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Home My Public Portal AboutExhibit MSD 89H - Solids Handling Master Plan Phase 2 Technical MemorandumBLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 1 TECHNICAL MEMORANDUM NO. 1 – BISSELL POINT WWTP SOLIDS PROCESSING ALTERNATIVES EVALUATION To: Metropolitan St. Louis Sewer District From: Jim Rowan, Gustavo Queiroz, Patricia Scanlan, Hari Santha This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Bissell Point Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. The following sections describe the existing biosolids management system, the solids quantities used as the basis for the evaluation, and the treatment options evaluated for Bissell Point. Table of Contents 1. Existing Plant Information ............................................................................................ 3 2. Solids Quantities ........................................................................................................... 7 3. Solids Processing Alternatives ...................................................................................... 9 a.Alternative B-1 – Re-use of MHIs and BFPs ......................................................... 9 b.Alternative B-2 – New FBI and Centrifuges ........................................................ 10 4. Technologies for Solids Processing Alternatives ....................................................... 12 a.Solids Thickening ................................................................................................. 12 b.Sludge Wells ......................................................................................................... 13 c. Dewatering ............................................................................................................ 13 (1) Alternative B-1 – Existing Belt Filter Press Dewatering ............................ 13 (2) Alternative B-2 – New Centrifuge Dewatering .......................................... 14 d.Cake Conveyance and Storage ............................................................................. 15 (1) Alternative B-1 - Existing Cake Conveyance and Storage System ............ 15 (2) Alternative B-2 - New Cake Conveyance and Storage System .................. 17 e. Incinerator Systems ............................................................................................... 19 (1) Alternative B-1 - Existing Multiple Hearth Incinerator Systems ............... 21 (2) Alternative B-1 - Air Pollution Control ...................................................... 23 (3) Alternative B-1 – Induced Draft (ID) Fans ................................................. 25 (4) Alternative B-1 – Ash Handling System .................................................... 25 Exhibit MSD 89H BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 2 (5) Alternative B-2 - Fluidized Bed Incinerator System .................................. 27 (6) Alternative B-2 - Primary and Secondary Heat Exchangers ...................... 29 (7) Alternative B-2 – Air Pollution Control Equipment ................................... 30 (8) Alternative B-2 – Ash Handling System .................................................... 32 (9) Alternative B-2 - Fluidizing Air Blower ..................................................... 33 (10) Alternative B-2 - Fuel Storage Tank and Pumps .................................... 33 (11) Alternative B-2 - Sand System ................................................................ 35 (12) Alternative B-2 - Energy Recovery Options ........................................... 36 (13) Steam Generation – Steam Sale to Trigen Option B-2-A ....................... 36 (14) Waste Heat Boilers – B-2-A ................................................................... 37 (15) Water Treatment System – B-2-A ........................................................... 39 (16) Power Generation Option – B-2-B .......................................................... 40 (17) Waste Heat Boilers – B-2-B .................................................................... 41 (18) Steam Turbine Generator – B-2-B .......................................................... 43 (19) Steam Condenser – B-2-B ....................................................................... 44 (20) Cooling Water Heat Exchangers – B-2-B ............................................... 45 (21) Condensate Handling System – B-2-B.................................................... 46 (22) Water Treatment System – B-2-B ........................................................... 47 (23) Future Advanced Air Pollution Control – B-2-C .................................... 47 (24) Conditioning Tower – B-2-C .................................................................. 49 (25) Carbon Injection and Storage – B-2-C .................................................... 51 (26) Fabric Filters – B-2-C ............................................................................. 52 (27) Dry Ash System – B-2-C ........................................................................ 53 (28) Induced Draft Fans – B-2-C .................................................................... 54 5. Alternative B-1 – Layout Plans.................................................................................... 54 6. Alternative B-2 – Layout Plans.................................................................................... 54 7. Site Plan ....................................................................................................................... 55 8. Staffing Requirements ................................................................................................. 55 9. Cost Summary .............................................................................................................. 56 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 3 1. Existing Plant Information The Bissell Point WWTP was commissioned in 1970 with a permitted design flow of 250 mgd. The plant has both trickling filters and activated sludge for secondary treatment. However, the activated sludge system is currently not in use. A site plan of Bissell Point WWTP is shown on Figure 1-1. Figure 1-1. Bissell Point WWTP Site Plan The WWTP generates primary solids (PS) and tricking filter solids (TFS), which are co- thickened in primary clarifiers to approximately 3 percent total solids (TS). The Bissell watershed also receives thickened undigested solids pumped into the collection system from the Coldwater WWTP. Grease wastes are trucked to the WWTP and unloaded via manholes upstream from the pre-aeration tanks. Grease and scum are collected from the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 4 primary clarifiers, pumped to scum thickeners and then conveyed to two sludge wells by progressing cavity pumps where they are combined with the co-thickened sludge pumped from the primary clarifiers. The combined solids are dewatered to approximately 30 percent TS using fifteen belt filter presses (BFP). Polymer is added to the sludge at a rate of approximately 10 lb of active polymer per dry ton of solids (lb/dt). Bottom sludge from the scum concentrators and filtrate from the BFPs are combined in the Dewatering Building Drainage Well and returned to the primary clarifiers. The dewatered cake from the BFPs is discharged to belt conveyors, which convey it to six equalization bins. Hydraulic piston pumps are used to feed the dewatered cake from the equalization bins to six multiple hearth incinerators (MHIs). The MHIs thermally oxidize the dewatered cake to produce ash and exhaust gases. The exhaust gases from the incinerators are treated using wet scrubbers and the ash is sluiced and pumped to two ash lagoons located on site. A schematic of the existing solids treatment processes is presented in Figure 1-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 5 Figure 1-2. Existing Solids Processes at Bissell Point WWTP The specifications of the existing solids processing facilities at the WWTP are summarized in Table 1. Table 1-1. Rated Capacities of Existing Solids Processing Facilities Equipment Units Value WASTE ACTIVATED SLUDGE THICKENING (NOT IN USE) Gravity Belt Thickeners (GBT) Number of GBTs No. 12 Belt Width m 2 Hydraulic Capacity gpm/m 220 SOLIDS DEWATERING Belt Filter Presses (BFP) Number of BFPs No. 15 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 6 Table 1-1. Rated Capacities of Existing Solids Processing Facilities Equipment Units Value Belt Width m 2 Hydraulic Capacity gpm/m 125 INCINERATION Multiple Hearth Incinerators (MHI) Number of MHIs No. 6 Capacity dtpd 60 Pictures of the existing solids processing facilities are shown in Figure 1-3. Gravity Belt Thickeners Incinerator Feed Pumps BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 7 Belt Filter Presses Multiple Hearth Incinerators Figure 1-3. Existing Solids Processing Facilities at the Bissell Point WWTP 2. Solids Quantities The Bissell Point WWTP serves a mature watershed with little flow increase expected in the future. The solids quantities used for this evaluation were developed based on implementing biological nutrient removal (BNR) in the future. The primary process modification for BNR will include re-commissioning the activated sludge process, resulting in the generation of a waste activated sludge (WAS) stream. The WAS quantities with BNR were estimated using process models, which are summarized in the BNR Basin Sizing and Estimation of Waste Activated Sludge Production Report (Appendix B). The PS quantities were based on historical plant data. A summary of the solids quantities from the model is presented in Table 1-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 8 Table 1-2. Projected Solids Quantities1 Parameter Units Max. Month Ann. Avg. Primary Sludge Total Solids dtpd 75.0 62.0 Volatile Solids Fraction % of TS 59 59 Volatile solids dtpd 44.3 36.6 Waste Activated Sludge Total Solids dtpd 48.0 24.5 Volatile Solids Fraction % of TS 55 55 Volatile solids dtpd 26.4 13.5 Total Solids Total Solids2 dtpd 125.7 89.1 Volatile Solids Fraction % of TS 58.0 58.2 Volatile solids dtpd 73.0 51.9 Solids Concentration % 1.5 1.5 Flow gpd 1,997,480 1,413,380 1 Solids quantities listed include thickened undigested sludge from Coldwater WWTP. Solids quantities are based on historical plant data for year 2009 only. Modeling including additional years of historical plant data is recommended prior to detailed design. 2 Total solids include grease wastes. Solids modeling results based on existing plant data projected lower than typical volatile solids (VS) concentrations in PS and WAS. The lower VS concentration may be attributed to the higher fraction of inorganics in the plant influent during high flows. The maximum month (MM) quantities were used as the basis for equipment sizing at Bissell Point. The mid-point (10-year) annual average quantities were used as the basis for determining the operations and maintenance (O&M) costs for the evaluation. The BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 9 mid-point average solids quantities are identical to the future annual average solids production since the Bissell watershed is mature with minimum future growth. The other assumptions made in developing the solids quantities for the process evaluations are summarized below.  Co-thickened solids (PS + WAS) concentration of 1.5 percent from primary clarifiers.  Solids capture efficiency of 98 percent in BFP dewatering units.  Solids capture efficiency of 98 percent in Centrifuge dewatering units.  Dewatered cake solids concentration of 30 percent from belt filter presses and 35 percent from centrifuges.  Volume calculations for cake storage and conveyance equipment based on 30 percent TS. 3. Solids Processing Alternatives Based on discussions with the District staff and site visits to the Bissell Point WWTP, two alternatives were developed for processing and management of biosolids generated at the Bissell Point WWTP. Descriptions of the alternatives are presented in the following sections. Refer to Appendix C of this report for detailed process flow diagrams for all alternatives. a. Alternative B-1 – Re-use of MHIs and BFPs This alternative is the base-case scenario and will include re-use of the existing cake receiving and handling equipment, belt filter presses (BFPs), multiple hearth incinerators (MHIs), ash handling, and air pollution control systems (APCs). Modifications and upgrades to the existing systems will be required and are discussed later in this report. Figure 1-4 illustrates the overall process flow diagram for Alternative B-1. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 10 Figure 1-4: Solids Flow Diagram - Alternative B-1 b. Alternative B-2 – New FBI and Centrifuges This alternative will consist of new solids processing facilities including cake receiving and handling facilities, dewatering centrifuges, incinerator feed pumps, fluidized bed incinerators (FBIs), air pollution control systems and heat recovery. The air pollution control system evaluation will include options for mercury removal and dry ash handling. The heat recovery evaluation will include steam generation with sale to a local utility provider, Trigen, and power generation to reduce plant electricity purchased from the electrical utility serving the plant. Based on the larger size for the new fluidized bed incinerators and preliminary assessment of the existing incinerator building, it was determined that the current available space is not sufficient to house the new larger fluidized bed incinerators and associated equipment. In addition, the construction of a new solids processing facility BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 11 will provide additional flexibility allowing the existing solids processing system to remain in operation during construction phase of the new facility. Figure 1-5 illustrates the overall process flow diagram for Alternative B-2. Figure 1-5: Solids Flow Diagram - Alternative B-2 – New FBIs A summary of the new and existing equipment being evaluated for each alternative is presented in Table 1-3. Table 1-3. Solids Processing Alternatives Equipment Alternative B-1 Re-use MHIs Alternative B-2 New FBIs Cake Receiving and Handling E N Dewatering Belt Filter Presses E --- Dewatering Centrifuges --- N Dewatered Cake Equalization Bins E N BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 12 Table 1-3. Solids Processing Alternatives Equipment Alternative B-1 Re-use MHIs Alternative B-2 New FBIs Incinerator Cake Feed Pumps E N Multiple Hearth Incinerators E --- Fluidized Bed Incinerators --- N Air Pollution Control (Wet Scrubber) E N Advanced Air Pollution Control (Fine Particulate and Mercury Removal) --- N Dry Ash Handling --- N Legend E = Existing system will be evaluated and modifications/upgrades recommended. : N = The implementation of a new system will be evaluated. 4. Technologies for Solids Processing Alternatives The solids processing technologies considered to support the two alternatives are briefly discussed in the following sections. a. Solids Thickening The existing primary clarifiers will be used to co-thicken PS and WAS to approximately 1.5 percent TS. Since solids production is not expected to increase during the planning period, no additional thickening capacity will be required in the future. It is important to note that the future conversion from trickling filters (TFs) to a BNR system with phosphorous removal will preclude the use of the primary clarifiers for co- thickening PS and WAS. Co-thickening PS and WAS has the potential to create anaerobic conditions and re-release phosphorous in the primary clarifiers, reducing the overall phosphorous removal efficiency. In the future, if biological phosphorous removal is incorporated, it is recommended that WAS be thickened separately using the existing gravity belt thickeners (GBTs) or other mechanical thickening technologies. WAS BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 13 thickening technologies are not evaluated as part of this report. The existing GBTs have adequate capacity to handle the projected WAS quantities as indicated in Table 1-4. Table 1-4. Existing GBT Loading at Projected Loads Design Conditions Units Max. Month Ann. Avg. Operating Schedule h/d 24/7 24/7 Number of Operating Units No. 4 2 Rated Hydraulic Capacity gpm/m 220 220 Hydraulic Loading Rate gpm/m 200 204 Expected Solids Concentration % 5 5 b. Sludge Wells The existing sludge wells are expected to have sufficient capacity to process future solids and are not evaluated for this report. c. Dewatering (1) Alternative B-1 – Existing Belt Filter Press Dewatering The existing BFPs were evaluated as part of Alternative B-1 to dewater the combined PS and future WAS. Typically, trickling filter solids has a higher fraction of inorganics and dewaters better than WAS. Consequently, when the activated sludge process is brought online in the future, the throughput for the dewatering units may be lower than the current loadings with trickling filters. According to the projected solids production in Table 2, the existing dewatering BFPs and the BFP feed pumps are expected to have adequate capacity to process future solids quantities. However, based on age and expected life of the existing equipment, the dewatering equipment will need to be replaced or significantly overhauled during the evaluation period. Preliminary equipment design information for dewatering BFPs and BFP feed pumps is listed in Table 1-5. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 14 Table 1-5. BFPs and Feed Pumps Design Criteria Equipment Units Specifications Belt Filter Presses Number of Units1 No. 10 (6 duty, 4 standby) Operation Schedule h/d/wk 24/7/52 Belt width m 2 Hydraulic Loading Rate2 gpm/m 125 Solids Loading Rate2 pph/m 940 Solids capture rate % 98 Feed Solids % 1.5 Cake Solids % 30 Polymer use (active) lb/dt solids 10-15 BFP Feed Pumps Number of units No. 3 (2 duty, 1 standby) Pump type Centrifugal (Wemco vortex type)3 Required Flow (each)4 gpm 1,100 1 Four (4) BFP units will be required to process solids at AA conditions. A total of six (6) BFP units will be required to process solids at MM conditions. 2 Loading rates listed are based on feedback from MSD for current operation. 3 Pump selected to match existing BFP feed pumps. 4 Required pump flow rate based on estimated capacity for existing equipment. (2) Alternative B-2 – New Centrifuge Dewatering New centrifuges were evaluated as part of Alternative B-2. For this alternative, the raw co-thickened sludge will be pumped from the existing sludge wells to new centrifuges located in a new solids processing facility. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 15 Preliminary equipment information for the centrifuges and centrifuge feed pumps is listed in Table 1-6 below. Table 1-6. Centrifuge and Centrifuge Feed Pump Design Criteria Equipment Units Specifications Centrifuges Number of Units1 No. 6 (5 Duty, 1 Standby) Operation Schedule h/d/wk 24/7/52 Rated Capacity gpm/machine 279 Required Hydraulic Loading Rate2 gpm/machine 277 Required Solids Loading Rate2 pph/machine 2,094 Approximate Diameter in. 23 Solids Capture Rate % 98 Feed Solids % 1.5 Cake Solids % 35 Polymer Use (active) lb/dt solids 15-25 Centrifuge Feed Pumps Number of units No. 6 (5 Duty, 1 Standby) Pump type3 Centrifugal with AFD (Wemco vortex type) Flow (each) gpm 280 1 Four (4) centrifuges are required to process solids at AA conditions, and Five (5) centrifuges are required to process solids at MM conditions. 2 Required centrifuge loading rates based on MM conditions. 3 Pump type selected to match existing BFP feed pumps. d. Cake Conveyance and Storage (1) Alternative B-1 - Existing Cake Conveyance and Storage System Belt conveyors are used to transfer dewatered cake from the existing BFPs to live-bottom (screw type) equalization bins (see Figure 1-2), which discharge solids to cake pumps BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 16 feeding the incinerators. The capacity of the existing belt conveyors, live-bottom equalization bins and cake pumps will be sufficient for the future solids production. However, based on age and expected life of the existing equipment, they will need to be replaced or significantly overhauled during the evaluation period. The existing cake receiving facility will be upgraded or overhauled to continue receiving cake from other facilities. Preliminary cake conveyance and storage equipment specifications are presented in Table 1-7 below. Table 1-7. Existing Cake Conveyance and Storage Equipment Design Criteria Equipment Units Specifications Dewatered Cake Conveyor System Conveyor type Belt Required capacity1 cf/h 590 Equalization Bins Number of units No. 4 (2 Duty, 2 Standby) Type Live bottom (screw) Required volume (each)2 cy 10 Equalization Bins Number of units No. 4 (2 Duty, 2 Standby) Type Live bottom (screw) Required volume (each)2 cy 10 Dewatered Cake Pumps Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston Required flow (each) gpm 35 1 Required capacity based on MM solids condition. 2 Equalization bin sizing based on existing equipment. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 17 (2) Alternative B-2 - New Cake Conveyance and Storage System A new cake conveyance and storage system will be required for Alternative B-2. The system will be located in the new solids processing building. Shafted screw conveyors will be used to transfer dewatered cake from the centrifuges to cake transfer pumps that will feed the equalization bins, as shown on Figure 1-5. Each hopper will be equipped with a sliding frame-type live bottom, which will discharge solids to cake pumps feeding the incinerators. A new cake receiving facility will be required to accept cake hauled from other facilities. The receiving facility will include a cake receiving bin, screw conveyors, storage silos and transfer pumps (Figure 1-5). Preliminary equipment design information for the sludge conveying and storage facilities is listed in Table 1-8. Table 1-8. New Cake Conveying and Storage Equipment Design Criteria Equipment Units Specifications Dewatered Cake Conveyor System Number of units No. 2 Conveyor type1 Shafted Screw Required capacity (each)2 cf/h 560 Cake Transfer Pumps (from dewatered cake conveyors to equalization bins) Number of units No. 2 (1 Duty, 1 Standby) Pump type Hydraulic piston (Dual Discharge) Required flow (each) gpm 70 Equalization Bins Number of units No. 2 Type Live bottom (Sliding Frame) Required volume (each)3 cy 65 Dewatered Cake Pumps (from equalization bin to incinerator) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 18 Table 1-8. New Cake Conveying and Storage Equipment Design Criteria Equipment Units Specifications Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston (Dual Discharge) Required flow (each) gpm 70 Dewatered Cake Receiving Bin Number of units No. 1 Type Live bottom (screw type) Required volume cy 30 Dewatered Cake Transfer Pumps (from receiving bin to storage silo) Number of units No. 2 (1 Duty, 1 Standby) Pump type Hydraulic piston (Dual Discharge) Required flow (each) gpm 100 Dewatered Cake Storage Silo Number of units No. 2 Storage days 2 Required volume cy 500 Dewatered Cake Storage Silo Recirculation Pumps4 Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston Volume turnover hr 6 Turnover capacity cy/hr 80 Required flow (each) gpm 270 Dewatered Cake Pumps (from storage silo to incinerator) Number of units No. 1 Pump type Hydraulic piston (Dual Discharge) Required flow (each) gpm 70 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 19 1 Shafted screw conveyors used for this evaluation. Shaft-less screw type conveyors may be evaluated during detailed design. 2 Each cake conveyor system is designed to transfer solids at incinerator capacity. 3 Equalization bins sized for approximately 3 hours of storage capacity for each incinerator at 120 dtpd. 4 The use of the cake recirculation pump concept for odor reduction will be verified during detailed design. e. Incinerator Systems Incinerator systems combust dewatered cake, converting the organic portion of the feed solids to heat and sterile ash. Descriptions for incinerator system components are presented in the following sections. Many plants currently use multiple hearth incinerators (MHI) to burn dewatered cake generated at their facility. Most of the MHIs were built in the 1970s and 1980s. With over 20 years or more of service they are requiring repairs and upgrades to continue operation. Owners are asking if it is worthwhile to spend the resources to upgrade or replace the units with fluidized bed incinerators (FBI). Table 1-9 presents a discussion of the merits and concerns with upgrading MHIs or replacing them with new FBIs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 20 Table 1-9. Incinerator Technologies Comparison Item MHI FBI Comment Unit capacity and Sizing 23 ft. diameter MHI will burn 25 to 50 dry tons per day of dewatered sewage solids. The typical FBI will burn 50 to 120 dtpd of solids with most units sized for about 100 dtpd. For every two MHIs, one FBI can match or exceed their capacity, reducing the number of units and space needed. Operation skill and complexity Generally requires one operator per 1 or 2 units to adjust and monitor Typically requires less time with one operator assigned to dewatering and incineration operation. Plant operators, who have experience with both, report that operation of a FBI is less demanding than for a MHI. Cost No new MHIs are being built. Many are undergoing repairs, rebuilding and emissions control upgrades with equipment and installation costs of $2M to $6M per unit. FBIs have equipment and installation costs of $15M to $20M per unit. New FBIs typically require a new building and support facilities, resulting in costs of $30M to $40M for a single unit. For comparison, costs for upgrading MHIs (2 units) would range from $4M to $12M and would provide same or less capacity than one FBI. Emission Controls The MHIs currently use wet scrubbers consisting of a variation of venturis, impingement scrubbers, and wet electrostatic precipitators for particulate and acid gas removal from exhaust gases. CO, THC, and NOx are controlled by operational parameters including temperature and oxygen content. There is no mercury control. FBIs use similar wet scrubbers as MHIs but are inherently better combustion devices with lower emissions of CO, THC, and NOx. Mercury removal has been used for FBIs. New regulations will lower emission limit requirements for both types with the MHIs being impacted the most for CO, NOx and Hg emissions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 21 Table 1-9. Incinerator Technologies Comparison Item MHI FBI Comment Turndown MHIs will burn under turn down conditions but with some additional fuel usage. FBIs can also be turned down but with much less efficient operation. To accommodate lower feed rates, FBIs are operated in a weekly batch mode where they burn the solids at design rates until the weekly quantity is depleted. Then they are “bottled up” until the cycle repeats. Some auxiliary fuel will be used for warming prior to introducing solids again. Both type incinerators operate more efficiently at design loading. MHIs are more appropriate for small facilities with FBIs used for large facilities. Power generation from incineration Can be implemented to produce electricity with steam/steam turbine. Steam at 400 psia. Can be implemented to produce electricity with steam/steam turbine. Steam at 400 psia. Power produced is proportional to the volatile solids burned. For 100 dtpd feed rate, 1 to 1.5 MW produced. Descriptions for each incinerator system alternative can be found in the following sections. (1) Alternative B-1 - Existing Multiple Hearth Incinerator Systems The existing MHIs were evaluated as part of Alternative B-1. For the projected solids quantities in Table 1-2, the existing MHIs are expected to have sufficient capacity to process future solids. However, based on age and expected life of the MHI equipment, the MHIs will need significant rehabilitation during the evaluation period. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 22 Figure 1-6 illustrates the proposed Alternative B-1 MHI incineration system. Figure 1-6: Alternative B-1 – Reuse of MHIs Two incinerators are designed to process the total projected feed solids at annual average conditions. For maximum month conditions, three incinerators will be required to operate. The fourth incinerator will provide spare capacity at maximum month conditions. Preliminary equipment design information for the MHIs is listed in Table 1-10. Table 1-10. Multiple Hearth Incinerators Design Criteria Equipment Units Specifications Multiple Hearth Incinerators Required Number of Units No. 4 Operation Schedule h/d/wk 24/7/52 Required Capacity (each) dtpd 60 Incinerator Vessel BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 23 Table 1-10. Multiple Hearth Incinerators Design Criteria Equipment Units Specifications Type No. of Hearths No. Multiple Hearth 11 Size Diameter Height ft ft 23 45 Wall Construction Inner Layer of Walls Outer Layer of Walls Outer Layer of Top Refractory brick Insulated fire brick High duty castible Auxiliary Fuel Source Natural gas Min Natural Gas Pressure psig 10 Discharge Temperature oF 950-1,100 (2) Alternative B-1 - Air Pollution Control To reduce particulate emissions and provide additional operational flexibility for the incinerators, the existing impingement tray scrubbers, induced draft (ID) fans, and associated exhaust ductwork will be replaced. The new scrubbers will re-use the existing scrubber vessels with the current internal components removed. In addition, the upper section of the existing scrubber vessels will be extended to accommodate a new multiple venturi section. A new exhaust gas quench section will be added to pre-condition the exhaust gases before entering the wet scrubber. The new scrubber will be a vertical upflow unit with impingement trays used for cooling and saturating the gas, followed by multiple fixed venturi sections with water injection and mist eliminators with sprays. Plant effluent water will be used for the impingement trays. Strained plant effluent water will be used for the venturi injection and high pressure spray lances. Service water (potable water downstream of a backflow preventer) will be used for the mist eliminator sprays. Booster pumps will be supplied with the scrubbers BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 24 for venturi and high pressure spray lance water injection. Strained plant effluent water is required for the venturi injection and high pressure spray lances to prevent nozzle clogging while potable water is required for the mist eliminator to prevent fouling. Preliminary equipment design information for the wet scrubber and quench section are listed in Table 1-11. Table 1-11. Wet Scrubber and Quench Section Design Criteria Equipment Units Specifications Wet Scrubbers and Quench Station Number of Units No. 4 Type Combined impingement tray, and multiple fixed venturis Configuration Vertical, up flow Pressure Drop in w.c. 30 Dimensions Diameter Height ft 12 30 Water Requirements (per scrubber) Quench Section Sprays Under Tray Sprays Impingement Trays Venturi Section Sprays Mist Eliminator gpm 100 60 1,200 150 10 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 25 (3) Alternative B-1 – Induced Draft (ID) Fans New ID fans will be required to overcome the increased pressure drop associated with the new wet scrubbers. The ID fans will be located in the same area as the existing fans. The ID fans will pull the clean gas from the air pollution control equipment and discharge it to the stack. Preliminary equipment design information for the ID fans is listed in Table 1-12. Table 1-12. Induced Draft Fan Design Criteria Equipment Units Specifications Induced Draft Fan Number of Units No. 4 Type Single stage centrifugal, direct drive Inlet Gas Temperature oF 90-130 Required Capacity acfm 22,000 Flow Adjustment Variable Frequency Drive Pressure Rise (design) in w.c. 44 Motor hp 250 Special Construction/Materials 316 SS wheels and shafts (4) Alternative B-1 – Ash Handling System The existing ash handling system collects incinerator bottom ash and combustion air heat exchanger fly ash. The ash is sluiced and pumped to ash lagoons (see Figure 1-1). For MHIs, the majority of the ash (~90 percent) is collected at the bottom of the incinerators while the remaining portion will travel in suspension with the exhaust gases as fly ash. A small fraction of the fly ash drops at the combustion air heat exchanger while the remaining fraction is removed by the wet scrubbers. The existing sluice tank and pumps BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 26 are expected to have sufficient capacity to process future ash quantities. However, MSD has experienced some dust problems with the current ash handling system. To alleviate the dust problem, an ash slurry system including ash slurry pumps and slurry tanks is recommended to replace the existing ash sluice system. The new ash slurry system will use scrubber drain water to mix the ash into a slurry form, which will be pumped to the existing ash lagoons. A new vibrating screen feeder will be installed at the ash discharge of each incinerator to prevent clinkers from entering the ash slurry system and clogging the ash slurry pumps or slurry lines. The new ash slurry system will be capable of processing bottom ash from the incinerator and fly ash from the combustion air heat exchanger. Preliminary equipment design information for the ash slurry system is listed in Table 1- 13. Table 1-13. Ash Slurry System Design Criteria Equipment Units Specifications Clinker Grinder Number of Units No. 4 Material Handled MHI bottom ash heat exchanger fly ash Maximum Size Passing In. 1/4 Type Double-Roll Ash Slurry Tanks Number of Units No. 4 Material Handled MHF bottom ash and combustion air heat exchanger fly ash Tank Dimensions Length Width Height ft 10’-0” 10’-0” 6’-0” BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 27 Table 1-13. Ash Slurry System Design Criteria Equipment Units Specifications Ash Slurry Concentration % 0.5 to 1 Ash Slurry Pumps Number of Units (per incinerator) No. 8 (4 Duty, 4 Standby) Material Handled Ash Slurry Incinerator Ash Flow Rate pph 1,950 Combustion Air Heat Exchanger Flow Rate pph 150 Maximum Flow Rate at Maximum Speed gpm 850 Minimum Flow Rate at Reduced Speed gpm 425 Discharge Point Ash Lagoons Discharge Head at Maximum Flow ft 100 Motor hp 35 1 Ash flow rate based on low volatile (58% VS) condition and incinerator capacity. (5) Alternative B-2 - Fluidized Bed Incinerator System For Alternative B-2, fluidized bed incinerator (FBI) trains will be installed in a new solids processing building. Each incinerator vessel will consist of three zones: hot windbox, sand bed, and freeboard. Preheated fluidizing air will be directed into the windbox and distributed to the bed through tuyeres in a refractory arch. The air will fluidize the sand bed above the refractory arch and will provide combustion air for the process. Dewatered cake will be pumped into the incinerator through multiple injection nozzles and into the sand bed. Auxiliary fuel injection lances (fuel oil or natural gas) will provide supplemental fuel, if needed. All exhaust gases. Including combustion products and ash, will exit the fluidized bed incinerator through the freeboard and exhaust gas duct. Figure 1-7 illustrates the proposed Alternative B-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 28 Figure 1-7: Alternative B-2 – New FBIs Each incinerator is designed to process the total projected feed solids at annual average conditions. For maximum month conditions, both incinerators will be required to operate. Preliminary equipment design information for the FBIs is listed in Table 1-14. Table 1-14. Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Fluid Bed Incinerators Number of Units No. 2 Operation Schedule h/d/wk 24/7/52 Required Capacity (each) dtpd 120 Incinerator Vessel Type Refractory lined w/ refractory arch BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 29 Table 1-14. Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Windbox Hot Air Size Freeboard Diameter Height ft 34 45 Wall Construction Inner layer of walls and dome Outer layer of walls and dome Refractory Brick Insulated Fire Brick Number of Solids Feed Nozzles No. Multiple around periphery, 4 minimum Auxiliary Fuel Source Natural Gas and Fuel Oil Minimum Natural Gas Pressure psig 10 Discharge Temperature oF 1,500 -1,650 max Preheat Provisions Preheat supplied by natural gas fired burner (6) Alternative B-2 - Primary and Secondary Heat Exchangers Primary and secondary heat exchangers will recover waste heat from the exhaust gases. The primary heat exchanger will transfer heat from the incinerator exhaust gases to the fluidizing air. A primary heat exchanger bypass (with damper) will control the temperature of the fluidizing air and heat recovery. This “hot windbox” design is expected to reduce the amount of auxiliary fuel required for combustion and, in some cases, may allow autogenous (without additional fuel) combustion. Following the primary heat exchanger, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas. Heating the scrubber outlet gas prior to discharge to the atmosphere will help suppress visible plumes. The secondary heat exchanger may also be used to pre-heat exhaust to future emission control equipment. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 30 Preliminary equipment design information for the primary and secondary heat exchangers is listed in Table 1-15. Table 1-15. Primary and Secondary Heat Exchangers Design Criteria Equipment Units Specifications Primary Heat Exchanger Number of Units No. 2 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Fluidizing air in Fluidizing air out oF 1,650 1,200 60 1,030 Size Vessel Diameter Height ft 12 30 Design Pressure psig 10 Secondary Heat Exchanger Number of Units No. 2 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Scrubber outlet gas in Scrubber outlet gas out oF 1,200 1,050 100 300 Design Pressure psig 10 (7) Alternative B-2 – Air Pollution Control Equipment Exhaust gases leaving the secondary heat exchangers will be directed to the air pollution control equipment. Initial air pollution control equipment will include quench sprays and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 31 wet scrubbers. The quench spray section will consist of multiple water sprays that cool the exhaust gases prior to entering the wet scrubber. The new scrubber will be a vertical upflow unit with impingement trays used for cooling and saturating the gas, followed by a multiple fixed venturi section with water injection and mist eliminators with sprays. Plant effluent water will be used for the impingement trays. Strained plant effluent water will be used for the venturi injection and high pressure spray lances. Service water (potable water downstream of a backflow preventer) will be used for the mist eliminator sprays. Booster pumps will be supplied with the scrubbers for venturi and high pressure spray lance water injection. Strained plant effluent water is required for the venturi injection and high pressure spray lances to prevent nozzle clogging while potable water is required for the mist eliminator to prevent fouling. Preliminary equipment information for the wet scrubber is listed in Table 1-16. Table 1-16. Wet Scrubber Design Criteria Equipment Units Specifications Wet Scrubbers Number of Units No. 2 Type Combined Impingement Tray, and Multiple Fixed Venturis Configuration Vertical, Upflow Dimensions, ft Diameter Height ft 14 30 Water Requirements (per scrubber) Quench Sprays Under Tray Sprays Impingement Trays Venturi Section Mist Eliminator gpm 150 60 1,650 200 15 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 32 (8) Alternative B-2 – Ash Handling System For FBIs, a small fraction of the ash is collected at the waste heat boilers (for power generation option only) while the majority of the ash is removed by the wet scrubber. A new ash slurry system including ash slurry pumps and slurry tanks is recommended to handle the ash slurry from the bottom of the scrubber. The new ash slurry system will collect the scrubber drain water including the ash and transfer it to the existing ash lagoons. Preliminary equipment design information for the ash slurry system is listed in Table 1-17. Table 1-17. Ash Slurry System Design Criteria Equipment Units Specifications Ash Slurry Tanks Number of Units No. 2 Material Handled FBI and WHB fly ash Tank Dimensions Length Width Height ft 15’-0” 10’-0” 8’-0” Ash Slurry Concentration % 0.5 to 1 Ash Slurry Pumps Number of Units (per incinerator) No. 4 (2 Duty, 2 Standby) Material Handled Ash Slurry Incinerator Ash Flow Rate pph 4,200 Maximum Flow Rate at Maximum Speed gpm 1,700 Minimum Flow Rate at Reduced Speed gpm 850 Discharge Point Ash Lagoons Discharge Head at Maximum Flow ft 100 Motor hp 70 1 Ash flow rate based on low volatile (58% VS) condition and incinerator capacity. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 33 (9) Alternative B-2 - Fluidizing Air Blower Each incinerator will have a dedicated blower to supply fluidizing air. The fluidizing air will be drawn from outside the solids processing building, and will be preheated in the primary heat exchanger before entering the FBI windbox. Fluidizing air serves two purposes: to suspend the solids in the incinerator bed and to provide combustion air. Preliminary equipment design information for the fluidizing air blowers is listed in Table 1-18. Table 1-18. Fluidizing Air Blower Design Criteria Equipment Units Specifications Fluidizing Air Blowers Number of Units No. 2 Type Multiple-Stage Centrifugal Drive Direct Required Flow scfm 13,000 Flow Adjustment Inlet Damper Pressure Rise psig 8 Motor hp 700 (10) Alternative B-2 - Fuel Storage Tank and Pumps Fuel oil will be delivered to the site by tankers and stored in an above ground storage tank located next to the new solids processing building. Fuel oil transfer pumps will be installed in the fuel oil storage area to transfer fuel oil from the storage tank to a day tank. A second set of pumps, fuel oil feed pumps, will be used to transfer fuel oil from the day tank to each incinerator. The fuel oil, which will be used for supplemental fuel during incinerator warm up, will be injected into the incineration process through fuel injection lances. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 34 Preliminary equipment design information for the fuel storage tank and pumps is listed in Table 1-19. Table 1-19. Fuel Oil Storage Tank and Pumps Design Criteria Equipment Units Specifications Fuel Oil Tank Type Double wall, above ground Number of Units No. 1 Tank Size Diameter Length ft 12 30 Volume gal 20,000 Fuel Oil Transfer Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Gear Required Flow gpm 60 Minimum Discharge Pressure psi 5 Motor hp 1 Fuel Oil Day Tank Number of Units No. 1 Tank Size Diameter Total Height ft 6 9 Volume gal 1,600 Fuel Oil Injection Pumps Number of Units No. 3 (2 Duty, 1 Standby) Type AFD, Gear Type Required Flow gpm 4 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 35 Table 1-19. Fuel Oil Storage Tank and Pumps Design Criteria Equipment Units Specifications Minimum Discharge Pressure psi 50 Motor hp 0.5 (11) Alternative B-2 - Sand System Sand will be delivered to the site by truck and stored in an indoor sand storage tank. Pneumatic transporters will convey sand from the sand storage tank to each of the FBIs to replenish sand entrained in the exhaust gas stream. Preliminary equipment design information for the sand storage system is listed in Table 1-20. Table 1-20. Sand System Design Criteria Equipment Units Specifications Storage Tanks Number of Units No. 1 Type Vertical with dual conical base Volume1 cf 360 Storage months 1 to 9 Size Diameter Total Height2 ft 9 40 Transporters Number of Units No. 2 Compressed Air Requirements Flow, scfm Pressure range, psig scfm psig 150 100-120 1 Silo capacity based on sand demand of 50 lbs/hr for one incinerator. Feed rate for BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 36 make up sand range from 5 to 50 lbs/hr. 2 Silo height includes clearances for transport and dust collection equipment. (12) Alternative B-2 - Energy Recovery Options Waste heat from the exhaust gases will be used to generate steam in the waste heat boilers. Two end use options for the steam have been evaluated: a) Medium pressure saturated steam for sale to Trigen; b) High pressure superheated steam for power generation. Energy recovery options will only be considered for Alternative B-2 due to limited space available at the Bissell Point WWTP site. (13) Steam Generation – Steam Sale to Trigen Option B-2-A For this option, waste heat will be used to generate medium pressure steam that will be sold to Trigen. The waste heat remaining in the flue gas downstream of the primary heat exchangers will be used in waste heat boilers to generate steam. Exhaust gas from the waste heat boiler will be treated through the secondary heat exchanger. Heat removed from the exhaust gas will be transferred to the scrubber outlet gas for plume suppression. Figure 8 below illustrates the proposed steam generation option for Option B-2-A. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 37 Figure 8: Option B-2-A – New FBIs with Optional Steam Generation (14) Waste Heat Boilers – B-2-A Flue gases from the each FBI will be ducted to waste heat boilers. The waste heat boilers will recover heat from the incinerator exhaust gases to produce medium pressure saturated steam. A bypass will be provided around the waste heat boilers to allow the steam production equipment to be taken out of service without affecting incinerator operation. Preliminary equipment design criteria for the waste heat boilers are listed in Table 1-21. Table 1-21. Waste Heat Boiler Design Criteria Equipment Units Specifications Waste Heat Boilers Number of Units No. 2 Type Water Tube Flue Gas Conditions BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 38 Table 1-21. Waste Heat Boiler Design Criteria Equipment Units Specifications Flue Gas Pressure psia 14.7 Flue Gas Inlet Temperature oF 1,200 Flue Gas Outlet Temperature oF 500 Design Flue Gas Flow1 pph 111,550 Flue Gas Flow at AA Conditions (70% VS and 28% TS) pph 68,250 Flue Gas Flow at AA Conditions (58% VS and 35% TS) pph 66,500 Steam Conditions Steam Pressure psia 180 Steam Temperature oF 373 (saturated) Steam Flow at AA Conditions (70% VS and 28% TS) pph 15,100 (each boiler) Steam Flow at AA Conditions (58% VS and 35% TS) pph 14,400 (each boiler) Waste Heat Fly Ash Transport System (From waste heat boiler to ash storage silo)2 Number of surge hoppers No. 2 Type Dry ash surge hopper capacity cf Vertical with Conical Base 1 Number of pneumatic transporters No. 2 Type Air flow Operating pressure scfm psig Dense Phase 15 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 50 5 1 Design exhaust flow rate for waste heat boiler based on incinerator capacity at 70% VS BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 39 and 28% TS. 2 Required for options with dry ash handling. For options where dry ash handling is not required, the ash transport system will transfer the waste heat boiler fly ash to the wet slurry tanks. (15) Water Treatment System – B-2-A A package type water treatment system will be provided to treat potable water for boiler water make up. The water treatment equipment will depend on the potable water quality and make up water quality requirements. The water treatment system will consist of cartridge filters, carbon filters, water softeners, reverse osmosis (RO), demineralizers, demineralized water storage tank, and make up water pumps. The water treatment systems will include standby components to support 7 day, 24 hour incinerator operation during water system equipment cleaning and regeneration. The water softening and the demineralizer systems will require periodic regeneration; the RO system will require a periodic clean-in-place (CIP). All regeneration and CIP is expected to be performed off- site through a service contract. The calculated capacities for the packaged water treatment system were based on a “once through system” with no condensate return. Preliminary equipment design information for the packaged water system is listed in Table 1-22. Table 1-22. Packaged Water Treatment Design Criteria Equipment Units Specifications Water Treatment System Number of Units No. 2 (1 Duty, 1 Standby) Water source Potable Water Required treated water flow rate gpm 40 to 50 Design Pressure Loss As required by vendor Make Up Water Tank Capacity gal 3,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 40 Table 1-22. Packaged Water Treatment Design Criteria Equipment Units Specifications Packaged Water Treatment System Pumps (Booster pumps to waste heat boiler) Number of Units No. 4 (2 Duty, 2 Standby) Water source Treated Water Flow Rate gpm 50 Discharge Pressure ft 600 Motor hp 20 (16) Power Generation Option – B-2-B In this option, waste heat remaining in the exhaust gases after the primary heat exchanger will be used in waste heat boilers to generate high pressure superheated steam. The superheated steam will be used in steam turbines to generate electricity, which will be used on-site to reduce electricity purchases. The generated electricity will be used onsite. Following the waste heat boiler, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas for plume suppression. Figure 1-9 illustrates the proposed Option B-2-B power generation option. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 41 Figure 1-9: Alternative B-2-B – FBIs with Power Generation (17) Waste Heat Boilers – B-2-B Flue gases from the FBI will be ducted to a new waste heat boiler. The waste heat boiler will recover heat from the incinerator exhaust gases to produce high pressure superheated steam for power generation. A bypass will be provided around the waste heat boilers to allow the steam production equipment to be taken out of service without affecting incinerator operation. Preliminary equipment design information for the waste heat boilers is listed in Table 1- 23. Table 1-23. Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Waste Heat Boilers Number of Units No. 2 Type Water Tube BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 42 Table 1-23. Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Flue Gas Conditions Flue Gas Pressure psia 14.7 Flue Gas Inlet Temperature oF 1,150 Flue Gas Outlet Temperature oF 500 Design Flue Gas Flow1 pph 111,550 Design Flue Gas Flow at AA Conditions (70% VS and 28% TS) pph 68,250 Design Flue Gas Flow at AA Conditions (58% VS and 35% TS) pph 66,500 Steam Conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Steam Flow at AA Conditions (70% VS and 28% TS) pph 11,800 (each boiler) Steam Flow at AA Conditions (58% VS and 35% TS) pph 11,300 (each boiler) Waste Heat Fly Ash Transport System (From waste heat boiler to ash storage silo)3 Number of surge hoppers No. 2 Type Dry ash surge hopper capacity cf Vertical with Conical Base 1 Number of pneumatic transporters No. 2 Type Air flow Operating pressure scfm psig Dense Phase, Conical Base 15 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 50 5 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 43 1 Design flow rate for waste heat boiler based on incinerator capacity at 70% VS and 28% TS). 2 Steam flow rates shown include deduction for parasitic loads (i.e., de-aerator, etc.). 3 Required for options with dry ash handling. For options where dry ash handling is not required, the ash transport system will transfer the waste heat boiler fly ash to the wet slurry tanks. (18) Steam Turbine Generator – B-2-B One steam turbine generator will convert steam to electrical power. The skid-mounted steam turbine will be installed in the new sludge processing building and will include an oil lubrication system, mounted on a separate skid. Preliminary equipment design information for the steam turbine generator is listed in Table 1-24. Table 1-24. Steam Turbine Generator Design Criteria Equipment Units Specifications Steam Turbine Number of Units No. 1 Type Full condensing to 4 in. Hg absolute Steam conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Design Steam Flow1 pph 16,400 Generator speed rpm 4,750 Alternator Speed rpm 1,800 Power output – AA (70% VS and 28% TS) MW 1.0 Power output – AA (58% VS and 35% TS) MW 0.8 Output Voltage V 4,160 Type Synchronous BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 44 1 Steam turbine sized for steam rate prior to parasitic load deduction. Power output based on net steam rate after parasitic load deduction. (19) Steam Condenser – B-2-B One steam condenser will be provided to condense steam from the turbine. The condensate will be returned to the waste heat boiler steam drum. Preliminary equipment design information for the steam condenser and condensate pumps is listed in Table 1-25. Table 1-25. Steam Condenser and Condensate Pumps Design Criteria Equipment Units Specifications Steam Surface Condenser Number of Units No. 1 Type Water Cooled Temperature of Condensate oF 125 Operating Pressure in Hga 4 Cooling Water Recirculated Potable Water Cooling Water Supply Temperature oF 85 Cooling Water Return Temperature oF 105 Condensate Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Vertical Multistage Centrifugal Design Flow Rate gpm 30 Approximate Head ft 60 Approximate Motor size hp 1.5 Drive Constant Speed BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 45 (20) Cooling Water Heat Exchangers – B-2-B A once-through cooling system, consisting of heat exchangers and pumps, will provide cooling water to the steam condensers. Plant effluent water (PEW) will be used as the coolant. A portion of the heated PEW exiting the cooling water heat exchangers will be used in the incinerator wet scrubber system impingement trays. Preliminary equipment design information for the cooling heat exchanger is listed in Table 1-26. Table 1-26. Cooling Water Heat Exchanger Design Criteria Equipment Units Specifications Cooling Water Heat Exchangers Number of Units No. 2 (1 Duty + 1 Standby) Type Plate and frame Cooling Fluid Type PEW Approximate Flow gpm 1,500 Design Pressure Drop psi 10 Design Inlet Temperature oF 80 Design Outlet Temperature oF 100 Cooled Fluid Type Recirculated potable water Approximate Flow gpm 1,400 Design Pressure Drop psi 10 Design Inlet Temperature oF 105 Outlet Temperature oF 85 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 46 (21) Condensate Handling System – B-2-B A condensate handling system consisting of deaerators, condensate storage tank, and waste heat boiler feed water pumps will be provided to condition, store and pump condensate in the closed-loop waste heat boiler steam system. Preliminary equipment design information for the condensate handling system is listed in Table 1-27. Table 1-27. Condensate Handling System Design Criteria Equipment Units Specifications Condensate Storage Tank Number of Units No. 1 Type Vertical, Carbon Steel. Capacity min 30 Capacity gal 900 Deaerator Number of Units 1 Type Tray Type Condensate flow rate pph 16,400 Steam Flow pph 1,000 to 2,000 Sump Storage 10 minutes Waste Heat Boiler Feed Pumps Number of Units 2 (1 Duty, 1 Standby) Type Centrifugal Design flow rate gpm 30 Approximate head ft 1,200 Approximate motor size hp 30 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 47 (22) Water Treatment System – B-2-B A package type water treatment system will be provided to treat potable water for boiler water make up. The water treatment equipment will depend on the potable water quality and make up water quality requirements. The water treatment system will consist of cartridge filters, carbon filters, water softeners, reverse osmosis (RO), demineralizers, demineralized water storage tank, and make up water pumps. The water treatment systems will include standby components to support 7 day, 24 hour incinerator operation during water system equipment cleaning and regeneration. The water softening and the demineralizer systems will require periodic regeneration; the RO system will require a periodic clean-in-place (CIP). All regeneration and CIP is expected to be performed off- site through a service contract. Preliminary equipment design information for the packaged water system is listed in Table 1-28. Table 1-28. Packaged Water Treatment Design Criteria Equipment Units Specifications Packaged Water Treatment Number of Units No. 2 (1 Duty, 1 Standby) Required Treated Water Flow Rate gpm 15 Design Pressure Loss As Required by Vendor Make Up Water Tank Capacity gal 1,800 (23) Future Advanced Air Pollution Control – B-2-C Regulations associated with mercury discharge from sludge incinerators are anticipated to change in the next five to ten years. Regulatory restrictions are currently being imposed on plants in the Northeast United States and may be adopted throughout the country. The regulation modifications are expected to require the addition of an advanced air pollution control system for mercury removal from incinerator exhaust gases. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 48 Mercury differs from other metals in the incineration process. Metals in the incinerator feed solids typically are removed from the process entrained in the ash or through the wet scrubber. While some mercury becomes entrained in the ash or is collected in the wet scrubber, the remainder is volatilized as elemental mercury (Hg0) in the incinerator. As the gaseous elemental mercury is cooled through the remaining processes, it can react with other components of the flue gas to form oxidized gaseous mercury (Hg2+). The components can be halogens (chlorine, fluorine, and bromine) or oxides of sulfur, such as sulfur dioxide (SO2) and sulfur trioxide (SO3) or nitrogen, such as nitrogen dioxide (NO2). Little mercury is typically retained in the ash. A fraction of the oxidized mercury (Hg2+) is soluble in water and is captured in the wet scrubbing process. The elemental species, which has low solubility in water and is emitted from the stack, must be oxidized and removed through scrubbing. The exhaust gases from the secondary heat exchanger will be directed to the advanced air pollution control system. Air pollution control equipment for mercury removal includes an exhaust gas conditioning tower, carbon injection tower, carbon storage, fabric filter (followed by previously described wet scrubber), dry ash system, and ID fan. Figure 10 shows the main mercury scrubbing process using carbon injection and a fabric filter. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 49 Figure 10: Advanced Air Pollution Control System w/ Mercury Scrubbing Mercury removal may also be accomplished by fixed bed carbon scrubbers. Comparison of the different mercury scrubbing options was not included for this evaluation, but it is recommended prior to final system selection. Descriptions of the various advanced air pollution control equipment required for a carbon injection system are included below. (24) Conditioning Tower – B-2-C The exhaust gases leaving the secondary heat exchanger will be directed to the gas conditioning tower, where it will be cooled adiabatically using a small amount of BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 50 atomized PEW. The conditioning tower system includes the gas conditioning vessel, atomized water-air spray lances, water booster pumps and air compressors. Preliminary equipment design information for the conditioning tower system is listed in Table 1-29. Table 1-29. Gas Conditioning Equipment Design Criteria Equipment Units Specifications Gas Conditioning Equipment Number of Conditioning Towers No. 2 Vessel Dimensions Diameter ft 12 Height ft 45 Design temperatures Exhaust gas in (normal operation)1 oF 1,050 Exhaust gas in (bypass operation) oF 1,200 Exhaust gas in (from SHE with heat recovery option) oF 400 Exhaust gas out oF 300 Quench water flow – (high temperature inlet condition) gpm 40 to 50 Quench water flow – (low temperature inlet condition) gpm 10 to 20 Water design pressure psig 60 Number of Air Compressors (per tower) No. 2 (1 duty, 1 standby) Compressor Dimensions Length ft 10 Width ft 6.5 Compressor Motor hp 150 1 Normal operation defined as no power generation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 51 (25) Carbon Injection and Storage – B-2-C Carbon will be injected upstream from the fabric filter for mercury removal. The mercury will adsorb onto the carbon and more than 90 percent of the mercury will be removed by the fabric filters. The removed mercury/carbon solids will be handled through the ash handling process. The carbon system will include a powdered activated carbon silo, volumetric feeder, carbon conveyance blower and carbon injection assembly. Powdered activated carbon will be delivered to the site by truck and stored in a carbon storage silo. Conveyance blowers will deliver the carbon from the carbon storage silo to the exhaust gas stream feed point ahead of the fabric filter. Preliminary equipment design information for the carbon system is listed in Table 1-30. Table 1-30. Carbon System Design Criteria Equipment Units Specifications Carbon System Number of carbon storage silos No. 1 Type Vertical with conical base Volume1 Storage cf days 860 30 Size Diameter ft 12 Total Height2 ft 45 Number of carbon volumetric feeders 2 Feed rate (each) pph 30 Number of carbon conveyance blowers 2 Flow (each) scfm 100 1 Carbon storage based on incinerator capacity for one unit in operation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 52 2 Silo height includes clearances for transport and dust collection equipment. (26) Fabric Filters – B-2-C The carbon solids will form a layer on the surface of the fabric filter bags, which will act as a mercury adsorption layer. Periodic, automatic filter cleaning will be performed using compressed air. The mercury-laden carbon and other particulate matter will be collected at the bottom of each fabric filter as dry ash. The dry ash will be collected by a screw conveyor at the base of the fabric filter and pneumatically conveyed to ash storage silos. Preliminary equipment design information for the fabric filters is listed in Table 1-31. Table 1-31. Fabric Filter Design Criteria Equipment Units Specifications Fabric Filter System Number of fabric filters No. 2 Type Multi-Chamber Dimensions Length Width Height ft 42 14 55 Exhaust Flow Temperature Volume1 oF acfm 350 max 45,000 No. of ash collection screw conveyors No. 2 Capacity2 lb/min 70 Motor hp 25 1 Fabric filter exhaust flow rate capacity based on incinerator capacity at high volatile (70% VS) conditions. 2 Ash conveyor capacity rate based on incinerator capacity and low volatile (58% VS) condition. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 53 (27) Dry Ash System – B-2-C The dry ash collected at the fabric filters will be transported to a dry ash storage silo by dense phase pneumatic conveyance systems consisting of an ash surge hopper, a pneumatic transporter, compressors and conveyance piping. The dry ash will be stored in a dry ash storage silo to be hauled off site for disposal. Preliminary equipment design information for the dry ash system is listed in Table 1-32. Table 1-32. Dry Ash System Design Criteria Equipment Units Specifications Dry Ash System Number of surge hoppers1 No. 2 Type Dry ash surge hopper capacity cf Vertical with Conical Base 10 Number of pneumatic transporters1 No. 2 Type Air flow Operating pressure scfm psig Dense Phase, Conical Base 100 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 100 25 Number of storage silos No. 2 Type Vertical with Conical Base Volume (each silo)2 Storage (AA conditions) cy days 390 7 Dimensions Diameter Total Height3 ft 24 60 1 Ash surge hopper and transporter vessel located under each fabric filter ash BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 54 conveyor. Transport system based on incinerator capacity and low volatile (58% VS) condition. 2 Ash storage based on low volatile (58% VS) and AA solids feed rate conditions. 3 Silo height includes clearances for nozzle, ash unloading equipment and truck. (28) Induced Draft Fans – B-2-C ID fans will provide additional energy to convey exhaust gases from the wet scrubber through the advanced emission control and discharge to the stack. Preliminary equipment design information for the ID Fan is listed in Table 1-33. Table 1-33. Induced Draft Fan Design Criteria Equipment Units Specifications ID Fan Number of Units 2 Type Single-Stage Centrifugal, Direct Drive Inlet Gas Temperature oF 90-130 Air Flow1 acfm 34,000 Flow Adjustment Variable Frequency Drive Pressure Rise in w.c. 40 Motor hp 350 Special Construction/Materials --- 316 wheels and shafts 1 Fan capacity based on incinerator capacity and high volatile (70% VS) condition. 5. Alternative B-1 – Layout Plans Refer to Figures C-1 through C-3 in Appendix C for preliminary layouts of the new wet scrubber and ash slurry systems. 6. Alternative B-2 – Layout Plans Refer to Figures C-4 through C-7 in Appendix D for preliminary layouts for the new FBIs, wet scrubbers and auxiliary systems. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 55 7. Site Plan Refer to Figure A-1 in Appendix A for a preliminary site plan showing the proposed location of the new Solids Processing Building. 8. Staffing Requirements Table 1-33 lists the anticipated staffing requirements for each of the alternatives and options. These staffing requirements are for the biosolids processing beginning with dewatering. For the options, the staffing requirements are in addition to the staffing for the alternative to which the option is added. Table 1-33. Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Alternative B-1 – Re-use of MHI and BFPs Supervisor 3 8 1 7 52 8,736 Operator 4.5 8 3 7 52 39,312 Maintenance 3.5 8 3 5 52 21,840 Alternative B-2 – New FBIs and Centrifuges Supervisor 3 8 1 7 52 8,736 Operator 4 8 3 7 52 39,944 Maintenance 3 8 3 5 52 18,720 Option B-2-A – Steam Generation Operator --- --- --- --- --- --- Maintenance 0.5 8 1 5 52 1,040 Stationary1 Engineer 0.5 8 3 7 52 4,368 Option B-2-B– Power Generation Operator --- --- --- --- --- --- Maintenance 1 8 1 5 52 2,080 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 56 Table 1-33. Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Stationary1 Engineer 1 8 3 7 52 8,736 Option B-2-C – Future Air Pollution Control Operator 0.5 8 3 7 52 4,368 Maintenance 1 8 1 5 52 2,080 1 Licensed steam boiler engineer/operator. 9. Cost Summary Table 1-34 presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were determined based on the descriptions of alternatives and options presented here. These costs and benefits were developed and presented in Technical Memorandum No.9 Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 57 Table 1-34. Opinions of Costs, Savings and Life Cycle Costs Alternative B-1 MHI+BFP B-2 FBI +CFG B-2-A FBI + Steam B-2-B FBI + Power B-2-C FBI + AEC Capital Costs Salvage Value $56,655 ($518) $150,089 ($3,400) $13,392 ($1,106) $29,003 ($494) $25,843 ($1,156) Annual O&M Costs $7,855 $7,731 $357 $653 $246 Annual Revenue ($0) ($0) ($588) ($349) ($0) Present Worth Costs Capital Salvage $56,655 ($195) $150,089 ($1,281) $13,392 ($417) $29,003 ($186) $25,843 ($436) O&M $97,896 $96,358 $4,449 $8,138 $3,068 Revenue ($0) ($0) ($7,328) ($4,355) ($0) Total Present Worth Costs $154,356 $245,166 $10,096 $32,600 $28,475 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 58 Appendix A Site Plan BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 59 Appendix B Detailed Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Bissell Point WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 60 Appendix C Layout Plans: Existing MHI and New Solids Processing Building BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 1 TECHNICAL MEMORANDUM NO. 2 – LEMAY WWTP SOLIDS PROCESSING ALTERNATIVES EVALUATION To: Metropolitan St. Louis Sewer District From: Jim Rowan, Gustavo Queiroz, Patricia Scanlan, Hari Santha This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Lemay Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. The following sections describe the existing biosolids management system, the solids quantities used as the basis of the evaluation, and the treatment options evaluated for Lemay. Table of Contents 1. Existing Plant Information ......................................................................................................... 