NACWA Regulatory Alert (RA 05-05)

To: Members & Affiliates, Biosolids Management Committee, Air Quality Committee
From: National Office
Date: May 20, 2005
Subject: NACWA/WERF SURVEY ON INCINERATOR EMISSION MONITORS
Reference: RA 05-05
Attachment: • Biosolids Incineration Survey Report (PDF, 63KB)

A recent survey by the National Association of Clean Water Agencies (NACWA) and the Water Environment Research Foundation (WERF) has found that biosolids incinerators are consistently meeting total hydrocarbon (THC) and carbon monoxide (CO) emissions requirements of the Part 503 Regulation of the Clean Air Act. Specifically, the survey revealed that the monitored THC and CO emissions from these facilities are consistently in compliance with the regulatory limits of 100 ppm on an average monthly basis. In fact, survey respondents indicated that their 2003 annual per month average was approximately 27 ppm for THC and 30 ppm for CO.

The survey also found, however, that biosolids incinerator operators are struggling with operation and maintenance (O&M) issues with these monitoring systems. These problems include frequent breakdown, high repair costs of older models, and durability issues. It is with regard to these O&M issues that NACWA has outlined a strategy of next steps (see below) to help the publicly owned treatment work (POTW) community meet these O&M challenges.

The survey was distributed in May 2004 to all of the known wastewater treatment agencies located within the United States that practice biosolids incineration. Completed surveys were received from 34 wastewater treatment agencies representing 46 POTWs located in 18 different states. The survey participants own and operate a total of 105 multiple hearth incinerators and 10 fluidized bed incinerators. Participants reported that they have to spend an average of 20 person-hours per week maintaining their emissions monitoring and data acquisition systems. Twenty-four respondents reported spending an average of $25,000 per agency per year to operate and maintain their systems. Combined O&M costs for the 24 respondents totaled $600,000 per year.

Next Steps
Based on the O&M problems being encountered, the survey report suggests that NACWA, WERF, the Water Environment Federation (WEF), and the U.S. Environmental Protection Agency (EPA) work together to:

• Explore alternative technologies for monitoring these emissions that are more efficient and durable,

• Investigate the feasibility of implementing a more realistic CO limit for multiple hearth incinerators, and

• Provide additional training and guidance to the biosolids incinerator community on various issues surrounding the use of THC-CEMS.

Robert P. Dominak, Co-Chair of NACWA’s Biosolids Management Committee and Residuals and Air Emissions Manager at the Northeast Ohio Regional Sewer District, Cleveland, Ohio, developed and oversaw the survey in coordination with NACWA and WERF. A more thorough analysis of the survey results, conclusions, and next steps are available in the attached survey report. For more information, contact Will Pettit, NACWA, at 202/833-3280 or wpettit@nacwa.org.

ATTACHMENT

• Biosolids Incineration Survey Report (PDF, 63KB)