Soil REmediation Units and Incinerators
The Alaska Department of Environmental Conservation (ADEC) defines “thermal remediation units” as a stationary source that causes contaminants to be desorbed from soils by heating the soil in a kiln. "Incinerator" is defined as a device used for the thermal oxidation of garbage or other wastes, other than a wood-fired heating device, including an air curtain incinerator burning waste other than clean lumber, wood wastes, or yard wastes.
18 AAC 50.502(b)
Minor permits are required under 18 AAC 50.502(b)(2)&(4) before construction, modification, or relocation of a stationary source containing a soil remediation unit with a rated capacity of at least five tons per hour or one or more incinerators with a cumulative rated capacity of 1,000 pounds or more per hour.
Under 18 AAC 50.050 visibility through the exhaust effluent of an incinerator, including an air curtain incinerator, may not be reduced by visible emissions, excluding condensed water vapor, by more than 20 percent averaged over any six consecutive minutes. Particulate matter emissions from an incinerator may not exceed the particulate matter standard listed for that incinerator in Table 4 of 18 AAC 50.050 dependent on the rated capacity of the incinerator.
18 AAC 50.508(5)
This section of the Administrative Code contains provisions for owners or operators of soil remediation units to take Owner Requested Limits (ORLs) avoid permit classifications such as the need to obtain an Air Quality Control Title V Operating Permit issued under 18 AAC 50.326 or to avoid classification as a major source of Hazardous Air Pollutants (HAPs) for the emissions of hydrogen fluoride (HF).
40 C.F.R. 60
The New Source Performance Standards (NSPS) are regulatory standards issued by the U.S. Environmental Protection Agency (EPA) under Section 111 of the Clean Air Act. These standards are designed to control air pollution from new, modified, and reconstructed sources in various industrial sectors, including incinerators. The NSPS subparts for incinerators outline the specific emission limits and operational requirements needed to minimize environmental impact.
Subpart E - Incinerators
Subpart E establishes standards of performance for incinerators that burn municipal solid waste (MSW). These standards apply to incinerators commenced after August 17, 1971. The key points of Subpart E include:
Emission limits for particulate matter
Operational standards for temperature control
Requirements for monitoring and reporting emissions
Subpart BBBB - Commercial and Industrial Solid Waste Incineration Units
Subpart BBBB sets forth the standards for commercial and industrial solid waste incineration (CISWI) units. These regulations apply to units commenced after June 4, 2010, and include:
Emission limits for pollutants such as particulate matter, sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), and hazardous air pollutants (HAPs)
Requirements for continuous emissions monitoring
Operational standards for ensuring complete combustion and minimizing emissions
Subpart CCCC - Municipal Waste Combustors
Subpart CCCC covers large municipal waste combustors (MWCs) with capacities greater than 250 tons per day. This subpart applies to MWCs commenced after December 20, 1989, and specifies:
Emission limits for dioxins, furans, mercury, cadmium, lead, and acid gases
Requirements for performance testing and compliance
Standards for operator training and certification
Subpart DDDD - Small Municipal Waste Combustors
Subpart DDDD pertains to small municipal waste combustors (MWCs) with capacities of 35 to 250 tons per day. These standards apply to MWCs commenced after August 30, 1999. Key points include:
Emission limits for particulate matter, SO2, NOx, and HAPs
Operational standards for temperature control and combustion efficiency
Requirements for monitoring and reporting emissions
The NSPS subparts for incinerators are crucial for controlling air pollution and ensuring environmental protection. By adhering to these standards, incinerator operators can minimize the release of harmful pollutants and contribute to cleaner air quality. It is essential for operators to stay informed about specific requirements and to implement best practices in their operations.
40 C.F.R. 63
The National Emission Standards for Hazardous Air Pollutants (NESHAP) are regulations established by the EPA to control emissions of HAPs from various industrial sources, including incinerators. These regulations are designed to protect human health and the environment by setting emission limits and operational standards for equipment that emits HAPs.