3 2. Solids Quantities ........................................................................................................................ 7 3. Solids Processing Alternatives ................................................................................................... 8 a. Alternative L-1 .....................................................................................................................8 b. Alternative L-2 .....................................................................................................................9 c. Alternative L-3 ...................................................................................................................10 4. Technologies for Solids Processing Alternatives ..................................................................... 12 a. Solids Thickening ..............................................................................................................13 b. Thickened Sludge Well ......................................................................................................13 c. Dewatering .........................................................................................................................14 (1) Alternatives L-1, L-2 and L-3 – Existing Belt Filter Press Dewatering ................. 14 (2) Alternative L-3 – New Centrifuge Dewatering ...................................................... 16 d. Cake Conveyance and Storage...........................................................................................17 (1) Alternative L-1 - Existing Cake Conveyance and Storage System ........................ 17 (2) Alternative L-2 - Existing Cake Storage System and New Cake Pumps ............... 17 (3) Alternative L-3 - New Cake Conveyance and Storage System .............................. 18 (4) Cake Storage and Load Out to Regional Facility Option ....................................... 20 e. Incinerator Systems ............................................................................................................21 (1) Alternative L-1 - Existing Multiple Hearth Incinerator Systems ............................ 23 f. Alternative L-1 - Air Pollution Control .............................................................................25 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 2 g. Alternative L-1 – Induced Draft (ID) Fans ........................................................................27 h. Alternatives L-2 and L-3 - Fluidized Bed Incinerator System ..........................................27 (1) Alternatives L-2 and L-3 – Primary and Secondary Heat Exchangers ................... 29 (2) Alternatives L-2 and L-3 – Air Pollution Control Equipment ................................ 31 (3) Alternatives L-2 and L-3 – Ash Handling System.................................................. 32 (4) Alternatives L-2 and L-3 - Fluidizing Air Blower .................................................. 33 (5) Alternatives L-2 and L-3 - Fuel Storage Tank and Pumps ..................................... 33 (6) Alternatives L-2 and L-3 - Sand System................................................................. 35 (7) Energy Recovery Option - Power Generation – L-1-A, L-2&3-A ......................... 36 i. Waste Heat Boiler – L-1-A and L-2&3-A .........................................................................38 j. Steam Turbine Generator – L-1-A and L-2&3-A ..............................................................40 k. Steam Condenser – L-1-A and L-2&3-A ...........................................................................41 l. Cooling Water Heat Exchangers – L-1-A and L-2&3-A ...................................................42 m. Condensate Handling System – L-1-A and L-2&3-A .......................................................43 n. Water Treatment System – L-1-A and L-2&3-A ...............................................................45 (1) Future Air Pollution Control – L-1-B and L-2&3-B .............................................. 45 o. Conditioning Tower – L-1-B and L-2&3-B.......................................................................48 p. Carbon Injection and Storage – L-1-B and L-2&3-B ........................................................49 q. Fabric Filters – L-1-B and L-2&3-B ..................................................................................50 r. Dry Ash System – L-1-B and L-2&3-B .............................................................................51 s. Induced Draft Fans – L-1-B and L-2&3-B ........................................................................53 (1) Alternative L-1 – Layout Plans ............................................................................... 54 (2) Alternatives L-2 and L-3 Layout Plans ................................................................... 54 5. Site Plan ................................................................................................................................... 54 6. Staffing Requirements ............................................................................................................. 54 7. Cost Summary .......................................................................................................................... 55 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 3 1. Existing Plant Information The Lemay WWTP was commissioned in 1968. The WWTP has an average design capacity of 167 mgd and peak hydraulic design capacity of 233 mgd. The plant has both primary and secondary treatment. A site plan of the Lemay WWTP is shown in Figure 2-1. Figure 2-1: Lemay WWTP Site Plan The WWTP generates primary solids (PS) and waste activated solids (WAS), which are co- thickened in primary clarifiers to approximately 3 percent total solids (TS). Scum is collected from the primary and secondary clarifiers, pumped to scum thickeners and then pumped to three sludge wells where they are combined with the co-thickened sludge pumped from the primary clarifiers. The combined solids are dewatered by belt filter presses (BFP) to approximately 28 percent TS. There are six belt filter presses, but not all are continually used. Polymer is added to the sludge at a rate of approximately 10 lb of active polymer per dry ton of solids (lb/dt). Bottom BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 4 sludge from the scum thickeners are returned to the aeration tanks and filtrate from the BFPs are combined in drainage wells and returned to the primary clarifiers. The dewatered cake from the BFPs is discharged to belt conveyors and screw conveyors, which convey it to two equalization bins. Belt conveyors are used to feed the dewatered cake from the equalization bins to four multiple hearth incinerators (MHIs). The MHIs thermally oxidize the dewatered cake to produce ash and exhaust gases. The exhaust gases from the incinerators are treated using wet scrubbers and the ash is pumped in slurry form to three ash lagoons located off site. Waste heat from the exhaust gases is recovered downstream from each incinerator exhaust for use in a waste heat boiler to generate medium pressure steam for building heat. A schematic of the existing solids treatment processes is presented in Figure 2-2. Figure 2-2: Existing Solids Processes at Lemay WWTP BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 5 The specifications of the existing solids processing facilities at the WWTP are summarized in Table 2-1. Table 2-1. Rated Capacities of Existing Solids Processing Equipment Equipment Units Value SOLIDS DEWATERING Belt Filter Presses (BFP) Number of BFPs No. 6 Belt Width m 2 Hydraulic Capacity gpm/m 125 INCINERATOR EQUALIZATION BINS Live Bottom Bins (Screw Type) Number of Equalization Bins No. 2 Capacity2 cy 10 INCINERATION Multiple Hearth Incinerators (MHI) Number of MHIs No. 4 Capacity (per incinerator)1 Incinerator No.1 Incinerator No.2 Incinerator No.3 Incinerator No.4 dtpd 59 66 52 77 1 Incinerator capacity information provided by MSD. 2 Equalization bin capacity information provided by MSD. Pictures of the existing solids processing facilities are shown in Figure 2-3. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 6 Belt Conveyors Cake Equalization Bins Wet Scrubber Venturi Section Multiple Hearth Incinerators Figure 2-3. Existing Solids Processing Facilities at the Lemay WWTP BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 7 2. Solids Quantities The solids quantities for this evaluation were carried forward from Phase I – TM 2: Facility Summaries and Solids Projections and are summarized in Table 2-2. Table 2-2. Projected Solids Quantities Parameter Units Max. Month Ann. Avg. Primary Sludge Total Solids dtpd 30.0 21.0 Volatile Solids Fraction % of TS 45.5 50.5 Volatile solids dtpd 13.7 10.6 Waste Activated Sludge Total Solids dtpd 64.0 30.1 Volatile Solids Fraction % of TS 45.5 50.5 Volatile solids dtpd 29.1 15.2 Total Solids Total Solids dtpd 94.0 51.1 Volatile Solids Fraction % of TS 45.5 50.5 Volatile solids dtpd 42.8 25.8 Solids Concentration % 1.5 1.5 Flow gpd 1,502,800 816,900 The primary solids quantities listed in Table 2-2 reflect the primary treatment facilities wet weather expansion. Since the Lemay watershed is mature, no dry weather growth is expected. Therefore, the future WAS solids quantities for process evaluations were assumed to be the same as current conditions. The projected solids quantities presented lower than typical volatile solids (VS) concentrations in PS and WAS. The lower volatile solids (VS) concentration may be attributed to the higher fraction of inorganics in the plant influent during high flows. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 8 The maximum month (MM) quantities were used as the basis for equipment sizing at Lemay, except for the fluidized bed incinerator alternative, the size for which is described in more detail in the following section. The annual average quantities were used as the basis for determining the operations and maintenance (O&M) costs for the evaluation. The other assumptions used for the process evaluations are as follows:  Co-thickened solids (PS + WAS) concentration of 1.5 percent from primary clarifiers.  Solids capture efficiency of 98 percent in BFP dewatering units.  Solids capture efficiency of 98 percent in centrifuge dewatering units.  Dewatered cake solids concentration of 30 percent from belt filter presses and 35 percent from centrifuges.  Two days of storage at maximum month conditions for cake storage silos (load out to regional facility).  Volume calculations for cake storage and conveyance equipment based on 30 percent TS. 3. Solids Processing Alternatives Based on discussions with the District staff and site visits to the Lemay WWTP, three alternatives were developed for processing and management of biosolids generated at the Lemay WWTP. Descriptions of the alternatives are presented in the following sections. Refer to Appendix B of this report for detailed process flow schematics for all alternatives. a. Alternative L-1 This alternative is the base-case scenario and will include re-use of the existing cake handling equipment, belt filter presses, multiple hearth incinerators, ash handling, air pollution control systems, and heat recovery. Modifications and upgrades to the existing systems will be required and are discussed later in this report. This alternative will also include options for additional air pollution control systems and heat recovery. The heat recovery evaluation includes power generation to reduce plant electricity purchased from the electrical utility serving the plant. Figure 2-4 illustrates the overall process flow diagram for Alternative 1. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 9 Figure 2-4: Solids Flow Diagram - Alternative L-1 b. Alternative L-2 This alternative consists of re-use of the existing belt filter presses and cake equalization bins, new incinerator feed pumps (located in the existing dewatering room of the Incinerator and Filter Building), new solids processing facilities including fluidized bed incinerators (FBIs), air pollution control systems and heat recovery. The air pollution control system evaluation includes options for mercury removal and dry ash handling. The heat recovery evaluation includes power generation to reduce plant electricity purchased from the electrical utility serving the plant. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 10 Based on the larger size for the new fluidized bed incinerator and preliminary assessment of the existing Incinerator and Filter Building, it was determined that the current available space is not sufficient to house the new larger fluidized bed incinerator and associated equipment. In addition, the construction of a new solids processing facility will provide additional flexibility allowing the existing solids processing system to remain in operation during construction phase of the new facility. Figure 2-5 illustrates the overall process flow diagram for Alternative 2. Figure 2-5: Solids Flow Diagram - Alternative L-2 – New FBI and Existing BFPs c. Alternative L-3 This alternative consists of new solids processing facilities including dewatering centrifuges, re- use of existing belt filter presses (during low volatile conditions), equalization bins, incinerator BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 11 feed pumps, fluidized bed incinerators, air pollution control systems and heat recovery. The air pollution control system evaluation includes options for mercury removal and dry ash handling. The heat recovery evaluation includes power generation to reduce plant electricity purchased from the electrical utility serving the plant. Based on the larger size for the new fluidized bed incinerator and preliminary assessment of the existing Incinerator and Filter Building, it was determined that the current available space is not sufficient to house the new larger fluidized bed incinerator and associated equipment. In addition, the construction of a new solids processing facility will provide additional flexibility allowing the existing solids processing system to remain in operation during construction phase of the new facility. Figure 2-6 illustrates the overall process flow diagram for Alternative 3. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 12 Figure 2-6: Solids Flow Diagram - Alternative L-3 – New FBI and New Centrifuges A summary of the new and existing equipment being evaluated for each alternative is presented in Table 2-3. Table 2-3. Solids Processing Alternatives Equipment Alternative L-1 Alternative L-2 Alternative L-3 Re-Use BFPs and MHIs Re-Use BFPs and New FBIs New CFs and FBIs Dewatering Belt Filter Presses E E E Dewatering Centrifuges --- --- N Dewatered Cake Equalization Bins E E N Sludge Cake Storage/Loadout1 --- --- --- Incinerator Cake Feed Pumps --- N N Multiple Hearth Incinerators E --- --- Fluidized Bed Incinerators --- N N Air Pollution Control (Wet Scrubber) E N N Advanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling) N N N Legend: E = Existing system will be evaluated and modifications/upgrades recommended. N = The implementation of a new system will be evaluated. Notes: 1 Sludge cake storage/load out will be considered for regional facility option only. 4. Technologies for Solids Processing Alternatives The solids processing technologies considered to support the three alternatives are discussed in the following sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 13 a. Solids Thickening The existing primary clarifiers will continue to be used to co-thicken PS and WAS to approximately 1.5 percent TS. Since solids production is not expected to increase during the planning period, no additional thickening capacity will be required. It is important to note that if MSD implements biological phosphorus removal in the future, co- thickening is not recommended. Co-thickening PS and WAS can create anaerobic conditions and re-release phosphorous in the primary clarifiers, reducing the overall phosphorous removal efficiency. MSD is considering the addition of Biological Nutrient Removal (BNR) with phosphorous removal at the Bissell Point WWTP. If biological phosphorous removal is added at Lemay in the future, WAS should be thickened in a separate process. WAS thickening technologies are not evaluated as part of this report. b. Thickened Sludge Well The existing thickened sludge well is expected to have sufficient capacity to process future solids and will not be evaluated for this report. The existing thickened sludge well mixing system has experienced clogging problems due to rags and other non-biodegradable materials present in the thickened sludge stream. To improve this issue, an in-line grinder system is recommended to be installed upstream of the thickened sludge well. Preliminary equipment design information for the thickened sludge grinders is listed in Table 2- 4. Table 2-4. Thickened Sludge Grinders Design Criteria Equipment Units Specifications Thickened Sludge Grinder Number of Units No. 2 (1 Duty, 1 Standby) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 14 Table 2-4. Thickened Sludge Grinders Design Criteria Equipment Units Specifications Type In-line Operation Schedule Alternative 1 Alternative 2 h/d/wk 24/7/52 24/5/52 Inlet Cake Solids % 1.5 Rated Flow (each) gpm 1,100 Expected Pressure Drop psig 1.60 Motor hp 5 1 Existing CTPWS pump capacities will need to be further investigated during detailed design to verify that existing pumps are of sufficient capacity to overcome the additional head imposed by the new thickened sludge grinders. c. Dewatering (1) Alternatives L-1, L-2 and L-3 – Existing Belt Filter Press Dewatering Alternatives L-1 and L-2 include BFP dewatering. Based on the projected solids quantities listed in Table 2-2, the six existing dewatering BFPs and the BFP feed pumps are expected to have adequate capacity. However, based on age and expected life of the existing equipment, the dewatering equipment will need to be replaced or significantly overhauled during the evaluation period. For Alternative L-3, the existing BFP units will be retained (without overhaul) and used during low volatile solids conditions. Preliminary equipment design information for dewatering BFPs and BFP feed pumps are listed in Table 2-5. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 15 Table 2-5. BFPs and Feed Pumps Design Criteria Equipment Units Specifications Belt Filter Presses Number of Units1,2 No. 6 Operation Schedule h/d/wk 24/7/52 Belt width m 2 Hydraulic Loading Rate3 gpm/m 125 Solids Loading Rate3 pph/m 940 Solids capture rate % 98 Feed Solids % 1.5 Cake Solids % 30 Polymer use (active) lb/dt solids 10-15 BFP Feed Pumps Number of units No. 6 Pump type4 Centrifugal (Wemco vortex type) Flow (each) gpm 250 1 For Alternative L-1 (BFP with MHI), three (3) BFP units will be required to process solids at AA conditions and seven day operation schedule. A total of five (5) BFP units will be required to process solids at MM conditions and seven day operation schedule. Refer to Table 2-11 for proposed MHI operation. 2 For Alternatives L-2 and L-3 (BFP with FBI), four (4) BFP units will be required to process solids at AA conditions and five day operation schedule. A total of six (6) BFP units will be required to process solids at MM conditions and five day operation schedule. Refer to Table 2-14 for proposed FBI operation. 3 Loading rates listed are based on feedback from MSD for current operation. 4 Pump type selected to match existing BFP feed pumps. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 16 (2) Alternative L-3 – New Centrifuge Dewatering Alternative L-3 includes new centrifuge dewatering. For this alternative, the co-thickened sludge will be pumped from the existing sludge wells to new centrifuges located in a new Solids Processing Building. Preliminary equipment information for the centrifuges and centrifuge feed pumps is listed in Table 2-6 below. Table 2-6. Centrifuge and Centrifuge Feed Pump Design Criteria Equipment Units Specifications Centrifuges Number of Units1 No. 6 (5 Duty, 1 Standby) Operation Schedule h/d/wk 24/5/52 Rated Capacity gpm/machine 292 Required Hydraulic Loading Rate2 gpm/machine 292 Required Solids Loading Rate2 pph/machine 2,193 Approximate Diameter in. 23 Solids Capture Rate % 98 Feed Solids % 1.5 Cake Solids % 35 Polymer Use (active) lb/dt solids 15-20 Centrifuge Feed Pumps Number of units No. 6 (5 Duty, 1 Standby Pump type3 --- Centrifugal with AFD (Wemco vortex type) Flow (each) gpm 292 1 Three (3) centrifuges are required to process solids feeding one FBI at AA conditions, and five (5) centrifuges are required to process solids feeding one FBI at MM conditions. 2 Required centrifuge loading rates based on AA conditions for 5-day operation. 3 Pump type selected to match existing BFP feed pumps. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 17 d. Cake Conveyance and Storage (1) Alte rnative L-1 - Existing Cake Conveyance and Storage System Belt and screw conveyors are used to transfer dewatered cake from the existing BFPs to live- bottom (screw type) equalization bins (see Figure 2-2). The equalization bins discharge solids to belt conveyors that feed the incinerators. The capacity of the existing belt conveyors, screw conveyors, live-bottom and equalization bins will be sufficient for the future solids production; however, replacement of some existing equipment may be required during this project due to equipment age. Preliminary cake conveyance and storage equipment requirements are presented in Table 2-7. Table 2-7. Existing Cake Conveyance and Storage Equipment Design Criteria Equipment Units Specifications Dewatered Cake Conveyor System Conveyor type Belt Required capacity1 cf/h 440 Equalization Bins Number of units No. 2 Type Live bottom (screw) Required volume (each)2 cy 10 1 Required capacity based on MM solids conditions and seven day operation. 2 Equalization bin sizing based on existing equipment. (2) Alternative L-2 - Existing Cake Storage System and New Cake Pumps Existing screw and belt conveyors will be used to transfer dewatered cake from the existing BFPs to live-bottom (screw type) equalization bins (see Figure 2-5). New piston-type cake pumps will feed cake from the equalization basins to the new FBI incinerator. The capacity of BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 18 the existing belt conveyors, screw conveyors and live-bottom equalization bins will be sufficient for the future solids production; replacement of some existing equipment may be required during this project due to equipment age. The new cake pumps will be equipped with additional piping for cake load out to be used during times when the incinerator systems are not operating. Preliminary cake conveyance and storage equipment specifications are presented in Table 2-8 below. Table 2-8. Existing Cake Conveyance and Storage Equipment Design Criteria Equipment Units Specifications Dewatered Cake Conveyor System Conveyor type Belts/Screws Required capacity1 cf/h 620 Equalization Bins Number of units No. 2 Type Live bottom (screw) Required volume (each)2 cy 10 Dewatered Cake Pumps Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston (Dual Discharge) Flow Measurement Type Magnetic Flow Meter Required flow (each)3 gpm 50 1 Required capacity based on MM solids conditions and five day operation. 2 Equalization bin sizing based on existing equipment. 3 Cake pumps sized to transfer dewatered cake at incinerator capacity. (3) Alternative L-3 - New Cake Conveyance and Storage System A new cake conveyance and storage system will be required for Alternative L-3. The system will be located in the new Solids Processing Building with new FBI. Shafted screw conveyors BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 19 will be used to transfer dewatered cake from the centrifuges to cake transfer pumps that will feed the equalization bins, as shown on Figure 2-6. The hopper will be equipped with a sliding frame-type live bottom, which will discharge solids to piston-type cake pumps feeding the incinerator. The new cake pumps will be equipped with additional piping for cake load out to be used during times when the incinerator systems are not operating. Preliminary equipment design information for the sludge conveying and storage facilities is listed in Table 2-9. Table 2-9. New Cake Conveying and Storage Equipment Design Criteria Equipment Units Specifications Dewatered Cake Conveyor System Number of units No. 2 Conveyor type1 Shafted Screw Required capacity (each)2 cf/h 330 Cake Transfer Pumps (from dewatered cake conveyors to equalization bins) Number of units No. 2 (1 Duty, 1 Standby) Conveyor type Hydraulic piston (Dual Discharge) Required flow (each) gpm 50 Equalization Bins Number of units No. 2 Type Live bottom (Sliding Frame) Required volume (each)3 cy 35 Dewatered Cake Pumps (from equalization bin to incinerator) Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston (Dual Discharge) Flow Measurement Type Magnetic Flow Meter Required flow (each)4 gpm 50 1 Shafted screw conveyors used for this evaluation. Shaft-less screw type conveyors may be evaluated during detailed design. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 20 2 Required capacity based on FBI incinerator capacity. 3 Equalization bins sized for approximately 3 hours of storage capacity for each incinerator at 70 dtpd. 4 Cake pumps sized to transfer dewatered cake at incinerator capacity. (4) Cake Storage and Load Out to Regional Facility Option A new cake storage and load out system will be required for the option of hauling dewatered solids to a Regional Facility for incineration. The new cake storage and load out system will be located in a new building, east of the existing Incinerator and Filter Building. Cake transfer pumps will be required to transfer dewatered cake from the cake equalization bins to cake storage silos, as shown on Figure 2-4. The silo will be equipped with a sliding frame type live bottom, which will discharge solids to trucks that will transfer dewatered cake to the Regional Facility. Cake recirculation pumps will be provided as part of the cake storage system to help reduce the amount of odorous gases released from the stored cake. Cake load out is only considered for the Regional Facility option (refer to the Regional Facility chapter of this report). Incinerator upgrades at Lemay would not be required for a Regional Facility option. Preliminary equipment design information for the cake storage and load out facility is listed in Table 2-10. Table 2-10. New Cake Storage and Load Out Equipment Design Criteria Equipment Units Specifications Cake Transfer Pumps (feeding storage silos from existing equalization bins) Number of units No. 2 (one per equalization bin) Pump type Hydraulic piston (Dual Discharge) Required flow (each)1 gpm 55 Dewatered Cake Storage Silo (Truck Loading) Number of units No. 2 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 21 Table 2-10. New Cake Storage and Load Out Equipment Design Criteria Equipment Units Specifications Type Live bottom (Sliding Frame) Storage capacity2 days 2 Required volume (each) cy 390 Dewatered Cake Storage Silo Recirculation Pumps3 Number of units No. 4 (2 Duty, 2 Standby) Pump type Hydraulic piston Volume turnover hr 6 Turnover capacity cy/hr 65 Required flow (each) gpm 220 1 Cake transfer pump capacity based on MM conditions. 2 Cake storage based on MM conditions. 3 The use of the cake recirculation pump concept for odor reduction will be verified during detailed design. e. Incinerator Systems Incinerator systems process dewatered sludge by means of high temperature thermal oxidation (combustion). The dewatered cake is conveyed (for Alternative L-1) or pumped (for Alternatives L-2 and L-3) to the incinerators that oxidize the organic fraction in the solids, generating exhaust gases and ash. Many plants currently use multiple hearth incinerators (MHI) to burn dewatered cake generated at their facility. Most of the MHIs were built in the 1970s and 1980s. With over 20 years or more of service they are requiring repairs and upgrades to continue operation. Owners are asking if it is worthwhile to spend the resources to upgrade or replace the units with fluidized bed incinerators (FBI). Table 2-11 presents a discussion of the merits and concerns with upgrading MHIs or replacing them with new FBIs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 22 Table 2-11. Incinerator Technologies Comparison Item MHI FBI Comment Unit capacity and Sizing 23 ft. diameter MHI will burn 25 to 50 dry tons per day of dewatered sewage solids. The typical FBI will burn 50 to 120 dtpd of solids with most units sized for about 100 dtpd. For every two MHIs, one FBI can match or exceed their capacity, reducing the number of units and space needed. Operation skill and complexity Generally requires one operator per 1 or 2 units to adjust and monitor Typically requires less time with one operator assigned to dewatering and incineration operation. Plant operators, who have experience with both, report that operation of a FBI is less demanding than for a MHI. Cost No new MHIs are being built. Many are undergoing repairs, rebuilding and emissions control upgrades with equipment and installation costs of $2M to $6M per unit. FBIs have equipment and installation costs of $15M to $20M per unit. New FBIs typically require a new building and support facilities, resulting in costs of $30M to $40M for a single unit. For comparison, costs for upgrading MHIs (2 units) would range from $4M to $12M and would provide same or less capacity than one FBI. Emission Controls The MHIs currently use wet scrubbers consisting of a variation of venturis, impingement scrubbers, and wet electrostatic precipitators for particulate and acid gas removal from exhaust gases. CO, THC, and NOx are controlled by operational parameters including temperature and oxygen content. There is no mercury control. FBIs use similar wet scrubbers as MHIs but are inherently better combustion devices with lower emissions of CO, THC, and NOx. Mercury removal has been used for FBIs. New regulations will lower emission limit requirements for both types with the MHIs being impacted the most for CO, NOx and Hg emissions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 23 Table 2-11. Incinerator Technologies Comparison Item MHI FBI Comment Turndown MHIs will burn under turn down conditions but with some additional fuel usage. FBIs can also be turned down but with much less efficient operation. To accommodate lower feed rates, FBIs are operated in a weekly batch mode where they burn the solids at design rates until the weekly quantity is depleted. Then they are “bottled up” until the cycle repeats. Some auxiliary fuel will be used for warming prior to introducing solids again. Both type incinerators operate more efficiently at design loading. MHIs are more appropriate for small facilities with FBIs used for large facilities. Power generation from incineration Can be implemented to produce electricity with steam/steam turbine. Steam at 400 psia. Can be implemented to produce electricity with steam/steam turbine. Steam at 400 psia. Power produced is proportional to the volatile solids burned. For 100 dtpd feed rate, 1 to 1.5 MW produced. Descriptions for each incinerator system alternative are provided in the following sections. (1) Alternative L-1 - Existing Multiple Hearth Incinerator Systems Alternative L-1 retains the existing MHIs. Three of the existing four MHIs are expected to provide sufficient capacity for the projected solids quantities in Table 2-2. However, based on age and life of the MHI equipment, the MHIs are expected to need significant rehabilitation during the evaluation period. Three of the four existing MHIs will be rehabilitated to support the projected solids loading conditions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 24 The incinerators are sized such that one of the three incinerator trains must be operated to process annual average solids quantities. Two incinerators must be operated to support maximum month solids quantities. The third incinerator will provide spare capacity at maximum month conditions. For this base alternative, the existing waste heat boilers will be rehabilitated and continue to produce steam for building heat. Figure 2-7 illustrates the proposed Alternative L-1 MHI incineration system. Figure 2-7: Alternative 1 – Reuse of MHIs Preliminary equipment design information for the MHIs is listed in Table 2-12. Table 2-12. Multiple Hearth Incinerators Design Criteria Equipment Units Specifications Multiple Hearth Incinerators Number of Units No. 3 (2 Duty, 1 Standby) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 25 Table 2-12. Multiple Hearth Incinerators Design Criteria Equipment Units Specifications Operation Schedule h/d/wk 24/7/52 Required Capacity (each)1 dtpd 60 Incinerator Vessel Type No. of Hearths Multiple Hearth 11 Size Diameter Height ft ft 22’-3” 45 Wall Construction Inner Layer of Walls Outer Layer of Walls Outer Layer of Top Refractory brick Insulated fire brick High duty castible Auxiliary Fuel Source Natural gas Min Natural Gas Pressure psig 10 Exhaust Temperature oF 1,100-1,400 1 Average incinerator capacity used for calculation purposes. f. Alternative L-1 - Air Pollution Control The existing impingement tray scrubbers, induced draft (ID) fans, and associated exhaust ductwork will be replaced to reduce particulate emissions and provide additional operational flexibility. The new scrubbers will re-use the existing scrubber vessels, but will require new internal components. In addition, the upper section of the existing scrubber vessels will be extended to accommodate new multiple venturi sections. New exhaust gas quench sections will be added to pre-condition the exhaust gases before entering the wet scrubbers. The new scrubber will be a vertical upflow unit with impingement trays used for cooling and saturating the gas, followed by a multiple fixed venturi section with water injection and mist BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 26 eliminators with sprays. Plant effluent water will be used for the impingement trays. Strained plant effluent water will be used for the venturi injection and high pressure spray lances. Service water (potable water downstream of a backflow preventer) will be used for the mist eliminator sprays. Booster pumps will be supplied with the scrubbers for venturi and high pressure spray lance water injection. Strained plant effluent water is required for the venturi injection and high pressure spray lances to prevent nozzle clogging while potable water is required for the mist eliminator to prevent fouling. Preliminary equipment design information for the wet scrubber and quench section are listed in Table 2-13. Table 2-13. Wet Scrubber and Quench Section Design Criteria Equipment Units Specifications Wet Scrubbers and Quench Station Number of Units No. 3 (2 Duty, 1 Standby) Type Combined impingement tray, and multiple fixed venturis Configuration Vertical, up flow Pressure Drop in w.c. 30 Dimensions Diameter Height ft 12 30 Water Requirements (per scrubber) Quench Section Sprays Under Tray Sprays Impingement Trays Venturi Section Sprays Mist Eliminator gpm 100 60 1,200 150 10 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 27 g. Alternative L-1 – Induced Draft (ID) Fans New ID fans will be required to overcome the increased pressure drop associated with the new wet scrubbers. The ID fans will be located in the same area as the existing fans. The ID fans will pull the clean gas from the air pollution control equipment and discharge it to the stack. Preliminary equipment design information for the ID fans is listed in Table 2-14. Table 2-14. Induced Draft Fan Design Criteria Equipment Units Specifications Induced Draft Fans Number of Units No. 3 (2 Duty, 1 Standby) Type Single stage centrifugal, direct drive Inlet Gas Temperature oF 90-130 Required Capacity acfm 22,000 Flow Adjustment Variable Frequency Drive Pressure Rise (design) in w.c. 44 Motor hp 250 Special Construction/Materials 316 SS wheels and shafts h. Alternatives L-2 and L-3 - Fluidized Bed Incinerator System Alternatives L-2 and L-3 will include a single fluidized bed incinerator (FBI) train, installed in the new Sludge Processing Building. The incinerator vessel will consist of three zones: hot windbox, sand bed, and freeboard. Preheated fluidizing air will be directed into the windbox and distributed to the bed through tuyeres in a refractory arch. The air will fluidize the sand bed above the refractory arch and will provide combustion air for the process. Dewatered cake will be pumped into the incinerator through multiple injection nozzles and into the sand bed. Auxiliary fuel injection lances (fuel oil or natural gas) will provide supplemental fuel, if needed. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 28 All exhaust gases, including combustion products and ash, will exit the fluidized bed incinerator through the freeboard and exhaust gas duct. Alternatives 2 and 3 are shown on Figure 2-8. Figure 2-8: Alternatives L-2 and L-3 – New FBIs Preliminary equipment design information for the FBIs is listed in Table 2-15. Table 2-15. Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Fluid Bed Incinerators Number of Units1 No. 2 Operation Schedule h/d/wk 24/5/52 Required Capacity (each) dtpd 70 Incinerator Vessel Type Refractory lined w/ refractory BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 29 Table 2-15. Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Windbox arch Hot Air Size Freeboard Diameter Height ft 24 45 Wall Construction Inner layer of walls and dome Outer layer of walls and dome Refractory Brick Insulated Fire Brick Number of Solids Feed Nozzles Multiple around periphery, 4 minimum Auxiliary Fuel Source Natural Gas and Fuel Oil Minimum Natural Gas Pressure psig 10 Exhaust Temperature oF 1,500-1,650 max Preheat Provisions Preheat supplied by natural gas fired burner 1 One incinerator will have sufficient capacity to process total projected feed solids at annual average conditions and five day operation. Two incinerators will be required to operate during maximum month conditions and five day operation. (1) Alternatives L-2 and L-3 – Primary and Secondary Heat Exchangers Primary and secondary heat exchangers will recover waste heat from the exhaust gases. The primary heat exchanger will transfer heat from the incinerator exhaust gases to the fluidizing air. A primary heat exchanger bypass (with damper) will control the temperature of the fluidizing air and heat recovery. This “hot windbox” design is expected to reduce the amount of auxiliary fuel required for combustion and, in some cases, may allow autogenous (without additional fuel) combustion. Following the primary heat exchanger, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas. Heating the scrubber outlet gas prior to discharge to the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 30 atmosphere will help suppress visible plumes in the incinerator exhaust. The secondary heat exchanger may also be used to pre-heat exhaust to future emission control equipment. Primary and secondary heat exchanger information is presented in Table 2-16. Table 2-16 Primary and Secondary Heat Exchangers Design Criteria Equipment Units Specifications Primary Heat Exchanger Number of Units No. 2 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Fluidizing air in Fluidizing air out oF 1,650 1,200 60 1,030 Size Vessel Diameter Height ft 10 30 Design Pressure psig 10 Secondary Heat Exchanger Number of Units No. 2 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Scrubber outlet gas in Scrubber outlet gas out oF 1,200 1,050 100 300 Design Pressure psig 10 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 31 (2) Alternatives L-2 and L-3 – Air Pollution Control Equipment Exhaust gases leaving the secondary heat exchangers will be directed to the air pollution control equipment. Air pollution control equipment will include quench sprays and wet scrubbers. The quench spray section will consist of multiple water sprays used to cool the exhaust gases prior to entering the wet scrubber. The new scrubber will be a vertical upflow unit with impingement trays used for cooling and saturating the gas, followed by a multiple fixed venturi section with water injection and mist eliminators with sprays. Plant effluent water will be used for the impingement trays. Strained plant effluent water will be used for the venturi injection and high pressure spray lances. Service water (potable water downstream of a backflow preventer) will be used for the mist eliminator sprays. Booster pumps will be supplied with the scrubbers for venturi and high pressure spray lance water injection. Strained plant effluent water is required for the venturi injection and high pressure spray lances to prevent nozzle clogging while potable water is required for the mist eliminator to prevent fouling. Wet scrubber equipment information is presented in Table 2-17. Table 2-17. Wet Scrubber Design Criteria Equipment Units Specifications Wet Scrubbers Number of Units No. 2 Type Combined Impingement Tray, and Multiple Fixed Venturis Configuration Vertical, Upflow Dimensions, ft Diameter Height ft 14 30 Water Requirements (per scrubber) Quench Sprays Under Tray Sprays Impingement Trays Venturi Section Mist Eliminator gpm 100 50 1,400 150 15 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 32 (3) Alternatives L-2 and L-3 – Ash Handling System For FBIs, a small fraction of the ash is collected at the waste heat boilers (for power generation option only) while the majority of the ash is removed by the wet scrubber. A new ash slurry system including ash slurry pumps and slurry tanks is recommended to handle the ash slurry from the bottom of the scrubber. The new ash slurry system will collect the scrubber drain water including the ash and transfer it to the existing ash lagoons. Preliminary equipment design information for the ash slurry system is listed in Table 2-18. Table 2-18. Ash Slurry System Design Criteria Equipment Units Specifications Ash Slurry Tanks Number of Units No. 2 Material Handled Fly ash from FBIs Tank Dimensions Length Width Height ft 10’-0” 10’-0” 8’-0” Ash Slurry Concentration % 0.5 to 1 Ash Slurry Pumps Number of Units (per incinerator) No. 4 (2 Duty, 2 Standby) Material Handled Ash Slurry Incinerator Ash Flow Rate pph 2,920 Maximum Flow Rate at Maximum Speed gpm 1,170 Minimum Flow Rate at Reduced Speed gpm 585 Discharge Point Ash Lagoons Discharge Head at Maximum Flow ft 100 Motor hp 50 1 Ash flow rate based on low volatile (50% VS) condition and FBI incinerator capacity. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 33 (4) Alternatives L-2 and L-3 - Fluidizing Air Blower The incinerator will have a dedicated blower to supply fluidizing air. The fluidizing air will be drawn from outside the Solids Processing Building, and will be preheated in the primary heat exchanger before entering the FBI windbox. Fluidizing air serves two purposes: to suspend the solids in the incinerator bed and to provide combustion air. Equipment information for the fluidizing air blowers is presented in Table 2-19. Table 2-19. Fluidizing Air Blower Design Criteria Equipment Units Specifications Fluidizing Air Blower Number of Units No. 2 Type Multiple-Stage Centrifugal Drive Direct Required Flow scfm 10,500 Flow Adjustment Inlet Damper Pressure Rise psig 8 Motor hp 600 (5) Alternatives L-2 and L-3 - Fuel Storage Tank and Pumps Fuel oil will be delivered to the site by truck and stored in an above ground storage tank located next to the new Solids Processing Building. Fuel oil transfer pumps will be installed in the fuel oil storage area to transfer fuel oil from the storage tank to a day tank. A second set of pumps, fuel oil feed pumps, will be used to transfer fuel oil from the day tank to each incinerator. The fuel oil, which will be used for supplemental fuel during incinerator warm up, will be injected into the incineration process through fuel injection lances. Equipment requirements for the fuel storage tank and pumps are listed in Table 2-20. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 34 Table 2-20. Fuel Oil Storage Tank and Pumps Design Criteria Equipment Units Specifications BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 35 Fuel Oil Tank Number of Units 1 Type Double wall, above ground Tank Size Diameter Length ft 10 20 Volume gal 10,000 Fuel Oil Transfer Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Gear Required Flow gpm 20 Minimum Discharge Pressure psi 5 Motor hp 0.5 Fuel Oil Day Tank Number of Units No. 1 Tank Size Diameter Height ft 3 10 Volume gal 500 Fuel Oil Injection Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type AFD, Gear Type Required Flow gpm 1 Minimum Discharge Pressure psi 50 Motor hp 0.25 (6) Altern atives L-2 and L-3 - Sand System BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 36 Sand will be delivered to the site by truck and stored in an indoor sand storage tank. A pneumatic transporter will convey sand from the sand storage tank to the FBI to replenish sand entrained in the exhaust gas stream. Preliminary equipment design information for the sand storage system is shown in Table 2-21. Table 2-21. Sand System Design Criteria Equipment Units Specifications Storage Tank Number of Units No. 1 Type Vertical with dual conical base Volume1 cf 360 Storage months 1 to 9 Size Diameter Total Height2 ft 9 40 Transporters Number of Units No. 2 Compressed Air Requirements Flow, scfm Pressure range, psig scfm psig 150 100-120 1 Silo capacity based on sand demand of 50 lbs/hr for one incinerator. Feed rate for make up sand range from 5 to 50 lbs/hr. 2 Silo height includes clearances for transport and dust collection equipment. (7) Energy Recovery Option - Power Generation – L-1-A, L-2&3-A Option L-1-A will include waste heat boilers and on-site power generation. Waste heat from the exhaust gases will be recovered downstream from the incinerator exhaust for use in waste heat boilers to generate high pressure superheated steam for power generation. The generated electricity will be used onsite. The waste heat boilers included in this alternative will be located BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 37 in the existing Incinerator and Filter Building while the power generation equipment will require a separate stand alone building. The option L-1-A for power generation is shown on Figure 2-9. Figure 2-9: Option L-1-A – MHIs with Power Generation For options L-2&3-A, the waste heat remaining in the exhaust gases after the primary heat exchanger will be used in waste heat boilers to generate high pressure superheated steam. The superheated steam will be used in steam turbines to generate electricity, which will be used on- site to reduce electricity purchases. Following the waste heat boiler, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas for plume suppression. Energy recovery and power generation equipment associated with Alternatives L-2 and L-3 will be located in the new Solids Processing Building. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 38 The proposed power generation options L-2&3-A are shown on Figure 2-10. Figure 2-10: Options L-2&3-A – FBI with Power Generation i. Waste Heat Boiler – L-1-A and L-2&3-A Flue gases from the incinerator(s) will be ducted to new waste heat boilers. The waste heat boilers will recover heat from the incinerator exhaust gases to produce high pressure superheated steam for power generation. Ducting from the incinerators will be configured such that either of the incinerators can provide exhaust gas to either of the waste heat boilers. Bypasse(s) will be provided around the waste heat boiler to allow the steam production equipment to be taken out of service without affecting incinerator operation. Equipment information for the waste heat boiler is provided in Table 2-22. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 39 Table 2-22. Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Waste Heat Boilers Number of Units1 No. 2 Type Water Tube Flue Gas Conditions Flue Gas Pressure psia 14.7 Flue Gas Inlet Temperature Option L-1-A Options L-2&3-A oF 1,100 1,200 Flue Gas Outlet Temperature oF 500 Design Flue Gas Flow2 Option L-1-A Options L-2&3-A pph 66,100 65,000 Flue Gas Flow at AA Conditions (each boiler)3 Option L-1-A (70% VS and 28% TS) (50% VS and 35% TS) Options L-2&3-A (70% VS and 28% TS) (50% VS and 35% TS) pph 56,300 40,300 65,000 46,600 Steam Conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Steam Flow at AA Conditions4 Option L-1-A (70% VS and 28% TS) (50% VS and 35% TS) Options L-2&3-A (70% VS and 28% TS) (50% VS and 35% TS) pph 7,900 5,500 11,250 7,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 40 Table 2-22. Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Waste Heat Fly Ash Transport System (From waste heat boiler to ash storage silo)5 Number of surge hoppers No. 2 Type Dry ash surge hopper capacity cf Vertical with Conical Base 1 Number of pneumatic transporters No. 2 Type Air flow Operating pressure scfm psig Dense Phase, Conical Base 10 to 15 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 50 5 1 Boiler capacity will only be provided for duty incinerators. 2 Design exhaust flow rate for each waste heat boiler based on incinerator capacity at 70% VS and 28% TS. 3 Operation schedule of five days per week will yield biosolids quantities of approximately 71 dtpd. Five day operation is being considered for FBI alternatives only. 4 Steam flow rates shown include deduction for parasitic loads (i.e., de-aerator, etc.). 5 Required for options with dry ash handling. For options where dry ash handling is not required, the ash transport system will transfer the waste heat boiler fly ash to wet slurry tanks. j. Steam Turbine Generator – L-1-A and L-2&3-A One steam turbine generator will be used to convert steam to electrical power. The skid-mounted steam turbine will be installed in the new Solids Processing Building and will include an oil lubrication system, mounted on a separate skid. Preliminary equipment information for the steam turbine generator is listed in Table 2-23. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 41 Table 2-23. Steam Turbine Generator Design Criteria Equipment Units Specifications Steam Turbine Number of Units No. 1 Type Full condensing to 4 in. Hg absolute Steam conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Design Steam Flow1 Option L-1-A Options L-2&3-A pph 9,200 12,900 Turbine speed rpm 4,750 Alternator Speed rpm 1,800 Power output at AA Conditions Option L-1-A (70% VS and 28% TS) (50% VS and 35% TS) Options L-2&3-A (70% VS and 28% TS) (50% VS and 35% TS) MW 0.55 0.39 0.8 0.55 Output Voltage V 4,160 Type --- Synchronous 1 Steam turbine sized for steam rate prior to parasitic load deduction. Power output based on net steam rate after parasitic load deduction. k. Steam Condenser – L-1-A and L-2&3-A BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 42 One steam condenser will be provided to condense steam from the turbine. The condensate will be returned to the waste heat boiler steam drum. Preliminary equipment design information for the steam condenser and condensate pumps is shown in Table 2-24. Table 2-24. Steam Condenser and Condensate Pumps Design Criteria Equipment Units Specifications Steam Surface Condenser Number of Units No. 1 Type Water Cooled Temperature of Condensate oF 125 Operating Pressure in Hga 4 Cooling Water Recirculated Potable Water Cooling Water Supply Temperature oF 85 Cooling Water Return Temperature oF 105 Condensate Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Vertical Multistage Centrifugal Design Flow Rate Option L-1-A Options L-2&3-A gpm 20 25 Approximate Head ft 60 Approximate Motor size hp 1 Drive Constant Speed l. Cooling Water Heat Exchangers – L-1-A and L-2&3-A A once-through cooling system, consisting of heat exchangers and pumps, will provide cooling water to the steam condensers. Plant effluent water (PEW) will be used as the coolant. A BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 43 portion of the heated PEW exiting the cooling water heat exchangers will be used in the incinerator wet scrubber system impingement trays. Equipment information for the cooling heat exchanger is provided in Table 2-25. Table 2-25. Cooling Water Heat Exchanger Design Criteria Equipment Units Specifications Cooling Water Heat Exchangers Number of Units No. 2 (1 Duty + 1 Standby) Type Plate and frame Cooling Fluid Type PEW Approximate Flow Option L-1-A Options L-2&3-A gpm 900 1,200 Design Pressure Drop psi 10 Design Inlet Temperature oF 80 Design Outlet Temperature oF 100 Cooled Fluid Type Recirculated potable water Approximate Flow Option L-1-A Options L-2&3-A gpm 800 1,100 Design Pressure Drop psi 10 Design Inlet Temperature oF 105 Outlet Temperature oF 85 m. Condensate Handling System – L-1-A and L-2&3-A A condensate handling system consisting of deaerators, condensate storage tank, and waste heat boiler feed water pumps will be provided to condition, store and pump condensate in the closed- loop waste heat boiler steam system. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 44 Preliminary equipment information for the condensate handling system is listed in Table 2-26. Table 2-26. Condensate Handling System Design Criteria Equipment Units Specifications Condensate Storage Tank Number of Units No. 1 Type Vertical, Carbon Steel. Capacity min 30 Capacity Option L-1-A Options L-2&3-A gal 600 750 Deaerator Number of Units No. 1 Type Tray Type Condensate flow rate Option L-1-A Options L-2&3-A pph 9,200 12,900 Steam Flow pph 1,000 Sump Storage 10 minutes Waste Heat Boiler Feed Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Centrifugal Design flow rate Option L-1-A Options L-2&3 gpm 20 25 Approximate head ft 1,200 Approximate motor size Options L-1-A Options L-2&3 hp 20 25 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 45 n. Water Treatment System – L-1-A and L-2&3-A A package type water treatment system will be provided to treat potable water for boiler water make up. The water treatment equipment will depend on the potable water quality and make up water quality requirements. The water treatment system will consist of cartridge filters, carbon filters, water softeners, reverse osmosis (RO), demineralizers, demineralized water storage tank, and make up water pumps. The water treatment systems will include standby components to support 7 day, 24 hour incinerator operation during water system equipment cleaning and regeneration. The water softening and the demineralizer systems will require periodic regeneration; the RO system will require a periodic clean-in-place (CIP). All regeneration and CIP is expected to be performed off-site through a service contract. Preliminary information for the packaged water system is presented in Table 2-27. Table 2-27. Packaged Water Treatment Design Criteria Equipment Units Specifications Packaged Water Treatment Number of Units No. 2 (1 Duty, 1 Standby) Required Treated Water Flow Rate gpm 10 Design Pressure Loss As Required by Vendor Make Up Water Tank Capacity gal 1,200 (1) Future Air Pollution Control – L-1-B and L-2&3 -B Regulations associated with mercury discharge from sludge incinerators are anticipated to change in the next five to ten years. Regulatory restrictions are currently being imposed on plants in the Northeast United States and may be adopted throughout the country. The regulation modifications are expected to require the addition of an advanced air pollution control system for mercury removal from incinerator exhaust gases. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 46 Mercury differs from other metals in the incineration process. Metals in the incinerator feed solids typically are removed from the process entrained in the ash or through the wet scrubber. While some mercury becomes entrained in the ash or is collected in the wet scrubber, the remainder is volatilized as elemental mercury (HgO) in the incinerator. As the gaseous elemental mercury is cooled through the remaining processes, it can react with other components of the flue gas to form oxidized gaseous mercury (Hg2+). The components can be halogens (chlorine, fluorine, and bromine) or oxides of sulfur, such as sulfur dioxide (SO2) and sulfur trioxide (SO3) or nitrogen, such as nitrogen dioxide (NO2). Little mercury is typically retained in the ash. A fraction of the oxidized mercury (Hg2+) is soluble in water and is captured in the wet scrubbing process. The elemental species, which has low solubility in water and is emitted from the stack, must be oxidized and removed through scrubbing. For Option L-1-B, the exhaust gases from the waste heat boiler will be directed to the advanced air pollution control system. For Options L-2&3-B, the exhaust gases from the secondary heat exchanger will be directed to the advanced air pollution control system. Air pollution control equipment for mercury removal includes an exhaust gas conditioning tower, carbon injection tower, carbon storage, fabric filter (followed by previously described wet scrubber), dry ash system, and ID fan. Figure 2-11 shows the main mercury scrubbing process using carbon injection and a fabric filter. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 47 Figure 2-11: Advanced Air Pollution Control System w/ Mercury Scrubbing Mercury removal may also be accomplished using fixed bed carbon scrubbers. Comparison of the different mercury scrubbing options was not included for this evaluation, but it is recommended prior to final system selection. Descriptions of the various advanced air pollution control equipment required for a carbon injection system are included below. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 48 o. Conditioning Tower – L-1-B and L-2&3-B The exhaust gases leaving the waste heat boiler (Option L-1-B) or secondary heat exchanger (Options L-2&3-B) will be directed to the gas conditioning tower, where it will be cooled adiabatically using a small amount of atomized PEW. The conditioning tower system includes the gas conditioning vessel, atomized water-air spray lances, water booster pumps and air compressors. Preliminary equipment information for the conditioning tower system is listed in Table 2-28. Table 2-28. Gas Conditioning Equipment Design Criteria Equipment Units Specifications Gas Conditioning Equipment Number of Conditioning Towers No. 2 Vessel Dimensions Diameter ft 10 Height ft 45 Design temperatures Exhaust gas in (normal operation)1 Option L-1-B Options L-2&3-B oF 500 1,050 Exhaust gas in (from bypass) Option L-1-B Options L-2&3-B oF 1,100 1,200 Exhaust gas in (from SHE) Options L-2&3-B oF 400 Exhaust gas out oF 300 Quench water flow – (high temperature inlet condition) gpm 30 to 40 Quench water flow – (low temperature inlet condition) gpm 5 to 10 Water design pressure psig 60 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 49 Table 2-28. Gas Conditioning Equipment Design Criteria Equipment Units Specifications Number of Air Compressors No. 2 (1 duty, 1 standby) Compressor Dimensions Length ft 8 Width ft 5.0 Compressor Motor hp 100 1 For Option L-1-B, normal operation includes use of existing waste heat boiler. For Options L-2&3-B, normal operation is defined as no power generation. p. Carbon Injection and Storage – L-1-B and L-2&3-B Carbon will be injected upstream from the fabric filter for mercury removal. The mercury will adsorb onto the carbon and more than 90 percent of the mercury will be removed by the fabric filters. The removed mercury/carbon solids will be handled through the ash handling process. The carbon system will include a powdered activated carbon silo, volumetric feeder, carbon conveyance blower and carbon injection assembly. Powdered activated carbon will be delivered to the site by truck and stored in a carbon storage silo. Conveyance blowers will deliver the carbon from the carbon storage silo to the exhaust gas stream feed point ahead of the fabric filter. Preliminary equipment information for the carbon system is listed in Table 2-29. Table 2-29. Carbon System Design Criteria Equipment Units Specifications Carbon System Number of carbon storage silos No. 1 Type and Size Vertical with conical base Volume1 Storage Option L-1-B2 Options L-2&3-B cf days 500 40 30 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 50 Table 2-29. Carbon System Design Criteria Equipment Units Specifications Size Diameter ft 12 Total Height3 ft 42 Number of carbon volumetric feeders No. 2 Feed rate Option L-1-B Options 2&3-B pph 13 18 Number of carbon conveyance blowers 2 Flow (each) scfm 50 1 Carbon storage based on FBI incinerator capacity (70 dtpd). 2 Storage capacity calculated based on AA conditions for Option 1 (51.1dtpd). 3 Silo height includes clearances for transport and dust collection equipment. q. Fabric Filters – L-1-B and L-2&3-B The carbon solids will form a layer on the surface of the fabric filter bags, which will act as a mercury adsorption layer. Periodic, automatic filter cleaning will be performed using compressed air. The mercury-laden carbon and other particulate matter will be collected at the bottom of each fabric filter as dry ash. The dry ash will be collected by a screw conveyor at the base of the fabric filter and pneumatically conveyed to ash storage silos. Preliminary equipment information for the fabric filters is listed in Table 2-30. Table 2-30. Fabric Filter System Design Criteria Equipment Units Specifications Carbon System Number of fabric filters No. 2 Type Multi-Chamber BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 51 Table 2-30. Fabric Filter System Design Criteria Equipment Units Specifications Dimensions Length Width Height ft 40 12 55 Exhaust Flow Temperature Volume1 Option L-1-B Options L-2&3-B oF acfm acfm 350 max 33,000 25,000 No. of ash collection screw conveyors No. 2 Length ft 30 Capacity 2 Option L-1-B Options L-2&3-B lb/min 5 50 Motor Option L-1-B Options L-2&3-B hp 5 15 1 Fabric filter exhaust flow rate capacity based on incinerator capacity at high volatile (70% VS) conditions. 2 Ash conveyor capacity rate based on incinerator capacity and low volatile (50% VS) condition. r. Dry Ash System – L-1-B and L-2&3-B For Option L-1-B, the dry ash collected at the fabric filters will be transported to the existing ash slurry system used to process the incinerator bottom ash. For Options L-2&3-B, the dry ash collected at the fabric filters will be transported to a dry ash storage silo to be hauled off site for disposal. The dry ash system will be of the dense phase pneumatic conveyance type consisting of an ash surge hopper, a pneumatic transporter, compressors and conveyance piping. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 52 Preliminary equipment information for the dry ash system is listed in Table 2-31. Table 2-31. Dry Ash System Design Criteria Equipment Units Specifications Dry Ash System Number of surge hoppers1 No. 2 Type Dry ash surge hopper capacity Option L-1-B Options L-2&3-B cf cf Vertical with Conical Base 1 5 Number of pneumatic transporters1 No. 2 Type Air flow Option L-1-B Options L-2&3-B Operating pressure scfm scfm psig Dense Phase, Conical Base 20 60 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Option L-1-B Options L-2&3-B Compressor motor Option L-1-B Options L-2&3-B scfm scfm hp hp Scroll or Screw Type 50 75 15 20 Number of storage silos (Options L-2&3 only)2 No. 2 Type Vertical with Conical Base Volume3 Storage (AA Conditions) cy days 260 5 Dimensions Diameter Total Height4 ft 20 60 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 53 1 Ash surge hopper and transporter vessel located under each fabric filter ash conveyor. Transport system based on incinerator capacity and low volatile (50% VS) condition. 2 For Option L-1-B, the ash collected at the fabric filters will be transported to the existing ash slurry system. 3 Ash storage based on low volatile (50% VS) and AA solids feed rate conditions and 5 day operation. 4 Silo height includes clearances for nozzle, ash unloading equipment and truck. s. Induced Draft Fans – L-1-B and L-2&3-B ID fans will provide additional energy to convey exhaust gases through the advanced emission control and wet scrubber and discharge to the stack. Preliminary equipment information for the ID Fan is listed in Table 2-32. Table 2-32. Induced Draft Fan Design Criteria Equipment Units Specifications ID Fan Number of Units Option L-1-B Options L-2&3-B No. 3 (2 Duty, 1 Standby) 2 (1 Duty, Standby) Type Single-Stage Centrifugal, Direct Drive Inlet Gas Temperature oF 90-130 Air Flow1 Option L-1-B Options L-2&3-B scfm 23,000 20,000 Flow Adjustment Variable Frequency Drive Pressure Rise Option L-1-B Options L-2&3-B in w.c. 55 40 Motor Option L-1-B Options L-2&3-B hp 350 200 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 54 Table 2-32. Induced Draft Fan Design Criteria Equipment Units Specifications Special Construction/Materials 316 SS wheels and shafts 1 Fan capacity based on incinerator capacity and high volatile (70% VS) condition. (1) Alternative L-1 – Layout Plans Refer to Figures C-1 through C-4 in Appendix C for preliminary layouts for the new WHBs and wet scrubbers systems. (2) Alternatives L-2 and L-3 Layout Plans Refer to Figures C-5 through C-8 in Appendix C for preliminary layouts for the new FBIs, wet scrubbers and auxiliary systems. 5. Site Plan Refer to Figure A-1 in Appendix A for a preliminary site plan showing the proposed location of the new Solids Processing Building. 6. Staffing Requirements Table 2-33 lists the anticipated staffing requirements for each of the proposed alternatives. Table 2-33. Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Alternative L-1 (Base Case) – Re-use of MHI and BFPs Supervisor 1 8 3 7 52 8,736 Operator 3 8 3 7 52 26,208 Maintenance 3 8 2 5 52 12,480 Alternative L-2 (Base Case) – New FBIs and Re-use BFPs Supervisor 1 8 3 7 52 2,912 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 55 Table 2-33. Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Operator 3 8 3 7 52 26,208 Maintenance 2.5 8 2 5 52 10,400 Alternative L-3 (Base Case) – New FBIs and Centrifuges Supervisor 1 8 3 7 52 8,736 Operator 3 8 3 7 52 26,208 Maintenance 2.5 8 2 5 52 10,400 Option L-1-A and L-2&3-A – Power Generation Operator --- --- --- --- --- --- Maintenance 0.5 8 1 5 52 1,040 Stationary1 Engineer 1 8 3 7 52 8,736 Option L-1-B and L-2&3-B – Future Air Pollution Control Operator 0.5 8 3 7 52 4,368 Maintenance 1 8 1 5 52 2,080 1 Licensed steam boiler engineer/operator. 