What you need to know about the EPA’s new Sewage Sludge Incinerator Rule
In April of 2015, the EPA proposed a Federal Implementation Plan for sewage sludge incinerators (SSI units). Affected facilities are required to comply with the plan by March 21, 2016. The plan specifies two subcategories of SSI units: multiple hearth and fluidized bed units. Based on that classification, units have certain emission standards they are required to meet. In addition, there are numerous testing and recordkeeping requirements. Below is a summary of these requirements.
- Initial Compliance Test (by March 21 2016)
- Annual Compliance Tests, and/or use of CEMS
- Annual pollution control device inspections (based on control device)
- Monitoring of operating parameters and limits
- including minimum operating or afterburner temp, feed rate of sludge, moisture content of sludge, and site specific operating requirements for fugitive ash
- other specific requirements based on control device
Record keeping and Reporting
- Increments of Progress – 1st and 2nd increment
- Initial Compliance Report
- Annual report
- Deviation report
- Qualified operators status report (if a qualified operator is not available for 2 weeks or more)
- All operators must be fully trained and qualified- “An SSI unit cannot be operated unless a fully trained and qualified SSI unit operator is accessible, either at the facility or can be at the facility within 1 hour”. An annual review/refresher course is also required. This documentation must be updated annually on site.
- A site-specific monitoring plan must be submitted before March 21 for each continuous monitoring system, bag leak detection system (if applicable), and for ash-handling.