tuesday, June 15, 2004.

If you have any questions or require additional information concerning the questions contained within this survey, please do not hesitate to contact either Bob Dominak, Chair, AMSA’s Incineration Workgroup, by e-mail at dominakr@neorsd.org or by phone at 216-881-6600 ext. 6405, or Will Pettit, AMSA’s Regulatory Analyst, by email at wpettit@amsa-cleanwater.org or by phone at 202-833-3280. Thank you for participating in this important survey!