NESHAP Subparts Applicable to Incinerators
Incinerators are subject to several NESHAP subparts depending on the type of waste they process and other operational characteristics. These subparts include:
Subpart E: Hazardous Waste Combustors
Subpart E of NESHAP applies to hazardous waste combustors, which include incinerators, cement kilns, and lightweight aggregate kilns that burn hazardous waste. This subpart establishes standards to control emissions of particulate matter (PM), dioxins and furans, mercury, and other metals, as well as hydrogen chloride (HCl) and chlorine gas (Cl2).
Subpart O: Commercial and Industrial Solid Waste Incinerators (CISWI)
Subpart O regulates commercial and industrial solid waste incinerators. These incinerators are designed to burn nonhazardous solid waste from commercial and industrial activities. Subpart O establishes emission limits for pollutants including PM, carbon monoxide (CO), dioxins and furans, mercury, and other metals.
Subpart CCCC: Incinerators in the Municipal Waste Combustors (MWC) Category
Subpart CCCC applies to municipal waste combustors, which are incinerators that burn municipal solid waste (MSW). This subpart sets forth emission limits for PM, sulfur dioxide (SO2), nitrogen oxides (NOx), hydrogen chloride (HCl), and other pollutants. It also includes requirements for monitoring, reporting, and recordkeeping.
Subpart LLL: Industrial, Commercial, and Institutional Boilers and Process Heaters
Although primarily focused on boilers and process heaters, Subpart LLL also applies to certain incinerators used for industrial, commercial, or institutional purposes. This subpart addresses emissions of PM, CO, dioxins and furans, mercury, and other metals from these sources.
Subpart EEEE: Other Solid Waste Incineration Units (OSWI)
Subpart EEEE covers other types of solid waste incineration units that do not fall under the CISWI, MWC, or hazardous waste combustor categories. This subpart establishes emission limits and operational standards for a variety of pollutants, including PM, CO, dioxins and furans, mercury, and other metals.
Subpart UUU: Petroleum Refineries
Subpart UUU applies to incinerators used in petroleum refineries. It establishes standards for controlling emissions of HAPs from these incinerators, including PM, SO2, NOx, hydrogen chloride (HCl), and other pollutants.
Compliance and Monitoring Requirements
NESHAP subparts for incinerators typically include detailed requirements for compliance, monitoring, and reporting. Key elements of these requirements are:
Emission Limits: Specific numeric limits on the amount of each pollutant that can be emitted from the incinerator.
Performance Testing: Procedures for conducting initial and periodic performance tests to demonstrate compliance with emission limits.
Continuous Monitoring: Requirements for continuous emission monitoring systems (CEMS) to track pollutant levels in real-time.
Recordkeeping: Obligations to maintain records of performance tests, monitoring data, and other compliance-related information.
Reporting: Mandates for submitting periodic reports to the EPA or state environmental agencies, including results of performance tests and monitoring data.
Implications for Incinerator Operators
Compliance with NESHAP subparts can have significant implications for operators of incinerators. These include:
Operational Changes
Operators may need to implement changes to their incineration processes to meet the stringent emission limits and operational standards set forth in NESHAP subparts. This can involve upgrading equipment, adopting new technologies, or modifying operational practices.
Financial Costs
Compliance with NESHAP subparts can entail substantial financial costs. These costs can arise from the need to purchase and install emission control equipment, conduct performance tests and continuous monitoring, and maintain records and reports. Additionally, penalties for non-compliance can be significant.
Environmental Benefits
While compliance with NESHAP subparts can be challenging, it also offers substantial environmental benefits. By reducing emissions of hazardous air pollutants, these regulations help to protect human health and the environment. Cleaner air can lead to better public health outcomes and contribute to the overall well-being of communities.
NESHAP subparts for incinerators are an essential component of the EPA's efforts to control emissions of hazardous air pollutants. By setting stringent emission limits and operational standards, these regulations help to ensure that incinerators operate in a manner that protects human health and the environment. While compliance can be demanding, the environmental benefits of reduced pollutant emissions are significant and contribute to a cleaner, healthier future.
Understanding and adhering to the specific NESHAP subparts applicable to incinerators is crucial for operators to maintain compliance and avoid penalties. Through diligent monitoring, reporting, and implementing necessary operational changes, incinerator operators can achieve compliance and contribute to the overall goal of reducing hazardous air pollutants.