7. Cost Summary Table 2-34 presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were determined based on the descriptions of alternatives and options presented here. These costs and benefits were developed and presented in Technical Memorandum No.9 Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 56 Table 2-34. Opinions of Costs, Savings and Life Cycle Costs ($1000) Alternative L-1 MHI+BFP L-2 FBI +BFP L-3 FBI + CFG L-1-A MHI + Power L-1-B MHI + AEC L-2&3-A FBI + Power L-2&3-B FBI + AEC Capital Costs Salvage Value $22,911 ($0) $96,098 ($1,632) $121,211 ($2,622) $29,036 ($494) $30,535 ($1,237) $24,223 ($494) $23,642 ($994) Annual O&M Costs $4,176 $4,320 $4,913 $648 $339 $565 $295 Annual Revenue ($0) ($0) ($0) ($180) ($0) ($182) ($0) Present Worth Costs Capital Salvage $22,911 ($0) $96,098 ($615) $121,211 ($988) $29,036 ($186) $30,535 ($466) $24,223 ($186) $23,642 ($375) O&M $52,045 $53,833 $61,229 $8,076 $4,223 $7,041 $3,674 Revenue ($0) ($0) ($0) ($2,245) ($0) ($2,268) ($0) Total Present Worth Costs $74,956 $149,315 $181,452 $34,681 $34,292 $28,810 $26,941 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 57 Appendix A Site Plan BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 58 Appendix B Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lemay WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 59 Appendix C Layout Plans: Existing MHI and New Solids Processing Building BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 1 TECHNICAL MEMORANDUM NO. 3 - COLDWATER WWTP SOLIDS PROCESSING ALTERNATIVES EVALUATION To: Metropolitan St. Louis Sewer District From: Bently Green, Alan Christanell, Yinan Qi, Hari Santha This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Coldwater Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. The following sections describe the existing solids processing facilities, the solids quantities used as the basis for the evaluation, and solids treatment and final use options evaluated for the Coldwater WWTP. An economic evaluation of the solids processing alternatives as well as an analysis of greenhouse gas (GHG) emissions associated with each alternative will be included in future memos. Table of Contents 1. Existing Plant Information ..........................................................................................................2 2. Solids Quantities .........................................................................................................................5 3. Solids Processing Alternatives ....................................................................................................8 a. Alternative C-1 – Continuation of Existing Solids Management Scheme ..........................8 b. Alternative C-2 – Landfilling of Raw Dewatered Solids .....................................................8 c. Alternative C-3 – Anaerobic Digestion ...............................................................................9 d. Technologies for Solids Processing Alternatives ..............................................................11 (1) Solids Thickening ................................................................................................... 12 e. Solids Stabilization ............................................................................................................14 f. Solids Dewatering ..............................................................................................................17 g. Cake Storage and Loadout .................................................................................................21 h. Energy Recovery ................................................................................................................23 (1) Digester Gas Utilization Technologies ................................................................... 24 (a) Engine-Generators .................................................................................................. 25 (b) Microturbines .......................................................................................................... 26 (2) Digester Gas Cleaning Requirements ..................................................................... 27 (3) Exhaust Emissions .................................................................................................. 29 i. Solids Final Use and Disposal ...........................................................................................30 4. Staffing Requirements ..............................................................................................................30 5. Cost Summary ...........................................................................................................................31 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 2 1. Existing Plant Information The Coldwater WWTP was commissioned in 1965 with a permitted design flow of 40 mgd. Recent improvements at the plant have increased the peak secondary treatment capacity to 55 mgd and the primary treatment capacity to 135 mgd. A site plan of Coldwater WWTP is shown on Figure 3-1. The WWTP generates primary solids (PS) and waste activated solids (WAS), which are thickened in separate gravity thickeners. The thickened PS (TPS) and thickened WAS (TWAS) are combined and pumped to the Bissell Point Service Area collection system for incineration at the Bissell Point WWTP. Prior to December 2008, the thickened solids were anaerobically digested onsite and the digester gas was used as fuel in boilers to generate hot water for process and building heating and in engines that were used to drive the influent pumps and the aeration blowers. The anaerobic digesters were removed from service in 2008 once the new interceptor sewer was in place and the pumps and blowers that were driven by the digester-gas fired engines were rendered obsolete by the secondary capacity expansion. Currently, two of the tanks are used for emergency storage of thickened solids downstream from the thickeners. The existing solids processing facilities at the Coldwater WWTP are presented in Figure 3-1. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 3 Figure 3-1: Existing Solids Processing Facilities at the Coldwater WWTP The specifications of the existing solids processing facilities at the WWTP are summarized in Table 3-1. Table 3-1. Rated Capacities of Existing Solids Processing Facilities Equipment Units Capacity Primary Sludge Thickening Gravity Thickener Number of Gravity Thickeners No. 1 Diameter of Gravity Thickeners ft 45 Approximate Side Water Depth ft 10 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 4 Table 3-1. Rated Capacities of Existing Solids Processing Facilities Equipment Units Capacity Surface Area per Unit sf 1,590 Waste Activated Sludge Thickening Gravity Thickeners Number of Gravity Thickeners No. 1 Diameter of Gravity Thickeners ft 65 Approximate Side Water Depth ft 10 Surface Area per Unit sf 3,317 Anaerobic Digestion (Not In Use) Number of Digesters 6 Volume per Digester MG 1.1 Total Volume MG 6.6 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 5 Pictures of the existing solids processing facilities are shown in Figure 3-2. PS Thickener WAS Thickener Anaerobic Digesters Sludge Transfer Pumps to Bissell Figure 3-2: Existing Solids Processing Facilities at the Coldwater WWTP 2. Solids Quantities The Coldwater WWTP serves a mature watershed with little flow increase expected in the future. The solids quantities for this evaluation were carried forward from Phase I – TM 2: Facility Summaries and Solids Projections and are summarized in Table 3-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 6 Table 3-2. Solids Quantities Flow Condition Total Solids (dtpd) Volatile Solids (dtpd) Total Solids in Digested (dtpd) Volatile Solids in Digested (dtpd) Current Conditions Maximum Month 18.5 15.0 13.9 8.5 Annual Average 14.1 11.0 10.5 6.2 Design Conditions Maximum Month 18.5 15.0 -- -- Annual Average 14.1 11.0 -- -- The design solids quantities are identical to current conditions since no flow increase is expected in the future. Historical information on PS and WAS quantities and characteristics were not available. Consequently, the PS and WAS quantities were based on estimated generation ratios. Performance estimates were based on typical values and vendor recommendations. The assumptions used in developing the solids quantities for process evaluations are summarized below.  A 50:50 blend of PS and WAS on a dry weight basis.  The volatile solids concentrations in PS and WAS were adjusted to match the combined volatile solids concentrations of 81 percent at maximum month conditions and 78 percent at average conditions (Table 3-2).  PS concentration of 1 percent from the primary clarifiers and WAS concentration of 0.5 percent from the final clarifiers.  Solids capture efficiencies of 90 percent in gravity thickeners and 95 percent in rotary drum thickeners.  Thickened PS concentration of 4 percent from gravity thickeners.  Thickened WAS concentration of 3 percent from gravity thickeners and 5 percent from rotary drum thickeners. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 7  Volatile solids reduction of 45 percent in anaerobic digesters. Digester gas production estimates were based on a biogas yield of 15 standard cubic feet per pound (scf/lb) of volatile solids destroyed. The energy computations were based on heating values of 600 British thermal units per standard cubic foot (Btu/scf) for digester gas.  Solids capture efficiency of 92 percent in dewatering units.  Dewatered cake solids concentration of raw solids: 23 percent from belt filter presses, 26 percent from centrifuges, and 26 percent from rotary presses.  Dewatered cake solids concentration of digested solids: 17 percent from belt filter presses, 20 percent from centrifuges, and 20 percent from rotary presses. The PS and WAS quantities based on the assumptions listed above are summarized in Table 3-3. The future maximum month solids quantities were used for equipment sizing and the mid-point (10-year) annual average solids production was used for estimation of operation and maintenance (O&M) costs. The mid-point average solids quantities are identical to the design annual average solids production. Table 3-3. Projected Solids Quantities Parameter Units Max. Month Ann. Average Total Solids Total Solids dtpd 18.5 14.1 Volatile Solids dtpd 15.0 11.0 Volatile Solids Fraction % of TS 81 78 Primary Sludge Total Solids dtpd 9.3 7.1 Volatile Solids Fraction % of TS 84 81 Volatile Solids dtpd 7.8 5.7 Solids Concentration % 1 1 Flow gpd 221,800 169,100 Waste Activated Sludge BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 8 Table 3-3. Projected Solids Quantities Parameter Units Max. Month Ann. Average Total Solids dtpd 9.3 7.1 Volatile Solids Fraction % of TS 78 75 Volatile Solids dtpd 7.2 5.3 Solids Concentration % 0.5 0.5 Flow gpd 443,600 338,100 3. Solids Processing Alternatives Based on discussions with the District staff, and information gathered during site visits to the Coldwater WWTP, three alternatives were developed for processing and management of solids generated at the WWTP. Descriptions of the alternatives are presented in the following sections. Appendix A contains Process Flow Diagrams for these alternatives. a. Alternative C-1 – Continuation of Existing Solids Management Scheme This alternative is the base-case scenario and continues the current practice of pumping thickened raw solids to the Bissell watershed for processing at the Bissell Point WWTP. With minimum growth expected in the Coldwater watershed, the existing solids handling and processing facilities at the WWTP have adequate capacity to handle the future solids production. This alternative will require minimum modifications to the existing facilities except for replacement of equipment that reaches the end of its useful life during the planning period. This alternative will be developed based on rehabilitating the existing force main and providing a new pump station and force main for solids transfer. b. Alternative C-2 – Landfilling of Raw Dewatered Solids Alternative 2 involves landfilling dewatered raw solids. The current practice of thickening PS and WAS in gravity thickeners will be continued. The thickened solids will be combined and dewatered using new mechanical dewatering units. The dewatering technologies evaluated for this alternative will include belt filter presses (BFP), centrifuges, and rotary presses. The BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 9 dewatering equipment will be located in a new building. Dewatered cake will be hauled to a landfill for disposal. Schematic of this solids handling alternative is shown on Figure 3-3. Figure 3-3: Schematics of Solids Handling Processes Alternative C-2 c. Alternative C-3 – Anaerobic Digestion Under Alternative C-3, PS will continue to be thickened using the existing gravity thickener. New rotary drum thickeners (RDTs) will be used to thicken WAS. The thickened PS and WAS will be combined and pumped to existing anaerobic digesters, improved as part of this alternative, for stabilization. The stabilized solids will be dewatered using new mechanical dewatering units. The end-use/disposal options under this alternative will include landfilling, land application, or third-party composting of the stabilized solids. Digester gas generated during the anaerobic digestion process will be cleaned to remove contaminants and used onsite for cogeneration. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 10 The RDTs and the dewatering equipment will be located in a new building. The existing anaerobic digesters will be rehabilitated for solids stabilization. The existing digester control building will house digestion equipment, including pumps, heat exchangers, mixing equipment, boilers, and the digester gas handling equipment. The gas cleaning system will be located adjacent to the digester control building. The cleaned gas will be piped to the combined heat and power (CHP) equipment, which will be located in the building currently occupied by the old engines. A schematic of this solids processing alternative is shown on Figure 3-4. Figure 3-4: Schematics of Solids Handling Processes Alternative C-3 A summary of the new and existing equipment being evaluated for each alternative is presented in Table 3-4. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 11 Table 3-4. Solids Processing Alternatives Equipment C-1 Continuation of Current C-2 Landfill of Raw Sludge C-3 Anaerobic Digestion Solids Thickening Gravity Thickener (PS) E E E Gravity Thickener (WAS) E E -- Rotary Drum Thickeners (WAS) -- -- N Solids Transfer to Bissell Pump station and Force Main N -- -- Solids Stabilization Anaerobic Digestion -- -- N Solids Dewatering BFPs/Centrifuges/Rotary Presses -- O O Cake Storage and Loadout Conveyors/Cake Pumps -- N N Cake Storage Silos/Loadout -- N N Energy Recovery Digester Gas Cleaning -- -- N Cogeneration -- -- N Legend: E = Existing system will be evaluated and modifications/upgrades recommended N = Implementation of a new system will be evaluated O = Options being evaluated d. Technologies for Solids Processing Alternatives The solids processing technologies considered to support the three alternatives are reviewed in the following sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 12 (1) Solids Th ickening Alternative C-1 and Alternative C-2 - Existing Gravity Thickeners for PS and WAS Alternative C-1 and Alternative C-2 will use the existing gravity thickeners for PS and WAS thickening. Since the design solids quantities are same as the current solids production, no additional thickening capacity will be required. However, based on the expected life of the existing equipment, the thickening equipment may need to be replaced or overhauled during the evaluation period. The estimated solids and hydraulic loading rates to the gravity thickeners at design conditions are shown in Table 3-5. Table 3-5. Design Criteria of Gravity Thickeners Equipment Units Max. Month Ann. Average Primary Sludge Thickening Number of Gravity Thickeners No. 1 Total Surface Area sf 1,590 Primary Sludge Total Solids ppd 18,500 14,100 Flow gpd 221,800 169,100 Hydraulic Loading Rate gpd/sf 140 106 Solids Loading Rate ppd/sf 12 9 Recommended Maximum Hydraulic Loading Rate1 gpd/sf 600-800 Recommended Maximum Solids Loading Rate1 ppd/sf 20 - 30 Waste Activated Sludge Thickening Number of Gravity Thickeners No. 1 Total Surface Area sf 3,317 Waste Activated Sludge Total Solids ppd 18,500 14,100 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 13 Table 3-5. Design Criteria of Gravity Thickeners Equipment Units Max. Month Ann. Average Flow gpd 443,600 338,100 Hydraulic Loading Rate gpd/sf 134 102 Solids Loading Rate ppd/sf 5.6 4.2 Recommended Maximum Solids Loading Rate1 ppd/sf 2.4 – 7.2 Recommended Maximum Hydraulic Loading Rate1 gpd/sf 100 - 200 1 Black & Veatch recommendation Alternative C-3 - Existing Gravity Thickener for PS and RDTs for WAS The existing primary sludge thickener will continue to be used for PS thickening. Based on the age of the existing equipment, the thickening equipment may need to be replaced or overhauled during the evaluation period. The solids and hydraulic loading rates to the gravity thickener at design conditions are identical to those shown in Table 3-5 for PS thickening. Alternative C-3 will involve mechanical thickening of WAS using new RDTs. The preliminary design criteria for the RDTs are listed in Table 3-6. Table 3-6. RDT Design Criteria Equipment Units Max. Month Ann. Average Waste Activated Sludge Total Solids ppd 18,500 14,100 Flow gpd 443,600 338,100 Rotary Drum Thickeners Number of Units No. 2 ( 1 duty, 1 standby) Operation Schedule h/d/wk 24/7/52 Required HLR gpm/unit 308 235 Required SLR pph/unit 771 588 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 14 Table 3-6. RDT Design Criteria Equipment Units Max. Month Ann. Average Solids Capture Rate % 95 Thickened Solids % 5 Polymer Use (active) lb/dt solids 5 -10 The building layout for RDT thickening is shown on Figure 3-6. e. Solids Stabilization Solids stabilization was evaluated only for Alternative C-3. Alternative C-3 – Anaerobic Digestion Implementing mesophilic digestion at the Coldwater WWTP will require rehabilitation of the existing digesters. The anaerobic digesters will be operated as a two-stage system. Two of the six existing digesters will operate as primary digesters followed by two secondary units. The two remaining units will be used for digested sludge storage. The conceptual design criteria for the digestion facilities are summarized in Table 3-7. Table 3-7. Anaerobic Digester Design Criteria Equipment Units Specifications Primary Digesters Number of Units No. 2 (Existing) Volume per Digester MG 1.1 Diameter ft 90 SRT Maximum Month days 24 Annual Average days 31 Cover Fixed Steel Mixing Pumped Secondary Digesters Number of Units No. 2 (Existing) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 15 Table 3-7. Anaerobic Digester Design Criteria Equipment Units Specifications Volume per Digester MG 1.1 Diameter, ft ft 90 SRT Maximum Month days 24 Annual Average days 31 Cover Membrane Gas Holder Approximate Gas Storage cf 165,000 Mixing Pumped The existing concrete covers on the primary digesters will be replaced with fixed steel covers. The existing concrete covers are over 40 years old and from our experience with similar construction at other plants, concrete and the reinforcing steel are susceptible to deterioration by acidic constituents of the digester gas. The new fixed steel covers will be insulated to minimize transmission losses. The secondary digesters will be equipped with membrane gas-holder covers to provide gas storage and to ensure equalization of gas pressures for effective gas utilization. Membrane covers will also allow the liquid level to vary over nearly the entire depth of the tank. All the digesters will be mixed continuously to reduce stratification of material and minimize scum layer formation. All the digesters will be equipped with pumped mixing systems. Pumped mixing consists of pumps, suction and discharge piping, and nozzles at the end of the discharge piping. The pumps are installed outside of the digester to facilitate maintenance and are typically “chopper” style pumps or incorporate in-line grinders, to break down solids and prevent clogging. The piping can be configured so that the pumps withdraw sludge from the digester at the top, bottom, or both. Mixing is promoted by discharging recycled sludge through nozzles mounted on the tank’s interior perimeter and aimed tangentially to the tank diameter. The high velocity nozzles can create helical or dual-zone mixing patterns depending on the manufacturer. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 16 Nozzles will also be provided at the top of the tank to break up scum formation on the digester liquid surface. The digesters will be heated using a sludge recirculation external heating system. The raw sludge will be uniformly distributed between the primary digesters, which will be heated by means of a sludge recirculation loop, including pumps and external heat exchangers. A heating water system will provide the heat source to the external heat exchangers. The secondary digesters will also be equipped with external heat exchangers, pumps, and recirculation loops for heating so that they can function as primary digesters if needed. The digester gas from the digesters will be collected through a common header and stored in the membrane gas holder covers on the secondary digesters. The gas can be used in a boiler for meeting process and building heating needs or for cogeneration. Depending on the end-use option, the digester gas may require removal of water vapor, hydrogen sulfide and siloxanes. The anticipated performance of the anaerobic digestion system is summarized in Table 3-8. The layout of the existing digester complex is shown in Figure 3-7. The digestion complex will be upgraded as needed for conformance with the current requirements of NFPA 820, Standard for Fire Protection in Wastewater Treatment and Collection Facilities. Table 3-8. Anaerobic Digester Performance Parameter Units Max. Month Ann. Average Digester Feed Total Feed Solids ppd 34,200 26,100 Feed Solids Concentration % 4.5 4.5 Feed Flow gpd 92,100 70,200 Volatile Solids in Feed ppd 27,700 20,300 Organic Loading Rate ppd/1000 cf 94 69 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 17 Table 3-8. Anaerobic Digester Performance Parameter Units Max. Month Ann. Average Performance Parameters Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas and Energy Digester Gas Production scfd 186,900 137,200 Heating Value of Digester Gas Btu/scf 600 600 Gross Energy from Digester Gas mmBtu/d 112 82 Stabilized Solids Total Stabilized Solids ppd 21,800 16,900 Solids Concentration % 2.8 2.9 f. Solids Dewatering Alternative C-2 and Alternative C-3 include solids dewatering prior to final use or disposal. Alternative C-2 Two of the abandoned digesters will be rehabilitated to storage tanks for thickened primary sludge and TWAS. TPS and TWAS will be stored separately to prevent anaerobic digestion during the storage. Sludge storage tanks will only be used during the weekend when the dewatering equipment is not operating. TPS and TWAS streams will be blended in a new wet well upstream from the dewatering units. The dewatering technologies evaluated for Alternative C-2 include BFPs, centrifuges, and rotary presses. The preliminary design criteria for the dewatering equipment for this alternative are listed in Table 3-9. The layout of a Dewatering BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 18 Building with BFPs is shown in Figure 3-8 and with rotary presses in Figure 3-9. The location of the Dewatering Building is shown in Figure 3-10. Table 3-8. Design Criteria for Dewatering Equipment (Alternative C-2) Parameter Units Max. Month Ann. Average Thickened Raw Solids (5-day Basis) Feed Solids ppd 46,600 35,500 Feed Solids Concentration % 3.4 3.4 Feed Flow gpd 163,100 124,300 Operation Schedule hr/d/wk 24/5/52 Required HLR gpm 113 86 Required SLR pph 1,940 1,480 Belt Filter Presses Number of Units No. 2 ( 1 duty, 1 standby) Belt Width m 2 HLR gpm/m 57 43 SLR pph/m 970 740 Thickened Solids % 23 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 10 - 15 Centrifuges Number of Units No. 2 ( 1 duty, 1 standby) Approximate Diameter in. 18 HLR gpm/unit 113 86 SLR pph/unit 1,940 1,480 Thickened Solids % 26 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 15 - 25 Rotary Presses BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 19 Table 3-8. Design Criteria for Dewatering Equipment (Alternative C-2) Parameter Units Max. Month Ann. Average Number of Units No. 2 ( 1 duty, 1 standby) Number of Channels per Unit No. 6 HLR per Channel gpm 19 14 SLR per Channel pph 323 247 Thickened Solids % 26 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 15 - 25 Alternative C-3 The dewatering units will receive stabilized solids from the secondary digesters. The new digested sludge storage wetwell will function as feed wells for the dewatering units. Dewatering technologies evaluated for Alternative C-3 include belt filter presses (BFP), centrifuges, and rotary presses. The preliminary design criteria for the dewatering equipment for this alternative are listed in Table 3-10. The layout of a Dewatering Building with BFPs is shown in Figure 3-8 and with rotary presses in Figure 3-9. The location of the Dewatering Building is shown in Figure 3-10. Table 3-9. Design Criteria for Dewatering Equipment (Alternative C-3) Parameter Units Max. Month Ann. Average Digested Solids (5-day Basis) Feed Solids ppd 28,500 22,300 Feed Solids Concentration % 2.7 2.7 Feed Flow gpd 128,900 98,200 Operation Schedule hr/d/wk 24/5/52 Required HLR gpm 89 68 Required SLR pph 1,190 930 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 20 Table 3-9. Design Criteria for Dewatering Equipment (Alternative C-3) Parameter Units Max. Month Ann. Average Belt Filter Presses Number of Units No. 2 ( 1 duty, 1 standby) Belt Width m 2 HLR gpm/m 45 34 SLR pph/m 595 465 Thickened Solids % 17 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 10 - 15 Centrifuges Number of Units No. 2 ( 1 duty, 1 standby) Approximate Diameter in. 18 HLR gpm/unit 89 68 SLR pph/unit 1,190 930 Thickened Solids % 20 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 15 - 25 Rotary Presses Number of Units No. 2 ( 1 duty, 1 standby) Number of Channels per Unit No. 5 HLR per Channel gpm 18 14 SLR per Channel pph 240 190 Thickened Solids % 20 Solids Capture Rate % 98 Polymer Use (active) lb/dt solids 15 - 25 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 21 g. Cake Storage and Loadout Storage silos will be provided for dewatered cake storage for Alternative C-2 and Alternative C- 3, both of which involve cake hauling to end-use or disposal sites. For purposes of this evaluation, cake storage requirements were based on 8 hours per day, 5 days per week hauling to the landfill or the end-use sites. The solids from the dewatering units will be conveyed to one of the two storage silos using cake pumps. Each silo will provide four days of storage at future maximum month solids production. Storage silos will be equipped with sliding frame-type live bottoms, which will discharge solids to trucks for hauling. The cake storage silos and the loadout facilities will be vented to odor control scrubbers. Since there is a potential for high odors with unstabilized solids, the silos will be equipped with recirculation pumps for moving the stored material to prevent anaerobic conditions and consequent hydrogen sulfide buildup. Preliminary design criteria for cake conveyance and storage for dewatering Alternative C-2 is listed in Table 3-11 below. Table 3-10. Design Criteria for Cake Conveyance and Storage (Alternative C-2) Parameter Units BFPs Centrifuges/Rotary Presses Max. Month Ann. Average Max. Month Ann. Average Dewatered Raw Solids (5-day Basis) Total Solids ppd 45,700 34,800 45,700 34,800 Solids Concentration % 23 23 26 26 Density of Solids lb/cf 55 55 55 55 Volume of Solids cfd 3,600 2,800 3,200 2,400 Dewatered Cake Conveyor Conveyor Type Shafted Screw Shafted Screw Required Capacity cfh 150 115 135 100 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 22 Table 3-10. Design Criteria for Cake Conveyance and Storage (Alternative C-2) Parameter Units BFPs Centrifuges/Rotary Presses Max. Month Ann. Average Max. Month Ann. Average Dewatered Cake Pumps Number of Units No. 3 (2 Duty, 1 Standby) 3 (2 Duty, 1 Standby) Pump Type Hydraulic Piston Hydraulic Piston Required Flow (each) gpm 8 6 7 5 Storage Silos Solids (7-day Basis) cfd 2,600 2,000 2,300 1,700 Number of Units No. 2 2 Type Sliding frame/live bottom Sliding frame/live bottom Volume (each) cy 190 170 Storage days 4.0 5.1 4.0 5.4 Preliminary design criteria for cake conveyance and storage for dewatering Alternative C-3 is listed in Table 3-12 below. Table 3-11. Design Criteria for Cake Conveyance and Storage (Alternative C-3) Parameter Units BFPs Centrifuges/Rotary Presses Max. Month Ann. Average Max. Month Ann. Average Dewatered Stabilized Solids (5-day Basis) Total Solids ppd 28,000 21,900 28,000 21,900 Solids Concentration % 17 17 20 20 Density of Solids lb/cf 55 55 55 55 Volume of Solids cfd 3,000 2,300 2,500 2,000 Dewatered Cake Conveyor BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 23 Table 3-11. Design Criteria for Cake Conveyance and Storage (Alternative C-3) Parameter Units BFPs Centrifuges/Rotary Presses Max. Month Ann. Average Max. Month Ann. Average Conveyor Type Shafted Screw Shafted Screw Required Capacity cfh 125 98 106 83 Dewatered Cake Pumps Number of Units No. 3 (2 Duty, 1 Standby) 3 (2 Duty, 1 Standby) Pump Type Hydraulic Piston Hydraulic Piston Required Flow (each) gpm 7 6 6 5 Storage Silos Solids (7-day Basis) cfd 2,100 1,700 1,800 1,400 Number of Units No. 2 2 Type Sliding frame/live bottom Sliding frame/live bottom Volume (each) cy 160 135 Storage days 4.0 5.1 4.0 5.2 h. Energy Recovery The digester gas production at design conditions was based on an estimated volatile solids concentration of 78 to 81 percent in the mixed solids and a volatile solids reduction of 45 percent in the digesters. Gas production was estimated using a biogas yield of 15 standard cubic feet per pound (scf/lb) of volatile solids destroyed. The energy computations were based on a heating value of 600 British thermal units per standard cubic foot (Btu/scf) of digester gas. The estimated digester gas quantities at design conditions are summarized in Table 3-13. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 24 Table 3-12. Anaerobic Digester Performance Parameter Units Max. Month Ann. Average Volatile Solids in Digester Feed ppd 27,700 20,300 Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas and Energy Digester Gas Production scfh 8,600 6,400 Methane Content % 60 60 Heating Value of Digester Gas Btu/scf 600 600 Gross Energy from Digester Gas mmBtu/h 5.2 3.8 Digester gas production at design average conditions was used for sizing the gas cleaning and cogeneration equipment. The excess gas flows during maximum month conditions will be flared without treatment. A new gas flare will be required at the plant. (1) Digester Gas Utilization Technologies Digester gas is a valuable resource that can be used to offset part of the energy requirements for wastewater treatment plant operations and energy recovery from digester gas is now regarded as one of the mature waste-to-energy technologies. Digester gas can be collected, stored, and converted to electricity using on-site power generation equipment. Additionally, heat can be recovered from the power generation units in the form of hot water or steam for use in heating digesters and for heating buildings. These types of equipment that can produce electricity and heat are called CHP (combined hear and power) or cogeneration systems and can have an overall gas utilization efficiency of up to 80 percent if all the recovered heat can be used. The available on-site power generation technology options vary with respect to size, fuel requirements, efficiency, costs, and their overall compatibility with the existing facilities. The options range from traditional engine-generators and gas turbine generators to recently developed microturbines and fuel cells. Internal combustion engines are by far the most BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 25 common generating technology choice. About 80 percent of the power generation facilities at WWTPs use reciprocating engines. Gas turbines have also been used for power generation, but are typically used at larger WWTPs. Microturbines, which are modular combustion turbines with capacities less than 250 kW, are being used more because of their low air emissions. Fuel cells have also gained interest, as a result of their extremely low air emissions. Based on the scale of operation, the CHP technology options for Coldwater are limited to engine-generators and microturbine generators. (a) Engine-Generators Engine-generators are the most commonly used means of on-site power generation at wastewater treatment plants, with unit capacities ranging from 130 kW to 2,000 kW. The equipment typically consists of a skid-mounted package of a reciprocating engine, generator and a control panel. The popularity of engine-generators is attributed to availability from multiple suppliers and familiarity of plant maintenance personnel with engines that resemble an automobile engine. The engine is a spark-ignited natural gas engine modified and de-rated for use with the low-Btu digester gas. Originally engines using digester gas as fuel were naturally aspirated, which produced low mechanical efficiencies and high emissions. Engine manufacturers have developed newer turbocharged, lean-burn engines which have higher efficiencies, lower air emissions, and operate at low gas pressures. Selective catalytic reduction (SCR) technology can be added to engine- generators to reduce NOx emissions. The engines typically operate at speeds up to 1,800 rpm. Heat can be recovered from the engine’s jacket water and from the exhaust gases. The recovered heat can be used to generate hot water for process and building heating requirements. Heat not recovered for useful purposes from the engine jacket water is removed in an engine cooling exchanger by circulating water from a cooling tower or by using a radiator to cool the jacket water to the required temperature. Engine-generators are typically housed in a building where they are accessible for servicing, but may also be installed outdoors in an acoustic enclosure. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 26 Digester gas should be treated to remove hydrogen sulfide (H2S) and siloxanes before use in engine-generators. The typical H2S and siloxane concentration limits recommended by engine manufacturers are listed in Table 3-16. Where the contaminants have been removed from digester gas, engine owners report maintenance efforts similar to those for an engine operating on natural gas; a substantial reduction in the frequency and cost of maintenance compared to units operating on untreated digester gas. The typical maintenance requirements for an engine-generator include monthly oil changes, top end overhauls every 2 years, and major engine rebuilds every 3 to 5 years. The estimated downtime is approximately 8 hours for oil changes, one month for top end overhauls, and two months for major rebuilds for a two-man crew. (b) Microturbines Microturbines are a relatively new technology for on-site power generation at wastewater plants, with the first commercial units installed in 1998. Combustion turbines have been operated with digester gas in the past, but the minimum capacity is approximately 1,000 kW. Microturbines are small combustion turbines, with capacities ranging from 30 to 250 kW. For increased capacities, multiple microturbines can be installed in parallel. They are available as modular packaged units that include the combustor, turbine, generator, cooling and heat recovery equipment. Microturbines are attractive for small plants, making on-site generation available to plants that formerly did not have this choice. Digester gas is compressed and burned with air in the combustor, generating heat that causes the gases to expand. The expanding gases drive the turbine, which in turn drives a generator producing electricity. Heat from the turbine exhaust is recovered in the recuperator and is used to preheat incoming combustion air. This helps improve the overall operating efficiency of the unit. Microturbines have lower efficiencies than engine-generators. The efficiencies are reduced further when operating at higher inlet temperatures. Microturbines produce minimal noise and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 27 have lower emissions when compared to engine-generators. The units may also be provided with an acoustic enclosure for further noise reduction. Microturbines require higher levels of gas treatment compared to engine-generators and inlet pressures ranging from 75 to 100 pounds per square inch (psi). The contaminant limits recommended by microturbine manufacturers are listed in Table 3-16. Table 3-14 presents a comparison of typical unit sizes, efficiencies, fuel consumption, heat recovery rates, and maintenance requirements for engine-generators, and microturbines. Table 3-13. Digester Gas Utilization Equipment Comparison Parameter Units Engine-Generators Microturbines Inlet Gas Pressure Required psig 1 to 5 75 to 100 Performance Efficiency Range % 25 to 40 25 to 30 Heat Recovery % 40 to 50 30 to 40 Overall Efficiency % 65 to 90 55 to 70 Typical Maintenance Top End Overhaul hr Every 16,000 -- Bottom End Overhaul hr Every 32,000 -- Lining and Fuel Injector Replacement hr -- Every 15,000 Turbine Replacement hr -- Every 30,000 Emissions NOx1 ppmv Approx. 65 ppmv Approx. 9 ppmv 1 Based on using natural gas as fuel (2) Digester Gas Cleaning Requirements Digester gas is composed primarily of methane (CH4) and carbon dioxide (CO2), but can also contain impurities such as hydrogen sulfide (H2S) and organic silicon compounds known as siloxanes. The gas is also saturated with moisture at the operating temperature of the digesters with more moisture present at higher operating temperatures. If left untreated, the moisture and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 28 contaminants will increase the maintenance requirements for the gas utilization equipment and reduce their useful life. Since digester gas sampling data was not available from the Coldwater WWTP, typical contaminant concentrations observed at other facilities were used as the basis for sizing the gas cleaning system. The digester gas quality used for cleaning system sizing is summarized in Table 3-15. Gas sampling, if it can be completed, is recommended prior to design to confirm the contaminant concentrations. Since digesters had been decommissioned at the Coldwater WWTP, gas sampling is not applicable. It is recommended gas analysis results from the MO River WWTP to be used as the design basis for the gas cleaning system at the Coldwater WWTP. Digester gas cleaning requirements are based on the end use of the gas and the type of gas utilization equipment. Based on the capacity requirements, only engine-generators and microturbine generators were identified for digester gas utilization at the Coldwater WWTP. Recommended gas quality requirements for these technologies were obtained from equipment suppliers and are listed in Table 3-16. Table 3-15. Gas Quality Requirements for Gas Utilization Equipment Contaminants Units Raw Gas Engine-Generators Microturbines Moisture -- Saturated at 95oF 40ºF dew point min. 18ºF dew point min. H2S ppmv 1,500 Less than 1,0001 Less than 5,0001 Siloxanes ppbv 3,000 Less than 4002 Less than 5 Table 3-14. Digester Gas Quality Equipment Units Max. Month Hydrogen Sulfide ppmv 1,500 mg/m3 2,130 Siloxanes ppbv 3,000 mg/m3 38 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 29 1 Less than 50 ppmv recommended for maintaining siloxane media performance 2 Engines without catalysts. Limit is 150 ppb for engines with catalysts The H2S concentrations listed above are the maximum values recommended by the equipment suppliers. However, the gas cleaning process is limited by the absorptive selectivity of the media used for siloxane removal. The siloxane removal media is generally limited to a maximum inlet H2S concentration of 50 ppmv. The maximum desired siloxanes concentration was established based on standards recommended by the engine suppliers for engines without catalytic converters. It is not expected, but if catalytic converters are required, a more rigorous gas treatment process may be required. The digester gas cleaning systems were sized to handle the design average gas flow of 148,500 scfd. The capacity requirements and costs of the gas treatment systems typically depend on several variables, including the quantity of gas treated, the initial concentration of contaminants, and the final concentration of contaminants in the gas to meet the quality requirements for the gas utilization equipment. The location of a Digester Gas Cleaning Building is shown on Figure 3-10. (3) Exhaust Emissions Any new digester gas utilization equipment will need to be permitted with the Missouri Department of Natural Resources as a new emission source. Nitrogen oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) are typically the main emission concerns with onsite power generation units. EPA’s 40CFR Part 60, Subpart JJJJ addresses standards of performance for stationary spark ignition internal combustion engines operating on digester gas or natural gas and the dates these limits will take effect. Table 3-17 outlines the proposed limits and the effective dates. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 30 Table 3-16. Emission Limits, pounds/brake horsepower-hr (lb/bhp-hr) Fuel NOx CO VOC Effective Date Digester Gas 2.0 5.0 1.0 Jan 1, 2011 Natural Gas 1.0 2.0 0.7 Jan 1, 2011 Additionally, EPA has regulations for facilities regarding the potential to emit, which are the total emissions if the equipment is operated continuously. The limits for NOx and VOC are set at 40 tons per year each and for CO at 100 tons per year. If these limits are exceeded for the facility, then permitting requirements for a major source facility will be required. i. Solids Final Use and Disposal Final use and disposal options of solids for the proposed solids processing alternatives are presented as follows. Alternative C-1 Alternative C-1 will continue the current solids disposal practice by pumping the thickened solids to the Bissell Point WWTP for further processing. Alternative C-2 Since no stabilization process is included in Alternative C-2, the dewatered raw sludge will be hauled and disposed to landfills. Alternative C-3 Alternative C-3 incorporates anaerobic digestion for sludge stabilization to produce Class B biosolids. Dewatered cake from Alternative C-3 can be disposed to landfills, hauled to a composting facility for composting, or beneficially used for land application. 4. Staffing Requirements Table 3-18 lists the anticipated staffing requirements for each of the alternatives. These staffing requirements are for the new biosolids processing facilities only and do not include the existing BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 31 processes. It is assumed that hauling and disposal of dewatered cake will be handled by a third- party contractor and will not require MSD staff. The staffing requirements for the different dewatering technology options are identical and therefore not listed separately. Table 3-17. Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Alternative C-1 – Continuation of Current Processes Supervisor 0 0 0 0 0 0 Operator 1 1 3.0 7 52 1,092 Maintenance 1 0.5 1.0 5 52 130 Alternative C-2 – Landfill of Raw Sludge Supervisor 1 2 1.0 5 52 520 Operator 1 4 3.0 5 52 3,120 Maintenance 1 4 1.0 5 52 1,040 Alternative C-3 – Anaerobic Digestion Operator 1 4 1.0 5 52 1,040 Maintenance 2 4.5 3.0 7 52 9,828 Stationary1 Engineer 1.5 8 1.0 5 52 3,120 5. Cost Summary Table 3-19 presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were developed based on the descriptions of alternatives and options presented in Section 3.0. Alternative C-2 and Alternative C-3 are based on using BFPs for dewatering. Detailed costs and benefits for each of these options are presented in Technical Memorandum No.9 - Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 32 Table 3-18. Opinions of Costs, Savings and Life Cycle Costs ($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Capital Costs $6,868 $17,233 ($1,026) ($1,611) $31,636 ($349) ($647) Salvage Value ($601) ($401) ($0) ($0) $584 $0 $0 Annual O&M Costs $117 $1,433 ($112) ($210) $2,081 ($123) ($139) Annual Revenue $0 $0 $0 $0 ($175) $0 $0 Present Worth Costs Capital Costs $6,868 $17,233 ($1,026) ($1,611) $31,636 ($349) ($647) Salvage Value ($227) ($151) $0 $0 $0 $0 O&M Costs $1,458 $17,858 ($1,396) ($2,617) $25,938 ($1,533) ($1,732) Revenue $0 $0 $0 $0 ($2,177) $0 $0 Total Present Worth Costs $8,100 $34,940 ($2,420) ($4,230) $55,180 ($1,880) ($2,380) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Coldwater WWTP Alternative Evaluation September 9, 2010 MSD Contract No. 2009145 33 Appendix A Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 1 TECHNICAL MEMORANDUM NO. 4 - MISSOURI RIVER WWTP SOLIDS PROCESSING ALTERNATIVE EVALUATION To: Metropolitan St. Louis Sewer District From: Yinan Qi, Hari Santha, Webster Hoener, Alan Christanell This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Missouri River Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. The following sections describe the existing solids processing facilities, the solids quantities used as the basis for the evaluation, and solids treatment and final use options evaluated for Missouri River WWTP. Table of Contents 1. Existing Plant Information ............................................................................................. 3 2. Solids Quantities ............................................................................................................ 6 3. Solids Processing Alternatives ....................................................................................... 8 a. Alternative M-1 – Continuation of Existing Solids Management Scheme.............. 8 b. Alternative M-2 – FOG Co-digestion ...................................................................... 8 c. Technologies for Solids Processing Alternatives .................................................. 10 1. Solids Thickening ........................................................................................... 11 d. Co-Digestion of FOG ............................................................................................. 12 1. Receiving Station ............................................................................................ 12 2. Storage ............................................................................................................ 15 3. Other Ancillary Equipment ............................................................................ 16 e. Solids Stabilization – Anaerobic Digestion ........................................................... 16 1. Solids Quantities ............................................................................................. 17 2. FOG Quantity ................................................................................................. 18 3. Anaerobic Digester ......................................................................................... 20 f. Digester Gas Utilization ......................................................................................... 22 1. Digester Gas Production ................................................................................. 22 2. Digester Gas Treatment System ..................................................................... 23 3. Combined Heat and Power (CHP) Technology Options ................................ 23 g. Solids Dewatering .................................................................................................. 26 h. Cake Storage and Loadout ..................................................................................... 27 i. Final Use ................................................................................................................ 28 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 2 1. Composting ..................................................................................................... 29 2. Landfill ........................................................................................................... 30 3. Land Application ............................................................................................ 30 4. Staffing Requirements ................................................................................................. 31 5. Cost Summary .............................................................................................................. 31 List of Tables Table 4-1 Rated Capacities of Existing and Planned Solids Processing Facilities ............. 4 Table 4-2 Summary of Solids Quantities ............................................................................ 7 Table 4-3 Solids Processing Alternatives ........................................................................... 9 Table 4-4 RDT Design Criteria......................................................................................... 11 Table 4-5 Summary of Solids Quantities .......................................................................... 17 Table 4-6 FOG Quantities ................................................................................................. 18 Table 4-7 Solids and FOG Quantities ............................................................................... 19 Table 4-8 Anaerobic Digestion Facilities ......................................................................... 21 Table 4-9 Digester Gas Production with FOG .................................................................. 22 Table 4-10 Digester Gas Utilization Equipment Comparison .......................................... 24 Table 4-11 Potential Energy Generation and Heat Recovery ........................................... 25 Table 4-12 Design Criteria for Dewatering Equipment .................................................... 27 Table 4-13 Design Criteria for Cake Conveyance and Storage ........................................ 28 Table 4-14 Design Criteria for Final Use Solids .............................................................. 29 Table 4-15 Staffing Requirements .................................................................................... 31 Table 4-16 Opinions of Costs, Savings and Life Cycle Costs ($1000) ............................ 32 List of Figures Figure 4-1: Existing Solids Processing Facilities at the Missouri River WWTP ............... 4 Figure 4-2: Existing Solids Processing Facilities at the Missouri River WWTP ............... 6 Figure 4-3 Facilities for Co-Digestion of FOG................................................................... 9 Figure 4-4 Thickening/Dewatering Storage Layout. ........................................................ 11 Figure 4-5 FOG Receiving Facility with Rock Traps ....................................................... 13 Figure 4-6 Scum / Grease Concentrator ............................................................................ 14 Figure 4-7 Digestion Facilities.......................................................................................... 21 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 3 1. Existing Plant Information The Missouri River WWTP was commissioned in 1989 and has a permitted design flow of 28 mgd. The plant has recently undergone improvements to increase its wet weather capacity. With the completion of the wet weather expansion, the fine screens and grit removal facilities are sized to handle a peak flow of 190 mgd. Primary treatment (including pre-aeration basins and primary clarifiers) has been sized to handle 80 mgd. Wet weather storage basins will capture all flows greater than 80 mgd. The secondary treatment facilities will also be expanded to handle 80 mgd and include replacement of the trickling filters with an activated sludge treatment process. This design is ongoing with construction expected to start in summer 2011. The new average day permitted design flow will be 38 mgd. A site plan of the Missouri River WWTP is shown in Appendix A on Figure A-1. Currently, the plant has a design sludge production of 7,556 dry tons per year. Significant changes to the solids processing will be completed within the next several years. The current practice of co-thickening secondary sludge in the primary clarifiers will be done away with. The secondary sludge will be thickened separately using rotary drum thickeners before combining with primary sludge for anaerobic digestion. The existing digesters will be rehabilitated and a new primary digester constructed. The existing belt filter presses will be replaced with three dewatering centrifuges. The dewatered biosolids are primarily disposed of at the Fred Weber Sanitary Landfill. A fraction of the solids is also hauled to the City of St. Peters composting facility for further treatment. Refer to Figure 4-1for an illustration of the major sludge components. This figure illustrates the solids processing facilities after implementation of the improvements to be completed as part of the Secondary Treatment Expansion and Disinfection Facilities project. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 4 Figure 4-1: Existing Solids Processing Facilities at the Missouri River WWTP The specifications of the existing and planned solids processing facilities at the WWTP are summarized in Table 4-1. Table 4-1 Rated Capacities of Existing and Planned Solids Processing Facilities Equipment Units Capacity Waste Activated Sludge Thickening Rotary Drum Thickener Number of Rotary Drum Thickeners No. 4 Capacity, each gpm 400 Anaerobic Digestion Number of Primary Digesters No. 4 Volume per Primary Digester MG 3 @ 0.86, BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 5 Table 4-1 Rated Capacities of Existing and Planned Solids Processing Facilities Equipment Units Capacity 1 @ 1.66 Total Primary Digester Volume Gal 4.24 Number of Secondary Digesters 1 Volume per Secondary Digester MG 0.86 Solids Dewatering Centrifuges Number of Centrifuges No. 3 Hydraulic Capacity, each gpm 250 Solids Capacity, each pph 3,500 Sludge Storage Number of Silos No. 2 Storage Volume, each cy 460 Pictures of the existing solids processing facilities are shown in Figure 4-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 6 Engine-Generator Anaerobic Digesters Digester Recirculation Pump Digester Heat Exchanger Figure 4-2: Existing Solids Processing Facilities at the Missouri River WWTP 2. Solids Quantities The primary solids (PS) and waste activated sludge (WAS) solids quantities used for this evaluation are summarized in Table 4-2. Current and Future (year 2030) solids quantities are based on the quantities listed in the July 2009 Design Memorandum for the Secondary Treatment Expansion and Disinfection Facilities project. Mid-point (year 2020) solids quantities were developed by averaging the current and future solids quantities. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 7 Table 4-2 Summary of Solids Quantities Parameter Units Current Mid-point Future Max. Month Ann. Ave. Max. Month Ann. Ave. Max. Month Ann. Ave. Primary Sludge Quantity dtpd 28.0 21.7 32.5 25.4 37.1 29.1 Total Solids % 4.0 4.0 4.0 4.0 4.0 4.0 Volatile Solids dtpd 22.1 17.2 25.9 20.3 29.7 23.3 Volatile Solids % 79 79 80 80 80 80 Flow gpd 167,700 130,000 195,100 152,300 222,400 174,500 Waste Activated Solids Quantity dtpd 16.6 12.3 18.8 15.5 20.9 18.7 TS % 0.3 0.3 0.3 0.3 0.3 0.3 Volatile Solids dtpd 13.6 10.0 15.2 12.5 16.8 14.9 Volatile Solids % 82 81 80 80 80 80 Flow gpd 1,324,300 981,200 1,499,100 1,236,000 1,673,900 1,490,800 Performance information on the new solids treatment processes was not available. Consequently, estimates of expected performance were used in this evaluation. These estimates include the following:  PS concentration of 4.0 percent from the primary clarifiers.  WAS concentration of 0.3 percent from the final clarifiers.  Solids capture efficiency of 95 percent in rotary drum thickeners.  Thickened WAS concentration of 5 percent from rotary drum thickeners.  MLSS concentration of 1,000 mg/L. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 8  Volatile solids reduction of 47 percent in anaerobic digesters. Digester gas production estimates were based on a biogas yield of 15 standard cubic feet per pound (scf/lb) of volatile solids destroyed. The energy computations were based on heating values of 600 British thermal units per standard cubic foot (Btu/scf) for digester gas.  Solids capture efficiency of 95 percent in dewatering units.  Dewatered cake solids concentration of 22 percent. 3. Solids Processing Alternatives Based on discussions with the District staff, and information gathered during site visits to and design activities for the Missouri River WWTP, two alternatives were developed for processing and management of solids generated at the WWTP. Descriptions of the alternatives are presented in the following sections. Appendix A includes Process Flow Schematics for the different alternatives. a. Alternative M-1 – Continuation of Existing Solids Management Scheme This alternative is the base-case scenario. It incorporates the solids improvements included with the Secondary Treatment Expansion and Disinfection Facilities and the Digester Rehabilitation projects. WAS will be thickened in rotary drum thickeners and combined with PS for digestion, upstream of centrifuge dewatering. The schematic for this alternative is shown on Figure 4-3. b. Alternative M-2 – FOG Co-digestion Alternative M-2 involves the same solids management practice described for the base- case scenario, but includes a fats, oil, and grease (FOG) receiving facility for co-digestion of this material in the anaerobic digesters. The existing engine generators will continue to be used for cogeneration. Any additional capacity required based on FOG co-digestion BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 9 will be provided by new engine-generators. A schematic of this alternative is shown on Figure 4-3. Figure 4-3 Facilities for Co-Digestion of FOG A summary of the new and existing equipment being evaluated for each alternative is presented in Table 4-3. Note that equipment identified as “E”, or existing, includes equipment scheduled for installation with the current expansion and upgrade project. Table 4-3 Solids Processing Alternatives Equipment M-1 Continuation of Current M-2 FOG Co-Digestion Solids Thickening Rotary Drum Thickeners E E BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 10 Table 4-3 Solids Processing Alternatives Equipment M-1 Continuation of Current M-2 FOG Co-Digestion Co-Digestion FOG Receiving Facilities --- N Solids Stabilization Anaerobic Digestion E E Solids Dewatering Centrifuges E E Cake Storage and Loadout Cake Pumps E E Cake Storage Silos/Loadout E E Energy Recovery Digester Gas Cleaning E E Engine-Generators E E/N Other Combined Heat & Power (CHP) Options --- O Legend: E = Existing system will be evaluated and modifications/upgrades recommended. N = The implementation of a new system will be evaluated. O = Options being evaluated. c. Technologies for Solids Processing Alternatives The solids processing technologies for the two alternatives are discussed in the following sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 11 1. Solids Thickening Alternative M-1 and Alternative M-2 - Planned Rotary Drum Thickeners for WAS Alternative M-1 and Alternative M-2 will use the planned rotary drum thickeners for WAS thickening. These will be installed in conjunction with the Secondary Treatment Expansion and Disinfection Facilities improvements. Consequently, no additional thickening capacity will be required. The design criteria for the RDTs are listed in Table 4-4. Table 4-4 RDT Design Criteria Equipment Units Max. Month Ann. Average Waste Activated Sludge Total Solids ppd 41,900 37,300 Flow gpd 1,670,700 1,494,800 Rotary Drum Thickeners Number of Units No. 4 ( 3 duty, 1 standby) Operation Schedule h/d/wk 24/7/52 Required HLR gpm/unit 390 350 Hydraulic Capacity gpm/unit 400 400 Required SLR pph/unit 580 520 Solids Capacity pph/unit 1,000 1,000 Solids Capture Rate % 95 Thickened Solids % 5 Polymer Use (active) lb/dt solids 5 -10 The RDTs will be located in the Solids Handling Building as part of the Secondary Treatment Expansion project. The layout of this building is shown in Figure 4-4 Thickening/Dewatering Storage Layout. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 12 d. Co-Digestion of FOG Alternative M-2 – FOG Co-digestion Alternative M-2 will include the co-digestion of FOG to provide increased energy recovery. FOG is highly biodegradable in the anaerobic digestion process and can significantly increase gas production. FOG has a high volatile solids (VS) content, with reported values of 90 percent or more and a high VS destruction rate, ranging from 70 to 80 percent in mesophilic processes. Biogas yields of up to 21 standard cubic feet per pound of VS destroyed (scf/lb VS) have been reported from FOG as compared with a typical biosolids gas generation rate of 15 scf/lb VS from biosolids. Recent research has indicated that the addition of FOG has a symbiotic effect on the digestion process, with higher biogas yields than would be expected from biosolids and FOG digested separately. Existing co-digestion facilities have varying FOG to sewage sludge feed ratios; however, digester operation appears to remain stable with FOG volumetric feed rates of up to 20 to 30 percent of the total digester feed volatile solids. Co-digestion operates in a similar fashion as conventional anaerobic digestion processes operating solely on biosolids. Since the FOG is completely biodegraded during the digestion process, the characteristics of the digested solids are similar to those generated from conventional digestion. Co-digestion requires construction of FOG receiving and handling facilities. FOG can be difficult to handle and requires special design considerations, which are discussed in the following sections. 1. Receiving Station The FOG receiving facility will consist of a rock trap, a recessed impeller pump and a grinder upstream from the holding tank. Heavier solids in the FOG will drop out in the rock box. The particle size of the solids escaping the trap will be further reduced by the grinder upstream from the holding tank. Screens will not be provided on the FOG BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 13 receiving line. From Black & Veatch’s experience from past projects, screens are prone to blinding with FOG, needing frequent cleaning and more operator attention. A picture of a FOG receiving facility with rock traps is shown on Figure 4-5. Figure 4-5 FOG Receiving Facility with Rock Traps The receiving station may also include a thickening or concentration step to increase the solids concentration of the FOG and to reduce the impact of FOG on hydraulic loading to the digesters. Concentrators are not necessary when the quantity of FOG comprises only a small portion of digester feed. Concentration equipment is available from several vendors, including Tenco-Hydro, Walker Process and Envirocare, or can be fabricated locally. A photo of a package FOG concentration system is shown on Figure 4-6. These systems, which can operate as batch or continuous processes, allow FOG to float to the surface of the concentrator tank, where it is skimmed to a discharge hopper. The subnatant is returned to the liquid stream process. Some of these systems include heated holding tanks or concentrators to prevent grease from congealing on pipes and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 14 equipment, particularly during colder months. Concentrators can increase the solids concentration of FOG to 40 to 60 percent dry solids. Figure 4-6 Scum / Grease Concentrator (Courtesy of Tenco-Hydro) While FOG can have varying characteristics depending on the source, it is often characterized by pH values and can be corrosive to equipment and piping. Consequently, the equipment will be constructed of corrosion-resistant materials, including stainless steel, FRP, or will be glass-lined. The maintenance requirements for the FOG facility will include periodic cleaning of the rock box to remove any accumulated material and preventive maintenance of mechanical components. To clean the rock traps, any collected liquid will be drained to the floor and washed down to a drain to the head of the plant. The accumulated solids will then be cleaned manually. A full time operator will be assign to operate the FOG receiving station. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 15 Receiving equipment for FOG will be sized to support the daily FOG volume within the desired operating period. This evaluation is based on receiving FOG during an 8 or 10 hour day shift. 2. Storage Utilities that accept hauled FOG can control the hours during which FOG is accepted, but have little control over the frequency of deliveries. Since digesters operate best when fed consistently throughout a 24-hour period, a storage tank will be provided to hold and equalize FOG deliveries. The storage tanks will be continuously heated and mixed to prevent congealing and minimize stratification. For heating, equipment manufacturers recommend heating jackets with pumped hot water recirculation that will allow for homogeneous heat transfer, rather than the use of heat tracing, which may result in localized hotspots that can “cook” the material on the surface of the equipment. The high heat density of heat tracing can also aggravate corrosion. The FOG storage tanks will be vented to an odor control facility. The FOG receiving station will be located on the east side of the new solids handling building and the storage tanks will be connected to the odor control facility provided for the solids handling building. The FOG is typically conveyed to the digesters using progressing cavity or centrifugal chopper pumps. Gas Handling Equipment The addition of FOG to a digester can significantly increase gas production; with gas production spikes occurring very rapidly after FOG addition. Consequently, gas handling equipment, including piping, flame arresters, and storage vessels, will be designed to support the higher gas quantities expected with FOG. In addition, the gas utilization equipment (i.e., co-generation equipment, boilers, etc.) will be designed to support the higher gas production. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 16 3. Other Ancillary Equipment Some co-digestion facilities provide a truck rinse station to make disposal at the wastewater plant attractive as compared to competing disposal sites, such as landfills. Some haulers prefer the ability to gravity drain their trucks with either a raised or tilted platform so that their tanks can be emptied of as much material as possible. Employing a gravity truck unloading station also allows haulers with no other unloading method to use the FOG receiving facility, potentially increasing the quantity of FOG received. The equipment required for receiving FOG at the Missouri River WWTP includes: • Two 8,000 gallon FOG storage tank (total tank volume supports up to 4 - 4,000 gallon truck volumes), vented to the odor control system provided for the new solids handling building • Recessed impeller pumps for truck unloading (2 – 1 duty and 1 spare) • Rock/sand trap (1 per tank) • Pumped mixing for storage tanks • Storage tank heating • Progressing cavity pumps for digester feeding (2 – 1 duty and 1 spare) • Electronic monitoring station • Truck wash station FOG concentration is not required since the expected FOG quantities constitute only a small fraction of the total hydraulic load to the digesters. Concentrators can be installed as necessary in the future if the FOG quantities increase significantly. e. Solids Stabilization – Anaerobic Digestion Alternative M-1 and Alternative M-2 – Anaerobic Digestion Alternative M-1 and Alternative M-2 will use the existing and newly constructed digestion facilities for solids stabilization. No additional digestion capacity or equipment BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 17 will be required for this alternative. However, the capacity of the planned digesters limits the amount of FOG that can be accepted for Alternative M-2. 