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Session Chair: Eric Roundy, Keller Associates, Inc.;
10:30am - 11:15am
Not Just Clean Water: How Clean Air Act Enforcement Changes Odor Control Treatment and Plant Operations
HDR, United States of America;
Washington State includes a variety of Clean Air Agencies (CAA) that work to enforce provisions of the Clean Air Act. Unlike application of the Clean Water Act (CWA), which has spurred much of modern wastewater treatment and reuse, air emissions from wastewater treatment plants (WWTP) are normally considered a secondary issue in comparison with meeting the applicable effluent discharge permit. The level of focus on air treatment systems varies widely between municipalities (whether odor control or exhaust emissions from boilers, digesters, etc.), depending on many local factors and potential impacts to neighbors.
In many cases, designs for odor control systems follow industry standards that are common in many states (WEF MOP 25, etc.), with custom tailored application to site specific concerns. How a CAA can regulate an odor control design (and operation) is less well understood when compared to how an agency like the Department of Ecology regulates wastewater treatment designs. This presentation is intended to help bridge this knowledge gap by addressing the following key topics from both an engineering and operations perspective:
· Examples of key parts of CAA regulations and how they have been traditionally applied.
· Recent trends in regulatory enforcement that may shift expectations for redundancy and reliability in traditional odor control treatment systems.
· How design and operation of odor control systems will need to account for permitting and enforcement standards related to clean air requirements.
· Discussing how municipalities can tailor air emission permits to provide greater flexibility in operation and maintenance and engage a local CAA (or similar body) to better manage expectations.
11:15am - 12:00pm
Complexities of Sewage Sludge Incinerator Rules - Utilities Bridge the Gap to Share the Burn Pain
Frank Dick1, Stephen Nelson2, Pamela Randolph3
1City of Vancouver, United States of America; 2Coal Creek Environmental Associates; 3City of Edmonds; , ,
With EPA’s Federal Implementation Plan for Sewage Sludge Incinerators, as codified in 40 CFR 62 Subpart LLL, Sewage Sludge Incinerator (SSI) Operators have struggled with understanding the complex air emissions regulations, reliably attaining the performance criteria and reporting results with confidence.
SSI Operators in Washington state have banded together to share resources and lessons learned to help navigate the regulatory burden. The group has established frequent conference call meetings to share updates in regulatory actions and interpretations, share of equipment, share technical information to help improve performance, and update individual facility status regarding reports and EPA acceptance in order to enable others to be proactive.
We propose a panel discussion focusing on lessons learned, compliance reporting challenges, cost of compliance, and opportunities for sharing resources and future planning to maintain compliance. Each panel member will take 5 minutes to describe their greatest challenge to implementing the new regulations, how they met the challenge and where they see themselves in 5 – 10 years. The remaining time will be open to a Q&A session.