40 C.F.R. 64
Compliance Assurance Monitoring (CAM) is a regulatory requirement under 40 CFR Part 64, aimed at ensuring that emission control measures are adequately maintained and operated.
Applicability of CAM
Under 40 CFR 64, CAM applies to incinerators that:
Are subject to emission limitations or standards for pollutants.
Have pre-control emissions equal to or greater than major source thresholds.
The regulation requires that these incinerators have a compliance assurance monitoring plan if they use a control device to meet these emission limitations.
Monitoring Requirements
The CAM rule requires owners or operators of incinerators to develop and implement a monitoring plan that includes:
Indicator Selection: Identifying key indicators that demonstrate proper operation and performance of the control device.
Performance Criteria: Establishing acceptable ranges for each indicator to ensure emission limits are met.
Monitoring Approach: Specifying the methods and systems used to measure the indicators.
Quality Assurance: Ensuring the accuracy and reliability of monitoring data through regular maintenance and calibration.
Recordkeeping and Reporting
Owners or operators must:
Maintain Records: Document all monitoring data, maintenance activities, and corrective actions taken.
Submit Reports: Provide periodic reports of monitoring data to the permitting authority, as required.
These records and reports are essential for demonstrating continuous compliance with emission standards.
Corrective Actions
If monitoring indicates that the control device is not operating within the established performance criteria, corrective actions must be taken promptly. This includes:
Investigating Causes: Identifying reasons for deviations from performance criteria.
Implementing Solutions: Making necessary adjustments or repairs to the control device.
Documenting Actions: Recording all corrective measures and outcomes.
Compliance Assurance Monitoring under 40 CFR 64 is crucial for ensuring that incinerators operate efficiently and within emission limits. By adhering to CAM requirements, operators can maintain environmental compliance and safeguard public health.
Title I Permit
Requirements
Permittees in Alaska are required to comply with all stationary source-specific requirements that were carried forward from previous SIP-approved Permits to Operate issued on or before January 17, 1997 and operating permits issued between January 18, 1997 and September 30, 2004, and with all stationary source-specific requirements in EPA Prevention of Significant Deterioration (PSD) permits, State Implementation Program (SIP)-approved construction permits, SIP-approved minor permits, and owner requested limits established under 18 AAC 50.225.
These requirements include Best Available Control Technology (BACT) limits, limits to ensure compliance with the attainment or maintenance of ambient air quality standards or maximum allowable ambient concentrations, and owner requested limits.
Background
Title I of the Clean Air Act encompasses preconstruction permits, which include New Source Review (NSR) and Prevention of Significant Deterioration (PSD) permits. These permits are designed to control emissions from new or modified sources before they commence operation. Title I requirements are aimed at preventing air quality degradation and ensuring that any new developments adhere to stringent environmental standards.
Ensuring Comprehensive Regulatory Oversight
Including Title I Permit requirements in Title V operating permits ensures that all regulatory obligations are documented and accessible in one comprehensive permit. This integration allows for a more streamlined approach to compliance monitoring and enforcement. By having all requirements in one place, regulatory agencies can more efficiently oversee and verify compliance, reducing the likelihood of violations and ensuring that facilities adhere to preconstruction obligations.
Preventing Air Quality Degradation
Title I permits play a crucial role in preventing air quality degradation by setting emission limits and control technologies for new or modified sources. The inclusion of these requirements in Title V permits helps maintain the integrity of air quality standards by ensuring that facilities continue to comply with pre-established limits and controls. This continuity is essential for sustaining long-term environmental protection and preventing any backsliding in air quality improvements.
Facilitating Transparency and Public Participation
Title V permits, which are subject to public review and comment, provide an opportunity for stakeholders to participate in the regulatory process. By including Title I Permit requirements in these permits, regulatory agencies enhance transparency and ensure that the public is fully informed about all aspects of a facility's operations and emissions controls. This openness fosters greater community involvement and support for environmental protection initiatives.
The inclusion of Title I Permit requirements in Title V operating permits is a critical practice that ensures comprehensive regulatory oversight, prevents air quality degradation, and facilitates transparency and public participation. By integrating these requirements, regulatory agencies can more effectively enforce compliance, safeguard environmental standards, and promote a healthier and more sustainable future.