1. Solids Quantities The digester feed solids quantities used for this evaluation are summarized in Table 4-5. Current and Future (year 2030) solids quantities are based on the quantities listed in the July 2009 Design Memorandum for the Secondary Treatment Expansion and Disinfection Facilities project. Mid-point (year 2020) solids quantities were developed by averaging the current and future solids quantities. Table 4-5 Summary of Solids Quantities Parameter Units Current Mid-point Future Max. Month Ann. Ave. Max. Month Ann. Ave. Max. Month Ann. Ave. Thickened Primary Sludge Quantity dtpd 28.0 21.7 32.5 25.4 37.1 29.1 Total Solids % 4.0 4.0 4.0 4.0 4.0 4.0 Volatile Solids dtpd 22.1 17.2 25.9 20.3 29.7 23.3 Volatile Solids % 79 79 80 80 80 80 Flow gpd 167,900 130,100 194,800 152,300 222,400 174,500 Thickened Waste Activated Solids Quantity dtpd 15.8 11.7 17.9 14.7 19.9 17.8 TS % 5.0 5.0 5.0 5.0 5.0 5.0 Volatile Solids dtpd 12.9 9.5 14.3 11.8 15.9 14.2 Volatile Solids % 82 81 80 80 80 80 Flow gpd 75,600 56,000 85,700 70,600 95,200 85,200 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 18 Table 4-5 Summary of Solids Quantities Parameter Units Current Mid-point Future Max. Month Ann. Ave. Max. Month Ann. Ave. Max. Month Ann. Ave. Total Raw Solids Quantity dtpd 43.8 33.4 50.4 40.1 57.0 46.9 TS % 4.3 4.3 4.3 4.3 4.3 4.3 Volatile Solids dtpd 35.1 26.6 40.3 32.1 45.6 37.5 Volatile Solids % 80 80 80 80 80 80 Flow gpd 243,500 186,100 280,500 222,900 317,600 259,700 2. FOG Quantity The FOG quantities for this evaluation were based on the Bissell Point Unloading Station Grease Separation Memorandum dated April 22, 2007, prepared by Jacobs (Appendix B of Phase I – TM 2: Facility Summaries and Solids Projections). The hauled wastes received at the Bissell Point WWTP come from a variety of sources. For purposes of this evaluation, only the grease volumes were included in the FOG quantities for the Missouri River WWTP. The grease quantities used in this evaluation are summarized in Table 4-6. These values, which are assumed to remain constant throughout the project life, were used for the FOG system capacity and impact on digester performance. Table 4-6 FOG Quantities Year Industrial Food Grease Domestic Food Grease Total gal gal gal gpd 2008 228,600 3,898,769 4,127,369 11,300 2007 1,863,980 4,093,652 5,957,632 16,300 2006 1,405,400 3,917,569 5,322,969 14,600 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 19 Table 4-6 FOG Quantities Year Industrial Food Grease Domestic Food Grease Total gal gal gal gpd Average 5,135,990 14,100 Grease receiving facility sizing is based on either the available quantities of FOG or the maximum FOG feed for stable digestion, whichever is limiting. As discussed in the previous section, FOG addition to the anaerobic digestion process is limited to less than 30 percent of total VS feed to maintain stable operation. The characteristics of FOG can vary depending on the source and it is recommended that a pilot or bench-scale test be conducted to characterize the FOG before designing the receiving and co-digestion facilities. Since no experimental data was available, TS and VS values from literature were used as the basis for this evaluation. The quantities and characteristics of solids and FOG are summarized in Table 4-7. Table 4-7 Solids and FOG Quantities Parameter Units 2030 Maximum Month 2030 Annual Average Solids FOG Solids FOG Flow gpd 317,600 14,100 259,700 14,100 Total Solids % 4.3 5.22 4.3 5.22 ppd 114,000 5,600 93,800 5,600 Volatile Solids1 % 80 90 80 90 ppd 91,200 5,000 75,000 5,000 % of total VS % 95 5 94 6 1 Based on solids density of 8.34 lb/gallon and FOG density of 7.65 lb/gallon 2 Based on sampling data of area FOG Based on a VS concentration of 90 percent in the FOG, the expected FOG quantity corresponds to 20 percent of the total digester VS feed at current annual average condition. As the projected solids quantities to digestion increase in the future, the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 20 percentage of VS from FOG decreases to 9 percent at mid-point annual average condition and 6 percent at 2030 annual average condition. Consequently, the operational stability of the digesters is not expected to be affected by the addition of FOG. 3. Anaerobic Digester The Missouri River WWTP has four existing mesophilic anaerobic digesters (3 primaries and 1 secondary) each with an operating volume of 0.86 million gallons (MG). A new 1.66 MG primary digester is currently being constructed to accommodate future solids loads. With the new digester in service, the primary digesters will provide a solids retention time (SRT) of 16.4 days and will operate at an organic loading rate (OLR) of 132 pounds per day per 1,000 cf (ppd/kcf) of digester volume at the 2030 annual average solids quantities listed in Table 4-3. Addition of FOG decreases the SRT to 15.5 days and increases the OLR to 141 ppd/kcf. At maximum month conditions, the primary digesters are operating at the higher end of the recommended organic loading rates for a PS-WAS feed blend. Consequently, addition of FOG to the digesters is not recommended at maximum month conditions as this may result in process upset. Specifications of the digesters are listed in Table 4-8. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 21 Table 4-8 Anaerobic Digestion Facilities Parameter Units M-1 Continuation of Current M-2 FOG Co-digestion 2030 MM 2030 AA 2030 MM 2030 AA Primary Digesters Type Concrete with Fixed Steel Cover (One primary digester will be equipped with membrane cover) Type of Mixing Pumped Existing Digesters Number of Units No. 3 Volume, each gal 863,600 New Digester Number of Units No. 1 Volume, each gal 1,660,000 SRT days 13.4 16.4 12.8 15.5 OLR ppd/kcf 160 132 169 141 Secondary Digester Type Concrete with Membrane Gas Holder Cover Type of Mixing Pumped Number of Units No. 1 Volume, each gal 863,600 SRT days 2.7 3.3 2.6 3.2 The layout for the digestion facilities is shown on: Figure 4-7 Digestion Facilities BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 22 f. Digester Gas Utilization Digester gas will be collected, cleaned of contaminants, and used for cogeneration onsite. 1. Digester Gas Production Gas production from the anaerobic digesters was estimated for 2020 annual average (AA) and 2030 AA conditions listed in Table 4-5. Gas production calculations the VS and Volatile Solids Reduction parameters presented in Table 4-9. The energy computations were based on a lower heating value of 600 British thermal units per standard cubic foot (Btu/scf) of digester gas. The digester gas estimates for 2030 AA conditions and 2020 AA conditions are listed in Table 4-9. Gas quantities at 2030 AA conditions were used for sizing of gas cleaning and gas utilization equipment; while 2020 AA gas quantities were used for annual operations and maintenance (O&M) cost estimates. Table 4-9 Digester Gas Production with FOG Parameter Units 2030 Max. Month 2030 Ann. Ave. Solids FOG Solids FOG Volatile Solids Reduction % 471 -- 471 90 Digester Gas Yield scf/lb VSr 15 -- 15 21 Gas Production Rate scfd 631,200 -- 518,500 93,600 scfm 438 -- 360 65 Percentage of Total Gas Production % 85 -- 85 15 Methane Content in Digester Gas % 60 -- 60 60 Heating Value of Digester Gas Btu/scf 600 -- 600 600 Gross Energy from Digester Gas mmBtu/hr 15.8 -- 13.0 2.3 Total Energy from Digester Gas mmBtu/hr 15.8 15.3 1Based on plant data. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 23 2. Digester Gas Treatment System The Missouri River WWTP has an existing digester gas treatment system and engine generators for on-site power production. The digester gas treatment system was supplied by Applied Filter Technology (AFT) and installed in 2007-2008. It is designed to remove moisture, particulate, hydrogen sulfide, and siloxanes. Siloxanes are a contaminant of particular concern, since if this is not removed from the fuel it will be converted to sand in the combustion chamber, creating a highly abrasive material. The AFT system consists of hydrogen sulfide removal tanks (with iron based media), particulate filters, chiller/heat exchanger dryer, blower, and siloxane removal tanks (with carbon graphite based media). The existing system has a design capacity of 343 scfm. As this capacity is below the projected available digester gas for future annual average conditions, the evaluation will be based on modifying the existing system as needed to provide additional capacity. 3. Combined Heat and Power (CHP) Technology Options The existing engine generators are close to the end of their useful life and will be replaced with a new CHP system. The available CHP technology options vary with respect to size, fuel requirements, efficiency, costs, and their overall compatibility with the existing facilities. The options range from traditional engine-generators and gas fired combustion turbine generators to recently developed microturbines and fuel cells. Internal combustion engines are by far the most common cogeneration technology used at WWTPs. About 80 percent of the WWTPs that have cogeneration facilities use reciprocating engines. Some gas fired combustion turbine generators have also been used for cogeneration, but are typically used at larger WWTPs. Microturbines, which are modular gas fired combustion turbines with capacities less than 250 kW, are being used more because of their smaller size and lower air emissions. Fuel cells have also gained interest, as a result of their extremely low air emissions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 24 Table 4-10 presents a comparison of typical unit sizes, efficiencies, fuel consumption, heat recovery rates, and maintenance requirements for engine-generators, microturbine generators, and fuel cells. Because of their high initial and maintenance costs and minimal experience operating on digester gas, fuel cells were not evaluated further. Table 4-10 Digester Gas Utilization Equipment Comparison Parameter Units Engine-Generators Microturbines Fuel Cells Gas pressure required psig 1 to 5 75 to 100 15 to 30 Performance Efficiency range % 25 to 40 25 to 30 40 to 45 Heat recovery % 40 to 50 30 to 40 30 to 35 Overall efficiency % 65 to 90 55 to 70 70 to 80 Typical Maintenance Top end overhaul hr Every 16,000 -- -- Bottom end overhaul hr Every 32,000 -- -- Lining and fuel Injector replacement hr -- Every 15,000 -- Turbine replacement hr -- Every 30,000 -- Carbon Replacement hr -- -- Every 3,000 Fuel stack replacement hr -- -- Every 40,000 Emissions NOx1 ppmv Approx. 65 ppmv Approx. 9 ppmv Approx. 3 ppmv Capital Costs2 Costs $/kW 1,500 to 2,000 2,000 to 2,500 4,000 to 4,500 1 Based on using natural gas as fuel. 2 Does not include installation costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 25 CHP equipment is sized based on digester gas quantity at 2030 annual average condition. The potential electricity generation and heat recovery with and without FOG co-digestion at 2020 and 2030 annual average conditions are presented in Table 4-11. Information listed in Table 4-11 is based on the best engineering estimates at the conceptual design stage and should not be used for CHP equipment sizing. Table 4-11 Potential Energy Generation and Heat Recovery Parameter Units M-1 M-2 Continuation of Current FOG Co-digestion 2030 Max. Mon. 2030 Ann. Ave. 2030 Max. Mon. 2030 Ann. Ave. Input gas quantity scfd 631,200 518,500 631,200 612,100 Input gas quantity mmBtu/hr 15.8 13 15.8 15.4 Engine Generators Efficiency % 35 35 35 35 Heat recovery % 50 50 50 50 Overall efficiency % 85 85 85 85 Electricity Generation kW 1,620 1,330 1,620 1,580 Heat Recovery mmBtu/h 7.9 6.5 7.9 7.7 Microturbines Efficie ncy % 28 28 28 28 Heat recovery % 30 30 30 30 Overall efficiency % 58 58 58 58 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 26 Table 4-11 Potential Energy Generation and Heat Recovery Parameter Units M-1 M-2 Continuation of Current FOG Co-digestion 2030 Max. Mon. 2030 Ann. Ave. 2030 Max. Mon. 2030 Ann. Ave. Potenti al electrical power generation kW 1,300 1,070 1,300 1,265 Potenti al heat recovery mmBtu/h 4.7 3.9 4.7 4.6 The Missouri River plant currently has three engine generators with a total capacity of 1,050 kW (350 kW each). As indicated in Table 4-11, extra capacity is required to process all biogas produced at 2030 annual average condition. As the result of discussions with MSD staff, the existing engine generators will continue to operate and one extra engine generator with larger capacity will be installed. Since there is not enough space in the existing power generation building, the new generator set will be installed outdoor next to the power generation building as shown in the plant layouts. A container will be provided for the generator and heat recovery set. g. Solids Dewatering Alternative M-1 and Alternative M-2 will use the dewatering centrifuges provided with the Secondary Treatment Expansion and Disinfection Facilities project. Since more than 70 percent of FOG is expected to be destroyed through the digestion process, the impact of hauled FOG on dewatering capacity is not significant. The dewatering units will receive stabilized solids from the centrifuge receiving well in the Solids Handling Building and downstream of the secondary digester. Centrifuge feed BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 27 pumps will convey solids from the receiving well to the centrifuges. The design criteria for the centrifuges are listed in Table 4-12. Table 4-12 Design Criteria for Dewatering Equipment Parameter Units 2030 Max. Month Ann. Ave. Digested Solids (16-hours per day, 5-day Basis) Feed Solids ppd 71,100 58,500 Feed Solids Concentrations % 2.6 2.6 Feed Flow gpd 333,900 273,600 Number of Units No. 3 (2 duty, 1 standby) Centrifuge Diameter inches 29 Operation Schedule hr/d/wk 16/5/52 Required HLR gpm/unit 250 200 Required SLR pph/unit 3,100 2,560 Dewatered Solids % 22 22 Solids Capture Rate % 95 95 Polymer Use (active) lb/dt solids 20 20 The centrifuges will be located in the Solids Handling Building as part of the Secondary Treatment Expansion project. h. Cake Storage and Loadout Storage silos to be constructed in the near future as part of the Secondary Treatment Expansion and Disinfection Facilities improvements will be used for dewatered cake storage for both Alternatives. For purposes of this evaluation, cake storage requirements were evaluated based on 8 hours per day, 5 days per week hauling to the landfill or the end-use sites. The solids from the centrifuges will be conveyed to one of the two storage silos using cake pumps. Storage silos will be equipped with sliding frame-type live bottoms, which BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 28 will discharge solids to trucks for hauling. Design criteria for cake conveyance and storage for Alternative 1 and Alternative 2 are listed in Table 4-13. Table 4-13 Design Criteria for Cake Conveyance and Storage Parameter Units 2030 Max. Month Ann. Average Dewatered Raw Solids (5-day Basis) Total Solids ppd 94,600 77,800 Solids Concentration % 22 22 Density of Solids lb/cf 55 55 Volume of Solids cfd 7,820 6,430 Dewatered Cake Pumps (16-hours per day, 5-day Basis) Number of Units No. 3 (2 Duty, 1 Standby) Pump Type Progressive Cavity Operation Schedule hr/d/wk 16/5/52 Required Flow (each) gpm 30 25 Capacity (each) gpm 30 30 Storage Silos Solids (7-day Basis) cfd 5,585 4,590 Number of Units No. 2 Type Sliding frame/live bottom Volume (each) cy 460 Storage days 4.4 5.4 The sludge storage silos and truck loading facilities will be located in the Solids Handling Building as part of the Secondary Treatment Expansion Project. i. Final Use The existing practice for final use at Missouri River is to haul dewatered solids to the Fred Weber Sanitary Landfill for disposal and/or the City of St. Peters composting BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 29 facility for further treatment. Based on 2006, 2007, and 2008 plant records, a larger fraction of the dewatered solids were sent to St. Peters for composting. The solids quantities to composting have dropped considerably since then with only 15 percent of the total composted in 2009. With the increase in solids for final use, resulting from increased loadings and the conversion to an activated sludge treatment system, the proportion of solids to the two end use options is expected to change in the future. Design criteria for the final use solids are listed in Table 4-14. Table 4-14 Design Criteria for Final Use Solids Parameter Units 2030 Max. Month 2020 Ann. Avg. Alternative 1 w/o FOG Addition Cake Total Solids, Dry ppd 66,600 34,000 Cake Total Solids, Wet ppd 333,000 170,000 Cake Volume cy/day 208 106 Alternative 2 w/ FOG Addition Cake Total Solids, Dry ppd 67,800 35,000 Cake Total Solids, Wet ppd 339,000 175,000 Cake Volume cy/day 212 109 Final use options will be the same for both Alternative M-1 and Alternative M-2, and will include cake hauling for composting, landfill, or land application. General material related to regulatory requirements and disposal considerations of each of these alternatives was included in the Comprehensive Solids Handling Master Plant Phase 1 Technical Memorandum No. 3 – Solids Disposal/Reuse Alternatives. 1. Composting Composting is a natural process of aerobic, thermophilic microbiological degradation of organic matter or residues into a stabilized, useful product that is free of odors and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 30 pathogens, will not attract rodents and insects, and can be used beneficially for horticultural and agricultural purposes. Dewatered cake can be composted into a humus- like material that can be used as a soil amendment with a moderate nutrient content. For this final use alternative, dewatered cake solids will be hauled from the plant to the City of St. Peters’ Composting Facility. Solids in excess of capacity at the composting facility will have to be used for land application or disposed of in a landfill. 2. Landfill Landfilling has commonly been used as a disposal method for dewatered solids. Currently, all wastewater solids sent to landfill by MSD are hauled to the Fred Weber Sanitary Landfill at a 2009 bid cost of $25.58 per wet ton. Given the relatively low tipping fee and the relatively short distance from the plant to this landfill, this is a viable disposal option. For this final use alternative, dewatered cake solids will be hauled from the plant to the Fred Weber Sanitary Landfill. 3. Land Application Bulk land application is the most common option for beneficial use of biosolids and is often the most cost effective. Recycling biosolids through land application improves soil physical properties and supplies nutrients essential for plant growth, including nitrogen and phosphorus. Before biosolids from the plant can be land applied in bulk, they must meet Class B requirements established in 40 CFR Part 503 Regulations. In general the anaerobic digestion process employed at the Missouri River WWTP will meet Class B requirements, provided that the solids retention time is a minimum of 15 days. While the digesters are sized to provide this retention time, under some loading conditions this will not be the case if a digester is out of service. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 31 For this final use alternative, dewatered cake solids will be hauled from the plant to a land application site, assumed to be within a one-way hauling distance of 40 miles. 4. Staffing Requirements Table 4-15 lists the anticipated staffing requirements for each of the alternatives. These staffing requirements are for the new biosolids processing facilities only and do not include the existing processes. It is assumed that hauling and disposal of dewatered cake will be handled by a third-party contractor and will not require MSD staff. Table 4-15 Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Alternative M-1 – Continuation of Current Processes Supervisor 0 0 0 0 0 0 Operator 0 0 0 0 0 0 Maintenance 0 0 0 0 0 0 Alternative M-2 – FOG Codigestion Supervisor 0 0 1.0 7 52 0 Operator 1 8 1.0 5 52 2,080 Maintenance 1 0.5 1.0 5 52 130 5. Cost Summary Table 4-16 presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were developed based on the descriptions of alternatives and options presented in Section 3.0. Detailed costs and benefits for each of these options are presented in Technical Memorandum No.9 - Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 32 Table 4-16 Opinions of Costs, Savings and Life Cycle Costs ($1000) Alternative M-1 Continue Existing M-2 FOG Codigestion Capital Costs $2,073 $3,040 Salvage Value $0 $29 Annual O&M Costs $2,338 $2,505 Annual Revenue ($594) ($695) Present Worth Costs Capital Costs $2,073 $3,040 Salvage Value $0 ($11) O&M Costs $29,760 $31,218 Revenue ($7,403) ($8,661) Total Present Worth Costs $24,430 $25,590 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 33 Appendix A – Site Plan BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 TM-Missouri River WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 34 Appendix B – Detailed Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 1 TECHNICAL MEMORANDUM NO. 5 LOWER MERAMEC WWTP SOLIDS PROCESSING ALTERNATIVES EVALUATION To: Metropolitan St. Louis Sewer District From: Bently Green, Alan Christanell, Deniz Yurtsever, Hari Santha This Technical Memorandum discusses the evaluation of the solids processing and management alternatives for the Lower Meramec Wastewater Treatment Plant (WWTP) as part of the long- term biosolids management plan for the St. Louis Metropolitan Sewer District (MSD). Since MSD plans to decommission the Grand Glaize and Fenton WWTPs during the planning period, the solids processing requirements at Lower Meramec were based on receiving flows from the Grand Glaize and Fenton watersheds for treatment. Information on the existing facilities at Lower Meramec was obtained from plant records, interviews with MSD staff, and plant permits. The evaluation included the information on the existing plant, the solids quantities used, required equipment for the selected alternatives, and siting requirements for each alternative. Table of Contents 1. Existing Plant Information ......................................................................................................... 3 a. Lower Meramec ........................................................................................................ ......... 3 2. Solids Quantities ........................................................................................................................ 9 3. Solids Processing Alternatives ................................................................................................. 11 4. Description of Alternatives ...................................................................................................... 11 a. Alternative LM-1 – Gravity Thickening ................................................................... ....... 11 b. Alternative LM-2 – Mechanical Thickening of WAS .............................................. ....... 12 c. Technologies for Solids Processing Alternatives ..................................................... ....... 14 (1) Solids Thickening ................................................................................................. ....... 14 (2) Solids Stabilization ............................................................................................... ....... 18 (3) Solids Dewatering ................................................................................................. ....... 22 (4) Cake Storage and Loadout .................................................................................... ....... 24 (5) Energy Recovery ................................................................................................... ....... 25 (6) Digester Gas Utilization Technologies ................................................................. ....... 26 (7) Digester Gas Cleaning Requirements ................................................................... ....... 30 (8) Exhaust Emissions ................................................................................................ ....... 32 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 2 d. Final Use and Disposal Option ................................................................................. ....... 32 5. Staffing Requirements ............................................................................................................. 32 6. Cost Summary .......................................................................................................................... 33 List of Tables Table 5-1 Rated Capacities of Existing Solids Processing Facilities ............................................. 5 Table 5-2 Projected Solids Quantities........................................................................................... 10 Table 5-3 Solids Processing Alternatives ..................................................................................... 13 Table 5-4 Conceptual Design Criteria for Gravity Thickeners ..................................................... 16 Table 5-5 Conceptual Design Criteria for Gravity Thickeners ..................................................... 17 Table 5-6 Conceptual Design Criteria for RDTs .......................................................................... 17 Table 5-7 Conceptual Design Criteria for Anaerobic Digesters (Alternative LM-1) ................... 18 Table 5-8 Anaerobic Digester Performance (Alternative LM-1) ................................................. 20 Table 5-9 Conceptual Design Criteria for Anaerobic Digesters (Alternative LM-2) ................... 21 Table 5-10 Anaerobic Digester Performance (Alternative LM-2) ............................................... 22 Table 5-11 Design Criteria for Dewatering Equipment (Alternative LM-1) ................................ 23 Table 5-12 Design Criteria for Dewatering Equipment (Alternative LM-2) ................................ 23 Table 5-13 Design Criteria for Cake Storage Silos (Alternative LM-1) ...................................... 25 Table 5-14 Anaerobic Digester Performance ............................................................................... 26 Table 5-16 Digester Gas Quality .................................................................................................. 30 Table 5-17 Gas Quality Requirements for Gas Utilization Equipment ........................................ 31 Table 5-18. Emission Limits, pounds/brake horsepower-hr (lb/bhp-hr) ...................................... 32 Table 5-19 Staffing Requirements ........................................................................................... 33 Table 5-20 Opinions of Costs, Savings and Life Cycle Costs ...................................................... 33 List of Tables Figure 5-1 Existing Site Plan. ......................................................................................................... 3 Figure 5-2: Existing Solids Processing Facilities at the Lower Meramec WWTP ......................... 4 Figure 5-3: Existing Solids Processing Facilities at the Coldwater WWTP ................................... 6 Figure 5-4. Existing Solids Processing Facilities at the Grand Glaize WWTP .............................. 7 Figure 5-5. Existing Solids Processing Facilities at the Fenton WWTP ........................................ 9 Figure 5-6. Solids Processing Alternative LM-1 .......................................................................... 12 Figure 5-7. Solids Processing Alternative LM-2 ......................................................................... 13 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 3 1. Existing Plant Information a. Lower Meramec The Lower Meramec WWTP is a trickling filter plant that was commissioned in 2007 with a permitted design flow of 15 mgd. A plant expansion is currently being discussed that will likely convert the plant to an activated sludge process to better address expected nutrient removal regulations. A site plan of Lower Meramec WWTP is shown on: Figure 5-1 Existing Site Plan. The liquid stream processes at the WWTP generate primary solids (PS) and trickling filter solids (TFS). The PS and TFS are co-thickened in gravity thickeners. The thickened solids are dewatered using belt filter presses (BFPs). The dewatered cake from the BFPs is discharged to screw conveyors, which convey it to two sludge storage silos; from which trucks are loaded and the sludge hauled to a landfill for disposal. The existing solids processing facilities at the Lower Meramec WWTP are presented on Figure 5-2. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 4 Figure 5-2: Existing Solids Processing Facilities at the Lower Meramec WWTP The specifications of the existing solids processing facilities at the WWTP are summarized in Table 5-1. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 5 Table 5-1 Rated Capacities of Existing Solids Processing Facilities Equipment Units Capacity Primary Solids and TFS Co-Thickening Gravity Thickener Number of Gravity Thickeners No. 2 Diameter of Gravity Thickeners Ft 50 Approximate Side Water Depth Ft 12 Surface Area per Unit Sf 1,963 Solids Dewatering Belt Filter Presses Number of Units No. 2 Belt Width M 2 Sludge Storage/Truck Loading Silos Number of Units No. 2 Capacity per Unit cy 54 Pictures of the existing solids processing facilities are shown on Figure 5-3. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 6 BFP Dewatering Polymer System Truck Loadout Bays Figure 5-3: Existing Solids Processing Facilities at the Coldwater WWTP BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 7 b. Grand Glaize WWTP The Grand Glaize WWTP is an activated sludge plant that was commissioned in 1986 with a permitted design flow of 16 mgd. The plant was recently expanded to accommodate a design flow of 21 mgd. The improvements included addition of primary clarifiers, conversion of oxidation ditches to aeration basins, and final clarifiers to meet the higher flows. A second belt filter press was also installed as part of the improvements. The PS and waste activated sludge (WAS) generated at the WWTP are co-thickened in gravity thickeners, dewatered using BFPs, and disposed offsite at a landfill. The existing solids processing facilities at the Grand Glaize WWTP are presented on Figure 5-4. Figure 5-4. Existing Solids Processing Facilities at the Grand Glaize WWTP BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 8 MSD’s long-term plan is to decommission the Grand Glaize WWTP by year 2025 and convey the flows received at the facility to the Lower Meramec WWTP for treatment. Based on this consideration, the Grand Glaize facility was not included in this evaluation. c. Fenton WWTP The Fenton WWTP is an activated sludge plant that was commissioned in 1987 with a permitted design flow of 6.75 mgd. Liquid stream treatment at the plant includes screening, primary settling, aeration basins for secondary treatment, final clarification, and disinfection. The solids processing facilities include one gravity thickener, which is used for co-thickening PS and WAS, and one BFP for dewatering. The dewatered solids are transported for disposal at a landfill. The existing solids processing facilities at the Fenton WWTP are presented on Figure 5- 5. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 9 Figure 5-5. Existing Solids Processing Facilities at the Fenton WWTP MSD’s long-term plan is to decommission the Fenton WWTP by year 2015 and convey the flows received at the facility to the Lower Meramec WWTP for treatment. Based on this consideration, the Fenton facility was not included in this evaluation. 2. Solids Quantities MSD’s long-term plan is to decommission the Grand Glaize WWTP and Fenton WWTP and convey the flows now received at these facilities to the Lower Meramec WWTP for treatment. These additional flows will increase the average design flow to the Lower Meramec plant to 42.75 mgd. Additional development within the Lower Meramec watershed is anticipated to increase the future ultimate treatment capacity to 56 mgd. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 10 The solids quantities for this evaluation were carried forward from Phase I – TM 2: Facility Summaries and Solids Projections. The solids quantities at Lower Meramec were projected at 5 year intervals based on a linear growth through the planning period. Grand Glaize and Fenton were assumed to be mature watersheds and the future solids quantities at these facilities were assumed to be the same as at current conditions. To determine the capacity requirements at 2015 and 2025, when MSD plans to decommission the Fenton and Grand Glaize facilities respectively, the solids quantities were estimated by adding the 5-year incremental quantities at Lower Meramec to the current solids production at Fenton and Grand Glaize WWTP’s. A summary of the projected solids quantities at the Lower Meramec WWTP are presented in Table 5-2 below. Table 5-2 Projected Solids Quantities Flow Condition Total Solids (ppd) Volatile Solids (ppd) Flow (gpd) 2030 Design Conditions Maximum Month 106,400 79,700 1,913,700 Annual Average 78,200 58,600 1,410,000 2015 Conditions Maximum Month 43,700 32,600 786,000 2025 Conditions Maximum Month 92,900 69,700 1,687,000 Information on PS and WAS quantities and performance for future processes was not available. Consequently, estimated PS:WAS ratios and future process performance were estimated from typical solids production and performance information. Estimates used in this evaluation are as follows:  Solids from all three facilities were based on a 50:50 blend of PS and WAS on a dry weight basis.  The VS concentrations in PS and WAS at the Fenton WWTP were considered to be similar to those at the Grand Glaize WWTP. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 11  The overall VS concentrations in PS and WAS were adjusted to match the combined volatile solids concentrations of 75 percent at maximum month conditions.  PS concentration of 1 percent from the primary clarifiers and WAS concentration of 0.5 percent from the final clarifiers.  Solids capture efficiencies of 90 percent in gravity thickeners and 95 percent in rotary drum thickeners.  Thickened PS concentration of 4 percent from gravity thickeners.  Thickened WAS concentration of 3 percent from gravity thickeners and 5 percent from rotary drum thickeners.  Volatile solids reduction of 45 percent in anaerobic digesters. Digester gas production estimates were based on a biogas yield of 15 standard cubic feet per pound (scf/lb) of volatile solids destroyed. The energy computations were based on a heating value of 600 British thermal units per standard cubic foot (Btu/scf) of digester gas.  Solids capture efficiency of 92 percent in the dewatering units.  Dewatered cake solids concentration of 17 percent from belt filter presses for digested solids. 3. Solids Processing Alternatives Based on discussions with the District staff, and information gathered during site visits to the Lower Meramec WWTP, two alternatives were developed for solids processing and management at the facility. Appendix A contains detailed Process Flow Schematics of these alternatives. 4. Description of Alternatives a. Alternative LM-1 – Gravity Thickening This alternative will include the re-use of the existing gravity thickeners for PS and WAS thickening and BFPs for dewatering. The co-thickened PS and WAS will be pumped to new anaerobic digesters for stabilization. A new digester control building will house digestion equipment, including pumps, heat exchangers, mixing equipment, boilers, and digester gas collection and utilization equipment. The gas cleaning system will be located adjacent to the new digester control building. The cleaned gas will be piped to cogeneration equipment housed in a new building. The stabilized solids will be dewatered using BFPs and will be hauled to end BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 12 use or disposal sites. Figure 5-6 illustrates the overall process flow diagram for Alternative LM- 1. Figure 5-6. Solids Processing Alternative LM-1 b. Alternative LM-2 – Mechanical Thickening of WAS In Alternative LM-2, PS will continue to be thickened using the existing gravity thickener. New rotary drum thickeners (RDTs) will thicken WAS. The RDTs will be housed in the existing Process Building. The thickened PS and WAS will be combined and pumped to anaerobic digesters for stabilization. A new digester control building will house the digestion equipment and the digester gas collection and utilization equipment. The stabilized solids will be dewatered using the existing dewatering units. The end-use/disposal options considered under this alternative will include landfilling of dewatered solids, land application of dewatered solids, or BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 13 third-party composting of dewatered solids. Digester gas generated during the anaerobic digestion process will be cleaned to remove contaminants and used onsite for cogeneration. Figure 5-7 illustrates the overall process flow diagram for Alternative LM-2. Figure 5-7. Solids Processing Alternative LM-2 A summary of the new and existing equipment being evaluated for each alternative is presented in Table 5-3. Table 5-3 Solids Processing Alternatives Equipment LM-1 Gravity Thickening LM-2 Mechanical Thickening Solids Thickening Gravity Thickener (PS) E E Gravity Thickener (WAS) E -- BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 14 Table 5-3 Solids Processing Alternatives Equipment LM-1 Gravity Thickening LM-2 Mechanical Thickening Rotary Drum Thickeners (WAS) -- N Solids Stabilization Anaerobic Digestion N N Solids Dewatering BFPs E E Cake Storage and Loadout Conveyors/Cake Pumps E E Cake Storage Silos/Loadout E E Energy Recovery Digester Gas Cleaning N N Cogeneration N N Legend: E = Existing system will be evaluated and modifications/upgrades recommended N = Implementation of a new system will be evaluated c. Technologies for Solids Processing Alternatives The solids processing technologies evaluated for the two alternatives are discussed in the following sections. (1) Solids Thickening Alternative LM-1 - Existing Gravity Thickeners for PS and WAS The existing gravity thickeners will be used to co-thicken PS and WAS to a solids concentration of approximately 3 percent. The two existing gravity thickeners have adequate capacity to handle the projected solids quantities until 2015 maximum month conditions, including flows received from the Fenton watershed. Two additional units will be required to handle the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 15 increased flows expected when the Grand Glaize WWTP is decommissioned in 2025. The estimated solids and hydraulic loading rates to the gravity thickeners at the various flow conditions are shown in Table 5-4. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 16 Table 5-4 Conceptual Design Criteria for Gravity Thickeners Parameter Units 2015 MM 2025 MM 2030 MM Co-Thickening Combined Solids Total Solids ppd 43,700 92,900 106,400 Flow gpd 786,000 1,670,900 1,913,000 Gravity Thickeners Number of thickeners No. 2 4 4 Number of New Units No. 0 2 2 Thickener diameter ft 50 50 50 Total Surface Area sf 3,925 7,850 7,850 Recommended HLR1 gpd/sf 100 - 350 Recommended SLR1 ppd/sf 5 - 14 Operating Loading Rates Operating Schedule h/d/wk 24/7/52 24/7/52 24/7/52 Hydraulic Loading Rate gpd/sf 200 213 244 Solids Loading Rate ppd/sf 11.1 11.8 13.6 Thickened solids TS % 3.0 3.0 3.0 1 Black & Veatch recommendation Alternative LM-2 - Existing Gravity Thickener for PS and RDTs for WAS The existing primary sludge thickener will continue to be used for PS thickening. WAS will be thickened separately using new rotary drum thickeners (RDTs). The RDTs and a new emulsion polymer system with aging tanks will be installed in the existing Process Building. The conceptual design criteria for the WAS thickening facilities at the Lower Meramec WWTP are listed in Table 5-5 for gravity thickeners. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 17 Table 5-5 Conceptual Design Criteria for Gravity Thickeners Parameter Units 2015 MM 2025 MM 2030 MM PS Thickening Primary Sludge Total Solids ppd 21,900 46,500 53,200 Flow gpd 262,000 557,000 637,900 Gravity Thickeners Number of thickeners No. 2 2 2 Number of New Units No. 0 0 0 Thickener diameter ft 50 50 50 Total Surface Area sf 3,925 3,925 3,925 Recommended HLR1 gpd/sf 600 - 800 Recommended SLR1 ppd/sf 20 - 30 Operating Loading Rates Operating Schedule h/d/wk 24/7/52 24/7/52 24/7/52 Hydraulic Loading Rate gpd/sf 70 140 160 Solids Loading Rate ppd/sf 5.6 11.8 13.5 Thickened solids TS % 4.0 4.0 4.0 1 Black & Veatch recommendation The conceptual design criteria for the WAS thickening facilities at the Lower Meramec WWTP are listed in Table 5-6 for RDT’s. Table 5-6 Conceptual Design Criteria for RDTs Parameter Units 2015 MM 2025 MM 2030 MM Waste Activated Sludge Total Solids ppd 21,900 46,500 53,200 Flow gpd 524,000 1,113,900 1,275,800 Rotary Drum Thickeners BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 18 Table 5-6 Conceptual Design Criteria for RDTs Parameter Units 2015 MM 2025 MM 2030 MM Number of Units No. 3 (2 duty, 1 spare) 4 (3 duty, 1 spare) 4 (3 duty, 1 spare) Operation Schedule h/d/wk 24/7/52 24/7/52 24/7/52 Required HLR gpm/unit 180 260 300 Required SLR pph/unit 455 645 739 Solids Capture Rate % 95 Thickened Solids % 5 Polymer Use (active) lb/dt 5 - 10 (2) Solids Stabilization Alternative LM-1 –Anaerobic Digestion The facility requirements for implementing a conventional mesophilic digestion process at Lower Meramec WWTP with gravity co-thickening of PS and WAS will include four 1.4 million gallon (MG) digesters, providing a total retention time of approximately 14.6 days and 19.9 days at design maximum month and annual average flows, respectively. The anaerobic digesters will be operated as a two-stage system. Three of the digesters will operate as primary digesters followed by one secondary unit. The conceptual design criteria for the digestion facilities are summarized in Table 5-7. Table 5-7 Conceptual Design Criteria for Anaerobic Digesters (Alternative LM-1) Parameter Units 2015 MM 2025 MM 2030 MM Primary Digesters Number of Digesters No. 2 3 3 Volume per Digester MG 1.40 1.40 1.40 Diameter ft 90 90 90 SRT days 17.8 12.6 11.0 Cover Fixed Steel BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 19 Table 5-7 Conceptual Design Criteria for Anaerobic Digesters (Alternative LM-1) Parameter Units 2015 MM 2025 MM 2030 MM Mixing Pumped Secondary Digesters Number of Digesters No. 1 1 1 Volume per Digester MG 1.40 1.40 1.40 Diameter ft 90 90 90 SRT days 8.9 4.2 3.7 Cover Membrane Gas Holder Approximate Gas Storage cf 165,000 Mixing Pumped All the digesters will be mixed continuously to reduce stratification of digesting material and minimize scum layer formation. All the digesters will be equipped with pumped mixing systems. Pumped mixing consists of pumps, suction and discharge piping, and nozzles at the end of the discharge piping. The pumps are installed outside of the digester to facilitate maintenance and are typically “chopper” style pumps or incorporate in-line grinders, which break down solids and prevent clogging. The piping can be configured so that the pumps withdraw sludge from the digester at the top, bottom, or both. Mixing is promoted by discharging recycled sludge through nozzles mounted on the tank’s interior perimeter and aimed tangentially to the tank diameter. Nozzles are also provided to break up scum accumulations on the liquid surface of the digester. The high velocity nozzles can have helical or dual-zone mixing patterns depending on the manufacturer. The digesters will be heated using a decentralized heat delivery system. The raw sludge will be uniformly distributed among the primary digesters in service and individual heat exchangers will support the heating loads for each digester. The secondary digesters will also be equipped with external heat exchangers, pumps, and recirculation loops for heating so that they can function as a primary digester if needed. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 20 The digester gas from the digesters will be collected through a common header and stored in the membrane gas holder covers on the secondary digesters. The gas can be used in a boiler for meeting process and building heating needs or for cogeneration. Depending on the end-use option, the digester gas may require removal of water vapor, hydrogen sulfide and siloxanes. The anticipated performance of the anaerobic digestion system is summarized in Table 5-8. Table 5-8 Anaerobic Digester Performance (Alternative LM-1) Parameter Units 2015 MM 2025 MM 2030 MM Digester Feed Total Feed Solids ppd 39,300 83,600 95,800 Feed Solids Concentration % 3 3 3 Feed Flow gpd 157,200 334,200 382,700 Volatile Solids in Feed ppd 29,400 62,700 71,700 Organic Loading Rate ppd/1000 cf 78 112 128 Performance Parameters Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas and Energy Digester Gas Production scfd 198,200 423,300 484,100 Heating Value of Digester Gas Btu/scf 600 600 600 Gross Energy from Digester Gas mmBtu/d 119 254 290 Stabilized Solids Total Stabilized Solids ppd 26,100 55,400 63,500 Solids Concentration % 2 2 2 Digester Effluent Flow gpd 157,200 334,200 382,700 Alternative LM-2 – Anaerobic Digestion with Thickened WAS The facility requirements for implementing the conventional mesophilic digestion scheme at Lower Meramec WWTP will include three 1.8 million gallon (MG) digesters, providing a total BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 21 retention time of approximately 20.4 days and 27.6 days at design maximum month and annual average flows, respectively. The digester configuration and ancillary equipment will be identical to Alternative LM-1. The conceptual design criteria for the digestion facilities are summarized in Table 5-9. Table 5-9 Conceptual Design Criteria for Anaerobic Digesters (Alternative LM-2) Parameter Units 2015 MM 2025 MM 2030 MM Primary Digesters Number of Digesters No. 1 2 2 Volume per Digester MG 1.80 1.80 1.80 Diameter ft 100 100 100 SRT days 16.6 15.6 13.6 Cover Fixed Steel Mixing Pumped Secondary Digesters Number of Digesters No. 1 1 1 Volume per Digester MG 1.80 1.80 1.80 Diameter ft 100 100 100 SRT days 16.6 7.8 6.8 Cover Membrane Gas Holder Approximate Gas Storage cf 225,000 Mixing Pumped The anticipated performance of the anaerobic digestion system is summarized in Table 5-10. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 22 Table 5-10 Anaerobic Digester Performance (Alternative LM-2) Parameter Units 2015 MM 2025 MM 2030 MM Digester Feed Total Feed Solids ppd 40,400 85,900 98,400 Feed Solids Concentration % 4.5 4.5 4.5 Feed Flow gpd 108,700 231,100 264,700 Volatile Solids in Feed ppd 30,100 64,400 73,600 Organic Loading Rate ppd/1000 cf 125 134 153 Performance Parameters Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas and Energy Digester Gas Production scfd 203,500 434,600 497,100 Heating Value of Digester Gas Btu/scf 600 600 600 Gross Energy from Digester Gas mmBtu/d 122 261 298 Stabilized Solids Total Stabilized Solids ppd 26,900 57,000 65,300 Solids Concentration % 3 3 3 Digester Effluent Flow gpd 108,700 231,100 264,700 (3) Solids Dewatering The dewatering requirements for Alternative LM-1 and Alternative LM-2 were determined based on maintaining the existing BFPs. Alternative dewatering technologies were not evaluated. There are currently two existing Ashbrook 2m-BFPs at the Lower Meramec WWTP plant. One additional unit will be needed to meet the capacity requirements at 2030 design conditions. However, the existing BFPs are expected to reach the end of their useful life within the next 10 years. Therefore, the total project costs for this option will be based on replacing the existing BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 23 units with new BFPs in 2020. The preliminary design criteria for the dewatering equipment for Alternative LM-1 are listed in Table 5-11, below. Table 5-11 Design Criteria for Dewatering Equipment (Alternative LM-1) Parameter Units 2015 MM 2025 MM 2030 MM Digested Solids Total Solids ppd 26,100 55,400 63,500 Solids Concentration % 2 2 2 Flow gpd 157,200 334,200 382,700 Operation Schedule Hr/d/wk 24/5/52 Required HLR gpm 109 232 266 Required SLR pph 1,088 2,308 2,646 Belt Filter Presses Number of Units No. 2 3 3 Number of Operating Units No. 1 2 2 Number of New Units No. 0 1 1 HLR gpm/m/unit 55 58 67 SLR pph/m/unit 544 577 662 Thickened Solids % 17 Solids Capture Rate % 92 Polymer Use (active) lb/dt 10 - 15 The preliminary design criteria for the dewatering equipment for Alternative LM-2 is listed in Table 5-12, below Table 5-12 Design Criteria for Dewatering Equipment (Alternative LM-2) Parameter Units 2015 MM 2025 MM 2030 MM Digested Solids Total Solids ppd 26,900 57,000 65,300 Solids Concentration % 3 3 3 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 24 Table 5-12 Design Criteria for Dewatering Equipment (Alternative LM-2) Parameter Units 2015 MM 2025 MM 2030 MM Flow gpd 108,700 231,100 264,700 Operation Schedule hr/d/wk 24/5/52 Required HLR gpm 75 160 184 Required SLR pph 1,121 2,375 2,721 Belt Filter Presses Number of Units No. 2 3 3 Number of Operating Units No. 1 2 2 Number of New Units No. 0 1 1 HLR gpm/m/unit 38 40 46 SLR pph/m/unit 561 594 681 Thickened Solids % 18 Solids Capture Rate % 92 Polymer Use (active) lb/dt 10 - 15 (4) Cake Storage and Loadout Additional storage silos will be provided for dewatered cake storage for Alternative LM-1 and Alternative LM-2, both of which involve cake hauling to end-use or disposal sites. For purposes of this evaluation, cake storage requirements were based on 8 hours per day, 5 days per week hauling to the landfill or the end-use sites. The existing sludge storage/truck loading silos at the WWTP will provide approximately 11 hours storage at design maximum month conditions. Additional cake storage will be required to facilitate a 5-day cake hauling schedule. The dewatering and cake loadout facilities will be vented to odor control scrubbers. The conceptual design criteria for the cake storage facilities for the two alternatives are listed in Table 5-13. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 25 Table 5-13 Design Criteria for Cake Storage Silos (Alternative LM-1) Parameter Units 2015 MM 2025 MM 2030 MM Dewatered Solids (5-day Basis) Total Solids ppd 34,600 73,400 84,100 Solids Concentration % 17 17 17 Density of Dewatered Cake lb/cy 1,500 1,500 1,500 Volume of Solids cy/d 135 288 330 Storage Silos Solids (7-day Basis) cy/d 96 206 236 Storage Required days 4 4 4 cy 384 824 944 Existing Silos (total) cy 108 Storage in Existing Silos hrs 27 13 11 Additional Storage Required cy 276 716 836 Number of Silos No. 1 3 3 Volume (each) cy 280 280 280 (5) Energy Recovery The digester gas production at design conditions was based on an estimated volatile solids concentration of 75 percent in the mixed solids and a volatile solids reduction of 45 percent in the digesters. Gas production was estimated using a biogas yield of 15 standard cubic feet per pound (scf/lb) of volatile solids destroyed. The energy computations were based on a heating value of 600 British thermal units per standard cubic foot (Btu/scf) of digester gas. The estimated digester gas quantities for each alternative are summarized in Table 5-14. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 26 Table 5-14 Anaerobic Digester Performance Parameter Units 2030 Max. Month 2030 Ann. Average Alternative LM-1 Volatile Solids in Digester Feed ppd 71,700 52,800 Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas Production scfh 20,200 14,900 Methane Content % 60 60 Heating Value of Digester Gas Btu/scf 600 600 Gross Energy from Digester Gas mmBtu/h 12.1 8.9 Alternative LM-2 Volatile Solids in Digester Feed ppd 73,600 54,200 Volatile Solids Reduction % 45 Digester Gas Yield scf/lb VSR 15 Digester Gas Production scfh 20,700 15,200 Methane Content % 60 60 Heating Value of Digester Gas Btu/scf 600 600 Gross Energy from Digester Gas mmBtu/h 12.4 9.1 Digester gas production at design average conditions was used for sizing the gas cleaning and utilization equipment. The excess gas flows during maximum month conditions will be flared without treatment. (6) Digester Gas Utilization Technologies Digester gas can be collected, stored, and converted to electricity using on-site power generation equipment. Additionally, heat can be recovered from the power generation units in the form of hot water or steam for use in heating digesters and/or for building heating. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 27 The available on-site power generation technology options vary with respect to size, fuel requirements, efficiency, costs, and their overall compatibility with the existing facilities. The options range from traditional engine-generators and gas turbine generators to recently developed microturbines and fuel cells. Internal combustion engines are by far the most common generating technology choice. About 80 percent of the power generation facilities at WWTPs use reciprocating engines. Gas turbines have also been used for power generation, but are typically used at larger WWTPs. Microturbines, which are modular combustion turbines with capacities less than 250 kW, are being used more because of their low air emissions. Fuel cells have also gained interest, as a result of their extremely low air emissions. Based on the scale of operation, the combined heat and power (CHP) technology options for Lower Meramec are limited to engine-generators and microturbine generators. Engine-Generators Engine-generators are the most commonly used means of on-site power generation at wastewater treatment plants, with unit capacities ranging from 130 kW to 2,000 kW. The equipment typically consists of a skid-mounted package of a reciprocating engine, generator and a control panel. The popularity of engine-generators is attributed to availability from multiple suppliers and familiarity of plant maintenance personnel with engines that resemble an automobile engine. The engine is a spark-ignited natural gas engine modified and derated for use with the low-Btu digester gas. Originally engines using digester gas as fuel were naturally aspirated, which produced low mechanical efficiencies and high emissions. Engine manufacturers have developed newer turbocharged, lean-burn engines which have higher efficiencies, lower air emissions, and operate at low gas pressures. The engines typically operate at speeds up to 1,800 rpm. Heat can be recovered from the engine’s jacket water and from the exhaust gases. The recovered heat can be used to generate hot water for process and building heating requirements. Heat not recovered for useful purposes from the engine jacket water is removed in an engine cooling BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 28 exchanger by circulating water from a cooling tower or by using a radiator to cool the jacket water to the required temperature. Engine-generators are typically housed in a building where they are accessible for servicing, but may also be installed outdoors in an acoustic enclosure. The digester gas has to be treated to remove hydrogen sulfide (H2S) and siloxanes before use in engine-generators. The typical H2S and siloxane concentration limits recommended by engine manufacturers are listed in Table 5-16. Where the contaminants have been removed from digester gas, engine owners report maintenance efforts similar to those for an engine operating on natural gas; a substantial reduction in the frequency and cost of maintenance compared to units operating on untreated digester gas. The typical maintenance requirements for an engine-generator include monthly oil changes, top end overhauls every 2 years, and major engine rebuilds every 3 to 5 years. The estimated downtime is approximately 8 hours for oil changes, one week for top end overhauls, and two weeks for major rebuilds. Microturbines Microturbines are a relatively new technology for on-site power generation at wastewater plants, with the first commercial units installed in 1998. Combustion turbines have been operated with digester gas in the past, but the minimum capacity is approximately 1,000 kW. Microturbines are small combustion turbines, with capacities ranging from 30 to 250 kW. For increased capacities, multiple microturbines can be installed in parallel. They are available as modular packaged units that include the combustor, turbine, generator, cooling and heat recovery equipment. Microturbines are attractive for small plants, making on-site generation available to plants that formerly did not have this choice. Digester gas is compressed and burned with air in the combustor, generating heat that causes the gases to expand. The expanding gases drive the turbine, which in turn drives a generator producing electricity. Heat from the turbine exhaust is recovered in the recuperator and is used to preheat incoming combustion air. This helps improve the overall operating efficiency of the unit. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 29 Microturbines have lower efficiencies than engine-generators. The efficiencies are reduced further when operating at higher inlet temperatures. Microturbines produce minimal noise and have lower emissions when compared to engine-generators. The units may also be provided with an acoustic enclosure for further noise reduction. Microturbines require higher levels of gas treatment compared to engine-generators and inlet pressures ranging from 75 to 100 pounds per square inch (psi). The contaminant limits recommended by microturbine manufacturers are listed in Table 5-16. The maintenance requirements for a microturbine include lining and fuel injector replacement every 2 years and complete turbine replacement every 5 years. The estimated downtime for scheduled maintenance is approximately 3 weeks. Table 5-15 presents a comparison of typical unit sizes, efficiencies, fuel consumption, heat recovery rates, and maintenance requirements for engine-generators and microturbine generators. Because of their high initial cost and minimal experience operating on digester gas, fuel cells were not evaluated further. Table 5-15 Digester Gas Utilization Equipment Comparison Parameter Units Engine-Generators Microturbines Inlet Gas Pressure Required psig 1 to 5 75 to 100 Performance Efficiency Range % 25 to 40 25 to 30 Heat Recovery % 40 to 50 30 to 40 Overall Efficiency % 65 to 90 55 to 70 Typical Maintenance Top end overhaul hr Every 16,000 -- Bottom end overhaul hr Every 32,000 -- BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 30 Table 5-15 Digester Gas Utilization Equipment Comparison Parameter Units Engine-Generators Microturbines Lining and Fuel Injector replacement hr -- Every 15,000 Turbine replacement hr -- Every 30,000 Emissions NOx1 ppmv Approx. 65 ppmv Approx. 9 ppmv 1 Based on using natural gas as fuel (7) Digester Gas Cleaning Requirements Digester gas is composed primarily of methane (CH4) and carbon dioxide (CO2), but can also contain impurities such as hydrogen sulfide (H2S) and organic silicon compounds known as siloxanes. The gas is also saturated with moisture at the operating temperature of the digesters with more moisture present at higher operating temperatures. If left untreated, the moisture and contaminants will increase the maintenance requirements for the gas utilization equipment and reduce their useful life. Since Lower Meramec WWTP does not currently have digesters, typical contaminant concentrations observed at other facilities were used as the basis for sizing the gas cleaning system. The digester gas quality used for cleaning system sizing is summarized in Table 5-16. Gas sampling, if it can be arranged, is recommended prior to design to confirm the contaminant concentrations. Table 5-15 Digester Gas Quality Equipment Units Max. Month Hydrogen Sulfide ppmv 1,500 mg/m3 2,130 Siloxanes ppbv 3,000 mg/m3 38 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 31 Digester gas cleaning requirements are based on the end use of the gas and the type of gas utilization equipment. Based on the capacity requirements, only engine-generators and microturbine generators were identified for digester gas utilization at the Lower Meramec WWTP. Recommended gas quality requirements for these technologies were obtained from equipment suppliers and are listed in Table 5-17. Table 5-16 Gas Quality Requirements for Gas Utilization Equipment Contaminants Units Raw Gas Engine-Generators Microturbines Moisture -- Saturated at 95oF 40ºF dew point min. 18ºF dew point min. H2S ppmv 1,500 Less than 1,0001 Less than 5,0001 Siloxanes ppbv 3,000 Less than 4002 Less than 5 1 Less than 50 ppmv recommended for maintaining siloxane media performance 2 Engines without catalysts. Limit is 150 ppb for engines with catalysts The H2S concentrations listed above are the maximum values recommended by the equipment suppliers. However, the gas cleaning process is limited by the absorptive selectivity of the media used for siloxane removal. The siloxane removal media is generally limited to a maximum inlet H2S concentration of 50 ppmv. The maximum desired siloxanes concentration was established based on standards recommended by the engine suppliers for engines without catalytic converters. It is not expected, but if catalytic converters are required, a more rigorous gas treatment process may be required. The digester gas cleaning systems were sized to handle the design average gas flow of 148,500 scfd. The capacity requirements and costs of the gas treatment systems typically depend on several variables, including the quantity of gas treated, the initial concentration of contaminants, and the final concentration of contaminants in the gas to meet the quality requirements for the gas utilization equipment. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 32 (8) Exhaust Emissions Any new digester gas utilization equipment will need to be permitted with the Missouri Department of Natural Resources as a new emission source. Nitrogen oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) are typically the main emission concerns with onsite power generation units. EPA’s 40CFR Part 60, JJJJ addresses standards of performance for stationary spark ignition internal combustion engines operating on digester gas or natural gas and the dates these limits will take effect. Table 5-18 outlines the proposed limits and the effective dates. Table 5-17. Emission Limits, pounds/brake horsepower-hr (lb/bhp-hr) Fuel NOx CO VOC Effective Date Digester Gas 2.0 5.0 1.0 Jan 1, 2011 Natural Gas 1.0 2.0 0.7 Jan 1, 2011 Additionally, EPA has regulations for facilities with the potential to emit, which are the total emissions if the equipment is operated continuously. The limits for NOx and VOC are set at 40 tons per year each and for CO at 100 tons per year. If these limits are exceeded for the facility, then addition permitting will be required. d. Final Use and Disposal Option The District currently hauls dewatered cake from the WWTP to a landfill for disposal. With anaerobic digestion the additional final use options available to the District will include land application of Class B biosolids and/or hauling to a third-party facility for composting. These two final use options will be evaluated alongside landfill disposal of dewatered solids for the two processing alternatives. 5. Staffing Requirements Table 5-19 lists the anticipated staffing requirements for each of the alternatives. These staffing requirements are for the new biosolids processing facilities only and do not include the existing BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 33 processes. It is assumed that hauling and disposal of dewatered cake will be handled by a third- party contractor and will not require MSD staff. Table 5-18 Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs Alternative LM-1 – Gravity Thickening Supervisor 1 2 1.0 5 52 520 Operator 1 2 3.0 7 52 2,184 Maintenance 1 4 1.0 5 52 1,040 Alternative LM-2 – Mechanical Thickening Supervisor 1 2 1.0 5 52 520 Operator 1 4.5 3.0 7 52 4,914 Maintenance 1 6 1.0 5 52 1,560 6. Cost Summary Table 5-20 presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were developed based on the descriptions of alternatives and options presented in Section 3.0. Detailed costs and benefits for each of these options are presented in Technical Memorandum No.9 - Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. Table 5-19 Opinions of Costs, Savings and Life Cycle Costs Alternative LM-1 Gravity Thickening LM-2 Mechanical Thickening Capital Costs $40,553,000 $44,720,000 Salvage Value $5,275,000 $4,944,000 Annual O&M Costs $1,850,000 $2,057,000 Annual Revenue ($213,000) ($213,000) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 34 Table 5-19 Opinions of Costs, Savings and Life Cycle Costs Alternative LM-1 Gravity Thickening LM-2 Mechanical Thickening Life Cycle Costs Capital Costs $40,553,000 $44,720,000 Salvage Value ($1,988,000) ($1,863,000) Annual O&M Costs $23,055,000 $25,635,000 Revenue ($2,654,000) ($2,654,000) Total Life Cycle Costs $58,970,000 $65,840,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Lower Meramec WWTP Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 35 Appendix A Detailed Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 1 TECHNICAL MEMORANDUM NO. 6 – REGIONAL FACILITY SOLIDS PROCESSING ALTERNATIVES EVALUATION To: Metropolitan St. Louis Sewer District From: Jim Rowan, Gustavo Queiroz, Patricia Scanlan, Hari Santha This Technical Memorandum presents information on the solids processing and management options evaluated for the Regional Solids Processing Facility as part of developing a strategic plan for long-term management of biosolids. The following sections describe the proposed biosolids management system, the solids quantities used as the basis of the evaluation, the treatment and final use options evaluated for the Regional Facility. Table of Contents 1. Regional Facility – R-1 .............................................................................................................. 4 2. Solids Quantities ........................................................................................................................ 4 3. Solids Processing Evaluation ..................................................................................................... 6 4. Technologies for Solids Processing Evaluation ......................................................................... 7 a) Solids Receiving – R-1 ........................................................................................... 7 a. Thickening and Dewatering .................................................................................. 10 b. Incinerator Systems ............................................................................................... 10 (1) Fluidized Bed Incinerator System – R-1 .................................................................... 10 (2) Primary and Secondary Heat Exchangers – R-1 ........................................................ 12 (3) Air Pollution Control Equipment – R-1 ..................................................................... 13 (4) Ash Handling System – R-1 ....................................................................................... 14 (4) Fluidizing Air Blowers – R-1 ..................................................................................... 16 (5) Fuel Storage Tank and Pumps – R-1 .......................................................................... 16 (6) Sand System – R-1 ..................................................................................................... 18 c. Energy Recovery Options ..................................................................................... 18 (1) Steam Generation – Steam Sale to Trigen Option R-1-A .......................................... 19 (2) Waste Heat Boilers - R-1-A........................................................................................ 20 (3) Water Treatment System - R-1-A ............................................................................... 21 (4) Power Generation Option - R-1-B .............................................................................. 22 (5) Waste Heat Boiler - R-1-B ......................................................................................... 23 (6) Steam Turbine Generator - R-1-B .............................................................................. 25 (7) Steam Condenser - R-1-B ........................................................................................... 26 (8) Cooling Water Heat Exchangers - R-1-B ................................................................... 26 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 2 (9) Condensate Handling System - R-1-B ........................................................................ 