Page 62 - Wastewater Solids Incineration Systems

Permitting and Emissions Regulations 31

Continuous emission monitoring for carbon monoxide may be conducted instead
of monitoring for total hydrocarbons. A typical combustion unit will have air pollution
control devices including wet scrubbers, dry and wet electrostatic precipitators, and
fabric filters. Afterburners or regenerative thermal oxidizers may be used to control
volatile organic carbon emissions and/or odorous compounds. The efficiency of the air
pollution control system is included in the overall control efficiency of the combustion
process. Specific performance standards are not established for the control devices.
Management practices are defined that require sufficient monitoring equipment
is installed to ensure performance standards are met. These practices include a con-
tinuous emission monitor for total hydrocarbons or carbon monoxide and instru-
ments to monitor oxygen and moisture concentrations in the stack. Combustion tem-
peratures must be monitored at least daily to ensure that operating combustion
temperatures established during the performance test are not exceeded by more than
20%. Other parameters that monitor the performance of the air pollution control may
also be required to ensure their proper operation at a frequency appropriate for that
device. Frequency of sampling and analysis for metal concentrations will be deter-
mined by concentrations expected in the WWTP residuals.
Records that define performance of the incinerator and actual emissions rates
must be reported annually and kept for five years.

5.0 AIR QUALITY COMPLIANCE

The compliance assurance monitoring (CAM) requirements are defined in 40 CFR 64.
The CAM rules apply to a pollutant specific emissions unit at a major source that is
required to obtain a Title V Permit. The rules apply to an emissions unit that is sub-
ject to an emission standard or limitation, uses a control device to achieve compli-
ance, and exceeds the uncontrolled emission criteria. Operation of an incinerator is
required to achieve particulate control limits using a particulate control device. A
CAM plan demonstrating that the scrubber is operated as intended and achieves the
required emission limitations needs to be developed.
Permitting requirements under the CAA have evolved over the past 30 years. As
the CAA is amended, new interpretations of existing regulations are made and addi-
tional requirements are added. Thus, it is necessary for thermal treatment units to
review carefully the air quality permitting requirements as they apply to each loca-
tion. Satisfactory completion of air emissions testing and preparation of operating
permit applications may be needed for continued operation. Periodic monitoring,
recordkeeping, and reporting may be a continued condition of plant operation.