Page 245 - Wastewater Solids Incineration Systems

Instrumentation and Control 207

detailed references to Code of Federal Regulations appendices and performance
specifications. It must be emphasized that these requirements are exceedingly com-
plex and tedious. An entity must study them thoroughly and implement them care-
fully to achieve and maintain compliance.
Indeed, many regulations require not only notification of the failure of such a
monitoring system but also shutdown of the process after a failure of emission-moni-
toring equipment. Failures as a result of the incompleteness or inadequacy of quality
assurance/quality control (QA/QC) systems may also lead to regulatory penalties or
fines. Process and workplace safety requirements preclude the facility from contin-
uing process operations without the benefit of safety systems (and it is typically
illegal to do so). Maintenance and operation of instrument and control systems and
particularly continuous emissions monitoring systems are critical.

8.0 OTHER RELATED REGULATIONS
Federal regulations that govern other air pollution sources may apply to incineration
systems, which often creates confusion. Table 9.3 provides a look at three regulatory
references. They are mentioned here to caution the reader against designing or imple-
menting unneeded monitoring and instrument and control systems. Often, commer-
cial suppliers are not fully aware of incineration needs, and instead attempt to sell or
substitute a system designed for another emission program. The obvious results are
noncompliance with regulations and additional expense related to implementing
unnecessary instrumentation monitoring, recording, and recordkeeping systems.
The Clean Air Act (CAA) Part 70 program is often applicable to incineration sys-
tems because emissions typically exceed the threshold to be declared a major source
under the CAA. A specific determination must be made for facility-wide emissions
and may recognize efforts undertaken by the designer to limit the facility’s and
source’s “potential to emit” codified emissions. Recently designed incineration sys-
tems have been able to be declared a “minor” source category definition or a “syn-
thetic minor” category definition, thus are not subject to Part 70 rules.
Another federal program, compliance assurance monitoring (CAM) systems (40
CFR Part 64) often are mentioned. It is not applicable to incineration systems. The
CAM rule (see Table 9.3) requires owners and operators to oversee and evaluate the
effectiveness (QA/QC) of the instruments, control devices, and systems that monitor
process emissions. The rule requires reporting the status and accuracy of the moni-
toring system as well as reporting the facility’s actual determination of compliance or