28 (10) Water Treatment System - R-1-B ........................................................................... 29 d. Future Advanced Air Pollution Control - R-1-C .................................................. 29 (1) Conditioning Tower - R-1-C ...................................................................................... 32 (2) Carbon Injection and Storage - R-1-C ........................................................................ 33 (3) Fabric Filters - R-1-C ................................................................................................. 34 (4) Dry Ash System - R-1-C ............................................................................................ 35 (5) Induced Draft Fans - R-1-C ........................................................................................ 36 5. Layout Plans............................................................................................................................. 36 6. Site Plan ................................................................................................................................... 36 7. Staffing Requirements ............................................................................................................. 37 8. Cost Summary .......................................................................................................................... 37 9. Total System ............................................................................................................................ 38 (1) Alternative S-2 Lemay Hauling .............................................................................................. 41 (2) Alternative S-3 Lemay Pump Station...................................................................................... 43 c. Cost Summary ....................................................................................................................... 45 List of Tables Table 6-1 Projected Solids Quantities ............................................................................................. 5Table 6-2 Solids Processing Equipment ......................................................................................... 7 Table 6-3 Cake Receiving and Cake Pump Design Criteria ........................................................... 9 Table 6-4 Fluidized Bed Incinerator Design Criteria ................................................................... 11 Table 6-5 Primary and Secondary Heat Exchangers Design Criteria ........................................... 13Table 6-6 Wet Scrubber Design Criteria ...................................................................................... 14Table 6-7 Ash Slurry System Design Criteria .............................................................................. 15 Table 6-8 Fluidizing Air Blower Design Criteria ......................................................................... 16 Table 6-9 Fuel Oil Storage Tank and Pumps Design Criteria ...................................................... 17 Table 6-10 Sand System Design Criteria ...................................................................................... 18Table 6-11 Waste Heat Boiler Design Criteria ............................................................................. 20Table 6-12 Packaged Water Treatment Design Criteria ............................................................... 22 Table 6-13 Waste Heat Boiler Design Criteria (for Power Generation) ....................................... 23 Table 6-14 Steam Turbine Generator Design Criteria .................................................................. 25 Table 6-15 Steam Condenser and Condensate Pumps Design Criteria ........................................ 26Table 6-16 Cooling Water Heat Exchanger Design Criteria ........................................................ 27Table 6-17 Condensate Handling System Design Criteria ........................................................... 28 Table 6-18 Packaged Water Treatment Design Criteria ............................................................... 29 Table 6-19 Gas Conditioning Equipment Design Criteria ............................................................ 32 Table 6-20 Carbon System Design Criteria .................................................................................. 33Table 6-21 Fabric Filter Design Criteria ....................................................................................... 34Table 6-22 Dry Ash System Design Criteria ................................................................................ 35 Table 6-23 Induced Draft Fan Design Criteria ............................................................................. 36 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 3 Table 6-24 Staffing Requirements ................................................................................................ 37 Table 6-25 Costs Summary of Regional Facility ($1000) ............................................................ 38 Table 6-26 Base Case Solids Treatment Schemes for Individual Plants ...................................... 39Table 6-27 Modifications Required to the Base Case Treatment Options at Individual Plants for Implementing the Regional Total System S-2 .............................................................................. 41 Table 6-28 Total System Costs Summary ($1000) ....................................................................... 45 List of Figures Figure 6-1 Solids Process Flow Diagram ....................................................................................... 4 Figure 6-2 Solids Receiving ............................................................................................................ 8 Figure 6-3 Fluidized Bed Incinerator System ............................................................................... 11Figure 6-4 FBIs with Optional Steam Generation – R-1-A .......................................................... 19Figure 6-5 FBI with Optional Power Generation – R-1-B ........................................................... 23 Figure 6-6 Advanced Air Pollution Control System w/ Mercury Scrubbing ............................... 31 Figure 6-7. Solids Process Flow Chart for Decentralized (No Regional) Treatment S-1 ............. 40 Figure 6-8 Solids Process Flow Chart for Alternative S-2 Lemay Hauling ................................. 43Figure 6-9. Solids Process Flow Chart for Alternative S-3 Lemay Pump Station ...................... 44 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 4 1. Regional Facility – R-1 The Regional Facility will receive dewatered solids from Lower Meramec, Missouri River, Coldwater, Lemay and Bissell Point WWTPs. The new Regional Facility will be located in the existing Bissell Point WWTP site (refer to Appendix A, Figure A-1 for the proposed facility location). The dewatered solids from Lemay, Missouri River and Lower Meramec will be hauled to the site while solids processed at the Bissell Point facility (including Coldwater solids) will be pumped to a new Dewatering Building adjacent to the new Solids Processing Building for dewatering and further processing. Figure 6-1 illustrates the overall process flow diagram for the Regional Facility. Figure 6-1 Solids Process Flow Diagram 2. Solids Quantities The solids quantities used for this evaluation were carried forward from Phase I – TM 2: Facility Summaries and Solids Projections for all plants with exception of the Bissell Point and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 5 Coldwater WWTPs. Solids quantities for the Bissell Point WWTP (including Coldwater WWTP solids) were estimated using wastewater treatment process models. Solids quantities for all plants are presented in Table 6-1 below. Table 6-1 Projected Solids Quantities Parameter Units Max. Month Ann. Avg. Bissell Point and Coldwater WWTPs Total Solids dtpd 125.7 89.1 Volatile Solids Fraction % of TS 58.0 58.2 Volatile solids dtpd 73.0 51.9 Lemay WWTP Total Solids dtpd 94.0 51.1 Volatile Solids Fraction % of TS 45.5 50.5 Volatile solids dtpd 42.8 25.8 Missouri River WWTP Total Solids dtpd 58.0 47.7 Volatile Solids Fraction % of TS 80.2 80.1 Volatile solids dtpd 46.5 38.2 Lower Meramec WWTP Total Solids dtpd 53.2 39.2 Volatile Solids Fraction % of TS 74.9 75.1 Volatile solids dtpd 39.9 29.4 Total Solids Total Solids dtpd 331.0 227.0 Volatile Solids Fraction % of TS 61.0 64.0 Volatile solids dtpd 202.2 145.3 Solids Concentration % 25.0 25.0 Dewatered solids received at the Regional Facility will vary in total solids (TS) concentration and volatile organic composition depending on each plant’s treatment processes. A solids BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 6 concentration of 25 percent TS was used for equipment sizing throughout this evaluation to ensure that sufficient operating and storage volume is provided during low percent TS conditions from the various plants. The expected volatile solids (VS) concentrations in the Bissell Point and Lemay solids are relatively low. The low volatile solids concentration appears to be a result of a high concentration of inorganic material from inflow and/or infiltration for these plants during high flow events. The maximum month (MM) quantities were used as the basis for equipment sizing at the Regional Facility. The mid-point (10-year) annual average quantities were used as the basis for determining the operations and maintenance (O&M) costs for the evaluation. The mid-point average solids quantities are identical to the future annual average solids production since the watersheds for all the plants are mature with minimum future growth. Criteria used for equipment sizing for the regional facility are listed below.  All solids quantities listed in Table 6-1 are as raw solids.  Thickening and dewatering capture rates of 100 percent were used for this evaluation.  A dewatered cake concentration of 25 percent TS was used for equipment sizing.  The biosolids receiving cake storage is sized to provide 3 days storage at annual average conditions. 3. Solids Processing Evaluation The solids management processes for the Regional Facility were developed based on discussions with the District staff and site visits to the treatment plants. This evaluation included new solids processing facilities consisting of cake receiving and handling facilities, incinerator feed pumps, fluidized bed incinerators (FBIs), air pollution control systems and heat recovery. The air pollution control system evaluation includes options for mercury removal and dry ash handling. The heat recovery evaluation includes steam generation and sale to Trigen, a local utility provider and on-site power generation. Refer to Appendix B of this report for detailed process flow schematics. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 7 Implementation of a Regional Solids Processing Facility will require completely new equipment. A summary of the new equipment for the Regional Facility is presented in Table 6-2. Table 6-2 Solids Processing Equipment Cake Receiving and Handling Dewatered Cake Equalization Bins Incinerator Cake Feed Pumps Fluidized Bed Incinerators Air Pollution Control (Wet Scrubber) Advanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling) Odor Control 4. Technologies for Solids Processing Evaluation The solids processing technologies selected for the Regional Facility are discussed in the following sections. a) Solids Receiving – R-1 Dewatered cake will be hauled from the Lemay, Missouri River and Lower Meramec plants using end-dump trucks or trailers. Trucks will enter the 3-bay, enclosed unloading area through overhead doors that are controlled using an identification system, such as a card reader. Hauled cake will be discharged into the solids receiving pit. The solids receiving pit will extend below grade and be separated from the truck unloading area by a short wall, 30 inches tall, which will block trucks from backing into the receiving pit. An overhead bridge crane equipped with a clamshell style bucket will traverse the entire area of the solids pit and will be used to transfer the cake to one of three equalization bins upstream of incineration. Cake transfer will be controlled by an operator in a control room overlooking the biosolids pit. The cake transfer process will be limited to periods when trucks are not unloading. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 8 Each equalization bin will use a sliding frame type live bottom to prevent cake bridging. The equalization bins will discharge to a collection screw conveyor below the sliding frame. The collection screw will feed one of two piston type cake pumps (1 duty, 1 standby). Each piston pump will contain two discharge outlets to evenly split the flow of cake to an incinerator. Figure 6-2 illustrates the receiving process operation. Figure 6-2 Solids Receiving Preliminary equipment design information for the cake receiving facility and cake feed pumps is listed in Table 6-3. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 9 Table 6-3 Cake Receiving and Cake Pump Design Criteria Equipment Units Specifications Solids Receiving Pit Number of Units No. 1 Size Length Width Depth ft ft ft 130 50 15 Capacity1 wt 2,700 Days of Storage (MM Conditions) days 2 Days of Storage (AA Conditions) days 3 Bridge Crane with Clamshell Number of Units No. 2 Bridge crane type Double girder Bridge crane capacity tons 20 Clamshell capacity cy 10 Equalization Bins Number of Units No. 3 Type Vertical cylinders with sliding frame Size Diameter Height ft ft 15 20 Useable capacity dt 30 Cake Pumps Number of Units No. 6 Capacity dtph 5 Flow (each) gpm 85 1 Capacity based on AA conditions at 25 %TS. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 10 a. Thickening and Dewatering No thickening will be provided at the Regional Facility. All thickening will occur at the individual treatment plants. A Dewatering Building will be located adjacent to the Solids Processing Building to dewater sludge pumped from the Bissell Point plant. All other dewatering will occur at the individual treatment plants. b. Incinerator Systems Incinerator systems process dewatered cake by means of high temperature thermal oxidation (combustion). The dewatered cake is pumped to the incinerators that oxidize the organic (volatile) fraction, generating exhaust gases and ash. Descriptions for incinerator system components are presented in the following sections. (1) Fluidized Bed Incinerator System – R-1 Three fluidized bed incinerator (FBI) trains will be installed in the new Solids Processing Building as part of the Regional Facility. Each incinerator vessel will consist of three zones: hot windbox, sand bed, and freeboard. Preheated fluidizing air will be directed into the windbox and distributed to the bed through tuyeres in a refractory arch. The air will fluidize the sand bed above the refractory arch and will provide combustion air for the process. Dewatered cake will be pumped into the incinerator through multiple injection nozzles and into the sand bed. Auxiliary fuel injection lances (fuel oil or natural gas) will provide supplemental fuel, if needed. All exhaust gases, including combustion products and ash, will exit the fluidized bed incinerator through the freeboard and exhaust gas duct. Figure 6-3 illustrates the proposed FBI system. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 11 Figure 6-3 Fluidized Bed Incinerator System The incinerators are sized such that two of the three incinerator trains must be operated to process annual average solids quantities. All three incinerators must be operated to support maximum month solids quantities. No spare capacity is provided at maximum month conditions. Preliminary equipment design information for the FBIs is listed in Table 6-4. Table 6-4 Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Fluid Bed Incinerators Number of Units No. 3 Required Capacity (each) dtpd 120 Incinerator Vessel Type Refractory lined w/ refractory BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 12 Table 6-4 Fluidized Bed Incinerator Design Criteria Equipment Units Specifications Windbox arch Hot Air Size Diameter Height ft 34 45 Wall Construction Inner layer of walls and dome Outer layer of walls and dome Refractory Brick Insulated Fire Brick Number of Solids Feed Nozzles No. Multiple around periphery, 4 minimum Auxiliary Fuel Source Natural Gas and Fuel Oil Minimum Natural Gas Pressure psig 10 Discharge Temperature oF 1,500 - 1,650 max Preheat Provisions Preheat supplied by natural gas or fuel oil fired burner (2) Primary and Secondary Heat Exchangers – R-1 Primary and secondary heat exchangers will recover waste heat from the exhaust gases. The primary heat exchanger will transfer heat from the incinerator exhaust gases to the fluidizing air. A primary heat exchanger bypass (with damper) will control the temperature of the fluidizing air and heat recovery. This “hot windbox” design will reduce the amount of auxiliary fuel required for combustion and, in some cases, may allow autogenous (without additional fuel) combustion. Following the primary heat exchanger, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas. Heating the scrubber outlet gas prior to discharge to the atmosphere will help suppress visible plumes in the incinerator exhaust. The secondary heat exchanger may also be used to pre-heat exhaust to future emission control equipment. Preliminary equipment design information for the primary and secondary heat exchangers is shown in Table 6-5. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 13 Table 6-5 Primary and Secondary Heat Exchangers Design Criteria Equipment Units Specifications Primary Heat Exchanger Number of Units No. 3 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Fluidizing air in Fluidizing air out oF 1,650 1,200 60 1,030 Size Vessel Diameter Height ft 12 30 Design Pressure psig 10 Secondary Heat Exchanger Number of Units No. 3 Type Shell and Tube Configuration Vertical, Counterflow Design Temperatures Exhaust gas in Exhaust gas out Scrubber outlet gas in Scrubber outlet gas out oF 1,200 1,050 100 300 Design Pressure psig 10 (3) Air Pollution Control Equipment – R-1 Exhaust gases leaving the secondary heat exchangers will be directed to the air pollution control equipment. Air pollution control equipment will include quench sprays and wet scrubbers. The quench spray section will consist of multiple water sprays used to cool the exhaust gases prior to entering the wet scrubber. The new scrubber will be a vertical upflow unit with impingement trays used for cooling and saturating the gas, followed by a multiple fixed venturi section with BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 14 water injection and mist eliminators with sprays. Plant effluent water will be used for the impingement trays. Strained plant effluent water will be used for the venturi injection and high pressure spray lances. Service water (potable water downstream of a backflow preventer) will be used for the mist eliminator sprays. Booster pumps will be supplied with the scrubbers for venturi and high pressure spray lance water injection. Strained plant effluent water is required for the venturi injection and high pressure spray lances to prevent nozzle clogging while potable water is required for the mist eliminator to prevent fouling. Preliminary equipment information for the wet scrubber is shown in Table 6-6. (4) Ash Handling System – R-1 For FBIs, a small fraction of the ash is collected at the waste heat boilers (for power generation option only) while the majority of the ash is removed by the wet scrubber. Table 6-6 Wet Scrubber Design Criteria Equipment Units Specifications Wet Scrubbers Number of Units No. 3 Type Combined Impingement Tray, and Multiple Fixed Venturis Configuration Vertical, Upflow Dimensions, ft Diameter Height ft 14 30 Water Requirements (per scrubber) Quench Sprays Under Tray Sprays Impingement Trays Venturi Section Mist Eliminator gpm 150 100 1,650 200 15 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 15 A new ash slurry system including ash slurry pumps and slurry tanks is recommended to handle the ash slurry from the bottom of the scrubber. The new ash slurry system will collect the scrubber drain water including the ash and transfer it to the existing ash lagoons. Preliminary equipment design information for the ash slurry system is listed in Table 6-7. Table 6-7 Ash Slurry System Design Criteria Equipment Units Specifications Ash Slurry Tanks Number of Units No. 3 Material Handled FBI and WHB fly ash Tank Dimensions Length Width Height ft 15’-0” 10’-0” 8’-0” Ash Slurry Concentration % 0.5 to 1 Ash Slurry Pumps Number of Units (per incinerator) No. 6 (3 Duty, 3 Standby) Material Handled Ash Slurry Incinerator Ash Flow Rate pph 4,000 Maximum Flow Rate at Maximum Speed gpm 1,600 Minimum Flow Rate at Reduced Speed gpm 800 Discharge Point Ash Lagoons Discharge Head at Maximum Flow ft 100 Motor hp 70 1 Ash flow rate based on low volatile (60% VS) condition and incinerator capacity. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 16 (4) Fluidizing Air Blowers – R-1 Each incinerator will have a dedicated blower to supply fluidizing air. The fluidizing air will be drawn from outside the Solids Processing Building, and will be preheated in the primary heat exchanger before entering the FBI windbox. Fluidizing air serves two purposes: to suspend the solids in the incinerator bed and to provide combustion air. Preliminary equipment design information for the fluidizing air blowers is shown in Table 6-8. Table 6-8 Fluidizing Air Blower Design Criteria Equipment Units Specifications Fluidizing Air Blowers Number of Units No. 3 Type Multiple-Stage Centrifugal Drive Direct Required Flow scfm 13,000 Flow Adjustment Inlet Damper Pressure Rise psig 8 Motor hp 700 (5) Fuel Storage Tank and Pumps – R-1 Fuel oil will be delivered to the site by tankers and stored in an above ground storage tank located next to the new Solids Processing Building. Fuel oil transfer pumps will be installed in the fuel oil storage area to transfer fuel oil from the storage tank to a day tank. A second set of pumps, fuel oil feed pumps, will be used to transfer fuel oil from the day tank to each incinerator. The fuel oil, which will be used for supplemental fuel during incinerator warm up, will be injected into the incineration process through fuel injection lances. Preliminary equipment design information for the fuel storage tank and pumps is shown in Table 6-9. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 17 Table 6-9 Fuel Oil Storage Tank and Pumps Design Criteria Equipment Units Specifications Fuel Oil Tank Number of Tanks No. 1 Type Double wall, above ground Tank Size Diameter Length ft 12 30 Volume gal 20,000 Fuel Oil Transfer Pumps Number of Units No. 2 (1 Duty, 1 Standby) Type Gear Required Flow gpm 60 Minimum Discharge Pressure psi 5 Motor hp 1 Fuel Oil Day Tank Number of Tanks No. 1 Tank Size Diameter Height ft 6 10 Volume gal 1,600 Fuel Oil Injection Pumps Number of Units No. 3 (2 Duty, 1 Standby) Type AFD, Gear Type Required Flow gpm 4 Minimum Discharge Pressure psi 50 Motor hp 0.5 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 18 (6) Sand System – R-1 Sand will be delivered to the site by truck and stored in indoor sand storage tanks. Pneumatic transporters will convey sand from the sand storage tank to each of the FBIs to replenish sand entrained in the exhaust gas stream. Preliminary equipment design information for the sand storage system is shown in Table 6-10. Table 6-10 Sand System Design Criteria Equipment Units Specifications Storage Tanks Number storage tanks No. 2 Type Vertical with dual conical base Volume1 cf 360 Storage months 1 to 9 Size Diameter Total Height2 ft 9 45 Transporters Number of Pneumatic Transporters No. 2 (per storage tank) Compressed Air Requirements Flow, scfm Pressure range, psig scfm psig 150 100-120 1 Silo capacity based on sand demand of 50 lbs/hr for two incinerators. Feed rate for make up sand range from 5 to 50 lbs/hr. 2 Silo height includes clearances for transport and dust collection equipment. c. Energy Recovery Options Waste heat from the exhaust gases will be used to generate steam in the waste heat boilers. Two end use options for the steam have been evaluated: a) Medium pressure saturated steam for sale to Trigen; b) High pressure superheated steam for power generation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 19 (1) Steam Generation – Steam Sale to Trigen Option R-1-A For this option, waste heat will be used to generate medium pressure steam that will be sold to Trigen. The waste heat remaining in the flue gas downstream of the primary heat exchangers will be used in waste heat boilers to generate steam. Exhaust gas from the waste heat boiler will be treated by the secondary heat exchanger. Heat removed from the exhaust gas will be transferred to the scrubber outlet gas for plume suppression. Figure 6-4 illustrates the proposed steam generation option. Ultimately a pipeline would need to be constructed along an existing right-of-way corridor in order to convey steam from the Regional Facility to the Trigen Facility located near Laclede’s Landing. It is anticipated that ownership and funding for the construction of this line will be negotiated in the future between MSD and Trigen. Figure 6-4 FBIs with Optional Steam Generation – R-1-A BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 20 (2) Waste Heat Boilers - R-1-A Flue gases from each FBI will be ducted to waste heat boilers. The waste heat boilers will recover heat from the incinerator exhaust gases to produce medium pressure saturated steam. A bypass will be provided around the waste heat boilers to allow the steam production equipment to be taken out of service without affecting incinerator operation. Preliminary equipment design criteria for the waste heat boilers are shown in Table 6-11 Table 6-11 Waste Heat Boiler Design Criteria Equipment Units Specifications Waste Heat Boilers Number No. 3 Type Water Tube Flue Gas Conditions Flue Gas Pressure psia 14.7 Flue Gas Inlet Temperature oF 1,150 Flue Gas Outlet Temperature oF 500 Design Flue Gas Flow1 pph 115,800 (each boiler) Flue Gas Flow at AA Conditions (70% VS and 25% TS) pph 109,500 (each boiler) Flue Gas Flow at AA Conditions (60% VS and 25% TS) pph 97,900 (each boiler) Steam Conditions Steam Pressure psia 180 Steam Temperature oF 373 (saturated) Steam Flow at AA Conditions (70% VS) pph 24,700 (each boiler) Steam Flow at AA Conditions (60% VS) pph 22,600 (each boiler) Waste Heat Fly Ash Transport System (From waste heat boiler to ash storage silo)2 Number of surge hoppers No. 3 Type Vertical with Conical BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 21 Table 6-11 Waste Heat Boiler Design Criteria Equipment Units Specifications Dry ash surge hopper capacity cf Base 1 Number of pneumatic transporters No. 3 Type Air flow Operating pressure scfm psig Dense Phase 15 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 100 10 1 Design exhaust flow rate for waste heat boiler based on incinerator capacity at 70% VS and 25% TS. 2 Required for options with dry ash handling. For options where dry ash handling is not required, the ash transport system will transfer the waste heat boiler fly ash to the wet slurry tanks. (3) Water Treatment System - R-1-A A package type water treatment system will be provided to treat potable water for boiler water make up. The water treatment equipment will depend on the potable water quality and make up water quality requirements. The water treatment system will consist of cartridge filters, carbon filters, water softeners, reverse osmosis (RO), demineralizers, demineralized water storage tank, and make up water pumps. The water treatment systems will include standby components to support 7 day, 24 hour incinerator operation during water system equipment cleaning and regeneration. The water softening and the demineralizer systems will require periodic regeneration; the RO system will require a periodic clean-in-place (CIP). All regeneration and CIP is expected to be performed off-site through a service contract. The calculated capacities for the packaged water treatment system were based on a “once through system” with no condensate return. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 22 Preliminary equipment design information for the packaged water system is shown in Table 6- 12. Table 6-12 Packaged Water Treatment Design Criteria Equipment Units Specifications Water Treatment System Number No. 2 (1 Duty, 1 Standby) Water source Potable Water Required treated water flow rate gpm 150 Design Pressure Loss As required by vendor Make Up Water Tank Capacity gal 9,000 Packaged Water Treatment System Pumps (Booster pumps to waste heat boiler) Number of Units No. 4 (2 Duty, 2 Standby) Water source Treated Water Flow Rate gpm 150 Discharge Pressure ft 600 Motor hp 60 (4) Power Generation Option - R-1-B In this option, waste heat remaining in the exhaust gases after the primary heat exchanger will be used in waste heat boilers to generate high pressure superheated steam. The superheated steam will be used in steam turbines to generate electricity, which will be used on-site to reduce electricity purchases. The generated electricity will be used onsite. Following the waste heat boiler, a secondary heat exchanger will transfer heat from the exhaust gases to the scrubber outlet gas for plume suppression. Figure 6-5 illustrates the proposed power generation option. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 23 Figure 6-5 FBI with Optional Power Generation – R-1-B (5) Waste Heat Boiler - R-1-B Flue gases from the FBI will be ducted to a new waste heat boiler. The waste heat boiler will recover heat from the incinerator exhaust gases to produce high pressure superheated steam for power generation. A bypass will be provided around the waste heat boilers to allow the steam production equipment to be taken out of service without affecting incinerator operation. Preliminary equipment design information for the waste heat boilers is listed in Table 6-13. Table 6-13 Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Waste Heat Boilers Number No. 3 Type Water Tube Flue Gas Conditions BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 24 Table 6-13 Waste Heat Boiler Design Criteria (for Power Generation) Equipment Units Specifications Flue Gas Pressure psia 14.7 Flue Gas Inlet Temperature oF 1,200 Flue Gas Outlet Temperature oF 500 Design Flue Gas Flow pph 106,200 Design Flue Gas Flow1 pph 115,800 (each boiler) Flue Gas Flow at AA Conditions (70% VS and 25% TS) pph 109,500 (each boiler) Flue Gas Flow at AA Conditions (60% VS and 25% TS) pph 97,900 (each boiler) Steam Conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Steam Flow at AA Conditions (70% VS)2 pph 20,800 (each boiler) Steam Flow at AA Conditions (60% VS)2 pph 19,000 (each boiler) Waste Heat Fly Ash Transport System (From waste heat boiler to ash storage silo)3 Number of surge hoppers No. 3 Type Dry ash surge hopper capacity cf Vertical with Conical Base 1 Number of pneumatic transporters No. 3 Type Air flow Operating pressure scfm psig Dense Phase 15 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 100 10 1 Design flow rate for waste heat boiler based on incinerator capacity at 70% VS and 25% TS). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 25 2 Steam flow rates shown include deduction for parasitic loads (i.e., de-aerator, etc.). 3 Required for options with dry ash handling. For options where dry ash handling is not required, the ash transport system will transfer the waste heat boiler fly ash to the wet slurry tanks. (6) Steam Turbine Generator - R-1-B One steam turbine generator will convert steam to electrical power. The skid-mounted steam turbine will be installed in the new Solids Processing Building and will include an oil lubrication system, mounted on a separate skid. Preliminary equipment design information for the steam turbine generator is listed in Table 6-14. Table 6-14 Steam Turbine Generator Design Criteria Equipment Units Specifications Steam Turbine Number No. 1 Type Full condensing to 4 in. Hg absolute Steam conditions Steam Pressure psia 400 Steam Temperature oF 600 (superheated) Design Steam Flow1 pph 50,000 Turbine speed rpm 4,750 Alternator Speed rpm 1,800 Power output – AA (70% VS) MW 2.9 Power output – AA (60% VS) MW 2.6 Output Voltage V 4,160 Type Synchronous 1 Steam turbine sized based on AA conditions for two waste heat boilers operating plus an additional 20 percent steam flow. Steam turbine sized for steam rate prior to parasitic load deduction. Power output based on net steam rate after parasitic load deduction. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 26 (7) Steam Condenser - R-1-B One steam condenser will be provided to condense steam from the turbine. The condensate will be returned to the waste heat boiler steam drum. Preliminary equipment design information for the steam condenser and condensate pumps is listed in Table 6-15. Table 6-15 Steam Condenser and Condensate Pumps Design Criteria Equipment Units Specifications Steam Surface Condenser Number No. 1 Type Water Cooled Temperature of Condensate oF 125 Operating Pressure in Hga 4 Cooling Water Recirculated Potable Water Cooling Water Supply Temperature oF 85 Cooling Water Return Temperature oF 105 Condensate Pumps Number No. 2 (1 Duty, 1 Standby) Type Vertical Multistage Centrifugal Design Flow Rate gpm 100 Approximate Head ft 60 Approximate Motor size hp 4 Drive Constant Speed (8) Cooling Water Heat Exchangers - R-1-B A once-through cooling system, consisting of heat exchangers and pumps, will provide cooling water to the steam condensers. Plant effluent water (PEW) will be used as the coolant. A BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 27 portion of the heated PEW exiting the cooling water heat exchangers will be used in the incinerator wet scrubber system impingement trays. Preliminary equipment design information for the cooling heat exchanger is shown in Table 6- 16. Table 6-16 Cooling Water Heat Exchanger Design Criteria Equipment Units Specifications Cooling Water Heat Exchangers Number No. 2 (1 Duty + 1 Standby) Type Plate and frame Cooling Fluid Type PEW Approximate Flow gpm 5,000 Design Pressure Drop psi 10 Design Inlet Temperature oF 80 Design Outlet Temperature oF 100 Cooled Fluid Type Recirculated potable water Approximate Flow gpm 4,900 Design Pressure Drop psi 10 Design Inlet Temperature oF 105 Outlet Temperature oF 85 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 28 (9) Condensate Handling System - R-1-B A condensate handling system consisting of deaerators, condensate storage tank, and waste heat boiler feed water pumps will be provided to condition, store and pump condensate in the closed- loop waste heat boiler steam system. Preliminary equipment design information for the condensate handling system is listed in Table 6-17. Table 6-17 Condensate Handling System Design Criteria Equipment Units Specifications Condensate Storage Tank Number No. 1 Type Vertical, Carbon Steel. Capacity min 30 Capacity gal 3,000 Deaerator Number No. 1 Type Tray Type Condensate flow rate pph 50,000 Steam Flow pph 4,000 Sump Storage 10 minutes Waste Heat Boiler Feed Pumps Number No. 2 (1 Duty, 1 Standby) Type Centrifugal Design flow rate gpm 100 Approximate head ft 1,200 Approximate motor size hp 100 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 29 (10) Water Treatment System - R-1-B A package type water treatment system will be provided to treat potable water for boiler water make up. The water treatment equipment will depend on the potable water quality and make up water quality requirements. The water treatment system will consist of cartridge filters, carbon filters, water softeners, reverse osmosis (RO), demineralizers, demineralized water storage tank, and make up water pumps. The water treatment systems will include standby components to support 7 day, 24 hour incinerator operation during water system equipment cleaning and regeneration. The water softening and the demineralizer systems will require periodic regeneration; the RO system will require a periodic clean-in-place (CIP). All regeneration and CIP is expected to be performed off-site through a service contract. Preliminary equipment design information for the packaged water system is shown in Table 6- 18. Table 6-18 Packaged Water Treatment Design Criteria Equipment Units Specifications Packaged Water Treatment Number No. 2 (1 Duty, 1 Standby) Required Treated Water Flow Rate gpm 50 Design Pressure Loss As Required by Vendor Make Up Water Tank Capacity gal 6,000 d. Future Advanced Air Pollution Control - R-1-C Regulations associated with mercury discharge from sludge incinerators are anticipated to change in the next five to ten years. Regulatory restrictions are currently being imposed on plants in the Northeast United States and may be adopted throughout the country. The regulation modifications are expected to require the addition of an advanced air pollution control system for mercury removal from incinerator exhaust gases. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 30 Mercury differs from other metals in the incineration process. Metals in the incinerator feed solids typically are removed from the process entrained in the ash or through the wet scrubber. While some mercury becomes entrained in the ash or is collected in the wet scrubber, the remainder is volatilized as elemental mercury (Hg0) in the incinerator. As the gaseous elemental mercury is cooled through the remaining processes, it can react with other components of the flue gas to form oxidized gaseous mercury (Hg2+). The components can be halogens (chlorine, fluorine, and bromine) or oxides of sulfur, such as sulfur dioxide (SO2) and sulfur trioxide (SO3) or nitrogen, such as nitrogen dioxide (NO2). Little mercury is typically retained in the ash. A fraction of the oxidized mercury (Hg2+) is soluble in water and is captured in the wet scrubbing process. The elemental species, which has low solubility in water and is emitted from the stack, must be oxidized and removed through scrubbing. The exhaust gases from the secondary heat exchanger will be directed to the advanced air pollution control system. Air pollution control equipment for mercury removal includes an exhaust gas conditioning tower, carbon injection tower, carbon storage, fabric filter (followed by previously described wet scrubber), dry ash system, and ID fan. Figure 6-6 shows the main mercury scrubbing process using carbon injection and a fabric filter. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 31 Figure 6-6 Advanced Air Pollution Control System w/ Mercury Scrubbing Mercury removal may also be accomplished by fixed bed carbon scrubbers. Comparison of the different mercury scrubbing options was not included for this evaluation, but it is recommended prior to final system selection. Descriptions of the various advanced air pollution control equipment required for a carbon injection system are included below. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 32 (1) Conditioning Tower - R-1-C The exhaust gases leaving the secondary heat exchanger will be directed to the gas conditioning tower, where it will be cooled adiabatically using a small amount of atomized PEW. The conditioning tower system includes the gas conditioning vessel, atomized water-air spray lances, water booster pumps and air compressors. Preliminary equipment design information for the conditioning tower system is listed in Table 6-19. Table 6-19 Gas Conditioning Equipment Design Criteria Equipment Units Specifications Gas Conditioning Equipment Number of Conditioning Towers No. 3 Vessel Dimensions Diameter ft 12 Height ft 45 Design temperatures Exhaust gas inlet (normal operation)1 oF 1,050 Exhaust gas inlet (from bypass) oF 1,200 Exhaust gas inlet (from SHE with heat recovery option) oF 400 Exhaust gas out oF 300 Quench water flow – (high temperature inlet condition) gpm 40 to 50 Quench water flow – (low temperature inlet condition) gpm 10 to 20 Water design pressure psig 60 Number of Air Compressors (per tower) No. 2 (1 duty, 1 standby) Compressor Dimensions Length ft 10 Width ft 6.5 Compressor Motor hp 150 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 33 1 Normal operation defined as no power generation. (2) Carbon Injection and Storage - R-1-C Carbon will be injected upstream from the fabric filter for mercury removal. The mercury will adsorb onto the carbon and more than 90 percent of the mercury will be removed by the fabric filters. The removed mercury/carbon solids will be handled through the ash handling process. The carbon system will include powdered activated carbon storage silos, volumetric feeders, carbon conveyance blowers and carbon injection assemblies. Powdered activated carbon will be delivered to the site by truck and stored in a carbon storage silo. Conveyance blowers will deliver the carbon from the carbon storage silo to the exhaust gas stream feed point ahead of the fabric filter. Preliminary equipment design information for the carbon system is shown in Table 6-20. Table 6-20 Carbon System Design Criteria Equipment Units Specifications Carbon System Number of carbon storage silos No. 2 Type Vertical with conical base Volume1 (each) Storage cf days 860 30 Size Diameter ft 12 Total Height2 ft 45 Number of carbon volumetric feeders 2 per silo Feed rate pph 30 Number of carbon conveyance blowers 2 per silo Flow (each) scfm 100 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 34 1 Carbon storage based on incinerator capacity for two units in operation. 2 Silo height includes clearances for transport and dust collection equipment. (3) Fabric Filters - R-1-C The carbon solids will form a layer on the surface of the fabric filter bags, which will act as a mercury adsorption layer. Periodic, automatic filter cleaning will be performed using compressed air. The mercury-laden carbon and other particulate matter will be collected at the bottom of each fabric filter as dry ash. The dry ash will be collected by a screw conveyor at the base of each fabric filter and pneumatically conveyed to ash storage silos. Preliminary equipment design information for the fabric filters is shown in Table 6-21. Table 6-21 Fabric Filter Design Criteria Equipment Units Specifications Carbon System Number of fabric filters No. 3 Type Multi-Chamber Dimensions Length Width Height ft 42 14 55 Exhaust Flow Temperature Volume1 oF acfm 350 max 45,000 No. of ash collection screw conveyors No. 3 (2 Duty, 1 Standby) Capacity (each)2 lb/min 67 Motor hp 25 1 Fabric filter exhaust flow rate capacity based on incinerator capacity at high volatile (70% VS) conditions. 2 Ash conveyor capacity rate based on incinerator capacity and low volatile (60% VS) condition. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 35 (4) Dry Ash System - R-1-C The dry ash collected at the fabric filters will be transported to dry ash storage silos by dense phase pneumatic conveyance systems consisting of ash surge hoppers, pneumatic transporters, compressors and conveyance piping. The dry ash will be stored in storage silos to be hauled off site for disposal. Preliminary equipment design information for the dry ash system is shown in Table 6-22 Table 6-22 Dry Ash System Design Criteria Equipment Units Specifications Dry Ash System Number of surge hoppers1 No. 3 Type Dry ash surge hopper capacity cf Vertical with Conical Base 10 Number of pneumatic transporters1 No. 3 Type Air flow Operating pressure scfm psig Dense Phase, Conical Base 100 100 Number of compressors No. 2 (one duty, one standby) Type Compressor capacity Compressor motor scfm hp Scroll or Screw Type 100 25 Number of storage silos No. 3 Type Vertical with Conical Base Volume (each)2 Storage (AA conditions) cy days 630 7 Dimensions Diameter Total Height3 ft 24 75 1 Ash surge hopper and transporter vessel located under each fabric filter ash conveyor. Transport system based on incinerator capacity and low volatile (60% VS) condition. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 36 2 Ash storage based on low volatile (60% VS) and AA solids feed rate conditions for two incinerators. 3 Silo height includes clearances for nozzle, ash unloading equipment and truck. (5) Induced Draft Fans - R-1-C ID fans will provide additional energy to convey exhaust gases from the wet scrubber through the air pollution control equipment and discharge to the stack. Preliminary equipment design information for the ID Fan is shown in Table 6-23. Table 6-23 Induced Draft Fan Design Criteria Equipment Units Specifications ID Fan Number of Units No. 3 Type Single-Stage Centrifugal, Direct Drive Air Flow1 scfm 35,700 Flow Adjustment Inlet damper Pressure Rise in w.c. 40 Motor hp 400 Special Construction/Materials --- 316 SS wheels and shafts 1 Fan capacity based on incinerator capacity and high volatile (70% VS) condition. 5. Layout Plans Refer to Figures C-1 through C-5 in Appendix C for preliminary layouts of the new Solids Processing Building which includes the new FBIs, wet scrubbers and auxiliary systems. 6. Site Plan Refer to Figure A-1 in Appendix A for a preliminary site plan showing the proposed location of the new Solids Processing Building. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 37 7. Staffing Requirements Table 6-24lists the anticipated staffing requirements for each of the proposed alternatives. Table 6-24 Staffing Requirements Type Value Number Hr/Shift Shift/day Day/Wk Wk/Yr Total hrs R-1 - New FBIs and Centrifuges Supervisor 3 8 1 7 52 8,736 Operator 4 8 3 7 52 34,944 Maintenance 3 8 3 5 52 18,720 R-1-A Option – Steam Generation Operator -- -- -- -- -- -- Maintenance 0.5 8 1 5 52 1,040 Stationary1 Engineer 0.5 8 3 7 52 4,368 R-1-B Option – Power Generation Operator -- -- -- -- -- -- Maintenance 1 8 1 5 52 2,080 Stationary1 Engineer 1 8 3 7 52 8,736 R-1-C Option – Future Air Pollution Control Operator 0.5 8 3 7 52 4,368 Maintenance 1 8 1 5 52 2,080 1 Licensed steam boiler engineer/operator. 8. Cost Summary Table 6-25presents the Engineer’s Opinions of Costs for construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs. These costs were determined based on the descriptions of alternatives and options presented here. These costs and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 38 benefits were developed and presented in Technical Memorandum No.9 Opinions of Costs for Alternatives. All costs and savings are in 2010 dollars. Table 6-25 Costs Summary of Regional Facility ($1000) Alternative R-1 FBI +CFG R-1-A FBI + Steam R-1-B FBI + Power R-1-C FBI + AEC Capital Costs Salvage Value $206,559 ($5,563) $20,603 ($1,106) $41,215 ($791) $37,873 ($1,513) Annual O&M Costs $13,648 $502 $864 $35 Annual Revenue ($0) ($1,898) ($1,136) ($0) Present Worth Costs Capital $206,559 $20,603 $41,215 $37,873 Salvage ($2,096) ($417) ($298) ($570) O&M $170,087 $6,256 $10,767 $433 Revenue ($0) ($23,658) ($14,153) ($0) Total Present Worth Costs $374,550 $2,784 $37,531 $37,736 9. Total System Regionalization of biosolids treatment is one means of taking advantage of the economy of scale. In addition to helping reduce overall capital expenditures, operations and maintenance costs can be reduced through economies in staffing. Rather than implement biosolids processing facilities at individuals plants, it may make more economic sense for MSD to consider implementing a regional biosolids processing facility at Bissell Point WWTP, which is the largest of all the WWTPs operated by MSD. Under the regional biosolids management scheme, the solids generated at Lemay, Coldwater, Missouri River, and Lower Meramec will be transported to Bissell Point for processing. The BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 39 following sections describe the regional system alternatives developed for evaluation and the process modifications required at the individual plants for implementing the regional system. a. Decentralized Treatment of Solids (Alternative S-1 No Regional Facility). The decentralized solids treatment alternatives for the WWTPs involve treatment and disposition of solids at the individual plants. Details of sludge treatment processes and equipment sizing for the decentralized options can be found in the Solids Processing Alternative Evaluation Technical Memorandums No. 1 through No. 6 for each treatment facility. To compare the overall economics of decentralized treatment with a regional system, base case solids treatment schemes were identified for the individual plants from the range of biosolids treatment options evaluated. Landfilling of dewatered cake or ash was used as the default disposal method for all base case option. Table 6-26summarizes the base case options considered for the individual plants. Table 6-26 Base Case Solids Treatment Schemes for Individual Plants Plant Treatment Alternative Bissell Point WWTP B-2: FBI + CFG Lemay WWTP . Solids processing includes co-thickening, centrifuge dewatering, and fluidized bed incineration. Landfill disposal of incinerator ash. No energy recovery as steam or power. L-3: FBI + CFG Coldwater WWTP . Solids processing includes co-thickening, centrifuge dewatering, and fluidized bed incineration. Landfill disposal of incinerator ash. No energy recovery as steam or power. C-1: Current Operation Missouri River WWTP . No solids processing at Coldwater. Thickened solids will be pumped to the Bissell watershed for processing at the Bissell Point WWTP. M-1: Current Operation Lower Meramec WWTP . No new solids processing facilities. All solids processing improvements included with the Secondary Treatment Expansion and Disinfection Facilities and the Digester Rehabilitation projects are considered existing. Additional cogeneration capacity required at projected design year digester loadings is included. LM-1: Co-thickening + AD. Solids processing involves re-use of existing gravity thickeners for PS and WAS co-thickening followed BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 40 by new anaerobic digesters for solids stabilization, and use of digester gas for cogeneration. Dewatering facilities are not included since dewatering was not evaluated as part of Phase II evaluations. A flow chart of the solids processes at each plant for the Decentralized (No Regional) Treatment Alternative S-1 is shown on Figure 6-7. Coldwater Thickening Gravity Thickening(New EQ) Force Main to Regional Facility (New PS & FM) Lower Meramec Thickening Gravity Thickening (New EQ & Tank) Dewatering1 BFP Cake Storage and Loadout to Disposal1 (New Extra Capacity) Lemay Thickening Gravity Thickening GBT Dewatering Centrifuge(New) Bissell Point Thickening Gravity ThickeningGBT Dewatering Centrifuge(New) Incineration FBI (New) Ash Dewatering (Ash Lagoon, upgrade to slurry system) Ash Loadout MSD Decentralized Treatment System (S-1) Solids Handling Process Flow Chart MO River Thickening RDT Thickening(New EQ) Anaerobic Digestion Dewatering Centrifuge Cake Storage and Loadout to Disposal CHP (New EQ) End Use End Use Incineration FBI (New) Ash Dewatering (Ash Lagoon, upgrade to slurry system) End Use EndUse Ash Loadout Anaerobic Digestion (New) CHP (New) Note 1Additional equipment needed but not included in the cost evaluation. Figure 6-7. Solids Process Flow Chart for Decentralized (No Regional) Treatment S-1 b. Regional Treatment of Solids. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 41 If the regional biosolids treatment facility is implemented at the Bissell Point WWTP, solids from the other MSD plants would either be hauled or pumped to the regional facility for incineration. Since digesting the solids upstream from incineration lowers the calorific value of the feed solids and may require auxiliary fuel for incineration, the regional system is based on discontinuing or not implementing anaerobic digestion at Missouri River and Lower Meramec WWTPs. Anaerobic digestion was considered for the decentralized option to provide added flexibility for biosolids end use and to increase the potential for energy recovery in the form of digester gas at the county plants. Two variations of the regional system were considered for evaluation. (1) Alternative S-2 Lemay Hauling The Total System Alternative S-2 is based on hauling dewatered solids from Lemay, Coldwater, Lower Meramec, and Missouri River WWTPs to the regional facility. The solids generated at the Bissell Point WWTP (including Coldwater solids) will be pumped to a new dewatering building adjacent to the new solids processing building for dewatering and further processing at the regional facility. The modifications required to the base case solids treatment alternatives at the individual plants for implementing the regional Total System S-2 processing scheme are summarized in Table 6-27. Table 6-27 Modifications Required to the Base Case Treatment Options at Individual Plants for Implementing the Regional Total System S-2 Base Case (No Regional) S-1 Alternative S-2 Lemay Hauling Bissell Point WWTP B-2: FBI + CFG. Co-thickening, centrifuge dewatering, and fluidized bed incineration. Landfill disposal of incinerator ash. R-1 Lemay WWTP . Regional Facility located at Bissell Point. The solids generated at Bissell Point (including Coldwater solids) will be dewatered using new centrifuges and pumped to the regional plant for incineration using new FBIs. Landfill disposal of ash. No energy recovery as steam or power. L-3: FBI + CFG. Co-thickening, centrifuge dewatering, and fluidized bed incineration. Landfill disposal of incinerator ash. Modified L-3. Solids processing includes co-thickening, and centrifuge dewatering. Dewatered solids will be hauled to the regional BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 42 Table 6-27 Modifications Required to the Base Case Treatment Options at Individual Plants for Implementing the Regional Total System S-2 Base Case (No Regional) S-1 Alternative S-2 Lemay Hauling facility. Incinerators and ash treatment system not required at plant. Coldwater WWTP C-1: Current Operation. Thickened solids pumped to the Bissell watershed for processing at the Bissell Point WWTP. C-1 Missouri River WWTP . No change from the decentralized base case option. Thickened solids will be pumped to Bissell Point for treatment. M-1: Current Operation. No new solids processing facilities. Additional cogeneration capacity included. Modified M-1 Lower Meramec WWTP . Existing anaerobic digestion, digester gas cleaning, and cogeneration will be decommissioned. Thickened PS and WAS will be a dewatered using existing centrifuge and dewatered solids hauled to the regional facility. LM-1: Co-thickening + AD. Co-thickening of PS and WAS in gravity thickeners and anaerobic digestion Dewatering facilities not included. Modified LM-1 A flow chart of the solids processes at each plant for the Total System Alternative S-2 is shown on . Co-thickened solids will be dewatered using existing BFPs and hauled to the regional facility. Anaerobic digestion, gas cleaning and cogeneration facilities will not be required. Figure 6-8. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 43 Coldwater Thickening Gravity Thickening Force Main to Regional Facility (New PS & FM) MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to RegionalFacility Lower Meramec Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP(New Add.EQ) Cake Storage and Loadout to RegionalFacility1 Lemay Thickening Gravity Thickening GBT Dewatering Centrifuge (New) Cake Storage and Loadout to Regional Facility Bissell Point Thickening Gravity Thickening GBT Dewatering Centrifuge (New) DewateredSludge Receiving (New)Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-2) Solids Treatment Process Flow Chart -Hauling Cake from Lemay Note 1Additional equipment needed but not included in the cost evaluation. Figure 6-8 Solids Process Flow Chart for Alternative S-2 Lemay Hauling (2) Alternative S-3 Lemay Pump Station The only variation from Alternative S-2 is the means of transport of solids from Lemay to the regional facility. For Alternative S-3, thickened solids from Lemay will be pumped to Bissell for dewatering and incineration at the Regional Facility. Dewatering facilities will not be required at the Lemay WWTP. A new pump station and force main will be provided to transfer co-thickened PS and WAS to the regional facility. The BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 44 additional pumping and dewatering capacity requirements at Bissell for receiving liquid sludge from Lemay were not evaluated in detail for the regional option. The dewatering facility costs at Lemay for the base case alternative were added to the regional facility costs to account for the additional capacity requirements. The solids processing requirements at all the other WWTPs are identical to Alternative S-2. A flow chart of the solids processes at each plant for the Alternative S-3 is shown on Figure 6-9. Coldwater Thickening Gravity Force Main to Regional Facility (New PS & FM) MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Regional Facility Lower Meramec Thickening Gravity Thickening(New EQ & Tanks) Dewatering1 BFP (New Add.EQ) Cake Storage and Loadout to Regional Facility1 Lemay Thickening Gravity ThickeningGBT Bissell Point Thickening Gravity ThickeningGBT Dewatering Centrifuge (New) DewateredSludge Receiving (New)Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-3) Solids Treatment Process Flow Chart -Pumping Sludge from Lemay Force Main to Regional Facility (New PS & FM) Note 1Additional equipment needed but not included in the cost evaluation. Figure 6-9. Solids Process Flow Chart for Alternative S-3 Lemay Pump Station BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 45 c. Cost Summary A comparison of Engineer’s Opinions of Costs for the No Regional Alternative S-1 and the Total System Alternatives S-2 and S-3 are presented in Table 6-28. The costs include construction costs, annual operation and maintenance costs, annual savings with biosolids use, and life cycle costs for the two options. Detailed cost information for this comparison is presented in Technical Memorandum No.9 Opinions of Costs for Alternatives. Table 6-28 Total System Costs Summary ($1000) Option S-1 No Regional S-2 Lemay Hauling S-3 Lemay Pump Station Capital Costs $324,923 $243,653 $276,608 Salvage Value ($12,208) ($7,832) ($11,781) Annual O&M Costs $16,960 $19,839 19,269 Annual Revenue ($807) ($0) ($0) Present Worth Costs Capital $324,923 $243,653 $276,608 Salvage ($4,601) ($2,952) ($4,440) O&M $211,359 $247,238 $240,134 Revenue ($10,057) ($0) ($0) Total Present Worth Costs $521,624 $487,939 $512,302 An evaluation of the alternatives presented here are included in TM 10 – Alternatives Selection Processes and Results. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 46 Appendix A Site Plans BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 47 Appendix B Detailed Process Flow Schematics BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Regional Facility Alternative Evaluation Re-Issued: September 10, 2010 MSD Contract No. 2009145 Reviewed by: B. Green 48 Appendix C Layouts Plans BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 1 Reviewed by: J. Rowan TECHNICAL MEMORANDUM NO. 7 REVIEW OF AIR EMISSION REQUIREMENTS To: Metropolitan St. Louis Sewer District From: Bently C. Green _____________________________________________________________________________ Table of Contents Table of Contents ............................................................................................................................ 1 1. Overview .............................................................................................................................. 1 2. Background .......................................................................................................................... 2 3. Current Regulatory Opposition ............................................................................................ 3 a. Water Environment Federation ........................................................................................ 4 b. NACWA ....................................................................................................................... 6 4. Impacts on MSD .................................................................................................................. 7 5. Conclusions ........................................................................................................................ 11 1. Overview Air emission requirements for municipal biosolids incinerators are currently under a state of regulatory revision, with a final outcome that is not known at this time. In fact, the ultimate outcome may not be entirely resolved for several years. As of June 4, 2010, the United States Environmental Protection Agency (USEPA) published in the Federal Register a proposed rule for the “Identification of Non-Hazardous Secondary Materials that are Solid Waste. ” Following publication of this proposed rule and a public comment period, USEPA is expected to publish a final rule by the court-mandated date of December 15, 2010. Pending the outcome of the proposed rule, potential legal challenges to USEPA’s interpretation could delay implementation of the rule for some time. There are two regulatory rule changes that are being considered that will have significant impact on biosolids incineration operations in the future. The first involves USEPA’s revised interpretation of wastewater solids (biosolids) as “solid waste” if they are processed in sewage sludge incinerators (SSI). Municipal wastewater SSI’s are currently regulated under Section 112 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 2 Reviewed by: J. Rowan of the Clean Air Act (CAA). If biosolids processed by SSI’s are regulated as “solid waste,” incineration of biosolids would no longer fall under the “domestic sewage exclusion” provision and would be regulated under Section 129 of the Clean Air Act. The second track potentially impacting future operation of SSI’s involves the development of air emission requirements for SSI’s under Section 129, which are established based on Maximum Achievable Control Technology (MACT) standards. Depending on how the MACT standards are ultimately determined for SSI’s, air emission requirements for SSI’s utilizing fluidizing bed incineration (FBI) or multiple hearth incineration (MHI) technology could face significant upgrades to meet air emission regulations. There have been discussions with the USEPA that indicate there may be separate emissions requirements for MHIs and FBIs, with the MHI limits reflecting less stringent requirements. Of these two incinerator technologies, MHI’s typically do not achieve the air emission limits that FBI systems do, and as such, are anticipated to have more difficulty in being able to achieve significantly reduced air emission requirements. The MHI limits may ultimately render MHIs obsolete for continued long-term use. 2. Background The Commercial and Industrial Solids Waste Incineration (CISWI) Rule was promulgated on December 1, 2000, and set emission standards for CISWI units pursuant to Section 129 of the CAA. Following a voluntary remand of the CISWI Rule, USEPA solicited comments on key definitions of the rule and issued its “CISWI Definitions Rule” on September 22, 2005, after a public comment period. Following a petition for review of the CISWI Definitions Rule by environmental groups, the Washington D.C. Circuit Court remanded and vacated the CISWI Definitions Rule on June 8, 2007. This court determined that Section 129 standards apply to any facility that combusts commercial or industrial solid waste material excluding available statutory exemptions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 3 Reviewed by: J. Rowan On January 2, 2009, the Environmental Protection Agency (EPA) issued an Advanced Notice of Proposed Rulemaking (ANPRM) to solicit comment on which non-hazardous secondary materials (that are used as fuels or ingredients in combustion units), are considered solid wastes under the Resource Conservation and Recovery Act (RCRA). This rulemaking included a proposal to define sewage sludge destined for incineration as a “solid waste,” by eliminating the “domestic sewage exclusion” provisions that had formerly been in place. The ruling also contended that combustion of sewage sludge for volume reduction did not qualify it as a legitimate fuel. On April 30, 2010, USEPA released a proposed set of rules addressing “the regulation of commercial and industrial incinerators and boilers under the CAA.” With these rules, USEPA proposed that sludge generated from publicly owned treatment works (POTW’s), when combusted, be classified as a solid waste and subject to CAA Section 129 requirements. On June 4, 2010, EPA published the final version of its proposed rule. A copy of the final rule is included in Appendix A of this memorandum. 3. Current Regulatory Opposition As expected, a number of organizations have taken the opportunity to voice their opposition to the proposed changes, including the Water Environment Federation (WEF), and the National Association of Clean Water Agencies (NACWA), among others. Opposition to the “biosolids as solid waste” portion of this rule is well-founded and based on historical precedent. Additionally, opponents have also pointed out numerous other weaknesses in EPA’s interpretation of the rule. Whether the USEPA responds favorably to these petitions will not be known until later in 2010 at the earliest. Various public forums and discussions with EPA have not been consistent in the message they conveyed. At times EPA has appeared sympathetic to these issues, but the fact remains that the ultimate proposal nevertheless took a very aggressive approach to the future BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 4 Reviewed by: J. Rowan regulation of SSI’s. A brief summary outlining the highlights of the arguments made in opposition to the rule are provided below. a. Water Environment Federation In comments published on August 2, 2010, the Water Environment Federation (WEF) took issue with a number of elements of the proposed rule, including the fact that although USEPA notes that the specific intent of the regulation is to apply the designation of “solid waste” to wastewater solids (biosolids) processed in SSI’s, the proposed rule places in jeopardy all other forms of biosolids management, including land application and beneficial reuse programs. WEF noted that the USEPA established three criteria for a material being exempted as a solid waste: 1) It is managed as a valuable commodity; 2) It has a meaningful heating value; and 3) It contains contaminants at levels comparable to those in traditional fuels for which the combustion unit was designed to burn. WEF provided a very articulate response to each of these issues, noting among other things that EPA’s defined criteria of meaningful heating value of 5,000 BTU per pound of wet feed is not appropriate for sewage sludge applications; which can operate in an SSI without supplemental fuel at heating values as low as 1,800 BTU per pound. WEF also pointed out that USEPA had used out-dated contaminant data in assessing and comparing contaminant levels to that of coal. As noted on Table 7-1, the USEPA used data from a 1980 study and a 1989 study, when more recent (2009) survey data was available that was more representative of current treatment capabilities. As the comparison table notes, contaminant levels in sewage sludge have dropped dramatically through the implementation of the risk-based Part 503 regulations; and although some contaminants remain higher than those found in the coal sources cited in USEPA’s proposed rule, the USEPA is not taking into consideration the greenhouse gas emissions impacts of burning coal as a fossil fuel versus biosolids as a biogenic fuel source. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 5 Reviewed by: J. Rowan Lastly, WEF noted the unintended consequences of the proposed rule, particularly the potential for land-applied biosolids to be classified as solid waste in the future on a state-by-state basis, the detrimental effect on energy recovery operations derived from carbon neutral energy sources, the reduction of valuable nutrients and energy available from biosolids, and the significantly greater cost for compliance among wastewater agencies. A copy of WEF’s response is included in Appendix B of this memorandum. Table 7- 1 Wastewater Treatment Sludge Contaminant Comparison to Coal BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 6 Reviewed by: J. Rowan b. NACWA NACWA similarly responded to the proposed rule-making, in a letter dated August 3, 2010 (included herein as Appendix C). NACWA’s response was similar to WEF’s in many regards, although significantly more comprehensive in its analysis of legal precedent. NACWA urged the USEPA to reconsider its position on the interpretation of biosolids stabilized through SSI’s. NACWA cited the long and successful history of the Part 503 regulations in protecting public health while also providing a “domestic sewage exclusion” provision that allowed SSI facilities to be operated under the regulatory authority of Part 503. In reviewing the regulatory history of SSI’s, NACWA pointed to the successful implementation of pre-treatment programs and their positive impact on the emission capabilities of the SSI’s, as evidence that SSI’s have been successfully regulated under the current authority of Part 503, as well as other environmental laws. NACWA pointed to the fact that the proposed rules will significantly disrupt the United States sewage sludge infrastructure while making no significant improvements to the overall public health. Additionally, NACWA estimated the cost impact to the proposed rule change to be in excess of $3 billion, along with a substantial increase in overall operating expenses; based on the fact that while some facilities could undertake significant improvements to meet the new emission limits, other facilities may be faced with having to abandon their existing facilities altogether – thus reducing the feasibility of continuing with environmentally “greener” process stabilization systems. Such systems, when faced with having to add treatment components in areas without adequate space requirements, could find themselves with no other option but to resort to disposal of solids in landfills; thus eliminating the renewable energy that is gained from the stabilization process as well as increasing overall operations costs while simultaneously undertaking a disposal option that has a significantly greater negative impact on the environment via greenhouse gas production. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 7 Reviewed by: J. Rowan NACWA noted that sewage sludge contains approximately 8,000 BTU/lb on a dry weight basis and 2,000 BTU/lb on an as-received basis (at 25% solids) and can generate 2.3 kilowatts of power per pound. NACWA provided numerous examples of utilities saving significant cost by using SSI’s as an energy source. 4. Impacts on MSD The USEPA’s proposed rule-making changes are expected to have significant impacts on municipal SSI’s, regardless of the ultimate outcome. MSD, with MHI systems at both its Bissell Point and Lemay wastewater treatment facilities, will face difficult choices in assessing whether its MHI’s can be retrofitted to meet new air emission requirements, or will need to be abandoned altogether and replaced with either FBI’s or alternative stabilization/disposal systems. If SSI’s are regulated under Section 129 of the CAA, they will ultimately have to comply with MACT standards, which have not been released as of the date of this memorandum. MACT standards are currently established based on the average emission limitation achieved by the best performing 12 percent of existing sources. USEPA is considering whether to make compliance equitable to the emission control achieved by the best controlled similar source. USEPA has also not made clear whether or not it will differentiate between MHI’s and FBI’s in establishing future air emission requirements. Should USEPA base emission limits on the best performing units currently in services, these limits would almost certainly be based on criteria established by the highest performing FBI’s, and thus effectively render MHI’s obsolete without major emission control improvements – which even then could turn out to be only a temporary solution. Although MACT standards have not been officially released, some information regarding the sources of data from USEPA’s information collection survey on SSI’s is known. Until the final rule and limits have been published and withstood any legal challenges that might occur, final regulatory impact will remain uncertain. However, based on previous precedents and generally BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 8 Reviewed by: J. Rowan known data from incineration facilities around the country, a reasonable approximation of anticipated future regulatory limits is feasible. Table 7- 2 below lists potential air emissions, some or all of which are anticipated to be regulated, along with an approximation of a discharge limit for the contaminant. The table also provides a summary assessment of the ability of an MHI or an FBI to achieve the potential contaminant discharge limit. These estimates are by no means conservative, and final limits could in fact be even more stringent. This table is provided simply to illustrate the varying difficulties of an MHI and an FBI in being able to achieve even moderately more stringent air emission requirements. Table 7- 2 – Comparison of MHI and FBI Capabilities to Meet Potential Air Emission Requirements Potential Section 129 OSWI Emission Limits Contaminant Limit Units MHI FBI (all corrected to 7% O2) Cadmium 18 µg/dscm Carbon monoxide 40 ppmdv CO emissions erratic Able to meet Dioxins/Furans 33 Ng TCDDeq/dscm Able to meet Able to meet HCl 1 ppmdv May require chemical addition to scrubber water May require chemical addition to scrubber water Lead 226 µg/dscm Able to meet Able to meet Mercury 74 µg/dscm May require additional scrubber. May require additional scrubber. Opacity 10 % Questionable ability to meet. Able to meet NOx (NO + NO2) 103 ppmdv Difficult to meet. Able to meet. ~ 4.5 lb/dt PM 0.013 ppmdv Able to meet Able to meet SO2 3.1 ppmdv May require chemical addition to scrubber water May require chemical addition to scrubber water BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 9 Reviewed by: J. Rowan Table Definitions: • All emission limits except for opacity are measured at 7 percent oxygen, dry basis, and standard conditions. • µg/dscm – micrograms per dry standard cubic meter • ppmdv – parts per million dry volume • Dioxins/Furans – determined on a total mass basis • Ng TCDDeq/dscm – nanograms tetrachlordibenzeo-p-dioxin equivalent, per dry standard cubic meter • PM – Particulate matter Air emission limits that are anticipated to be challenging to MHI’s are highlighted within the table. As noted, some significantly more stringent air emission requirements are achievable with additions and improvements such as scrubber systems to the facilities. Other contaminants could be difficult to meet on a consistent basis even with significant improvement. Carbon monoxide requirements for MHI’s, if based on MACT standards established by FBI’s, will be very difficult to meet on a consistent basis. Additionally, opacity and NOX limits for MHI’s present significantly more challenges from an operational standpoint. FBI facilities would also require significant emission control technology, depending on ultimate regulatory limits, as well as preferences for materials handling. As part of this study, District- staff have visited other FBI facilities to gain a better understanding of some of the operational challenges to be expected should the District ultimately conclude its MHI’s will have to be replaced. Figure 7- 1 on the following page highlights some of the initial conclusions developed, based on potential regulatory scenarios. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 10 Reviewed by: J. Rowan Figure 7-1 – MSD Initial Preferences for Emission Facilities for Various Parameters/Issues BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 11 Reviewed by: J. Rowan Solids Production 204 200 21 21 9 9 8 96 47 9 11 6 9 3 0 50 100 150 200 250 Bissell Point LeMay Missouri River Coldwater Lower Meramec Grand Glaize FentonDesign solids (dtpd)Design Current 5. Conclusions Approximately 85-percent of the District’s wastewater solids are treated and stabilized at its Bissell Point and Lemay wastewater treatment facilities, as illustrated in Figure 7- 2 below. Stabilization is achieved in these two facilities through multiple hearth incineration, with disposal of the ash material into a District-owned landfill (Prospect Hill). Figure 7- 2 – Solids Production Rates at MSD Treatment Facilities The MHI facilities have been in operation for approximately 40 years and have served the District well. Going forward however, as the District considers upgrades that may be necessary from a long-term operational standpoint, a key factor will be the actual or potential implementation of significantly stricter air emission requirements that these facilities may or may not be able to achieve (with varying degrees of improvement). Ultimate regulatory requirements may not be known for some time, as the final imposition of the USEPA’s proposed rule is not anticipated until December 15, 2010, following which there will likely be legal challenges by various stakeholders regardless of the outcome. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 23, 2010 MSD Contract No. 2009145 B&V File 44.000 12 Reviewed by: J. Rowan As a public utility, the District is charged with protecting public health through its wastewater collection and treatment systems, and doing so in a manner that is financially prudent. Consequently, major projects are not considered without significant due diligence to the most economical options available – both long-term and short-term. Future regulatory requirements will typically challenge public utilities across the country to choose between short-term and long-term goals, and for some the final decision will reside solely on their financial capability to undertake one project compared to another. In the District’s case, air emission requirements, and the subsequent significant investment in infrastructure upgrades to either ensure long-term usefulness of the existing systems (with the inherent operational and regulatory challenges anticipated) will be weighed against replacing the equipment entirely with new equipment that meets the regulatory challenges for the long-term, although at a potential greater upfront cost. As the District proceeds, some of the regulatory issues will ultimately be resolved prior to the District having to make decisions on large capital improvement projects. For planning purposes however, it is assumed that regulations will become inherently more stringent and that significant improvements will be necessary going forward to meet anticipated air emission requirements. The District has consistently reaffirmed this strategy in multiple workshops conducted as part of this evaluation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 12, 2010 MSD Contract No. 2009145 B&V File 44.000 Appendix A Federal Register Part II Environmental Protection Agency 40 CFR Part 241 Identification of Non-Hazardous Secondary Materials That Are Solids Waste; Proposed Rule Friday, June 4, 2010 Part II Environmental Protection Agency 40 CFR Part 241 Identification of Non-Hazardous Secondary Materials That Are Solid Waste; Proposed Rule VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31844 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 241 [EPA–HQ–RCRA–2008–0329; FRL–9148–2] RIN 2050–AG44 Identification of Non-Hazardous Secondary Materials That Are Solid Waste AGENCY: Environmental Protection Agency (EPA). ACTION: Proposed rule. SUMMARY: On January 2, 2009, the Environmental Protection Agency (EPA or the Agency) issued an Advanced Notice of Proposed Rulemaking (ANPRM) to solicit comment on which non-hazardous secondary materials that are used as fuels or ingredients in combustion units are solid wastes under the Resource Conservation and Recovery Act (RCRA). The meaning of ‘‘solid waste’’ as defined under RCRA is of particular importance since it will determine whether a combustion unit is required to meet emissions standards for solid waste incineration units issued under section 129 of the Clean Air Act (CAA) or emissions standards for commercial, industrial, and institutional boilers issued under CAA section 112. CAA section 129 states that the term ‘‘solid waste’’ shall have the meaning ‘‘established by the Administrator pursuant to [RCRA].’’ EPA is proposing a definition of non-hazardous solid waste that would be used to identify whether non-hazardous secondary materials burned as fuels or used as ingredients in combustion units are solid waste. EPA is also proposing that non-hazardous secondary materials that have been discarded, and are therefore solid wastes, may be rendered products after they have been processed (altered chemically or physically) into a fuel or ingredient product. This proposed rule is necessary to identify units for the purpose of developing certain standards under sections 112 and 129 of the CAA. In addition to this proposed rule, EPA is concurrently proposing air emission requirements under CAA section 112 for industrial, commercial, and institutional boilers and process heaters, as well as air emission requirements under CAA section 129 for commercial and industrial solid waste incineration units. DATES: Comments. Comments must be received on or before July 19, 2010. Under the Paperwork Reduction Act, comments on the information collection provisions are best assured of having full effect if the Office of Management and Budget (OMB) receives a copy of your comments on or before July 6, 2010. Public Hearing. We will hold a public hearing concerning this proposed rule and the interrelated proposed CAA rules, discussed in this proposal and published in the proposed rules section of today’s Federal Register, on June 21, 2010. Persons requesting to speak at a public hearing must contact EPA by June 14, 2010. ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ– RCRA–2008–0329, by one of the following methods: •http://www.regulations.gov: Follow the on-line instructions for submitting comments. •E-mail: Comments may be sent by electronic mail (e-mail) to: rcra- docket@epa.gov, Attention Docket ID No. EPA–HQ–RCRA–2008–0329. In contrast to EPA’s electronic public docket, EPA’s e-mail system is not an ‘‘anonymous access’’ system. If you send an e-mail comment directly to the docket without going through EPA’s electronic public docket, EPA’s e-mail system automatically captures your e- mail address. E-mail addresses that are automatically captured by EPA’s e-mail system are included as part of the comment that is placed in the official public docket, and made available in EPA’s electronic public docket. •Fax: Comments may be faxed to 202–566–9744, Attention Docket ID No. EPA–HQ–RCRA–2008–0329. •Mail: Proposed Rulemaking— Identification of Non-Hazardous Secondary Materials That Are Solid Waste, Environmental Protection Agency, Mailcode: 28221T, 1200 Pennsylvania Ave., NW., Washington, DC 20460. Please include a total of 2 copies. In addition, please mail a copy of your comments on the information collection provisions to the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk Officer for EPA, 725 17th St., NW., Washington, DC 20503. •Hand Delivery: Deliver two copies of your comments to Proposed Rulemaking—Identification of Non- Hazardous Secondary Materials That Are Solid Waste, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW., Washington, DC 20460. Attention Docket ID No. EPA–HQ–RCRA–2008– 0329. Such deliveries are only accepted during the Docket’s normal hours of operation and special arrangements should be made for deliveries of boxed information. Instructions: Direct your comments to Docket ID No. EPA–HQ–RCRA–2008– 0329. EPA’s policy is that all comments received will be included in the public docket without change and may be made available online at http:// www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Do not submit information that you consider to be CBI or otherwise protected through http:// www.regulations.gov or e-mail. The http://www.regulations.gov Web site is an ‘‘anonymous access’’ system, which means EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an e-mail comment directly to EPA without going through http:// www.regulations.gov, your e-mail address will be automatically captured and included as part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you include your name and other contact information in the body of your comment and with any disk or CD–ROM you submit. If EPA cannot read your comment due to technical difficulties and cannot contact you for clarification, EPA may not be able to consider your comment. Electronic files should avoid the use of special characters, any form of encryption, and be free of any defects or viruses. For additional information about EPA’s public docket, visit the EPA Docket Center homepage at http:// www.epa.gov/epahome/dockets.htm. For additional instructions on submitting comments, go to the SUPPLEMENTARY INFORMATION section of this document. We also request that interested parties who would like information they previously submitted to EPA to be considered as part of this action, to identify the relevant information by docket entry numbers and page numbers. Public Hearing: We will hold a public hearing concerning the proposed rule on June 21, 2010. Persons interested in presenting oral testimony at the hearing should contact Ms. Odessa Bowling, Program Implementation and Information Division, Office of Resource Conservation and Recovery, at (703) 308–8404 by June 14, 2010. The public hearing will be held in the Washington DC area at a location and time that will be posted at the following Web site: http://www.epa.gov/osw/nonhaz/ definition.htm. Please refer to this Web site to confirm the date of the public hearing as well. If no one requests to VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00002 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31845 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules speak at the public hearing by June 14, 2010 then the public hearing will be cancelled and a notification of cancellation posted on the following web site: http://www.epa.gov/osw/ nonhaz/definition.htm. Information regarding the interrelated CAA proposals referenced can be found at http://www.epa.gov/airquality/ combustion. Docket: All documents in the docket are listed in the http:// www.regulations.gov index. Although listed in the index, some information is not publicly available, e.g., CBI or other information whose disclosure is restricted by statute. Certain other material, such as copyrighted material, will be publicly available only in hard copy. Publicly available docket materials are available either electronically in http:// www.regulations.gov or in hard copy at the RCRA Docket, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW., Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Public Reading Room is (202) 566–1744, and the telephone number for the RCRA Docket is (202) 566–0270. FOR FURTHER INFORMATION CONTACT: George Faison, Program Implementation and Information Division, Office of Resource Conservation and Recovery, 5303P, Environmental Protection Agency, Ariel Rios Building, 1200 Pennsylvania Avenue, NW., Washington, DC 20460–0002; telephone number: 703–305–7652; fax number: 703–308–0509; e-mail address: faison.george@epa.gov. SUPPLEMENTARY INFORMATION: A. Does This Action Apply to Me? Categories and entities potentially affected by this action include: Generators Users Major generator category NAICS* Major boiler type and primary in- dustry category NAICS* Iron and Steel Mills ........................ 331111 ..........................................Industrial Boilers: Food Manufacturing ...................... 311, 312 Pulp and Paper Mills .................... 3221 Chemical Manufacturing ............... 325 Other Rubber Product Manufac- turing. 32629 ............................................ Petroleum Refining ....................... 32411 Primary Metal Manufacturing ....... 331 Fabricated Metal Manufacturing ... 332 Logging .......................................... 113310 .......................................... Other Manufacturing ..................... 313, 339, 321, 333, 336, 511, 326, 316, 327 Sawmills and Wood Preservation .. 32111. Veneer, Plywood, and Engineered Wood Product Manufacturing. 32121 ............................................Commercial Boilers: Pulp, Paper, and Paperboard Mills 3221 .............................................. Office ............................................ 813, 541, 921 Cattle Ranching and Farming ........ 1121 .............................................. Warehouse ................................... 493 Hog and Pig Farming ..................... 1122 .............................................. Retail ............................................. 442–454 Poultry and Egg Production ........... 1123 .............................................. Education ...................................... 611 Sheep and Goat Farming .............. 1124 .............................................. Social Assistance ......................... 624 Horses and Other Equine Produc- tion. 112920 .......................................... Lodging, Restaurant ..................... 721, 722 Crop Production ............................. 111 ................................................ Health Care Facilities ................... 621 Support Activities for Crop Produc- tion. 11511 ............................................ Other ............................................. 922140, others Food Manufacturing ....................... 311. Beverage and Tobacco Product Manufacturing. 312 ................................................Common Non-Manufacturing Boilers: Construction of Buildings ............... 236 ................................................ Agriculture (crop & livestock pro- duction). 111, 112, 115 Site Preparation Contractors ......... 238910 .......................................... All Mining ...................................... 212 Landscaping Services .................... 561730 .......................................... Construction .................................. 236 Iron and Steel Mills ........................ 331111. Fossil Fuel Electric Power Genera- tion. 221112 ..........................................Other Boilers: Cement Manufacturing .................. 327310 .......................................... Electric Utility Boilers .................... 2211 Bituminous Coal and Lignite Sur- face Mining. 212111. Bituminous Coal Underground Min- ing. 212112 .......................................... Non HW Burning Cement Kilns .... 327310 Anthracite Mining ........................... 212113. Sewage Treatment Facilities ......... 221320. Solid Waste Collection and Solid Waste Landfill. 562111, 562212. Metal-casting industry .................... 331522. Glass and Glass Product Manufac- turing. 3272. VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00003 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31846 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules Generators Users Major generator category NAICS* Major boiler type and primary in- dustry category NAICS* Packaging ...................................... 32611. Plastic manufacturers .................... 325211. Electrometallurgical Ferroalloy Product Manufacturing. 331112. Recycling Services for Degreasing Solvents Manufacturing. 325998. Solvent Dyes Manufacturing .......... 325132. Solvents Made in Petroleum Refin- eries. 324110. Automotive Repair and Replace- ment Shops. 811111. Recyclable Material Wholesalers ... 423930. Engineered Wood Members Manu- facturing. 321213. All Other Miscellaneous Chemical Product and Preparation Manu- facturing. 325998. *NAICS = North American Industrial Classification System. This table is not intended to be exhaustive, but rather provides a guide for readers regarding entities likely to be impacted by this action. This table lists examples of the types of entities of which EPA is aware that could potentially be affected by this action. Other types of entities not listed could also be affected. To determine whether your facility, company, business, organization, etc., is affected by this action, you should examine the applicability criteria in this rule. If you have any questions regarding the applicability of this action to a particular entity, consult the person listed in the preceding section: FOR FURTHER INFORMATION CONTACT. B. What Should I Consider as I Prepare My Comments for EPA? 1. Submitting CBI. Do not submit this information to EPA through http:// www.regulations.gov or e-mail. Clearly mark the part or all of the information that you claim to be CBI. For CBI information in a disk or CD ROM that you mail to EPA, mark the outside of the disk or CD ROM as CBI and then identify electronically within the disk or CD ROM the specific information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as CBI, a copy of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public docket. Information so marked will not be disclosed except in accordance with the procedures set forth in 40 CFR part 2. 2. Tips for Preparing Your Comments. When submitting comments, remember to: •Identify the rulemaking by docket number and other identifying information (subject heading, Federal Register date, and page number). •Follow directions—The agency may ask you to respond to specific questions or organize comments by referencing a Code of Federal Regulations (CFR) part or section number. •Explain why you agree or disagree, suggest alternatives, and substitute language for your requested changes. •Describe any assumptions and provide any technical information and/ or data that you used. •If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced. •Provide specific examples to illustrate your concerns, and suggest alternatives. •Explain your views as clearly as possible. •Make sure to submit your comments by the comment period deadline identified. 3. Docket Copying Costs. Many documents are available only in the original and, therefore, must be photocopied. Patrons are allowed 100 free photocopies. Thereafter, they are charged 15 cents per page. When necessary, an invoice indicating how many copies were made, the cost of the order, and where to send a check will be issued to the patron. Documents also are available on microfilm. The EPA/DC staff assist patrons locate the needed documents and operate the microfilm machines. The billing fee for printing microfilm documents is the same as for photocopying documents. Patrons who are outside of the metropolitan Washington, DC, area can request documents by telephone. The photocopying and microfilming fee is the same as for walk-in patrons. If an invoice is necessary, EPA/DC staff can mail one with the order. Preamble Outline I. Statutory Authority II. List of Abbreviations and Acronyms III. Introduction IV. Background A. What Is the History of CISWI, CISWI Definitions, and Boiler Rulemakings? B. Why Is the Court’s Decision Affecting the CAA Rules Relevant to RCRA? C. What Do Sections 112 and 129 of the CAA Require? V. Use of Secondary Materials A. Introduction B. Secondary Materials Use and Benefits VI. History of the Definition of Solid Waste A. Statutory Definition of Solid Waste B. Case Law on Definition of Solid Waste C. The Concept of Legitimacy VII. ANPRM Discussion, Summary of the Proposed Approach, Comments Received on the ANPRM, and Rationale for and Detailed Description of the Proposed Rule A. Summary of the ANPRM Approach 1. Traditional Fuels 2. Guiding Principles Used To Determine if Secondary Materials Used in Combustion Units Are Solid Wastes 3. Secondary Materials Used as Legitimate ‘‘Alternative’’ Fuels That Have Not Been Previously Discarded 4. Secondary Materials Used as Legitimate ‘‘Alternative’’ Fuels Resulting From the Processing of Discarded Secondary Materials 5. Secondary Materials Used as Legitimate Ingredients 6. Hazardous Secondary Materials That May Be Excluded From the Definition of Solid Waste Under RCRA Subtitle C Because They Are More Like Commodities Than Wastes 7. Additional Areas for Comment in the ANPRM VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00004 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31847 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules a. Fuels or Materials That Have Been Discarded That Are Generally Considered To Be Solid Wastes b. Other Approaches for Determining Whether Secondary Materials Are Fuels and Not Solid Wastes c. Materials for Which State Beneficial Use Determinations Have Been Made d. Biofuels B. Summary of the Proposed Approach 1. Changes From the ANPRM Approach 2. General Proposed Approach 3. Legitimacy Criteria 4. Traditional Fuels 5. Circumstances Under Which a Non- Hazardous Secondary Material Would Not Be Considered a Solid Waste 6. Petition Process C. What Were the Major Comments on the ANPRM? 1. Comments From State Agencies 2. Meaning of Discard 3. General Approach 4. Level of Processing Needed to Produce a Non-Waste Product From Discarded Waste Material 5. Comments on Specific Materials Used as Fuels a. Traditional Fuels b. Biomass c. Used Tires d. Used Oil e. Coal Refuse/Coal Combustion Residuals f. Sewage Sludge 6. Comments on Specific Materials Used as Ingredients a. Cement Kiln Dust b. Coal Combustion Residuals c. Foundry Sand d. Blast Furnace Slag/Steel Slag 7. Legitimacy Criteria a. General b. Fuels or Ingredients Being Managed as Valuable Commodities c. Fuels Must Have Meaningful Heating Value d. Fuel/Ingredient Contaminant Levels e. Ingredients Must Provide Useful Contribution f. Ingredients Must Produce a Valuable Product 8. De Minimis Concept D. Rationale for, and Detailed Description of, Proposed Approach 1. Non-Hazardous Secondary Materials Used as Fuel Within the Control of the Generator a. Scope and Applicability b. Restrictions and Requirements 2. Non-Hazardous Secondary Materials Used as Fuel Outside the Control of the Generator 3. Non-Hazardous Secondary Materials Used as Ingredients in Combustion Units 4. Non-Hazardous Secondary Materials Processed Into Non-Waste Fuel/ Ingredient Products a. Proposed Definition of Processing b. Rationale for Processing Discarded Material Into Non-Waste Product c. Examples of Adequate Processing d. Examples of Minimal Processing That Would Not Meet Proposed Definition of Processing e. Alternative Approach for Addressing Non-Hazardous Secondary Materials That Are Processed Into Non-Waste Fuels or Ingredients 5. Non-Waste Determination Process 6. Legitimacy Criteria a. Legitimacy Criteria for Fuels b. Legitimacy Criteria for Ingredients E. Alternative Approach F. Effect of Today’s Proposal on Other Programs 1. Clean Air Act 2. Renewable Energy 3. Subtitle C Hazardous Waste Program VIII. State Authority A. Applicability of State Solid Waste Definitions and Beneficial Use Determinations B. State Adoption of the Rulemaking IX. Cost and Benefits of the Proposed Rule X. Statutory and Executive Order Reviews A. Executive Order 12866: Regulatory Planning and Review B. Paperwork Reduction Act C. Regulatory Flexibility Act D. Unfunded Mandates Reform Act E. Executive Order 13132: Federalism F. Executive Order 13175: Consultation and Coordination With Indian Tribal Governments G. Executive Order 13045: Protection of Children From Environmental Health and Safety Risks H. Executive Order 13211: Actions That Significantly Affect Energy Supply, Distribution or Usage I. National Technology Transfer Advancement Act J. Executive Order 12898: Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Populations I. Statutory Authority The U.S. Environmental Protection Agency (EPA) is promulgating these regulations under the authority of sections 2002(a)(1) and 1004(27) of the Resource Conservation and Recovery Act (RCRA), as amended, 42 U.S.C. 6912(a)(1) and 6903(27). Section 129(a)(1)(D) of the CAA directs EPA to establish standards for Commercial and Industrial Solid Waste Incinerators (CISWI), which burn solid waste (section 129(g)(6) of the Clean Air Act (CAA), 42 U.S.C. 7429). Section 129(g)(6) provides that the term, solid waste, is to be established by EPA under RCRA. Section 2002(a)(1) of RCRA authorizes the Agency to promulgate regulations as are necessary to carry out its functions under the Act. The statutory definition of ‘‘solid waste’’ is provided in RCRA section 1004(27). II. List of Abbreviations and Acronyms ANPRM Advanced Notice of Proposed Rulemaking ASME American Society of Mechanical Engineers Btu British Thermal Unit CAA Clean Air Act CAFO Concentrated Animal Feeding Operations CCA Chromated Copper Arsenate CCR Coal Combustion Residuals CFR Code of Federal Regulations CISWI Commercial and Industrial Solid Waste Incinerator CKD Cement Kiln Dust CWA Clean Water Act DSE Domestic Sewage Exemption DSW Definition of Solid Waste EG Emission Guidelines EGU Electric Utility Steam Generating Unit EPA U.S. Environmental Protection Agency GACT Generally Available Control Technology GHG Greenhouse Gas HAP Hazardous Air Pollutant IWI Institutional Waste Incinerator LCA Life Cycle Analysis MACT Maximum Achievable Control Technology NESHAP National Emission Standards for Hazardous Air Pollutants NSPS New Source Performance Standards OSWI Other Solid Waste Incinerator PC Portland Cement PIC Product of Incomplete Combustion POTW Publicly Owned Treatment Works PVC Polyvinyl Chloride RCRA Resource Conservation and Recovery Act SWDA Solid Waste Disposal Act TDF Tire Derived Fuel VSMWC Very Small Municipal Waste Combustor III. Introduction In 1990, Congress added section 129 to the CAA to address emissions from solid waste incinerators. CAA section 129 directs EPA to promulgate emission standards for categories of ‘‘solid waste incineration units.’’ 42 U.S.C. 7429(a)(1). The term ‘‘solid waste incineration unit’’ is defined, in pertinent part, to mean ‘‘a distinct operating unit of any facility which combusts any solid waste material from commercial or industrial establishments * * *’’ Id. at §7429(g)(1). The CAA specifically excludes the following types of units from the definition of ‘‘solid waste incineration unit’’: (1) Incinerators or other units required to have a permit under section 3005 of RCRA; (2) material recovery facilities (including primary and secondary smelters) which combust waste for the primary purpose of recovering metals; (3) qualifying small power production facilities, as defined in section 3(17)(C) of the Federal Power Act, or qualifying cogeneration facilities, as defined in section 3(18)(B) of the Federal Power Act, which burn homogeneous waste (such as units which burn tires or used oil, but not including refuse-derived fuel) for the production of electric energy or in the case of qualifying cogeneration facilities which burn homogeneous waste for the production of electric energy or steam or forms of useful energy (such as heat) which are used for industrial, commercial, heating VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00005 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31848 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 1A secondary material is any material that is not the primary product of a manufacturing or commercial process, and can include post- consumer material, post-industrial material, and scrap. Many types of secondary materials have Btu or material value, and can be reclaimed or reused in industrial processes. For purposes of this notice, the term secondary materials include only non- hazardous secondary materials. See also American Mining Congress v. EPA, 824 F.2d 1177 (DC Cir. 1987) in which the U.S. Court of Appeals for the District of Columbia Circuit discussed secondary materials. 2EPA has delisted 3 of the 190 HAP initially listed in section 112(b)(1): Methyl ethyl ketone, glycol ethers, and caprolactam. 3A ‘‘major source’’ is any stationary source that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any HAP or 25 tons per year or more of any combination of HAP. CAA section 112(a)(1). or cooling purposes, or (4) air curtain incinerators, provided that such incinerators only burn wood wastes, yard wastes and clean lumber and that such air curtain incinerators comply with the opacity limitations to be established by the Administrator by rule. Id. CAA section 129 further states that the term ‘‘solid waste’’ shall have the meaning ‘‘established by the Administrator pursuant to the Solid Waste Disposal Act’’ Id. at 7429(g)(6). CAA section 129 refers to the Solid Waste Disposal Act (SWDA). However, this act, as amended, is commonly referred to as RCRA. Thus, the term ‘‘RCRA’’ is used in place of SWDA in this Notice. RCRA in turn defines the term ‘‘solid waste’’ to mean ‘‘* * * any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities, * * *’’ Section 1004 (27). IV. Background The discussion below was previously included in the Advanced Notice of Proposed Rulemaking (ANPRM). However, because it is also pertinent to the development of today’s proposal, it also is included here for the benefit of the reader. The entire record for the ANPRM is included in the record for this rulemaking. To the extent there are any inconsistencies or differences between the ANPRM and this proposal, the statements in this proposal apply. A. What is the history of CISWI, CISWI definitions, and boiler rulemakings? EPA promulgated a final rule setting forth performance emissions standards for Commercial and Industrial Solid Waste Incineration Units (referred to as the ‘‘CISWI Rule’’). 65 FR 75338 (December 1, 2000). Under CAA section 129, the emissions standards for new sources must be at least as stringent as the emissions control achieved in practice by the best-controlled similar source. For existing sources, the emissions standards must be at least as stringent as the average emissions limitation achieved by the best- performing 12 percent of units in the category. CAA section 129 (a)(2). This level of stringency is commonly referred to as the maximum achievable control technology (MACT) ‘‘floor.’’ EPA must also consider more stringent ‘‘beyond- the-floor’’ emissions controls, taking into account cost, energy, and non-air quality environmental impacts. The Administrator may also distinguish among classes, types (including mass- burn, refuse-derived fuel, modular and other types of units), and sizes of units within a category in establishing such standards. Id. at 7429(a)(2). The CISWI Rule established emission limitations for new and existing CISWI units for the following pollutants: Cadmium, carbon monoxide, dioxins/ furans, hydrogen chloride, lead, mercury, oxides of nitrogen (NOX), particulate matter (PM), sulfur dioxide (SO2), and opacity. In addition, the rule established certain monitoring and operator training and certification requirements. See 65 FR 75338 for a more detailed discussion of the CISWI Rule. The CISWI Rule was challenged in Sierra Club v. EPA (No. 01–1048) (DC Cir.). After promulgation of the CISWI Rule, the DC Circuit issued its decision in a challenge to EPA’s MACT standards for the cement kiln industry. Cement Kiln Recycling Coalition v. EPA, 255 F.3d 855 (DC Cir. 2001) (‘‘Cement Kiln’’). As a result of the courts decision in Cement Kiln, EPA requested a voluntary remand of the CISWI Rule, in order to address concerns related to the issues that were raised by the court in Cement Kiln. The court granted EPA’s request for a voluntary remand and remanded, without vacatur, the CISWI Rule back to EPA. Because the CISWI Rule was not vacated, its requirements remain in effect. See Sierra Club. v. EPA, 374 F. Supp.2d 30, 32–33 (D.D.C. 2005). On September 22, 2005, EPA issued revised definitions of ‘‘solid waste,’’ ‘‘commercial or industrial solid waste incineration unit,’’ and ‘‘commercial or industrial waste’’ (the ‘‘CISWI Definitions Rule’’). See 70 FR 55568. In the CISWI Definitions Rule, EPA defined ‘‘commercial and industrial solid waste’’ to exclude solid waste that is combusted at a facility in a combustion unit whose design provides for energy recovery or which operates with energy recovery. Therefore, a unit combusting solid waste with energy recovery was not considered a CISWI unit. The CISWI Definitions Rule was vacated by the DC Circuit in NRDC v. EPA (489 F.3d 1250 (DC Cir. 2007)). The court stated that the statute unambiguously requires any unit that combusts ‘‘any solid waste material at all’’—regardless of whether the material is being burned for energy recovery—to be regulated as a ‘‘solid waste incineration unit.’’ Id. at 1260. In the same decision, the court also vacated and remanded EPA’s emissions standards for commercial, industrial, and institutional major source boilers and process heaters (the Boiler MACT Rule), concluding that the universe of sources subject to that rule would be much smaller if it did not include units that combust solid waste for the purposes of energy recovery. B. Why is the court’s decision affecting the CAA rules relevant to RCRA? In responding to the court’s vacatur and remand of the CISWI Definitions Rule and the Boiler MACT Rule, EPA is establishing, under RCRA, which non- hazardous secondary materials1 are ‘‘solid waste.’’ This is necessary because, under the court’s decision, any unit combusting any ‘‘solid waste’’ at all must be regulated as a ‘‘solid waste incineration unit,’’ regardless of the function of the combustion device. If a non-hazardous secondary material (also referred to as secondary materials in this notice) is not a ‘‘solid waste’’ under RCRA, then a unit combusting that material must be regulated pursuant to CAA section 112 if it is a source of HAP. Alternatively, if such material is a ‘‘solid waste’’ under RCRA, then a unit combusting that material must be regulated under CAA section 129. C. What do CAA Sections 112 and 129 require? CAA section 112 requires EPA to promulgate regulations to control emissions of 187 2 hazardous air pollutants (HAP) from sources in each source category listed by EPA under section 112(c). The statute requires the regulations for major sources3 to reflect the maximum degree of reduction in emissions of HAP that is achievable taking into consideration the cost of achieving the emission reduction, any non-air quality health and environmental impacts, and energy requirements. For existing sources, the emissions standards must be at least as stringent as the average emissions limitation achieved by the best- VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00006 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31849 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 4An ‘‘area source’’ is any stationary source of HAP that is not a major source. CAA section 112(a)(2). Area sources may be regulated under CAA section 112(d)(2) standards if the Administrator finds that the sources ‘‘presen[t] a threat of adverse effects to human health or the environment (by such sources individually or in the aggregate) warranting regulation under this section.’’ Section 112(c)(3). Certain categories of area sources must be regulated in accordance with section 112(c)(3) and (k)(3)(B). 5Of these nine pollutants, cadmium, dioxins/ furans, hydrogen chloride, lead, and mercury are also regulated HAP pursuant to CAA section 112, and particulate matter and carbon monoxide are commonly used as surrogate emission standards to control specific CAA section 112 HAP (e.g., CAA section 112 HAP metal and organic emissions). 6The terms ‘‘life cycle analysis’’ and ‘‘life cycle assessment’’ are commonly used interchangeably. Life cycle assessment is a system-wide analytical technique for assessing the environmental (and sometimes economic) effects of a product, process, or activity across all life stages. 7Full cost accounting is an accounting system that incorporates economic, environmental, health, and social costs of a product, action, or decision. 8RCRA Section 6901(c)—Materials: The Congress finds with respect to materials, that—(1) Millions of tons of recoverable material which could be used are needlessly buried each year; (2) methods are available to separate usable materials from solid waste; and (3) the recovery and conservation of such materials can reduce the dependence of the United States on foreign resources and reduce the deficit in its balance of payments. 9For example, the GHG rate associated with the combustion of scrap tires is approximately 0.081 MTCO2E per MMBtu of scrap tires combusted, while the GHG emissions rate for coal is approximately 0.094 MTCO2E per MMBtu. Combined with the avoided extraction and processing emissions 0.006 MTCO2E/MMBtu for coal, the total avoided GHG is 0.019 MTCO2E per MMBtu. Substituting tire-derived fuel for coal would also avoid an estimated 0.246 Lbs/MMBtu of PM associated with extraction and processing of the coal. Please see the Materials Characterization Papers in the docket for further details on these estimates, and other estimates of avoided emissions associated with burning tires and other secondary materials as fuel. 10For purposes of this action, we define by- product as a secondary or incidental material derived from the primary use or production process that has value in the marketplace, or value to the user. 11Opportunities for improved economic efficiency are recognized through the Action Statement of the U.S. Business Council For Sustainable Development: ‘‘Promoting Sustainable Development by Creating Value Through Action Establishing Networks and Partnerships, and Providing a Voice for Industry.’’ performing 12 percent of units in the category or subcategory for categories and subcategories with at least 30 sources, and by the best-performing five sources in the category or subcategory for categories and subcategories with fewer than 30 sources. For new sources, the emissions standard must be at least as stringent as the emissions limitation achieved by the best-performing similar source. CAA section 112(d)(3). This level of stringency is commonly referred to as the MACT ‘‘floor.’’ Like the CAA section 112 standards, the CAA section 129 standards are based on a MACT floor. Also, as with the section 112 standards, above-the- floor standards may be established where EPA determines it is ‘‘achievable’’ taking into account costs and other factors. Although CAA section 129 ‘‘establishes emission requirements virtually identical to section [112’s],’’ Nat’l Lime Ass’n v. EPA, 233 F.3d at 631, the two sections differ in three primary respects. First, CAA section 112 requires that MACT standards be established for major sources of HAP emissions, but provides discretionary authority to establish standards based on ‘‘generally available control technology’’ (GACT) for area sources of HAP emissions.4 On the other hand, under CAA section 129, EPA must issue MACT standards for all solid waste incineration units in a given category regardless of size. Second, CAA section 129 requires that numeric emission limitations must be established for the following nine pollutants, plus opacity (as appropriate): cadmium, carbon monoxide, dioxins/furans, hydrogen chloride, lead, mercury, NOx, particulate matter (total and fine), and SO2.5 These nine pollutants represent the minimum that must be regulated; EPA has the discretion to establish standards for other pollutants as well. Third, CAA section 129 includes specific requirements for operator training, pre-construction site assessments, and monitoring that are not included in CAA section 112. See CAA section 129(a)(3), (c) and (d). Rather, CAA section 112’s implicit authority and CAA sections 113 and 114’s explicit authority is relied upon to include provisions as necessary to assure compliance with and enforcement of the section 112 emission limitations. It is important to note that CAA section 129(h)(2) specifies that no solid waste incineration unit subject to the performance standards under CAA sections 111 and 129 shall be subject to the standards under CAA section 112(d). V. Use of Secondary Materials A. Introduction The U.S. is pursuing an approach to materials management that employs the concepts of life cycle assessment6 and full cost accounting.7 Within the context of RCRA,8 this proposal aims to facilitate materials management to the extent allowed by the statute, through the establishment of a regulatory framework that guides the beneficial use of various secondary materials, while ensuring that such use is protective of human health and the environment. EPA, in conjunction with the states, seeks to further facilitate this objective through research, analysis, incentives, and communication. The Agency recognizes that secondary materials are widely used today as raw materials, as products, and as fuels and/or ingredients in industrial processes. We expect these uses will continue and expand in future years as effective materials management becomes more critical to a sustainable society. The use of materials from a variety of non- traditional sources, including the use of energy-containing secondary materials, is expected to play an important role in future resource conservation efforts. The use of secondary materials as alternative fuels and/or ingredients in manufacturing processes using combustion not only recovers valuable resources, it is known to contribute to emission reductions. For example, both greenhouse gas (GHG) and particulate matter (PM) emissions have been reduced as a co-benefit of the use of secondary materials.9 The use of secondary materials, such as use as a fuel in industrial processes may also result in other benefits. These may include reduced fuel imports, reducing negative environmental impacts caused by previous dumping (e.g., tires), and reduced methane gas generation from landfills. Secondary materials may, in most cases, be more appropriately defined as ‘‘by-products,’’10 reflecting their inherent resource recovery value in the generation and production of heat, energy, and/or marketable products. These secondary materials can provide micro (firm level) and macroeconomic benefits when legitimately used as an effective substitute for, or supplement to primary materials. Economic efficiency can be improved with the use of secondary materials, when substituted for increasingly scarce primary materials, because the use of such materials often results in an equivalent level of output at lower overall resource use, or in turn, more output could be generated using the same amount of resource inputs. When this occurs, monetary savings resulting from reduced resources would, theoretically, be applied to a higher and better use in the economy. This helps advance economic growth as a result of improved industrial efficiency,11 which, in turn, helps move the country toward material sustainability and energy self sufficiency, while protecting human health and the environment. B. Secondary Materials Use and Benefits A wide and diverse range of secondary materials are currently used as fuels and/or ingredients in VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00007 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31850 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 12The materials characterization paper on Silica Fume was the only paper not requiring updating. manufacturing or service processes. Based on our research conducted in support of the January 2, 2009 ANPRM, we identified eight non-hazardous secondary material fuels or fuel groups and six non-hazardous ingredients, or ingredient groups. The eight fuel source materials were: The biomass group (pulp and paper residuals, forest derived biomass, agricultural residues, food scraps, animal manure, and gaseous fuels); construction and demolition materials (building related, disaster debris, and land clearing debris); scrap tires; scrap plastics; spent solvents; coal refuse; waste water treatment sludge, and used oil. The six secondary material ingredients were: blast furnace slag; cement kiln dust (CKD); the coal combustion product group (fly ash, bottom ash, and boiler slag); foundry sand; silica fume; and secondary glass material. The ANPRM discussed and described these key secondary materials. In addition, we developed comprehensive Materials Characterization Papers for each of these fuel and ingredient materials. These papers were included in the docket for the ANPRM, which as we note above is incorporated into the docket for this proposed rule. Based on our review of the public comments submitted in response to the ANPRM, plus further research, we have identified three additional secondary materials not addressed in the ANPRM. These additional secondary materials are auto shredder residue, purification process byproducts, and resinated wood products. We have prepared Materials Characterization Papers for these newly identified secondary materials, which are also included in the docket for today’s proposed rule. In addition, we have updated and revised nearly all 12 of the existing Materials Characterization Papers to incorporate commenter information, as appropriate, plus relevant information derived from the 2008 combustion survey database (OMB Control Number 2060–0616). We believe that our newly defined list of secondary fuels and ingredients accounts for the vast majority of all secondary materials used in combustion processes in the U.S. However, as part of this proposal, we again solicit comment on these and any other non-hazardous secondary materials potentially used as fuels and/ or ingredients. Comments containing detailed, quality controlled data are welcome and will be very useful as we move forward in this rulemaking effort. Information on the annual quantity of material generated, used, and stored; major uses (i.e., fuel v. non-fuel); management practices; major markets; processing requirements; contaminants; and life cycle inventory data would be most helpful. VI. History of the Definition of Solid Waste A. Statutory Definition of Solid Waste RCRA defines ‘‘solid waste’’ as ‘‘* * *any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material *** resulting from industrial, commercial, mining, and agricultural operations, and from community activities * * *’’ (RCRA section 1004 (27) (emphasis added)). The key concept is that of ‘‘discard’’ and, in fact, this definition turns on the meaning of the phrase, ‘‘other discarded material,’’ since this term encompasses all other examples provided in the definition. The ANPRM provides a complete discussion on the concept of discard, as well as a description of the solid waste program under RCRA subtitle D, and the hazardous waste program under RCRA subtitle C. We refer the reader to the ANPRM for a detailed discussion on these subjects regarding the definition of solid waste. The ANPRM also includes a detailed discussion on the case law on the definition of solid waste, which we repeat below, and on the concept of legitimacy, or legitimate recycling. That discussion is relevant to this proposal and is incorporated into this rulemaking. We are repeating parts of the discussion on legitimacy below to the extent it helps in understanding this proposal. B. Case Law on Definition of Solid Waste Partly because the interpretation of the definition of solid waste is the foundation of the hazardous waste regulatory program, there has been a great deal of litigation over the meaning of ‘‘solid waste’’ under RCRA subtitle C. From these cases, a few key principles emerge which guide our thinking on the definition of solid waste. First, the ordinary plain-English meaning of the term, ‘‘discard’’ controls when determining whether a material is a solid waste. See American Mining Congress v. EPA, 824 F.2d 1177 (DC Cir. 1987) (‘‘AMC I’’). The ordinary plain- English meaning of the term discarded means ‘‘disposed of,’’ ‘‘thrown away,’’ or ‘‘abandoned.’’ The DC Circuit in AMC I specifically rejected a more expansive meaning for discard that would encompass any materials ‘‘no longer useful in their original capacity’’ even if they were not destined for disposal. 824 F.2d at 1185–87. The Court further held that the term ‘‘discarded materials’’ could not include materials ‘‘*** destined for beneficial reuse or recycling in a continuous process by the generating industry itself. (824 F.2d at 1190). Subsequent to AMC I, the DC Circuit discussed the meaning of discard in particular cases. In American Petroleum Institute v. EPA, 906 F.2d 729 (DC Cir. 1990) (‘‘API I’’), the court rejected EPA’s decision not to regulate recycled air pollution control equipment slag based on an Agency determination that waste ‘‘ceases to be a ‘solid waste’ when it arrives at a metals reclamation facility because at that point it is no longer ‘discarded material.’’’ 906 F.2d at 740. Instead, the court held that the materials were part of a mandatory waste treatment plan for hazardous wastes prescribed by EPA and continued to be wastes even if recycled. 906 F.2d at 741. Further, a material is a solid waste regardless of whether it ‘‘may’’ be reused at some time in the future. American Mining Congress v. EPA, 907 F.2d 1179 (DC Cir. 1990) (‘‘AMC II’’). One of the more important holdings of a number of court decisions is that simply because a waste has, or may have, value does not mean the material loses its status as a solid waste. See API I, 906 F.2d at 741 n.16; United States v. ILCO Inc., 996 F.2d 1126, 1131–32 (11th Cir. 1993); Owen Steel v. Browner, 37 F.3d 146, 150 (4th Cir. 1994). ILCO and Owen Steel, however, recognize that products made from wastes are, themselves, products and not wastes. The DC Circuit’s decision in Association of Battery Recyclers v. EPA, 208 F.3d 1047 (DC Cir. 2000) (‘‘ABR’’) reiterated the concepts discussed in the previous cases. The Court held that it had already resolved the issue presented in ABR in its opinion in AMC I, where it found that ‘‘** * Congress unambiguously expressed its intent that ‘solid waste’ (and therefore EPA’s regulatory authority) be limited to materials that are ‘discarded’ by virtue of being disposed of, abandoned, or thrown away’’ (208 F.2d at 1051). It repeated that materials reused within an ongoing industrial process are neither disposed of nor abandoned (208 F.3d at 1051–52). The court also explained that the intervening API I and AMC II decisions had not narrowed the holding in AMC I (208 F.3d at 1054–1056). Notably, the Court in ABR did not hold that storage before reclamation automatically makes materials ‘‘discarded.’’ Rather, it held that ‘‘*** at least some of the secondary material EPA seeks to regulate as solid waste (in VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00008 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31851 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 13On January 9, 2009, the Office of Solid Waste was renamed the Office of Resource Conservation and Recovery. 14See 73 FR 64668. 15The hazardous waste exclusions from the definition of solid waste became effective on December 29, 2008. On January 29, 2009, the Sierra Club submitted a petition under RCRA section 7004(a), 42 U.S.C. 6974(a), to the Administrator of EPA requesting that the Agency repeal the revisions to the definition of solid waste rule and stay the implementation of the rule. In addition, the Sierra Club and the American Petroleum Institute have filed petitions for judicial review of a rule with the Continued the mineral processing rule) is destined for reuse as part of a continuous industrial process and thus is not abandoned or thrown away’’ (208 F.3d at 1056). In this regard, the court criticized all parties in the case—industry as well as EPA—because they ‘‘presented this aspect of the case in broad abstraction, providing little detail about the many processes throughout the industry that generate residual material of the sort EPA is attempting to regulate * * *. ’’ (Ibid). American Petroleum Institute v. EPA, 216 F.3d 50, 55 (DC Cir. 2000) (‘‘API II’’), decided shortly after ABR and considered by the court at the same time, provides further guidance for defining solid waste, but in the context of two specific waste streams in the petroleum refining industry. The court overturned EPA’s determination that certain recycled oil bearing wastewaters are wastes (216 F.3d at 55–58) and upheld conditions imposed by the Agency in excluding petrochemical recovered oil from the definition of solid waste (216 F.3d at 58–59). In the case of oil-bearing wastewaters, EPA had determined that the first phase of treatment, primary treatment, results in a waste being created. 216 F.3d at 55. The court overturned this decision and remanded it to EPA for a better explanation, neither accepting EPA’s view nor the contrary industry view. The court noted that the ultimate determination that had to be made was whether primary treatment is simply a step in the act of discarding or the last step in a production process before discard. 213 F.3d at 57. In particular, the court rejected EPA’s argument that primary treatment was required by regulation, instead stating that the Agency needed to ‘‘set forth why it has concluded that the compliance motivation predominates over the reclamation motivation’’ and ‘‘why that conclusion, even if validly reached, compels the further conclusion that the wastewater has been discarded.’’ 213 F.3d at 58. The court also considered whether material is discarded in Safe Food and Fertilizer v. EPA, 350 F.3d 1263 (DC Cir. 2003) (‘‘Safe Food’’). In that case, among other things, the court rejected the argument that, as a matter of plain meaning, recycled material destined for immediate reuse within an ongoing industrial process is never considered ‘‘discarded,’’ whereas material that is transferred to another firm or industry for subsequent recycling must always be solid wastes. 350 F.3d at 1268. Instead, the court evaluated ‘‘whether the agency’s interpretation of * * * ‘discarded’ * * * is, reasonable and consistent with the statutory purpose* * * .’’ Id. Thus, EPA has the discretion to determine that a material is not a solid waste, even if it is transferred between industries. We also note that the Ninth Circuit has specifically found that non- hazardous secondary materials may, under certain circumstances, be burned and not constitute a solid waste under RCRA. See Safe Air For Everyone v. Waynemeyer (‘‘Safe Air’’), 373 F.3d 1035 (9th Cir., 2004) (Kentucky bluegrass stubble may be burned to return nutrients to the soil and not be a solid waste). C. The Concept of Legitimacy An important element under the RCRA subtitle C definition of solid waste (and an important element of today’s proposal) is the concept of legitimate use and recycling. Under RCRA subtitle C, some hazardous secondary materials that would otherwise be subject to regulation under RCRA’s ‘‘cradle to grave’’ system are not considered solid wastes if they are ‘‘legitimately recycled’’ or legitimately used as an ingredient or substitute for a commercial product. The principal reasoning behind this construct is that use or recycling of such materials often closely resembles normal industrial production, rather than waste management. However, since there can be considerable economic incentive to manage recyclable materials outside of the RCRA hazardous waste regulatory system, there is a clear potential for and historical evidence of some handlers claiming they are recycling, when in fact they are conducting waste treatment and/or disposal in the guise of recycling. EPA considers such ‘‘sham’’ recycling to be, in fact, discard and such secondary materials being sham recycled are solid wastes. To guard against hazardous secondary materials being discarded in the guise of recycling, EPA has long articulated the need to distinguish between ‘‘legitimate’’ (i.e., true) recycling or other use and ‘‘sham’’ (i.e., fake) recycling; see the preamble to the 1985 hazardous waste regulations that established the definition of solid waste under RCRA subtitle C (50 FR 638; January 4, 1985). A similar discussion that addressed legitimacy as it pertains to burning hazardous secondary materials for energy recovery (considered a form of recycling under RCRA subtitle C) was presented in the January 9, 1988 proposed amendments to the definition of solid waste (53 FR 522). Then on April 26, 1989, the Office of Solid Waste 13 issued a memorandum that consolidated the various preamble and other statements concerning legitimate recycling into a list of questions to be considered in evaluating the legitimacy of hazardous secondary materials recycling (OSWER directive 9441.1989(19)). This memorandum (known to many as the ‘‘Lowrance Memo,’’ a copy of which is included in the Docket to today’s preamble) has been a primary source of information for the regulated community and for overseeing agencies in distinguishing between legitimate and sham recycling. On October 30, 2008, EPA finalized several exclusions from the definition of solid waste for hazardous secondary materials being reclaimed and a non- waste determination process for persons to receive a formal determination that their hazardous secondary materials are not solid wastes when legitimately reclaimed.14 In that action, EPA codified in 40 CFR 260.43 the requirement that materials be legitimately recycled as a condition for the exclusion for hazardous secondary materials that are legitimately reclaimed under the control of the generator (40 CFR 261.2(a)(2)(ii) and 40 CFR 261.4(a)(23)) and as a condition of the exclusion for hazardous secondary materials that are transferred for the purpose of legitimate reclamation (40 CFR 261.4(a)(24) and 40 CFR 261.4(a)(25)). As part of that final rule, EPA also codified a legitimate recycling provision specifically as a requirement or condition of these exclusions and the non-waste determination process (40 CFR 260.34). Although this proposed rule does not address the Agency’s hazardous waste regulations, EPA believes the concept of legitimacy is an important one in determining when a secondary material is genuinely recycled and not discarded under the guise of recycling. Therefore, the Agency is including the following discussion in today’s preamble to provide the context in which EPA has integrated the concept of legitimacy into the recently promulgated hazardous waste exclusions from the definition of solid waste.15 VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00009 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31852 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules United States Court Of Appeals for The District Of Columbia Circuit. One of the issues that EPA will consider is the definition of legitimate recycling. However, until that occurs, the final rule, including the definition of legitimate recycling remains in effect until and unless EPA goes through another rulemaking process (proposed and final) to repeal or amend it. The legitimacy provision in the October 2008 final rule, which applies specifically to hazardous secondary materials excluded under the rule, has two parts. The first part includes two factors: (1) the hazardous secondary materials being recycled must provide a useful contribution to the recycling process or to the product or intermediate of the recycling process, and (2) the product or intermediate produced by the recycling process must be valuable. These two legitimacy factors make up the core of legitimacy, and, therefore, a process that does not conform to them cannot be a legitimate recycling process, but would be considered sham recycling. The second part of the legitimacy provision consists of two factors that must be considered when determining if a particular hazardous secondary material recycling process is legitimate for the purposes of the exclusion. These two factors are: (1) The generator and the recycler should manage the hazardous secondary material as a valuable commodity, and (2) the product of the recycling process does not contain significant concentrations of hazardous constituents that are not in analogous products. EPA believes these two factors are important in determining legitimacy, but has not made them factors that must be met because the Agency is aware of situations where a legitimate recycling process exists, but may not conform to one or both of these two factors. In making a determination that a hazardous secondary material is legitimately recycled, persons must evaluate all factors and consider legitimacy as a whole. If, after careful evaluation of these other considerations, one or both of the non-mandatory factors are not met, then this fact may be an indication that the material is not legitimately recycled. To evaluate the extent to which these factors are met and in determining the legitimacy of a recycling process that does not meet one or both of these factors, persons can consider the protectiveness of the storage methods, exposure from toxics in the product, the bioavailability of the toxics in the product, and other relevant considerations. EPA stated in the preamble to the October 2008 final rule that, although the Agency was only codifying the legitimacy provision as part of the new hazardous secondary materials recycling exclusions and non-waste determination process, it was stressing that EPA retains its long-standing policy that all recycling of hazardous secondary materials must be legitimate and that the four legitimacy factors codified at 40 CFR 260.43 are substantively the same as the Agency’s long-standing legitimacy policy, as stated in the 1989 Lowrance Memo and in various definition of solid waste rulemakings. EPA believes the same principle of ‘‘legitimacy’’ is likewise an important element in the recycling of non- hazardous secondary materials. That is, the concept of legitimate recycling is crucial to determining whether a non- hazardous secondary material being recycled is truly being recycled or is, in fact, being discarded through sham recycling. In the January 2, 2009 ANPRM, the Agency sought comment on the appropriate construct for determining when such non-hazardous secondary materials are legitimately burned as a fuel or used as a legitimate ingredient in an industrial process that involved combustion (see Section V, 74 FR 53–9). A general discussion of the comments EPA received follows in Section VII.C. VII. ANPRM Discussion, Summary of the Proposed Approach, Comments Received on the ANPRM, and Rationale for and Detailed Description of the Proposed Rule A. Summary of the ANPRM Approach In the ANPRM, the Agency considered various scenarios in evaluating the usage of secondary materials (e.g., as fuels or ingredients) and whether these materials should be considered solid wastes under RCRA when used in combustion devices, such that units burning these secondary materials would be subject to regulation under CAA section 129, rather than subject to CAA section 112. Specifically, the ANPRM identified several cases where such non-hazardous secondary materials are not solid wastes when combusted, and thus, subject to CAA section 112. These were: (1) Traditional fuels, (2) secondary materials used as legitimate ‘‘alternative’’ fuels that have not been previously discarded, (3) secondary materials used as legitimate ‘‘alternative fuels’’ resulting from the processing of discarded secondary materials, (4) secondary materials used as legitimate ingredients, and (5) hazardous secondary materials that may be excluded from the definition of solid waste under RCRA subtitle C because they are more like commodities than wastes. All other cases where non- hazardous secondary materials are combusted would be considered ‘‘solid wastes’’ and subject to CAA section 129. 