Activated Carbon | SSI | Section 129 | Sludge Cake | FOG | Applications
CAA Section 129 Compliance
See also: CAA Reference Material
Section 129 of the Clean Air Act (CAA) that passed in 1990 requires the Environmental Protection Agency (EPA) to set emissions limits for 9 pollutants for certain non-hazardous solid waste incinerators. Sewage Sludge Incinerators (SSI) were found to fall within this regulation, and on March 21, 2011 the EPA published new standards for new and existing SSI’s in 40CFR60 subparts MMMM & LLLL.
These new standards set strict numerical concentration emissions limits for: Cadmium, Carbon Monoxide, Hydrogen Chloride, Lead, Mercury, Nitrogen Oxides, Particulate Matter, Polychlorinated Dibenzo-p-dioxins & Polychlorinated Dibenzofurans, and Sulfur Dioxide. The new EPA regulations also set new standards for compliance monitoring and reporting, require annual operator training through a state approved program, and require a Title V Operating Permit. These new requirements called for final compliance by March 21, 2016, with the final rule published under 81FR26039. |
Every sewage sludge incinerator planning to stay in operation has to comply.
The time to start planning is now. Chavond-Barry Engineering is knowledgeable in the industrial and municipal incineration industry with the experience and expertise needed to help your facility comply with these new standards. With every facility being unique, CBE with its experienced staff can help you determine what your facility needs to comply with these new standards and then engineer any necessary retrofit. |
Title V Operating Permit
Under the new regulations set forth in CAA Section 129 (40CFR60), all incinerator locations are required to obtain a Title-V Operating Permit (TVOP). A TVOP will typically require modification to the existing permit to encompass new emissions limits and requirements for monitoring, recording, testing, reporting, and training as set forth by 40CFR Part 62. Chavond-Barry Engineering Corp. has successfully permitted dozens of installations, providing owners with sufficient "operating room" to assure continued emission compliance.
Under these new regulations, all municipal incinerators, regardless of size, will need a TVOP to stay in operation. CBE can prepare your paperwork and submit it to the regulating authority for you, including any negotiations that may be required. CBE can also review and submit your required annual reports, including Annual Emissions Statements, 6-Month Deviation Reports and Annual Certifications. |
*Unless
a unit is subject to an earlier Title V 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 the earliest date
specified in 1 through 3 below:
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Compliance Testing
With the new emissions limits, comes new requirements for compliance testing. SSI units are required to demonstrate initial and annual compliance with the new emissions limits via an EPA-approved method of emissions testing as part of an EPA-approved monitoring plan. This will entail either annual stack testing or a continuous monitoring system such as a CEMS or CASS.
Those facilities that opt for stack testing have the option of testing less often (every third year as opposed to annually) provided the performance testing for at least 2 consecutive years shows that the emissions are at or below 75% of the limit for the selected pollutant. The new rules also require annual inspections for all APC equipment used to meet the new emissions limits, along with revised monitoring and recordkeeping requirements. |
This increased frequency of testing will be a change for many facilities, but will be strictly required. CBE is experienced in drafting and editing stack testing protocols and will work side by side with your stack testing company, or recommend a stack testing company for your facility. We are also experienced with negotiating with the DEP or local regulatory authority to make sure they agree that your testing results are in compliance.
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Training Requirements
Part of the new regulations set forth in Section 129 of the Clean Air Act (40CFR62 and 40CFR60 subparts MMMM & LLLL), require owners or operators of SSI units to meet new operator training and qualification requirements. These include: completion of an operator training course, completion of annual refresher courses, and maintaining annually updated plant specific training / operations information. The required operator training must include at a minimum the following 10 core subjects:
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This represents a huge change for most facilities, which have never had formal training programs for incinerator operators. CBE can, with your input, develop a training program specific to your facility's needs and requirements, submit the training program to your local regulating authority for approval, prepare all paperwork and training materials, and administer the class at your facility.
Operator training not only ensures that everyone understands the basic principles of your systems operation but everything about running your equipment efficiently and safely. In addition, CBE can provide the required yearly refresher classes to ensure everyone stays on top of this knowledge. No one knows more about incinerators than we do. *Initial operator training and qualification must be completed by the later of the following three dates:
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