Page 60 - Wastewater Solids Incineration Systems

Permitting and Emissions Regulations 29

The operating permit program (Title V of the CAA) consolidates the emission
limits established for the entire facility and defines a means to monitor compliance
with the limits.
Once the facility is constructed, a performance test may be required by the pre-
construction permit that seeks to demonstrate that the emission limits established in
the permit have been met by the operating facility. Satisfactory completion of the
emission testing and submission of an operation permit application may be needed
for continued operating of the facility.
If the facility is a major source, a Title V Operating Permit (40 CFR 70, State Oper-
ating Permit Programs) may be needed. The operating permit identifies all air emission
sources present at the facility, summarizes the emission limitations and special condi-
tions that have been established by the pre-construction permit, and outlines a process
by which continued compliance with emission limitations can be demonstrated.
An accidental release prevention program may be required if hazardous material
is used or stored onsite above the threshold limits (40 CFR 68). Often this requirement
may apply to the disinfection process of the wastewater treatment plant and not the
solids-processing area.
Sampling and testing is also required as part of the wastewater residuals man-
agement program (40 CFR 503). Solids testing and other reporting requirements are
defined for land application and thermal treatment systems.

4.3 State Operating Permit Program

The state operating permit program applies to major emission sources that have
accepted federally enforceable operating limits to restrict annual emissions to levels
less than the major source thresholds or large minor emission sources whose poten-
tial emissions are less than the major source threshold but greater than the state oper-
ating permit program. The state operating permit program is similar to the federal
operating permit program except that compliance with the program is administered
through the state.

4.4 Accidental Release Prevention Program
The Chemical Accident Prevention Program requirements are defined in 40 CFR 68.
Facilities that use or store more than the threshold quantities must prepare and
implement a risk management plan (RMP). The operation of an incinerator does not
trigger this requirement as the chemicals used to operate the unit are not hazardous
or are not stored in quantities greater than the threshold limit.