1. Traditional Fuels The ANPRM categorized cellulosic biomass (e.g., wood) and fossil fuels (e.g., coal, oil, natural gas) and their derivatives (e.g., petroleum coke, bituminous coke, coal tar oil, refinery gas, synthetic fuel, heavy recycle, asphalts, blast furnace gas, recovered gaseous butane, coke oven gas) as traditional fuels that have been burned historically as fuels and have been managed as valuable products, and stated that they are considered unused products that have not been discarded and therefore are not solid wastes. The ANPRM further stated that wood collected from forest fire clearance activities and trees and uncontaminated wood found in disaster debris would not be discarded if managed properly and burned as a legitimate fuel, and therefore not a solid waste. 2. Guiding Principles Used To Determine if Secondary Materials Used in Combustion Units Are Solid Wastes The ANPRM explained key factors in determining if alternative fuels or ingredients are solid wastes under RCRA, including whether they have been discarded, and if they have been discarded, whether they have been processed to produce a fuel or ingredient product that would not be considered a solid waste. The ANPRM further explained that the plain-English meaning of the term discard applies to the RCRA definition of solid waste. That is, a material is discarded if it is disposed of, thrown away, or abandoned. Moreover, the ANPRM stated the term ‘‘discarded materials’’ could not include materials ‘‘*** destined for beneficial reuse or recycling in a continuous process by the generating industry itself,’’ and that determining whether a secondary material is used in a continuous process is important because certain materials under consideration are produced and managed in a continuous process within an industry (e.g., cement kiln dust that is recycled in cement kilns). The ANPRM went on to say that even if the secondary material is not used in a continuous process, if it is used as a legitimate fuel or ingredient, these secondary materials are not solid wastes if they were not previously discarded. For alternative fuels or ingredients not to be considered discarded, and thus not to be solid wastes, the ANPRM stated that they must be legitimate fuels or ingredients. It then described EPA’s criteria for determining if a secondary VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00010 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31853 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 16EPA is completing a study evaluating the use of a mobile unit for the combustion of vegetative and construction and demolition debris generated from natural disasters. This study includes monitoring of the source and ambient emissions, and a screening risk assessment. Results are projected to be available later in 2010. Extreme care needs to be taken to exclude specific materials in C&D debris, especially regulated-asbestos containing materials (RACM). Additionally, the wiring, plastics, and painted surfaces may contribute to emissions of concern and might not equate to traditional fuels. Upon publication, this study will be available at EPA’s National Risk Management Research Laboratory (NRMRL) publications Web site at http://www.epa.gov/nrmrl/ publications.html. 17In determining whether the concentration of contaminants in secondary materials is ‘‘significantly higher,’’ the Agency stated in the ANPRM that it could use a qualitative evaluation of the potential human health and environmental risks posed. A contaminant concentration could be elevated without posing unacceptable risk, and therefore may not be considered ‘‘significant’’ for the purposes of determining whether the secondary material is a legitimate fuel. material is a legitimate fuel or ingredient. The Agency explained that it generally considers secondary materials to be legitimate non-waste fuels if they are handled as valuable commodities, have meaningful heating value, and contain contaminants that are not significantly higher in concentration than traditional fuel products. If these criteria are not met, sham recycling may be indicated and the secondary material might be a solid waste. Similarly, for non-hazardous secondary materials to be considered a non-waste ingredient, the ANPRM stated that it would generally consider secondary materials to be non-waste ingredients if the secondary material is handled as a valuable commodity, the secondary material provides a useful contribution, the recycling results in a valuable product, and the product does not contain contaminants that are significantly higher in concentration than traditional products. 3. Secondary Materials Used as Legitimate ‘‘Alternative’’ Fuels That Have Not Been Previously Discarded For legitimate ‘‘alternative’’ fuels that have not been previously discarded, the ANPRM stated that the question of what constitutes a legitimate ‘‘fuel’’ reflects the availability of fuel materials generally, the demand for fuel, and technology developments. Thus, in addition to traditional fuels, the ANPRM stated that there is a category of secondary materials that are legitimate alternative fuels; that is, there are secondary materials that may not have been traditionally used as fuels, but that are nonetheless legitimate fuels today because of changes in technology and in the energy market. In cases where these legitimate alternative fuels have not been discarded, EPA said that it would not consider them to be solid wastes. We stated that much of the biomass currently used as alternative fuels are not solid waste since they have not been discarded in the first instance and are legitimate fuel products, noting that biomass can include a wide range of alternative fuels, and can be broken down into two different categories— cellulosic biomass and non-cellulosic biomass. Cellulosic biomass was described to include forest-derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, and tree harvesting residuals from logging and sawmill materials), food scraps, pulp and paper mill wood residuals (e.g., hog fuel, such as clean and unadulterated bark, sawdust, trim screenings; and residuals from tree harvesting), and agricultural residues (e.g., straw, corn husks, peanut shells, and bagasse). Non-cellulosic biomass was described to include manures and gaseous fuels (e.g., from landfills and manures). The ANPRM stated that biomass, especially cellulosic biomass, has a comparable composition to traditional fuel products due to the nature of the plants and animals (i.e., they would not be considered to have additional ‘‘contaminants’’). Thus, if they are managed as valuable commodities and have meaningful heating value, they would not be considered solid wastes. The ANPRM also noted that tires used as tire-derived fuel (TDF), which include whole or shredded tires, that have not been previously discarded, are legitimate fuels if they meet the legitimacy criteria i.e., they are handled as valuable commodities, have meaningful heating value, and do not contain contaminants that are significantly higher in concentration when compared to traditional fuel products (see Materials Characterization Paper on Scrap Tires in the docket for today’s rule for a complete discussion on contaminants in TDF [EPA–HQ– RCRA–2008–0329]). We noted that in many cases, used tires that are collected pursuant to state tire oversight programs (e.g., used tires from tire dealerships that are sent to used tire processing facilities) are handled as valuable commodities, and, therefore, have not been abandoned, disposed of, or thrown away. We noted that because states typically regulate these programs under their state solid waste authorities, it is not the Agency’s intent to undercut the state’s authority in this area. We requested comment on whether tires collected pursuant to state tire oversight programs have been discarded, and also requested comment on whether an EPA designation specifying that used tires, for example, managed pursuant to state collection programs are not solid wastes, would adversely impact a state’s ability to manage such a program. EPA notes that it is considering a change regarding the issue of tires collected under state programs, which is discussed later in the preamble. In particular, the Agency proposes that tires collected under these recycling programs are discarded and are solid wastes. EPA proposes this formulation for tires, but is asking for further comment on the ANPRM formulation that secondary material collected and sent for legitimate use as fuels are not discarded and are not solid wastes. For more discussion, see sections VII.C.5.c. and VII.D.2 of today’s proposal. EPA may issue a final rule containing either set of provisions depending on information received in the comment period and other information available to the Agency. The ANPRM described other non- traditional alternative fuels in use today that we are evaluating to determine whether they have been discarded and whether they are legitimate alternative fuels (e.g., construction and demolition materials,16 scrap plastics, non- hazardous non-halogenated solvents and lubricants, and wastewater treatment sludge). The ANPRM then described secondary materials we considered to be questionable as to whether they are legitimate fuels because they lack adequate heating value (wet biomass), or because they may contain contaminants that are significantly higher17 in concentration than those in traditional fuel products to the degree that sham recycling is indicated. The materials that were described in the ANPRM that could fall into this category include polyvinyl chloride (PVC), halogenated plastics, chromated copper arsenate (CCA) lumber, creosote lumber, copper-based treated lumber, lead-based treated lumber, and secondary mill residues, such as board, trim and breakage from the manufacture of reconstituted wood/ panel products. 4. Secondary Materials Used as Legitimate ‘‘Alternative’’ Fuels Resulting From the Processing of Discarded Secondary Materials The ANPRM also stated that legitimate fuel products may be extracted, processed, or reclaimed from non-hazardous secondary materials that have been discarded in the first instance and that such products would generally not be considered solid waste. Once processed to make a legitimate non- waste fuel product, such a product VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00011 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31854 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 18Turning scrap tires into TDF can involve two physical processing steps: Chipping/shredding and in some cases metal removal. The ANPRM stated that, at that point, the Agency’s view was that tire shredding/chipping alone (without metal recovery), as well as in combination with metal recovery, are legitimate processing activities sufficient to convert a discarded material into a fuel product. would not be discarded and therefore would not be a solid waste, provided it met the general principles discussed in today’s preamble for being a legitimate fuel. However, until a legitimate product has been processed, the secondary material that has been discarded is a solid waste, and must comply with any federal, state or local regulations. In addition, any waste generated in the ‘‘processing’’ of these materials would need to be managed properly and comply with the appropriate requirements. The ANPRM described various secondary materials that can be processed into fuels, including discarded biomass (e.g., with dewatering/drying techniques to increase the Btu/lb, or stripping the paint off wood to produce clean biomass), coal fines, used oil, tires,18 landfill ash, and secondary materials that are mixed and processed into pellets (or other forms) that have the consistency and handling characteristics of coal (e.g., K–Fuel, N–Viro). The ANPRM stated that the degree of processing necessarily will vary depending on the specific material, but the objective remains the same—the product from the processing must be a legitimate fuel (i.e., a material with meaningful heating value, with contaminants that are not present at significantly higher concentrations than those of traditional fuel products, and managed as a valuable commodity). Although the ANPRM stated that forest-derived biomass is not considered to have been discarded, we requested comment on whether any forest-derived biomass that was determined to have been discarded and was subsequently processed by chipping or sorting prior to use as a fuel through combustion would be considered to have undergone adequate processing to convert the discarded material into a fuel product. We also requested comment on whether mined landfill power plant residuals that is crushed, screened, and/or separated into its fundamental components through density separation is adequately processed to convert it into a fuel product or ingredient (under the assumption that it meets our previously described legitimacy criteria). With respect to used oil, the ANPRM stated that off-specification used oil that is collected from repair shops is generally thought to be originally discarded, but that on-spec used oil was considered to be a product fuel, not a waste. We also requested comment on whether off-specification used oil managed pursuant to the 40 CFR part 279 used oil management standards which are burned for energy recovery should be considered to be discarded, and thus whether such off-specification used oil should be considered a non- waste fuel. We stated that although off- specification used oil may contain contaminant levels that are higher in concentration than traditional (virgin) fossil fuels, they still are managed within the constraints of the used oil management standards, and may only be burned in specific types of combustion devices. 5. Secondary Materials Used as Legitimate Ingredients For secondary materials used as ingredients, the ANPRM also stated we must determine whether alternative ingredients, such as CKD, bottom ash, boiler slag, blast furnace slag, foundry sand, and secondary glass material have been discarded, or whether they are being used as legitimate non-waste ingredients. For example, the ANPRM stated that coal fly ash is handled as a commodity within continuous commerce when it is marketed to cement kilns as an alternative ingredient, and would not be considered a waste if it met the legitimacy criteria. The ANPRM also stated that secondary materials used as ingredients that were previously discarded could be processed into legitimate non-waste ingredients. 6. Hazardous Secondary Materials That May Be Excluded From the Definition of Solid Waste Under RCRA Subtitle C Because They Are More Like Commodities Than Wastes In the ANPRM, the Agency explained that, under the hazardous waste regulations, EPA has evaluated a number of hazardous secondary materials that are legitimately used or recycled and determined that such materials, while they either met a listing description or exhibited one or more of the hazardous waste characteristics, were not ‘‘solid wastes’’ for purposes of the subtitle C hazardous waste regulations. Specifically, black liquor, spent sulfuric acid, and comparable fuels may be burned under certain conditions and would not be solid wastes. The ANPRM discussed EPA’s interest in extending this determination so that these materials are not considered solid wastes under RCRA subtitle D as well. 7. Additional Areas for Comment in the ANPRM a. Fuels or Materials That Have Been Discarded That Are Generally Considered To Be Solid Wastes The ANPRM explained that secondary materials that have been previously discarded and not subsequently processed into legitimate fuels or ingredients are considered solid wastes under RCRA. However, the Agency requested comment as to whether these discarded materials—once recovered from the discard environment—should no longer be considered solid waste (assuming they are in fact valuable fuels or ingredients and otherwise meet the legitimacy criteria once recovered). EPA recognized that waste can be burned for energy or material recovery. Such materials, once they have been discarded, generally are considered ‘‘solid wastes’’ and units that burn these materials would be subject to the CAA section 129 incineration standards if they have not been processed into a legitimate non-waste ingredient or fuel. However, the ANPRM explained that as prices for primary materials have increased, in many cases, the economics of using secondary materials as a substitute for primary materials has shifted, changing how the secondary materials are considered in commerce. In addition, new technologies can expand the universe of secondary materials that could be considered legitimate fuels. The ANPRM therefore requested comment on those situations where discarded materials (e.g., used tires and coal refuse) can be directly used as a legitimate fuel or ingredient without processing because they are indistinguishable in all relevant aspects from a fuel or ingredient product. (Note that the Agency only requested comment on these secondary materials at the point they have been removed from their ‘‘discard’’ environment and managed as valuable commodities. Materials that have been disposed of in abandoned piles or landfills are clearly discarded while they remain in those environments and are subject to appropriate federal, state and local regulations.) b. Other Approaches for Determining Whether Secondary Materials Are Fuels and Not Solid Wastes The ANPRM requested comment on an approach, as presented to the Agency by industry representatives, for determining when non-hazardous secondary materials are fuels and thus, not solid waste, and how the process VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00012 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31855 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 19A copy of this industry-recommended approach entitled, ‘‘Outline of Regulatory Approach to Determine Materials Considered Fuels—not Solid Wastes—under RCRA,’’ is included in the docket to today’s proposed rule. may be implemented.19 Industry representatives suggested that non- hazardous secondary materials should be evaluated, on a case-by-case basis, to identify which criteria have been satisfied and determine whether the material is legitimately handled as a fuel. Criteria identified by industry stakeholders include: handling and storage of materials to minimize loss, use of materials within a reasonable period of time, material value (e.g., whether there is a market for the material as a fuel, internal or external to the company), material managed and treated as a commodity, and processing of material to enhance fuel value. Under the industry recommended approach, the secondary material would not necessarily have to satisfy all criteria. To implement the aforementioned concepts for determining when or which secondary materials are fuels, the ANPRM described two methods presented by industry, which were not meant to be mutually exclusive. One method is self-implementing, by which an owner or operator of a combustion device must determine that the secondary material meets the criteria set forth and maintain records to demonstrate that these criteria are met. The other method is not self- implementing, but would allow an owner or operator to petition EPA or the state to specifically list a secondary material as a legitimate non-waste fuel (in addition to a pre-established list of materials). In the petition, the owner or operator would use the criteria as the basis for proposing that EPA or the state list the secondary material, or the owner or operator could submit additional information to demonstrate the environmental equivalence of the material to other listed fuels. c. Materials for Which State Beneficial Use Determinations Have Been Made The ANPRM explained that states regulate the management of non- hazardous solid waste, including secondary industrial materials, and that many states have a process or promulgated regulations to determine when these materials are no longer wastes because they can beneficially and safely be used as products in commerce. Materials are no longer subject to the state’s solid waste regulations under the state rules when the state determines that the secondary materials are no longer solid wastes when beneficially used. The ANPRM further explained that the states are the lead Agencies for implementing the non-hazardous waste programs and, as such, the Agency wanted to make sure that state programs are not adversely affected by any decisions that are made by EPA, noting that we see a benefit to deferring to state decisions, which are able to consider site-specific information. As a result, the Agency requested comments on whether to consider secondary materials that receive a state beneficial use determination for use as a fuel or as an ingredient as not a solid waste, also not be considered a solid waste under federal law. d. Biofuels Biofuels can be generally described as a gas or liquid fuel made from biological materials, including plants, animal manure, and other organic sources. The ANPRM noted that biofuel production has increased dramatically in the past few years and is expected to continue increasing over the coming years, and stated that biofuels produced from secondary materials, such as ethanol and biodiesel, are not considered to be solid wastes themselves, but rather are viewed as legitimate fuel products. Secondary materials associated with biofuel production can be viewed to include both the feedstock materials that are used to produce biofuels, as well as the byproducts generated from the production of biofuels. The ANPRM stated that these materials are considered legitimate alternative fuels when they have meaningful heating value, do not contain contaminants that are significantly higher in concentration than traditional fuels, and are handled as a valuable commodity. B. Summary of the Proposed Approach 1. Changes from the ANPRM Approach While many of the concepts and provisions that were discussed in the ANPRM are included in this proposal, including discard and the legitimacy criteria, the basic framework is different based partly on the approach taken in the Definition of Solid Waste (DSW) final rule promulgated on October 30, 2008 (see 73 FR 64668) under subtitle C of RCRA, based partly on the comments received (see section VII.C for the comments and EPA’s response), as well as on our interpretation of whether these secondary materials are considered to be discarded (see section VII.C.2 for the comments and EPA’s response). The ANPRM indicated that there may be a number of secondary materials that would not be considered discarded even if the original generator sent them to another entity outside of its control. For example, used tires collected from automobiles at tire dealerships and managed pursuant to state tire collection programs were not viewed as solid wastes in the ANPRM. Comments received from some states suggested that non-hazardous secondary material fuels that are transferred to a third party have entered what is traditionally considered to be the ‘‘waste stream’’ (and have been regulated by the states as wastes) and therefore should appropriately be considered wastes (e.g., scrap tires) unless/until they are processed into non-waste fuel products. As discussed below, this proposal assumes that non- hazardous secondary materials that are used as fuels and are managed outside the control of the generator are solid wastes unless they are processed into non-waste fuel products. (Note: The same non-hazardous secondary material that is burned for energy recovery under the control of the generator and meets the legitimacy criteria would not be considered a solid waste since the non- hazardous secondary material would not be considered discarded.) We are also proposing, as discussed below, a non-waste determination petition process. That process will allow those persons who burn non-hazardous secondary material fuels that are not managed within the control of the generator (that this proposal would consider to be solid wastes), to petition EPA for a determination that such non- hazardous secondary materials are not discarded and therefore, are not solid wastes (assuming these materials have met the applicable legitimacy criteria). While the Agency recognizes that a petition process can be resource intensive, we also believe it necessary and appropriate to provide an opportunity for persons to demonstrate to EPA that their non-hazardous secondary material fuels would not be considered ‘‘discarded’’ under RCRA and therefore, not solid waste. Furthermore, some other important changes were made between the ANPRM and this proposal based on comments received and further investigation. One of the differences is the classification of ‘‘clean’’ biomass and on-specification used oil as a traditional fuel (see section VII.C.5.b.). In addition, EPA is only addressing non-hazardous secondary materials in this rulemaking, and thus, has decided not to address hazardous secondary materials that have been excluded from the definition of solid waste under subtitle C of RCRA in this rulemaking proceeding. Instead, facilities combusting hazardous secondary materials should refer to VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00013 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31856 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 20Bagasse is the matted cellulose fiber residue from sugar cane that has been processed in a sugar mill. For more information on bagasse, see the Materials Characterization Paper on Biomass- Agricultural Residues and Food Scraps, which is located in the docket of today’s proposed rule. EPA’s Subtitle C hazardous waste regulations to determine whether the materials they are combusting are solid wastes. Each of these changes is discussed in detail in the referenced sections. 2. General Proposed Approach This proposal maintains the same general principles for determining whether a non-hazardous secondary material is or is not a solid waste as expressed in the ANPRM. Under the proposed rule, the following are not solid wastes when combusted for purposes of the CAA: non-hazardous secondary materials used as fuels that remain within and are combusted within the control of the generator and that meet the legitimacy criteria; non- hazardous secondary materials that meet the legitimacy criteria and are used as ingredients in a manufacturing process; materials that meet the legitimacy criteria and have been sufficiently processed into a fuel or ingredient from discarded non- hazardous secondary materials that have been discarded; and non-hazardous secondary materials used as a fuel that does not remain within the control of the generator for which EPA grants a facility’s petition for a ‘‘non-solid waste’’ determination. The term ‘‘discarded’’ is intended to encompass material handling and management scenarios that meet the plain meaning of discard (abandoned, disposed of, or thrown away). For example, a secondary material that is thrown away and disposed of in a landfill is considered to have been discarded in the first instance. Materials that have been discarded in the first instance are solid waste even if they satisfy the legitimacy criteria (unless they are processed into a legitimate non- waste product) since both wastes and non-wastes may be legitimately recycled. 3. Legitimacy Criteria This proposal also maintains the same general principles as described in the ANPRM for determining whether a non- hazardous secondary material is or is not a legitimate fuel or ingredient. Secondary materials used in a combustion unit that are not a legitimate fuel or ingredient would be considered sham recycling and thus, a solid waste. For legitimate fuels, non-hazardous secondary materials must be handled as a valuable commodity, have meaningful heating value, be used as a fuel in a combustion unit that recovers energy, and contain contaminants at levels comparable to those in traditional fuels. As used throughout today’s proposal, ‘‘comparable’’ levels of contaminants refer to levels that are comparable or less than those in traditional fuels. For legitimate ingredients, the non- hazardous secondary material must be handled as a valuable commodity, provide a useful contribution, result in a valuable product or intermediate, and result in products that contain contaminants at levels that are comparable in concentration to those found in traditional products that are manufactured without the non- hazardous secondary material. As with fuels, contaminant levels that are comparable refers to levels that are comparable or less than contaminant levels found in traditional products that are manufactured without the non- hazardous secondary material ingredients. 4. Traditional Fuels This proposal recognizes that traditional fuels are not solid wastes when burned in a combustion unit. Traditional fuels are those fuels that have been historically managed as valuable fuel products rather than being managed as waste materials. Traditional fuels include fossil fuels (e.g., coal, oil, including used oil meeting on- specification levels, natural gas) and their derivatives (e.g., petroleum coke, bituminous coke, coal tar oil, refinery gas, synthetic fuel, heavy recycle, asphalts, blast furnace gas, recovered gaseous butane, and coke oven gas). Clean cellulosic biomass materials are also traditional fuels rather than wastes when burned as a fuel. ‘‘Clean’’ material is defined as those non-hazardous secondary materials that have not been altered (either chemically or through some type of production process), such that it contains contaminants at concentrations normally associated with virgin biomass materials. Clean cellulosic biomass includes forest- derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, and tree harvesting residuals from logging and sawmill materials), corn stover and other biomass crops used specifically for energy production (e.g., energy cane, other fast growing grasses), bagasse20 and other crop residues (e.g., peanut shells), wood collected from forest fire clearance activities, trees and clean wood found in disaster debris, and clean biomass from land clearing operations. We request comment on whether other fuels in use today also should be classified as traditional fuels, and also whether other types of cellulosic biomass should be designated as clean biomass, and thus a traditional fuel. In identifying other secondary materials as a traditional fuel, commenters will need to explain why such materials should be considered a traditional fuel—that is, an explanation of how the materials have historically been managed as a valuable fuel product and not a waste. EPA acknowledges that changes in technology and in the energy market over time may result in additional secondary materials being economically viable to be used as ‘‘traditional’’ fuels. It also may not always be clear whether a fuel material is a traditional fuel. We agree with commenters to the ANPRM that this rulemaking should be flexible to account for increasing use and changes in commodities, technologies, markets, and fuel prices. We, therefore, request comment on whether we should provide a petition process that would allow a facility or person to request that EPA determine whether the fuel that they burn qualifies as a traditional fuel. If we adopt such a petition process, it would be implemented through the same process as the non-waste determination petition process discussed in section VII.D.5. 5. Circumstances Under Which a Non- Hazardous Secondary Material Would Not Be Considered a Solid Waste Non-hazardous secondary materials used as fuels in combustion units would be considered solid wastes unless: (1) The non-hazardous secondary materials (not otherwise discarded) remain under the control of the generator as discussed in section VII.D.1, and meet the legitimacy criteria; or (2) they are legitimate non-waste fuels that meet the legitimacy criteria and are produced from the processing of discarded non- hazardous secondary materials as discussed in section VII.D.4. Non- hazardous secondary materials used as a fuel in combustion units that are transferred to a third party are considered solid wastes unless a non- waste determination has been granted pursuant to the proposed petition process (discussed below). Non-hazardous secondary materials used as ingredients that are combusted in combustion units would not be considered solid waste if they have not been discarded in the first instance and if they are legitimate ingredients, irrespective of whether they have been transferred to a third party. We are not VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00014 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31857 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 21Many states regulate used tires under a statutory authority outside of their solid waste management statutory authority, while some states regulate used tires pursuant to both their solid waste management authority, as well as separate tire statutory authority. 22Subsequent to the closing of the comment period, the Environmental Council of States (ECOS) approved Resolution 09–7, entitled ‘‘Meaning of ‘Solid Waste’ under the Resource Conservation and Recovery Act (RCRA) as it Applies to Non- Continued proposing to differentiate ingredients that are used within the control of the generator from those that are not since we believe the use of non-hazardous secondary materials as ingredients is considered to be more integral or akin to use in a commercial manufacturing process and thus these non-hazardous secondary materials would not be considered discarded provided they satisfy the legitimacy criteria. Except for the petition process, the proposed criteria are designed to be self- implementing in nature, not requiring Agency action. As such, we are proposing that it will be the facility’s (i.e., the facility that burns the material) responsibility to determine if the secondary material satisfies the proposed criteria that identifies which material is a solid waste when burned in a combustion unit. 6. Petition Process EPA is also proposing to establish a non-waste determination petition process for secondary materials used as fuels outside the control of the generator. The petition process provides persons with an administrative process for a formal determination that their non-hazardous secondary material fuel has not been discarded and is indistinguishable in all relevant aspects from a fuel and therefore not a solid waste. The determination will be based on whether the non-hazardous secondary material has been discarded, is a legitimate fuel and the following criteria: (1) Whether market participants handle the non-hazardous secondary material as a fuel rather than a solid waste; (2) whether the chemical and physical identity of the non-hazardous secondary material is comparable to commercial fuels; (3) whether the non- hazardous secondary material will be used in a reasonable time frame given the state of the market; (4) whether the constituents in the non-hazardous secondary material will be released to the air, water, or land from the point of generation to the combustion of the secondary material at levels comparable to what would otherwise be released from traditional fuels; and (5) other relevant factors. For further information regarding the non-waste determination petition process, see section VII.D.5. EPA developed two flowcharts that generally illustrate the process of determining whether nonhazardous secondary materials burned as a fuel or ingredient in combustion units are or are not solid waste. These diagrams present the proposed rule’s basic framework as a series of questions that should be considered when determining the appropriate characterization of a nonhazardous secondary material (i.e. as a solid waste or not when burned in a combustion unit). See ‘‘Flow Chart for Determining Whether Non-Hazardous Secondary Material Ingredients Burned In Combustion Units are Solid Wastes’’, and ‘‘Flow Chart for Determining Whether Non-Hazardous Materials Used as Fuel In Combustion Units are Solid Waste’’ in the docket for today’s proposal. We are soliciting comments on whether these flow charts should be included in the Code of Federal Regulations (CFR) as part of the final rule. C. What were the major comments on the ANPRM? 1. Comments from State Agencies EPA received comments from several states and state organizations in response to the ANPRM. Comments received expressed a range of viewpoints representing states with differing solid waste management programs and authorities. Consequently, it was not surprising that the comments received often articulated competing suggestions and recommendations based upon different state programs and experiences. Comment: Some states did not want EPA to define what is or is not a waste at the federal level if it impacts or limits the scope of what states currently regulate under their solid waste management authority. Some states noted a potential problem related to existing ‘‘stringency provisions’’ in some state laws. For example, if a solid waste determination is made at the federal level, it could be argued that the state is less stringent through their issued exemptions and the state rule must be rescinded. Conversely, some states argued they cannot, by state statute, be more stringent than the Federal regulations, and even if they don’t have this statutory limitation, they may feel pressure to not be more restrictive than the federal definition. Many states said we should defer the determination of whether those non-hazardous secondary materials used as fuels or ingredients are solid wastes to the states and urged flexibility in how each state could incorporate any new regulations into its existing solid waste management programs. EPA’s Response: The Clean Air Act (section 129(g)(6)) states that the term ‘‘solid waste’’ shall have the meaning established by the Administrator pursuant to the Solid Waste Disposal Act. Accordingly, EPA must define which non-hazardous secondary materials used as fuels or ingredients in combustion units are solid waste at the national level in order to identify the universe of sources subject to the boilers emissions standards to be issued under CAA section 112 and the CISWI emissions standards to be issued under CAA section 129. See section VIII of today’s proposal for a discussion on the applicability of state solid waste definitions and beneficial use determinations, as well as a discussion on state adoption of this rulemaking. Comment: Many states commented that they had long-standing ‘‘waste’’ management programs regulating non- hazardous secondary materials, that no one had questioned the legitimacy of their regulatory programs in the past, and that it was inappropriate and contrary to the intent of RCRA for EPA to exclude this material, which had been considered ‘‘waste’’ for many decades, from regulation under RCRA. On the other hand, other states were concerned a federal designation that some of these non-hazardous secondary materials are ‘‘wastes’’ would disrupt existing recycling markets by creating a deterrent from using these non- hazardous secondary materials as fuels or ingredients. These states emphasized the importance of promoting beneficial use of non-hazardous secondary materials and were concerned that regulation of certain materials (especially used tires) under CAA section 129 would create negative incentives to their beneficial use and consequently could have negative environmental impacts. Many states explained that they manage/regulate many of these secondary materials as solid waste (e.g., tires), but determine they are not wastes (via beneficial use determinations) when after analysis the state has determined they are going to a legitimate use (e.g., as a fuel). These states recommended that these materials remain a solid waste until they are approved for, procured and delivered to the potential end user in order to retain their ability to regulate the management of these secondary materials, usually under its solid waste management authority.21 For example, some states recommended that EPA exclude whole tires from the definition of solid waste at the point of combustion.22 VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00015 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31858 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules Hazardous Waste Programs.’’ This resolution, which was revised on March 23, 2010, urges EPA to exclude whole tires from the definition of solid waste for the purposes of combustion. Both the original (dated September 22, 2009) and revised versions are included in the docket for today’s rule. 23Id. ECOS Resolution 09–7 presents this position as an alternative to excluding whole tires from the definition of solid waste for the purposes of combustion. EPA’s Response: In developing this proposed rule, EPA attempted to balance and address the concerns raised by the states regarding potential impacts on their existing solid waste programs in determining which non-hazardous secondary materials are solid wastes when combusted, while at the same time, recognizing that the proposed rule needed to be based on whether these secondary materials are considered to have been managed in a way that meets the plain meaning of discard, as defined in AMC I. We believe we have addressed that balance, considering the statutory limitations, but also understand that today’s proposal could impact existing state solid waste management programs, as well as states’ beneficial use programs, and specifically request comment on how today’s proposal impacts or could impact such state programs. For example, does the proposed approach impact the ability of the states to continue to regulate the management of secondary materials prior to their final end use. Comment: Some state commenters suggested that the Agency address CAA section 129 implementation issues by subcategorizing energy recovery units that burn waste materials and regulate this combustion similarly to the CAA section 112 requirements.23 EPA’s Response: This comment relates to EPA’s regulation of solid waste incineration units under section 129 and is not relevant to this action, which proposes to define ‘‘solid waste’’ under RCRA for non-hazardous secondary materials. 2. Meaning of Discard As discussed in Section VI, RCRA defines ‘‘solid waste’’ as ‘‘* * * any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material * * * resulting from industrial, commercial, mining, and agricultural operations, and from community activities * * *’’ (RCRA section 1004 (27) (emphasis added)). The ANPRM provided a thorough discussion on the definition of solid waste, including a summary of relevant case law. See also Section VI.B in today’s preamble. Further, the ANPRM highlighted the importance of the concept of ‘‘discard,’’ noting that the definition of solid waste turns on the meaning of the phrase, ‘‘other discarded material,’’ as this term encompasses all other examples provided in the definition. Comment: Several comments stressed that the Agency use the plain meaning of discard (i.e., disposed of, abandoned, or thrown away) in defining the term ‘‘solid waste’’ for the purpose of establishing the appropriate standards for combustion units under CAA sections 112 and 129. EPA’s Response: EPA agrees with the premise of using the ‘‘plain meaning’’ of discard, as this position is consistent with case law on the issue (for a more detailed discussion, please refer to the ANPRM and section VI.B of today’s preamble). Comment: Some commenters noted that the same rationale and principles related to ‘‘discarded materials’’ should apply whether these materials are regulated under RCRA subtitles C or D, as the principles related to ‘‘discarded materials’’ are the same. Other commenters argued that the subtitle C approach should not be used for non- hazardous secondary materials since these materials pose less risk relative to hazardous wastes. EPA’s Response: EPA believes it is appropriate to use the same general framework that has been used to define solid waste for purposes of RCRA subtitles C and D (albeit tailored to specifically address non-hazardous secondary materials used as fuels or ingredients in combustion units), noting that the same statutory definition of solid waste applies to both RCRA subtitles D and C. However, EPA is not proposing in today’s action any revisions to its hazardous waste regulations. Comment: Some commenters argued that any secondary materials that are beneficially reused or recycled are not waste, regardless of whether or not the reuse or recycling is conducted in the same or different location or industry (on-site and off-site). EPA’s Response: The Agency does not agree with this assertion, as this position is not consistent with case law. Again, the question of whether a material is or is not a solid waste depends on the issue of discard. In Safe Food and Fertilizer v. EPA, 350 F. 3d 1263, the court rejected the argument that, as a matter of plain meaning, recycled material destined for immediate reuse within an ongoing industrial process is never considered ‘‘discarded,’’ whereas material that is transferred to another firm or industry for subsequent recycling must always be solid wastes. 350 F. 3d at 1268. Instead, the court evaluated ‘‘whether the Agency’s interpretation of * * * ‘‘discarded’’ * * * is, reasonable and consistent with the statutory purpose.’’ Id. Thus, EPA has discretion to determine if non-hazardous secondary materials are not a solid waste if it is managed within the control of the generator, as well as if it is transferred outside the control of the generator. As previously described, this proposal states that non-hazardous secondary materials used as a fuel in combustion units that remain under the control of the generator and meet the legitimacy criteria are not solid waste, but that non- hazardous secondary materials that are transferred to a third party and combusted are considered solid wastes, unless a petition for a non-waste determination has been granted. Ingredients, on the other hand, are determined not to be solid waste even if they are managed outside the control of the generator as long as they meet the legitimacy criteria. See section VII.D.6 for a discussion on EPA’s rationale for these determinations. Comment: One commenter noted that EPA’s hazardous waste regulations under subtitle C provide that hazardous secondary materials ‘‘burned to recover energy’’ or ‘‘used to produce a fuel’’ are ‘‘discarded’’ and, therefore, are solid wastes. 40 CFR.261.2(c)(2). The commenter went on to point out that under the ANPRM approach, EPA is interpreting the definition of solid waste to mean that burning of non-hazardous secondary material, under appropriate conditions, is not ‘‘discard’’ under RCRA. According to the comment, the ANPRM is inconsistent with the interpretation in 40 CFR 261.2. Regardless of whether EPA believes that it can issue separate definitions of solid waste for hazardous waste and non- hazardous waste, the commenter suggests ‘‘discarded’’ cannot be read both to include materials that are ‘‘burned to recover energy’’ or ‘‘used to produce a fuel’’ and to exclude such materials. EPA’s Response: EPA disagrees with this comment and does not believe the regulations are inconsistent. The hazardous waste definition may be considered a ‘‘presumption’’ that secondary materials burned for energy recovery, or used to produce a fuel, are solid wastes. EPA has, through rulemaking, excluded from the definition of solid waste a number of materials burned for energy recovery under certain conditions. See 40 CFR 261.2(c)(2)(A)(ii) (off specification commercial chemicals otherwise listed as hazardous wastes); 261.4(a)(6)(‘‘black liquor’’ in pulping processes); VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00016 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31859 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 24On August 18, 2009, EPA received a letter signed by nearly one hundred community groups and citizens that urged for an expansive definition of solid waste for the purposes of combustion and argued against the general approach of the ANPRM. A copy of this letter has been placed in the docket for today’s proposed rule. The letter highlights stakeholder concerns regarding the differences between CAA sections 112 and 129 and argues against an overly narrow definition of solid waste. Partially in response to these comments and others, we are considering and taking comment on an alternative approach to that proposed and described in section VII.D. This alternative approach would include, with certain exceptions, non-hazardous secondary materials that are burned as a fuel or used as an ingredient in the combustion process within the definition of solid waste. As such, units combusting those materials would be required to meet CAA section 129 standards. For more information on the alternative approach, see section VII.E of this proposed rulemaking. 261.4(a)(7) (spent sulfuric acid); and 261.4(a)(16) (comparable fuels). In addition, EPA has excluded materials used to produce fuels. See, 40 CFR 261.4(a)(12) (oil bearing hazardous secondary material inserted into the petroleum refining process), and 261.4(a)(18) (petrochemical recovered oil inserted into the refining process). Regardless of the appropriateness of these exclusions, or whether the Agency may appropriately exclude any secondary materials from the solid waste definition, consistency between the regulations for hazardous and non- hazardous secondary materials is not an issue. This proposed rule, which identifies certain secondary materials burned for energy recovery as not being solid wastes, is comparable to the conditional exclusions for the definition of solid waste in the hazardous waste regulations. Conditions apply to all of the secondary materials being considered for determinations as to whether they are solid wastes. The legitimacy criteria apply to all of the secondary materials. It is reasonable and within EPA’s discretion to determine that non- hazardous secondary materials may be burned as products and are not wastes. Today’s proposal acknowledges the difficulty that the combustion of secondary materials is commonly associated with disposal. However, this view does not take into account that the secondary material may often be used to produce a safe fuel product that is a valuable commodity and is sold in the marketplace no differently from traditional fuels. This position seems like a common sense interpretation of the term, ‘‘solid waste,’’ under RCRA. Another difficulty the Agency faces is the misconception that secondary material that is burned, either for destruction or energy recovery, by definition has high levels of contaminants. The manner in which the secondary material is managed is a key factor that determines discard. Contaminant levels are part of that consideration. If a material has high levels of contaminants, it would be considered sham recycling, which is one type of way a material can be ‘‘discarded.’’ Hazardous secondary materials— those that would be hazardous wastes under RCRA subtitle C, if discarded— are more likely to contain high levels of contaminants. Thus, EPA could reasonably presume that burning such secondary materials, even if burned for energy recovery, is likely a waste activity. This was the Agency’s rationale for issuing the subtitle C rule at 40 CFR 261.2(c)(2), which specifies that burning for energy recovery is a waste disposal activity. In EPA’s rule establishing the comparable fuels exclusion from the definition of solid waste for hazardous secondary materials, the Agency stated that these hazardous secondary materials (comparable fuels) are lower in hazardous contaminants than the normal hazardous wastes and that burning of the comparable fuels ‘‘does not present the element of discarding hazardous constituents through combustion that underlies the typical classification of hazardous waste- derived fuels as a solid waste. 50 FR at 629–630 (Jan. 4, 1985).’’ 63 FR at 33783 (1998). We may, after looking at certain secondary materials, decide that they are not in fact solid wastes and are being burned as valuable commodities to recover energy. This interpretation, however, is consistent with today’s proposal, which also evaluates whether materials burned for energy recovery are wastes or non-wastes. Moreover, the case law supports the conclusion that materials burned for energy recovery or used to produce fuels may or may not be solid wastes. American Mining Congress v. EPA, 824 F.2d 1177 (DC Cir. 1987) (‘‘AMC I’’), held that the term ‘‘discarded materials’’ could not include materials ‘‘ *** destined for beneficial reuse or recycling in a continuous process by the generating industry itself. 824 F.2d at 1190. The provision under consideration in this case dealt specifically with material ‘‘reclaimed’’ in a continuous process. That is, material is regenerated from a secondary material in a continuous process. However, it is highly likely the courts would apply this same reasoning to secondary materials that are otherwise reused or recycled in a continuous industrial process, such as material used, or combusted, to recover energy. Accord, Association of Battery Recyclers v. EPA, 208 F.3d 1047 (DC Cir. 2000) (‘‘ABR’’). It is also worth noting that the Ninth Circuit has specifically found that non- hazardous secondary materials may, under certain circumstances, be burned and not constitute solid waste under RCRA. See Safe Air For Everyone v. Waynemeyer (‘‘Safe Air’’), 373 F.3d 1035 (9th Cir., 2004) (Kentucky bluegrass stubble may be burned to return nutrients to the soil and not be a solid waste). This activity is not waste treatment even in the absence of energy recovery. We believe, therefore, that burning material for another useful purpose (e.g., energy recovery) does not necessarily constitute a disposal activity. With respect to materials used to produce fuels, in American Petroleum Institute v. EPA, 216 F.3d 50 (DC Cir. 2000) (‘‘API II’’), the court overturned EPA’s determination that certain recycled oil bearing wastewaters are wastes (216 F.3d at 55–58) and upheld conditions imposed by the Agency in excluding petrochemical recovered oil from the definition of solid waste (216 F.3d at 58–59). Both of these materials are returned to the petroleum refinery process and used to produce fuel. The court in this case was clearly considering the conditions under which two types of material may be excluded from the definition of solid waste. For purposes of the issue of concern in today’s proposal, this decision supports EPA’s discretion to determine whether or not a secondary material used as a fuel product is a solid waste or not, in light of factors relevant to determining whether the material is discarded. Therefore, EPA is not prevented from exercising its discretion to decide that issue either way. 3. General Approach EPA received several comments on the general approach outlined in the ANPRM for determining which non- hazardous secondary materials used as fuels or ingredients in combustion units are or are not solid wastes. Most commenters supported the general regulatory structure that included: (1) A recognition that certain materials are inherently fuel products, (2) a self- implementing approach for identifying those non-hazardous secondary materials that are not considered solid waste pursuant to general criteria and (3) a petition process for receiving a non-waste determination from the Agency.24 Comments: Several commenters discussed whether to include a list of wastes and/or a list of non-wastes in the regulations. One commenter recommended that a list of secondary materials that are considered wastes be VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00017 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31860 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules identified, rather than a list of secondary materials that are not considered wastes, while other commenters urged for the inclusion of a list of secondary materials that are not considered wastes when burned as a fuel. If EPA included a list of secondary materials that are not considered wastes when burned as a fuel in its regulations, one commenter also suggested that the Agency additionally include a list of secondary materials that are considered wastes in order to remove any uncertainty. Those commenters who urged that the regulations include a list of secondary materials not considered a waste when used as a fuel or ingredient also cautioned that such a list should not be all-inclusive in order to account for changes in technology and new secondary materials and processes that are not yet developed. EPA’s Response: In recognition of changes in economies, technologies, markets and material processes, EPA is not proposing to list specific non- hazardous secondary materials as either wastes or non-wastes in regulatory language, but is rather specifying the criteria to be used to determine if these secondary materials are or are not solid wastes. We believe that there could be instances where determinations of whether a particular non-hazardous secondary material meets the various criteria will have to be based on site- specific information; a national designation that in all circumstances, a particular non-hazardous secondary material is or is not a waste may not be possible. However, it is EPA’s goal in this proposal, as well as in the pending final rule preamble, to indicate, as clearly as possible, which non- hazardous secondary materials used as fuels or ingredients in combustion units are or are not considered solid waste based on this criteria. As several commenters also noted, any approach must be flexible enough to account for changing technologies and new secondary materials that could, in the future, be viable fuels or ingredients. The proposed approach allows for these changes, not by codifying a list of specific non-hazardous secondary materials that are or not waste, but rather by adopting a self-implementing approach that can consider site-specific information, if necessary. Comments: A few commenters noted a preference for categorical determinations that certain secondary materials were products, not wastes (e.g., traditional fuels) along with clear criteria for solid waste determinations for secondary materials not falling into one of these categories (i.e. a petition process for non-waste determinations). EPA’s Response: EPA partially agrees with this approach. The proposed rule discusses traditional fuels as a category of fuel products that are not secondary materials and therefore, are not solid waste. With respect to non-hazardous secondary materials, although this proposal does not list types/categories of such secondary materials that are or are not solid waste in regulatory text (as discussed above), we are proposing self- implementing regulatory criteria to be used by the regulated universe to determine whether the non-hazardous secondary material would or would not be a solid waste. The regulatory criteria are based on four categories of non- hazardous secondary materials that are managed under various scenarios, including: (1) Non-hazardous secondary materials that remain within the control of the generator and meet the legitimacy criteria and used as fuel; (2) non- hazardous secondary materials that meet the legitimacy criteria and are used as ingredients; (3) fuel or ingredient products that are processed from discarded non-hazardous secondary materials and that are used as fuels or ingredients in a combustion unit, provided they meet the legitimacy criteria; and (4) EPA has granted a non- waste determination for non-hazardous secondary material fuels managed outside the control of the generator. More detailed information on these categories and their respective criteria can be found in section VII.D. of this proposal. Comments: Some commenters suggested that a petition process for a waste determination should not be mandatory. Proponents of this position urged that any regulatory construct for demonstrating that non-hazardous secondary materials qualify as alternative fuels should be self- implementing and not involve the need for individual regulatory determinations. EPA’s Response: The non-waste petition process that applies to non- hazardous secondary material fuels managed outside the control of the generator is not mandatory; however, we note that the assumption in this proposed rule is that these materials would be a solid waste, unless they are granted a non-waste determination by EPA. Also, as explained above, we are proposing a self-implementing approach for all the other non-hazardous secondary material management categories that can consider site-specific information, if necessary (i.e., facilities will make a self-determination of whether the non-hazardous secondary material in question meets the regulatory criteria). We again note it is EPA’s intention to indicate in the preamble, as clearly as possible, which non-hazardous materials used as fuels or ingredients in combustion units are or are not considered solid waste based on the criteria laid out in regulatory text. The Agency expects this self- implementing approach will govern for the majority of situations. 4. Level of Processing Needed To Produce a Non-Waste Product From Discarded Waste Material In the ANPRM, we stated that if a non-hazardous secondary material is processed into a legitimate fuel or ingredient product, then the processed material would not be a discarded material. We listed various non- hazardous secondary materials we believed to have undergone adequate processing (e.g., tire-derived fuel), and requested comment on whether some of the materials, such as mined landfilled ash, should be considered to have undergone adequate processing, such that it would be rendered a non-waste. Comments: Most commenters generally agreed with the concept, but had differing views on what level of ‘‘processing’’ would render a discarded material a legitimate non-waste product fuel or ingredient product. Their views ranged from not requiring any processing, to specifying a minimum level of processing if processing criteria are retained. These commenters argued that any management activity associated with recovering the non-hazardous secondary material would be sufficient. Commenters who indicated that the non-hazardous secondary material should not be required to ‘‘undergo processing’’ before it is considered a non-waste fuel or ingredient argued that as long as these secondary materials meet the legitimacy criteria, they should not be viewed as a solid waste once recovered from the discard environment; these commenters provided examples of non-hazardous secondary materials, such as whole tires, biomass, and coal fly ash. Also, some commenters stated that the act of recovering or ‘‘extracting’’ the material from the ‘‘discard environment’’ should constitute the requisite degree of processing needed. Commenters who argued that no minimum level of processing be specified supported their position by noting that procedures for recovering solid waste vary widely and that the amount of processing required would be dependent on the application for which the non-hazardous secondary material is being prepared. EPA’s Response: We disagree with the commenters who generally argued that no level of processing or even a VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00018 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31861 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 25In the ANPRM, we did not distinguish between ‘‘clean’’ cellulosic biomass and that which is not. Therefore, the comments discussed in this section are only in reference to cellulosic biomass that does not meet the definition of ‘‘clean.’’ minimum level of processing should be sufficient to produce a non-waste fuel or ingredient. We likewise disagree with those commenters who argued that the act of recovering or ‘‘extracting’’ secondary material from the discard environment should be sufficient to be considered processing. Rather, the Agency believes that sufficient processing of the secondary material (e.g., changing the mass, chemical make- up, or removing particular components from the secondary material) must be undertaken to transform a waste-derived fuel or waste-derived ingredient into a fuel or ingredient product. Thus, our position on this issue has changed from that discussed in the ANPRM, as explained below. For example, the Agency no longer believes that, in light of the proposed definition of processing, simply cutting or sizing a material is sufficient to produce a product fuel or ingredient. Specifically, under the proposed rule, processing ‘‘means any operations that transform discarded non-hazardous secondary material into a new fuel or new ingredient product. Minimal operations, such as operations that result only in modifying the size of the material by shredding, do not constitute processing for purposes of this definition. Processing includes, but is not limited to, operations that: Remove or destroy contaminants; significantly improve the fuel characteristics of the material, e.g., sizing or drying the material in combination with other operations; chemically improve the as- fired energy content; and improve the ingredient characteristics.’’ See the proposed definition in §241.2. We believe the proposed definition is specific enough to describe the general level of processing that would be needed, but flexible enough to apply broadly to the wide range of non- hazardous secondary materials that are currently under consideration, or that could be under consideration in the future as technologies change. We believe that discarded non-hazardous secondary materials must be sufficiently processed in order to render a secondary material into a non-waste product. Without sufficient processing, the non- hazardous secondary material that is produced would remain a waste-derived fuel or waste-derived ingredient, and if burned in a combustion unit, would be subject to the CAA section 129 requirements. The Agency specifically requests comment on these points. See section VII.D.4 for a discussion of the processing of discarded non- hazardous secondary materials into non- waste fuel or ingredient products. That section describes EPA’s rationale for why this processed material is no longer considered a solid waste, as well as examples of processing that EPA believes does or does not meet the requisite level to render a discarded secondary material into a non-waste product. 5. Comments on Specific Materials Used as Fuels In the ANPRM, we listed a number of non-hazardous secondary materials, as well as traditional fuels, that we believe are currently being used as fuels and ingredients. We solicited comment on additional information, including: The composition or characteristics of non- hazardous secondary materials; how much of the non-hazardous secondary material is produced and utilized; how it is utilized (i.e. as a fuel or an ingredient); and how it is generally handled. The majority of comments submitted for fuels were in regard to traditional fuels and the following non- hazardous secondary materials— biomass, used tires, used oil, coal refuse, and sewage sludge. a. Traditional Fuels. The ANRPM described traditional fuels to include: Coal, oil, natural gas, and their derivatives (e.g., petroleum coke, bituminous coke, coal tar oil, refinery gas, synthetic fuel, heavy recycle, asphalts, blast furnace gas, recovered gaseous butane, and coke oven gas), as well as cellulosic biomass (e.g., wood). We requested comment on whether there are other fuels that should be considered as traditional fuels and would fall within this grouping. Comments: A few commenters suggested that bagasse should be included in the traditional fuel group because it is a valuable co-product which is fed directly from the mill to the boilers and has historically been the source of electrical power in communities located near the sugar cane mills. In addition, cellulosic biomass crops similar to bagasse (e.g., energy cane and other fast growing grasses) grown specifically for fuel production, agricultural seeds, woody biomass, and wood collected from forest fire clearance activities, land clearing biomass, trees, unadulterated wood from pallets, and uncontaminated wood from disaster debris were suggested as materials that should qualify as traditional fuels. Last, several commenters argued that used oil, on- spec and off-spec, should be listed as traditional fuels. Since neither type of used oil is discarded, the presumption is that it is recycled. EPA’s Response: We agree with commenters that many of the materials mentioned in the comments should be classified as traditional fuels, which are not solid waste. However, to further add clarity, we are proposing that in order to qualify as a traditional fuel, cellulosic biomass must be ‘‘clean’’—that is, must not be altered (either chemically or through some type of production process), such that it contains contaminants not normally associated with virgin biomass materials, to ensure that the material being burned does not introduce contaminants not normally associated with virgin biomass materials (we describe what we consider to be clean biomass in section VII.C.5.b). We believe clean biomass to include, but not necessarily be limited to: forest- derived biomass (e.g., green wood; forest thinnings; clean and unadulterated bark; sawdust; trim; and tree harvesting residuals from logging and sawmill materials); corn stover and other biomass crops used specifically for energy production (e.g., energy cane, other fast growing grasses); bagasse and other crop residues (e.g., peanut shells, agricultural seeds); wood collected from forest fire clearance activities; trees and clean wood found in disaster debris; clean biomass from land clearing operations; and clean construction wood. In regard to used oil, for the reasons discussed later in section VII.D.4, we are including on-spec used oil in the list of traditional fuels because we believe it meets our view of what is a traditional fuel (i.e., fuels that have been historically managed as valuable fuel products rather than being managed as waste materials). However, off-spec used oil will be considered a solid waste, unless it is processed into a legitimate non-waste fuel, such as on- spec oil. b. Biomass. Biomass includes a wide range of secondary materials which can be divided into two categories, cellulosic and non-cellulosic, as stated in the ANPRM.25 While the ANPRM indicated that much of the biomass currently used as fuels are not solid waste since they have not been discarded in the first instance and are legitimate fuel products, we specifically requested comment on whether some biomass contains contaminants that are significantly higher in concentration when compared to traditional fuel products. Comments: Cellulosic Biomass: For the cellulosic biomass category, several commenters argued that resinated wood products (e.g., board trim, sander dust, VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00019 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31862 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 26See U.S. EPA, ‘‘Wood Products in the Waste Stream: Characterization and Combustion Emissions, Vol. 1,’’ November 1996. See also National Council for Air and Stream Improvement, Inc. Technical Bulletin (TB) 906, ‘‘Alternative Fuels Used in the Forest Products Industry: Their Composition and Impact on Emissions.’’ September 2005. 27National Council for Air and Stream Improvement, Inc. Technical Bulletin (TB) 906, ‘‘Alternative Fuels Used in the Forest Products Industry: Their Composition and Impact on Emissions.’’ September 2005. 28Primary sludges consist of wood fiber and inorganic materials and secondary sludges are primarily microbial biomass. 29It is worth noting that, in response to a request from EPA’s Office of Air and Radiation (OAR), EPA’s National Center for Environmental Assessment (NCEA) initiated an update of the formaldehyde IRIS assessment to address significant new scientific information that had become available on formaldehyde. EPA anticipates deriving an inhalation reference concentration (RfC) and reexamining the inhalation cancer assessment as part of this update. The draft assessment has been reviewed by scientists and managers within NCEA and across EPA. EPA will release a draft for public comment and independent expert scientific peer review, with a National Academy of Sciences (NAS) panel review expected to commence in late April 2010, which will coincide with a formal public comment process through the Federal Register. panel trim) used to manufacture particleboard, medium density fiberboard, and hardboard are not discarded and are typically used on-site to either make composites or are used as fuel. One commenter stated that ‘‘[i]t is also important to note the quantity of formaldehyde actually present in these resonated wood fuels. It is minute. As the resins cure, virtually all of the formaldehyde in the adhesive is cross linked into polymers and no longer exists as formaldehyde. Current extraction tests on the highest formaldehyde content products show levels to be less than 0.02%, using the standard industry extraction test for formaldehyde from composites, EN 1203.’’ Commenters also point out that formaldehyde is a common product of incomplete combustion, suggesting that trace amounts of formaldehyde would be present in the emissions irrespective of whether formaldehyde was present in the residuals. One commenter noted that incomplete combustion of virtually all organic materials produces carbon monoxide and formaldehyde. Commenters also stated that California rules on product emissions will shortly push those numbers below 0.01%, and cite several studies that indicate emissions from burning resinated wood residuals are not significantly different than burning wood absent the resinated materials.26 Specific to panel trim, one commenter argued that emissions are not expected to be any different from those generated from unadulterated wood and traditional fuels like coal and oil that contain concentrations of part 261, Appendix VIII constituents that are orders of magnitude higher than in panel trim. One commenter discussed the use of pulp and paper sludges as fuel. This commenter states that because these residuals are primarily composed of biomass, emissions from burning these materials are essentially the same as the emissions from burning other biomass fuels, such as bark or wood. The commenter cited a report that found that the burning of kraft pulp mill wastewater treatment residuals in bark boilers at levels below about 10 to 15 percent of total heat input is not expected to lead to an increase in any of the criteria or criteria-related pollutants, such as NOX, SO2, or VOC.27 Further, the commenter states that a comparison of emission data for forty- eight organic compounds when burning wood residue and wood residue in combination with bleached kraft mill wastewater treatment residuals (around 12 percent of total heat input) in four wood-fired boilers showed no discernible differences in emissions of these organics when the residuals were co-fired. A similar comparison was conducted for metals, showing no discernable impact when burning these sludges. Another commenter stated that treated wood (e.g., pentachlorophenol, copper-based compounds, borate based compounds) also should be considered a fuel because it is not discarded and can be safely burned in boilers. In addition, commenters stated that creosote treated wood is a coal derivative and burning creosote would likely result in emissions no greater than burning coal. Creosote is a distilled and homogenous product that should burn more thoroughly than coal and is not burned in its pure form. Commenters also noted that creosote treated wood is a combination of two materials we listed as traditional fuels. For these reasons, it should qualify as a fuel. However, the same commenter noted that they would not be opposed to EPA requiring CCA lumber to be removed from the fuel stream. EPA’s Response: Cellulosic Biomass: We agree that certain biomass (cellulosic biomass that is ‘‘clean’’ and non-cellulosic biomass) materials can be legitimate fuels. We also generally agree with commenters that secondary materials, such as secondary mill residues (i.e., residues such as sanderdust, board, trim and breakage from the manufacture of reconstituted wood/panel products) and pulp and paper mill residuals (i.e., primary and secondary wastewater treatment sludges)28 are likely legitimate fuels. Regarding resinated wood products, we acknowledge that we have limited compositional data on these materials. As noted above, we did receive comments on the ANPRM concerning the contaminant data of these materials, specifically in regard to formaldehyde and emissions comparisons relative to burning wood that do not contain these resinated materials. Although emissions comparisons are not a direct indicator of whether these fuels satisfy the legitimacy criteria, we recognize that such data can be useful as an indicator of the contaminant levels in the secondary material fuels relative to traditional fuels. Based upon what limited data we do have regarding these materials, as well as comments received on the ANPRM, we have decided to classify resinated wood residuals as non-wastes for purposes of this proposed rule, if they are used as fuels within the control of the generator. (As we discuss in section VII.E of this preamble, the Agency is considering resinated wood residuals under the alternative approach as solid wastes when burned under the control of the generator for energy recovery, since as a matter of policy, the Agency may want to define a broader definition of solid waste.) Thus, given the general lack of data, we are requesting data and information both on the contaminant levels of these materials, as well as the appropriateness of categorizing them as non-wastes.29 Based on the data and information the Agency receives, we may decide that such secondary materials are more appropriately defined as solid wastes. We also acknowledge having limited data on pulp and paper sludges that are used as fuel. As noted above, we did receive comments on the ANPRM about contaminants associated with these secondary materials. Similar to resinated wood residuals, based on the limited data we have, we also have decided to classify pulp and paper sludges that are used as fuels within the control of the generator to be non-waste. (Like resinated wood residuals, the Agency also decided to classify pulp and paper sludges as solid wastes when burned under the control of the generator for energy recovery under the alternative approach being considered. See section VII.E.). Given the limited data we have, we also are requesting comment both on the contaminant levels of these materials, as well as the VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00020 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31863 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 30Based on data provided to EPA by USDA, research conducted by the Texas Agricultural Experiment Station and the Texas Cooperative Extension shows that manure has a dry, ash free heating value of 8,500 Btu/lb, while other research demonstrates the energy value of manure (as received) to be much lower (between 2,710–5,764 Btu/lb). For more information, please refer to the background paper entitled, ‘‘USDA Response to EPA’s Belief that Manure that is Burned as a Fuel is a Solid Waste,’’ which is located in the docket for today’s rule. appropriateness of categorizing them as non-wastes, and may decide based on the comments received to classify pulp and paper sludges as solid waste when burned under the control of the generator in a combustion unit for energy recovery when the rule is promulgated. Although limited information was submitted in regard to painted wood or pentachlorophenol, copper-based and borate-based compound treated wood materials and their contaminant concentrations, we believe these secondary materials contain elevated levels of contaminants relative to traditional fuels, and thus do not meet legitimacy criteria and should be considered solid waste if burned in a combustion unit. (It should also be noted that to the extent that any of these treated wood materials are identified as a hazardous waste, it would not be eligible to be burned in a non-hazardous waste combustion unit.) In regard to creosote treated lumber, we believe there is still a fair amount of uncertainty associated with the level of contaminants (e.g., levels of polycyclic aromatic hydrocarbons present in creosote) in comparison to traditional fuels. We, therefore, are requesting that commenters provide additional data on contaminant levels associated with these non-hazardous secondary materials relative to traditional fuels that are in use today as fuels. Comments: Non-cellulosic Biomass: One commenter stated that animal manure should not be categorically excluded from the definition of solid waste because it is inherently waste- like, is discarded, and does not meet the legitimacy criteria for ‘‘handled as a valuable commodity.’’ The commenter stated that manure generated in concentrated Animal Feeding Operation (CAFO) are known to contain heavy metals, halogens, dioxins, etc. Manure from CAFOs are discarded in two ways after it is collected: some manure is recycled for land application (e.g., ‘‘used in a manner constituting disposal’’) and excess manure is simply disposed. The same commenter acknowledged that manure can be recycled for use as bioenergy, but cautioned that it should not automatically be exempt from the definition of solid waste. In support of its position that manure recycled into bioenergy and used as fuel is still a solid waste, the commenter cites the regulations at 40 CFR 261.2(e)(2)(ii), which lists materials burned for energy recovery, used to produce a fuel, or contained fuels among materials that are solid wastes, even if recycling of those materials involves use, reuse, or return to the original process. Overall, the commenter is concerned with the large volumes of animal manure currently being generated at animal feeding operations and the lack of oversight at recycling facilities to ensure that recovery is immediate and happens without releasing any pollutants into the environment. Based on the commenter’s observations, current regulations (i.e. the 2008 CAFO NPDES Rule) still are not sufficient to assure that CAFO operations will meet the two benchmarks of immediacy and environmental care that define a ‘‘valuable commodity.’’ They conclude that for manure to be excluded from the definition of solid waste, it should have to meet numerous qualifying conditions to show that the manure is being recycled. EPA’s Response: Non-cellulosic Biomass: Because the focus of this rulemaking is to determine which non- hazardous secondary materials are or are not solid waste when burned as a fuel or ingredient in combustion units (not when utilized for other purposes, such as land application), we are not making any determination that manure is a solid waste for other possible beneficial end uses. Such beneficial use determinations are generally made by the states for these other end uses, and EPA will continue to look to the states to make such determinations. With respect to whether manure is a legitimate non-waste fuel, EPA recognizes that manure has been used previously as a fuel, and is currently used as a fuel source in other countries. In fact, some commenters have argued that manure should be considered a traditional fuel, and if not, should at least be considered a non-waste fuel since they believe that manure meets the legitimacy criteria. While we appreciate the information submitted in the comments, we lack data sufficient to evaluate the legitimacy criteria for manure. Therefore, we request information and data on how manure is handled from its point of generation to the point it is used as a fuel, in order that EPA can determine whether manure would meet this legitimacy criterion. In addition, EPA has limited data on the contaminant concentrations and Btu value of manure to determine whether it would meet these legitimacy criteria. Therefore, we are requesting that commenters provide additional information and data on the extent to which manure (including materials, such as chicken litter) is currently used as a fuel, as well as data to support whether these materials meet our legitimacy criteria, including the contaminant levels—that is, they contain contaminants at levels comparable to traditional fuels and heating content of the various types of manure.30 We will evaluate the information submitted during the public comment period and will discuss our determination in the final rule. On the other hand, if manure is processed into biofuels, by, for example, anaerobic digesters such biofuels would be considered a legitimate non-waste fuel that has been processed from a non- hazardous secondary material provided ‘‘the biofuel’’ meets the legitimacy criteria—that is, managed as a valuable commodity, has a meaningful heating value and contains contaminants at levels that are comparable to traditional fuel. We again acknowledge, however, that we have limited data (such as how the biofuels are managed, once generated, contaminant concentrations and Btu value) on biofuels that are produced from animal manures, and request that commenters provide additional data on the extent to which manures are currently processed into biofuels, as well as data to support whether these materials meet our legitimacy criteria, including contaminant levels and heating content. c. Used Tires. We discussed in the ANPRM that tires used as legitimate alternative fuels can be categorized as a non-waste fuel if they have not been previously discarded (i.e., if the used tires have not been abandoned and thrown away). The ANPRM further stated that used tires collected and managed pursuant to a state tire oversight program, are not considered to be discarded. The ANPRM also explained that discarded used tires that have been processed to make a legitimate fuel product (such as TDF) would not be a solid waste. Furthermore, we requested comment on whether used tires that fall within the category of secondary materials that are discarded, but can be directly used as a legitimate fuel or ingredient without processing because they are indistinguishable in all relevant aspects from a fuel or ingredient product (e g., whole tires) should not be considered a solid waste. VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00021 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31864 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 31For a discussion of state comments regarding used tires, see section VII.C.1., ‘‘Comments from State Agencies.’’ 32The petition process for a non-waste determination would also require the petitioner to describe how the non-hazardous secondary material satisfies the criteria outlined in the petition process, which includes whether it meets the legitimacy criteria. 33Devises include industrial boilers located at facilities that are engaged in a manufacturing process where substances are transformed into new products, utility boilers used to produce electric power, steam, heated or cooled air or other gases or fluids for sale, used oil fired space heaters provided the burner meets the provisions of 40 CFR 279.23, and hazardous waste incinerators subject to regulation under 40 CFR subpart O of parts 264 and 265. 34Once used oil is claimed to be on-spec and the marketer complies with the requirements for analysis and record retention, notification, and record tracking shipment to on-specification burners, it is no longer subject to other management standards. We note that today’s proposed rule does not change any of the regulations in place that regulate on-spec used oil. 35See Used Oil Final Rule, 50 FR 49181 (November 29, 1985). Comments: Other than the states,31 commenters generally agreed with the approach outlined in the ANPRM. Commenters did not agree, however, that whole tires taken from waste tire piles, but not processed, should be considered solid wastes. Several commenters responded that tires should be excluded from the definition of solid waste irrespective of where they are generated, including from waste tire piles. Along the same lines, some commenters argued that regardless of the source, scrap tires are indistinguishable from one another in terms of fuel/Btu value and air emissions and that the only distinction is whether they have been previously discarded. Others stated that extraction and reclamation from a waste tire pile should be sufficient processing to classify a tire as a legitimate non-waste fuel. EPA’s Response: As discussed in section VII.D.2, we now believe that whole used tires (even if collected from tire dealerships and automotive shops and overseen by a state tire collection oversight program) are initially abandoned and thus meet the plain meaning of discard. As a result, whole used tires that are not processed into a legitimate fuel or ingredient (e.g., shredded/chipped with steel belts removed) would be considered a solid waste. We acknowledge that whole tires can be legitimately burned as fuel, but because they have been discarded, whole tires would be considered solid wastes and subject to the CAA section 129 requirements unless processed into a non-waste fuel product. See section VII.D.2 for a more detailed discussion on why we now consider whole used tires to have been discarded by the original owner. We are also proposing a process by which a facility or person can apply for a non-waste determination for secondary materials that are not managed within the control of the generator. As outlined in section VII.D.5, the purpose of the petition process is to recognize that some non- hazardous secondary materials may remain outside the control of the generator and not be processed into a fuel product, but still be a legitimate non-waste fuel product. As part of this petition, the facility must demonstrate that the secondary material has not been discarded in the first instance.32 We also are requesting comment on whether discarded materials, such as used tires that have been abandoned and disposed of in waste tire piles and have not been processed (as defined in this proposal), should not be considered solid wastes if they meet the legitimacy criteria and are indistinguishable in all relevant aspects from a product or intermediate. d. Used Oil. As indicated in the ANPRM, we consider off-specification (or ‘‘off-spec’’) used oil that is collected from repair shops to have been discarded. Used oil that meets the on- specification (or ‘‘on-spec’’) levels and properties of 40 CFR 279.11 is considered be a legitimate non-waste fuel product. We requested comment on whether off-spec used oil managed pursuant to the 40 CFR part 279 used oil management standards and which is burned for energy recovery in certain types of combustion devices 33 should be considered a legitimate non-waste fuel. Comments: Most commenters believe that off-spec (and on-spec) used oil should not be classified as a solid waste. Various reasons were provided in support. Specifically, one commenter reasoned that off-spec used oil should not be treated as a solid waste if it has been delivered to a legitimate recycler for processing. Designation as a solid waste would lead to costly burning in hazardous waste incinerators, burning in uncontrolled space heaters, and more undesirable disposal methods. Many commenters also referred to Congress’ intent to manage used oil differently and EPA’s regulatory structure for the management of used oil as evidence that used oil should not be classified as a solid waste. They added that used oil is typically neither disposed of, thrown away, nor abandoned, but is collected and contained. Used oil is a valuable product that is subject to EPA’s recycling presumption. Btu content is not necessarily lower than on-spec used oil or virgin fuel, and contaminants, such as water, flashpoint, and metals can be effectively addressed. In a similar, but slightly different view, a number of commenters argued that on- spec and off-spec used oil should be included in the list of traditional fuels. Since neither is discarded, the presumption is that it is recycled. Only one commenter thought that off-spec used oil should continue to be considered a solid waste within the RCRA framework. EPA’s Response: We agree with the commenters who said that on-spec used oil should not be classified as a solid waste. Based upon how we define traditional fuels (i.e. fuels that have been historically managed as valuable fuel products rather than being managed as waste materials), we believe that on- spec used oil should be considered a traditional fuel. In accordance with 40 CFR part 279, once used oil is determined to be on-spec, it is no longer regulated under the used oil management standards.34 Used oil that has been determined to be on-spec has verified that it contains contaminants at levels below the maximum concentration limits established in the standards, such that the emissions resulting from the burning of on-spec used oil will not pose an increased threat to human health or the environment than the emissions resulting from the burning of virgin oil or diesel. This is because the contaminants of concern (i.e., those for which maximum concentration levels have been set) present in on-spec used oil are either at the same concentration or a lower concentration than virgin refined fuel oil.35 This approach is supported by Safe Food and Fertilizer v. EPA, 350 F.3d 1263 (DC Cir. 2003). The decision upheld an EPA rule that excluded from the definition of solid waste certain recycled materials used to make zinc fertilizers (and the fertilizers themselves) as long as they were not speculatively accumulated, met certain handling, storage and reporting conditions, and were ‘‘identical’’ to fertilizers made from raw materials, i.e., they had concentration levels for certain chemicals that fall below specified thresholds. 350 F.3d at 1265. We believe on-spec used oil satisfies these criteria. In regard to off-spec used oil, we disagree that it should not be classified as a solid waste. The used oil regulations are structured such that off- spec used oil is managed within the constraints of the used oil management VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00022 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31865 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 36These devices, listed in 40 CFR 279.61, were determined to not pose significant health risks when burning off-spec used oil because they typically are equipped with particulate control equipment (as required by CAA permits). Nonindustrial boilers (e.g., those located in apartment and office buildings, schools, and hospitals), on the other hand, were found to pose significant risk when off-spec used oil is burned because they are typically very small and may not achieve complete combustion and do not have any emission control equipment. 37Used Oil Final Rule, 50 FR 49194 (November 29, 1985). 38CFBs ability to achieve lower emissions levels is due to several factors: (1) CFB boilers are often newer than many existing pulverized coal utility boilers and may be equipped with better particulate matter (PM) controls; (2) CFBs utilize lower operating temperatures, which result in lower metal and NOX emissions; and (3) CFB boilers often add limestone to their feed to control SO2 emissions, which results in greater metal fixation to the ash. standards until it is processed into on- spec used oil or it is properly disposed of. It may only be burned in specific types of combustion devices.36 Although off-spec used oil may be managed within the control of the generator, it contains contaminants at levels that are not comparable to traditional fuels, and thus would not be considered a legitimate non-waste fuel per the legitimacy criteria. Therefore, today’s proposed rule considers off-spec used oil as a solid waste subject to the CAA section 129 requirements, as wells as state, and local requirements, unless it is processed to meet the on-spec used oil limits specified in 40 CFR 279.11. It also should be noted that off-spec used oil may be burned in used oil-fired space heaters pursuant to 40 CFR part 279, provided: (1) The heater burns only used oil that the owner or operator generates or used oil received from household do-it-yourself used oil generators; (2) the heater is designed to have a maximum capacity of not more than 0.5 million Btu per hour; and (3) the combustion gases from the heater are vented to the ambient air. The RCRA used oil regulations base this provision on a finding that uncontrolled emissions from these sources do not pose a significant threat to human health and the environment.37 However, consistent with our determination that off-spec used oil be considered a solid waste when burned as a fuel, we believe that off-spec used oil managed within the control of the generator would not qualify for the generator controlled exclusion when burned in a used oil fired-space heater, since contaminant levels are not comparable to traditional fuels. Therefore, we are proposing that off-spec used oil combusted at a unit that is within the control of the generator would be solid waste. We request comment on this approach, as well as any supporting information. e. Coal Refuse/Coal Combustion Residuals. The ANPRM identified coal refuse (i.e., mining rejects and recovered landfilled ash) as a solid waste because it has been discarded and has not been subsequently processed for use as a fuel. We solicited comment on whether there are circumstances under which these materials have been discarded, but not processed, and can be considered as non-waste fuels once they are removed or recovered from the ‘‘discard’’ environment and managed as legitimate fuels. Comments: Several commenters responded that coal refuse should not be classified as a solid waste. One commenter argued that there is no basis for continuing to classify an alternative fuel or ingredient as a solid waste merely because it does not have to undergo some type of processing before being used. The same commenter also indicated that the recovery of ash and mill rejects from disposal sites all involve some degree of processing. The materials have to be excavated, stored, and transported to their designated uses where they are also often subject to the same types of processing activities that are associated with the mining and management of virgin coal (i.e., screening, sizing, and chemical analysis to identify Btu, ash characteristics and sulfur content). Given the significant costs associated with the extraction of these materials, including excavation and handling, as well as the nearly identical nature of these materials to traditional fuels and ingredients, the extraction operations themselves constitute the requisite degree of processing necessary to be viewed as a non-waste. One commenter stated that they were aware of one electric utility that in the past recovered high-carbon content ash from a disposal facility that it owns, and used the ash as a fuel source by supplementing the coal used in one of their utility boilers. The same company today takes high-carbon fly and bottom ash directly from several existing boiler units and burns it at their power generating station. This commenter noted that there are at least four patented processes for removing unwanted carbon from fly ash that allow the processed ash to produce both technically compliant fly ash for use in concrete and a separate carbon stream that can be re-introduced into the boiler for its fuel value. One commenter contended that coal refuse is a solid waste due to its toxicity levels in comparison to normal coal. Specifically, waste coals can have up to four times more mercury and chromium, and three times more lead than other coals. EPA’s Response: As discussed in the Material Characterization Paper developed for this rulemaking, large volumes of coal refuse piles were accumulated at mining sites from the time mining first began in the Appalachians through the late 1970s. Beginning in the late 1970s, laws were enacted that, for the first time, required stabilization and reclamation of mining sites, including coal refuse disposal piles and fills. Current mining operations continue to generate the material, though likely at lower rates than in previous decades. For purposes of this proposal, we are therefore differentiating between coal refuse that was generated in the past and placed into ‘‘legacy’’ piles, and the current generation of coal refuse. Legacy piles of coal refuse would clearly be considered to be disposed of and abandoned, thus meeting the definition of a solid waste material. We would not consider currently generated coal refuse to be abandoned or disposed of and, therefore, would not be considered a solid waste. With regard to coal refuse from legacy piles, the processing of coal refuse for use as a fuel or ingredient involves separation through the use of screens or grizzlies, blending, crushing, and some drying. Although we understand that virgin coal is similarly processed, we believe that such operations would constitute ‘‘minimal processing’’ and would not meet the processing definition as proposed. See section VII.D.4 for a discussion of what does and does not constitute ‘‘processing’’ as defined in this proposal. Therefore, because coal refuse from legacy piles has been discarded and does not undergo a sufficient level of processing, it is considered a solid waste and would be subject to the CAA 129 requirements if burned in a combustion unit. We note that one commenter contended that coal refuse contained elevated levels of mercury, chromium, and lead when compared to other coals. We recognize that available data show that coal refuse generally has higher metals concentrations than non-refuse coal concentrations. Although coal refuse can contain metals concentrations that are higher than found in virgin coal, data also show that emissions levels from some facilities burning coal refuse (namely those equipped with circulating fluidized beds (CFBs)) are lower than most existing pulverized coal utility boilers.38 For the purposes of this proposal, however, it is not necessary to discuss whether coal refuse from legacy piles VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00023 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31866 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 39The ANPRM included landfill ash in its description of coal refuse. 40EPA has long viewed sewage sludge generated from POTWs as a solid waste, beginning with the 1980 Identification and Listing of Hazardous Waste rulemaking. In this final rule, EPA stated that the DSE is ‘‘only applicable to non-domestic wastes that mix with sanitary waste in a sewer system leading to a POTW.’’ See 45 FR 33097 (May 19, 1980). In the same rule, EPA further said it decided not to exclude sewage sludge from regulation under RCRA, since the statutory expressions regarding the definitions of ‘‘solid waste’’ and ‘‘sludge’’ was clear. (See 45 FR 33101). satisfies the contaminant requirement of the legitimacy criteria, given that we believe that such coal refuse is a solid waste because it is discarded and is not sufficiently processed into a fuel product. We are also differentiating between mined landfilled ash, which generally refers to landfilled coal ash, from coal refuse, which we generally characterize as coal mining rejects that have been placed in waste piles (known as gob or culm, for example).39 Coal combustion residuals (CCRs) that have been discarded in the first instance (e.g., coal ash mined from landfills) would be considered solid waste unless they are processed into legitimate non-waste fuel products. It appears that the patented processes described by the commenter that separates carbon from the fly ash to produce a fuel would satisfy the processing requirement included in this proposal. However, until the Agency has additional information, we are not in a position to indicate that such processing is sufficient to produce a non-waste fuel. Therefore, we are requesting that commenters provide additional information explaining how this processing is conducted, and the extent to which these high carbon fuels are produced nationwide. With respect to high-carbon fly and bottom ash taken directly from existing boiler units and burned at power generating stations, we believe that such secondary materials are not discarded and would not be considered a solid waste if it was managed within the control of the generator and satisfies the fuel legitimacy criteria. Regarding the commenter that indicated coal fly ash and mill rejects are often subjected to the same types of processing activities that are associated with the mining and management of virgin coal (i.e., screening, sizing, and chemical analysis to identify Btu, ash characteristics and sulfur content), we believe that screening, sizing, and chemical analysis constitutes a minimal level of processing, and would not satisfy the processing requirement of this proposal. Although we recognize that sizing of materials is an important processing step for fuels in order to improve combustion efficiency, we believe this represents an inadequate level of processing to change a discarded material into a product fuel and, therefore, these materials would be considered solid wastes under today’s proposal. However, we request that commenters provide additional information on the extent to which CCRs are recovered from the discard environment (e.g., landfills) and used as fuels. We also request that commenters provide more detailed information on how these secondary materials are processed, and whether these materials might satisfy the legitimacy criteria for fuels. f. Sewage Sludge. Sewage sludge or ‘‘wastewater treatment sludge’’ as referred to in the ANPRM, was one of several non-hazardous secondary materials that we solicited comment as to whether it is a legitimate alternative fuel and thus would not be solid waste if it has not been previously discarded. Comments: All commenters who addressed this issue argued that sewage sludge should not be classified as a solid waste. One commenter specifically pointed to the RCRA statutory definition of solid waste, stating that Congress expressly exempts solid and dissolved materials in domestic sewage processed at Publicly Owned Treatment Works (POTWs). Rather, sewage sludge should be regulated comprehensively under the Clean Water Act (CWA), or to the extent necessary to meet CAA obligations, EPA should regulate the combustion of POTW sewage sludge under CAA section 112. Additionally, it was put forth that if the Agency disagreed with the assertion that the RCRA statute requires the Agency to exempt sewage sludge from the definition of solid waste, that the Agency provide a regulatory exclusion for sewage sludge burned in incinerators in order to preserve the current framework for regulating sewage sludge managed under section 405 of the CWA to avoid redundancy. This commenter was also concerned about the implications a determination that sewage sludge is solid waste when incinerated would have on how states regulate sewage sludge managed for different purposes (e.g., land application). Two commenters stated that sewage sludge meets all three legitimacy criteria for fuels. It is handled as a valuable commodity by virtue of it being continuously dewatered and directly injected into the incinerator; it is not diverted or stored and every effort is made to maximize the quantity of sludge to be combusted. One commenter stated these materials have meaningful heating value, given that it recovers a net energy value of 4,300,000 Btus/hour of useable thermal energy from its combustion. Also, the CWA section 405 regulations provide risk-based limits for contaminants when incinerated, such that as long as the contaminant level is below the limits, it does not pose a significant health risk. EPA’s Response: We agree with commenters that the RCRA statutory definition of solid waste excludes the solid or dissolved material in domestic sewage. This is evidenced by the RCRA hazardous waste regulations that extend this exclusion to mixtures of hazardous waste with domestic sewage, provided that the mixture occurs in a pipeline en route to a POTW. See 40 CFR 261.4(a)(1). However, we do not agree with the commenters that the Domestic Sewage Exemption (DSE) applies to the sludge generated from the treatment process and thus, sewage sludge is a solid waste if it is discarded.40 We believe that sewage sludge burned without energy recovery (i.e., burned for destruction) in an incinerator is discarded, and thus a solid waste. Further, the Agency is not proposing to provide a regulatory solid waste exclusion for sewage sludge burned in incinerators that would preserve the current framework for regulating sewage sludge managed under section 405 of the CWA to avoid redundancy. However, we request comment on whether such an approach is within our discretion. Regarding the commenter’s concerns about possible impacts on how states regulate sewage sludge managed for different purposes (e.g., land application), as discussed in more detail in Section VIII, through this rulemaking, EPA is articulating the narrow definition of which non-hazardous secondary materials are or are not solid waste when used as fuel for energy recovery or as ingredients in combustion units. We are not making solid waste determinations that cover other possible secondary material end uses. In EPA’s view, these regulations should have no effect on state programs that choose to regulate this material in different ways and under different authorities. Two commenters indicated that many POTWs recover energy in the form of usable heat from the incineration of sewage sludge via waste heat boilers. Although waste heat boilers are useful devices for providing energy in the form of steam for secondary processes, the Agency does not regard them as legitimate energy recovery devices because they receive their energy input VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00024 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31867 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 41More information on the composition of municipal wastewater treatment sludges can be found in the Materials Characterization Paper on Wastewater Treatment Sludge, which has been placed in the docket for today’s proposed rule. from the combustion of off-gases via a separate combustion chamber. Under the RCRA program, a legitimate energy recovery device is one that meets the definition of a boiler or an industrial furnace (see 40 CFR 260.10). Among other criteria, a boiler’s combustion chamber and primary energy recovery section(s) must be of integral design, unless it falls under the process heater or fluidized bed combustion exemption. Thus, a combustion chamber that is connected by a duct to a waste heat boiler (or recuperator/heat exchanger) does not qualify as a legitimate energy recovery device. The CAA program views waste heat recovery units (i.e., external to the combustion chamber) similarly. Waste heat recovery units are designed to cool the exhaust gas stream, and/or to recover, indirectly, the useful heat remaining in the exhaust gas from a combustion unit that has some other primary purpose (such as an institutional waste incinerator). The presence of a waste heat recovery unit on the exhaust gas does not change the fact that the unit combusting the secondary material is primarily an incineration unit burning waste for disposal purposes. See Other Solid Waste Incinerators (OSWI) final rule at 70 FR 74870 at 74876, (December 16, 2005). Therefore, sewage sludge burned in a waste heat recovery unit would not satisfy the meaningful heating value legitimacy criteria and would thus be considered to be burning solid waste (for more discussion on the legitimacy criteria, see section VII.D.6). The Agency also notes that data generally shows that municipal sewage sludge contains metals that are typically higher in concentrations when compared to traditional fuels (e.g., coal and fuel oil). See the table below for a comparison of the concentration of certain toxics of municipal wastewater treatment sludges to coal. COMPARISON OF TOXICS OF MUNICIPAL WASTEWATER TREATMENT SLUDGES TO TRADITIONAL FUELS41 Element Sewage sludge Coal (mg/kg) 40-City study (mg/kg dry weight) National sewage sludge study (mg/kg dry weight) Arsenic ........................................................................................................9 .9 6 .7 10 Cadmium .....................................................................................................69 6 .9 0.5 Chromium ....................................................................................................429 119 20 Copper ........................................................................................................602 741 Not available. Lead ............................................................................................................369 134 .4 40 Mercury .......................................................................................................2 .8 5 .2 0.1 Molybdenum ................................................................................................17 .7 9 .2 Not available. Nickel ..........................................................................................................135 .1 42 .7 20 Selenium .....................................................................................................7 .3 5 .2 1 Zinc .............................................................................................................1,594 1,202 Not available. Sewage sludge findings in this table are for final sludge which is defined as the liquid, solid, or semi-solid residue generated during the treat- ment of domestic sewage in a treatment works, receiving secondary treatment or better, and which may include sewage sludge processed to meet the land application standards. As such, the Agency does not believe that sewage sludge would meet the legitimacy criteria for contaminants. Therefore, the Agency is proposing that sewage sludge, generated from POTWs and when combusted, be classified as a solid waste, and subject to the CAA Section 129 requirements. 6. Comments on Specific Materials Used as Ingredients The ANPRM identified a number of non-hazardous secondary materials that we believe are currently being used as ingredients in combustion processes (i.e., blast furnace slag; CKD; coal combustion residual group (fly ash, bottom ash, and boiler slag); foundry sand; silica fume; and secondary glass material). The ANPRM solicited comment on whether or not these non- hazardous secondary materials are legitimate ingredients per the legitimacy criteria, and requested additional data and/or information supporting whether these secondary materials are legitimate ingredients. The majority of comments submitted were in regard to: CKD, CCRs, foundry sand, and blast furnace slag/ steel slag. a. Cement Kiln Dust. For CKD, the ANPRM indicated that CKD is not a solid waste if it is recycled within the continuous clinker production process. Comments: One commenter responded that they strongly support this view, but that other CKD which may be available could be useful if industry could find a means to incorporate this viable ingredient into the process. Thus, they believe that any EPA interpretation regarding the use of CKD must allow for access of the material irrespective of where the ingredient is maintained prior to use. EPA’s Response: As explained in section VII.D.3, we are proposing that non-hazardous secondary materials used as ingredients in combustion units that are not discarded in the first instance would not be considered a solid waste provided they satisfy the legitimacy criteria for ingredients (discussed in section VII.D.6.b). This proposal does not assume that ingredients used in combustion units that are not managed within the control of the generator are discarded materials (as is the case for non-hazardous secondary material fuels) since we believe that non-hazardous secondary materials used as ingredients in manufacturing processes, such as cement kilns are commodities managed within continuous commerce and are used as an integral part of the manufacturing process. That is, secondary materials that are directly used (or in the case of previously used materials, reused), function as raw materials in normal manufacturing operations or as products in normal commercial applications, and thus, EPA has interpreted the definition of solid waste as excluding secondary materials recycled in ways that most closely resemble normal production processes. With respect to the comment that our interpretation regarding the use of CKD must allow for access of the material irrespective of where the ingredient is maintained prior to use, it is not clear what point the commenter is making. To the extent that the CKD has not been VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00025 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31868 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 42We note that used tires provide both fuel value and ingredient value in cement kilns. In this instance, however, we believe the primary purpose of using tires in a cement kiln is to recover their energy value, and therefore believe tires should satisfy the fuel criteria in determining whether the materials are discarded and legitimate. discarded in the first place, we are proposing that the use of CKD in a cement kiln would not be considered a solid waste whether it remains under the control of the generator or is transferred to another person, so long as it meets the legitimacy criteria. However, if CKD has been discarded, its use as an ingredient in the cement kiln would be considered combustion of a solid waste, (and the cement kiln would be subject to the CAA section 129 requirements), unless it has been processed (as defined in section VII.D.4) to produce a non-waste ingredient. b. Coal Combustion Residuals. The ANPRM identified what was considered to comprise the CCR group: Fly ash, bottom ash, and boiler slag. Similar to CKD, it was stated that coal fly ash that is handled as a commodity within continuous commerce when it is marketed to cement kilns as an alternative ingredient is not discarded. Under the ANPRM approach, if the CCR product was previously discarded, such non-hazardous secondary materials would be solid wastes, unless they were processed into a legitimate ingredient product. However, we solicited comment on the situation where a discarded material is recovered from the environment and directly used as an ingredient (i.e. without processing). Additionally, we solicited comment on the extent to which non-hazardous secondary materials that have already been discarded (e.g., coal fly ash that has been landfilled) are later processed and used as ingredients in combustion units, as well as requested descriptions of the types of processing that these secondary materials undergo. Comments: Several commenters believe CCRs can be either legitimate fuels or ingredients when used in a combustion unit. One commenter stated that there are a number of cement kilns that use or have used high carbon fly ash as a fuel and ingredient. As an ingredient, the constituents within the fly ash are similar to those required from natural materials (such as shale, marl or limestone) in that they contain fractions of silica, iron and aluminum needed in the kiln. As a fuel, the relatively high carbon content imparts energy through its combustion, reducing the need for some portion of fossil or other fuels for the kiln. EPA’s Response: As discussed above (and as further discussed in Section VII.D.6.b), we are proposing that non- hazardous secondary materials used as ingredients in combustion units that are not discarded in the first instance would not be considered a solid waste provided they satisfy the legitimacy criteria for ingredients. Commenters point out that CCRs can serve both as ingredients, as well as fuel supplements. This raises the question of whether these types of secondary materials should be treated like non-hazardous secondary materials used as fuels (where we assume they are discarded if they are managed outside the control of the generator), as opposed to ingredients (in which case they are not solid waste even if they are managed outside the control of the generator provided they satisfy the legitimacy criteria and have not been discarded in the first instance). It also raises the question as to whether these materials should be required to satisfy the legitimacy criteria for fuels or for ingredients, or both. We do not believe it would be appropriate to require these types of secondary materials to satisfy the criteria of both fuels and ingredients. As a result, we are proposing that the decision to treat them as fuels or ingredients should be based on the primary purpose of using the non-hazardous secondary material in the cement kiln. With respect to CCRs, we believe the primary purpose of their use is as an ingredient; thus, provided the CCRs satisfy the legitimacy criteria for ingredients and are not discarded in the first instance, they would not be considered solid waste.42 However, we specifically solicit comment on this point, and in particular, whether the use of CCRs is primarily used for their ingredient value as opposed for their fuel value. Comment: With respect to the extent that CCRs have been discarded, but are later processed, one commenter noted that there are at least four patented processes for removing unwanted carbon from fly ash that would allow the processed ash to produce both technically compliant fly ash for use in concrete and a separate carbon stream that can be re-introduced into the boiler for fuel value. Another commenter stated that coal fly ash (and mill rejects) recovered from disposal sites all involve some degree of processing, in that the materials have to be excavated, stored, and transported to their designated uses. The materials are also often subject to the same types of processing activities that are associated with the mining and management of virgin coal (i.e., screening, sizing, and chemical analysis to identify Btu, ash characteristics and sulfur content). Finally, one commenter disagreed with our position on CCRs. The commenter believes that CCRs are wastes due to their high concentration of contaminants, predominantly mercury. EPA’s Response: In regard to when a discarded material is recovered from the environment and directly used as a fuel or ingredient, we are proposing that the secondary material is a solid waste, unless it undergoes a sufficient level of processing to produce a legitimate fuel product or ingredient. As discussed in detail in section VII.D.4, when a non- hazardous secondary material has been discarded, unless sufficient processing occurs to change the material to produce a legitimate fuel product or ingredient, it would remain a solid waste under this proposal. However, we are also requesting comment on whether such non-hazardous secondary materials that have been discarded and shown to be a legitimate fuel or ingredient product, should nevertheless be considered a legitimate non-waste fuel or ingredient, even if the non-hazardous secondary material does not undergo processing at all or an adequate amount of processing. As previously described for processed CCR’s that are used as fuels, it appears that the patented processes described by the commenter that separates carbon from the fly ash to produce technically compliant fly ash for use in concrete would satisfy the processing requirement included in this proposal; however, we are requesting that commenters provide additional information explaining how this processing is conducted, and whether this type of fly ash is used as an ingredient in the clinker production process. Regarding the commenter that indicated that coal fly ash and mill rejects are often subject to the same types of processing activities that are associated with the mining and management of virgin coal (i.e., screening, sizing, and chemical analysis to identify Btu, ash characteristics and sulfur content), we do not believe that screening, sizing, and chemical analysis by itself is a sufficient level of processing that would render a discarded material into a non-waste ingredient product. As we noted previously in Section VII.C.5.e., while we recognize that screening, sizing, and chemical analysis can be important for producing traditional fuels, we also are proposing that such processing is not sufficient to change a waste-derived fuel into a product fuel. Thus, such secondary materials that undergo such minimal processing are still considered waste-derived fuels because such processing of CCRs, even with screening and chemical analyses, would not be VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00026 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31869 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 43For more information on the different types, or ranks, of coal, please refer to the Materials Characterization Paper on Traditional Fuels and Key Derivatives, which is located in the docket of today’s proposed rule. 44Listed by relative frequency. See ‘‘Technical Background Document for the Report to Congress on Removing Wastes from Fossil Fuel Combustion: Waste Characterization.’’ U.S. EPA. March 15, 1999. 45‘‘Study on Increasing the Usage of Recovered Mineral Components in Federally Funded Projects Involving Procurement of Cement or Concrete to Address the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users. Report to Congress.’’ June 3, 2008. EPA530–R–08– 007. When analyzing perceived safety and health risk barriers associated with the beneficial use of recovered mineral components (including CCRs et al), this study concluded that ‘‘Findings from [several cited] analyses did not identify significant risks to human health and the environment associated with the beneficial uses of concern. In addition, [EPA] identified no documents providing evidence of damage to human health and the environment from these beneficial uses. Our overall conclusions from these efforts, therefore, are that encapsulated applications, including cement and concrete uses, appear to present minimal risk.’’ Id. at 4–11. 46Id at 4–4. 47A series of reports have been and are being developed by U.S. EPA’s Office of Research Development. To date, three documents have been finalized, including: (1) ‘‘Characterization of Mercury-Enriched Coal Combustion Residuals from Electric Utilities Using Enhanced Sorbents for Mercury Control.’’ EPA–600/R–06/008. Feb. 2006; (2) ‘‘Characterization of Coal Combustion Residuals from Electric Utilities Using Wet Scrubbers for Multi-Pollutant Control.’’ EPA–600/R–08/077. July 2008; and (3) ‘‘Characterization of Coal Combustion Residuals from Electric Utilities Using Multi- Pollutant Control Technology—Leaching and Characterization Data.’’ EPA–600/R–09/151. December 2009. sufficient to produce a non-waste ingredient. However, we request that commenters provide additional information as to the extent to which CCRs are recovered from the discard environment (e.g., landfills) and used as ingredients in cement kilns, and if so, we request commenters provide more detailed information on the extent to which these CCRs are processed, and thus, might satisfy our proposed definition of processing in section VII.D.4. In addressing the commenter who argued that CCRs are solid wastes due to their high concentration of contaminants, we begin by noting that the chemical properties of CCRs are influenced to a great extent by those of the coal burned, the type of combustion unit, and the air pollution controls applied.43 We are also aware that fly ash may contain various levels of metals, such as vanadium, zinc, copper, chromium, nickel, lead, arsenic, and mercury.44 However, in a recent Report to Congress that addressed the use of these secondary materials as ingredients in cement and concrete applications, the overall conclusion reached with respect to the perceived safety health risk barriers was a positive one, in that the risk analyses did not identify significant risks to human health and the environment associated with these uses.45 The Report to Congress also identifies several industry stakeholders and state agencies that have recognized that regulatory programs for the control of mercury and NOX in electric utility air emissions (and the necessary new emission control technologies and configurations necessary to achieve emissions reductions) can potentially result in increased carbon levels in coal fly ash that impact the ability to use the ash as a supplementary cementitious material.46 Consequently, EPA is studying the possible effects of new air emission control technologies and configurations on the composition of CCRs and publishing its findings in a series of reports.47 Thus, we request comment on whether advanced emission control technologies, such as carbon control technologies for mercury and NOX, are resulting or will result in increased levels of contaminants in coal ash to the extent that coal ash would not satisfy our legitimacy criteria. c. Foundry Sand. Similar to the previously discussed ingredients, we requested data and/or information supporting whether foundry sand is discarded and if not discarded, whether it meets the legitimacy criteria. Comment: One commenter responded and stated that foundry sand meets all four legitimacy criteria for ingredients. The commenter offered several examples of applications for foundry sand in support of why it should not be a solid waste; however, very little information was provided in the context of utilizing foundry sand as an ingredient in a combustion process. EPA’s Response: Since this proposal is limited to those situations where the non-hazardous secondary material is used as a fuel or ingredient in a combustion process, examples of using foundry sand in other applications is not directly relevant. However, as previously explained, we are proposing that non-hazardous secondary materials used as ingredients in combustion units that are not discarded in the first instance would not be considered a solid waste provided they satisfy the legitimacy criteria for ingredients (discussed in section VII.D.6.b). d. Blast Furnace Slag/Steel Slag. The ANPRM also requested data and/or information regarding blast furnace slag and steel slag and their use as legitimate ingredients and thus, whether they are or are not considered solid waste. Comments: Two commenters responded that steelmaking slag and mill scale should be excluded from the definition of solid waste because they meet all four legitimacy criteria for ingredients. With respect to our solicitation for comment on when a material is previously discarded and has been processed into a legitimate ingredient product, one commenter responded that current practice to obtain these materials requires the procurement of a mining license and operating practices that are similar to processing of natural aggregates (though drilling and blasting practices are not required for recovery). In particular, iron and steel slag aggregates are removed by ripping and digging, followed by magnetic separation, crushing, further magnetic separation and finally sized by screening. They are then loaded and weighed in customer trucks subject to quality assurance and quality control for comparable virgin aggregate intended for the same use. EPA’s Response: As with the previous ingredients, we are proposing that blast furnace and steel slag used as ingredients in combustion units that are not discarded in the first instance would not be considered a solid waste provided they satisfy the legitimacy criteria for ingredients. If these materials, as described by the commenter, are considered to have been discarded in the first instance, then they would have to be sufficiently processed into ingredient products that satisfy the legitimacy criteria in order to be classified as a non-waste ingredient. Based on the processing operations described above, it appears that blast furnace and steel slag undergo sufficient processing; however, before the Agency concludes this to be the case, we request that commenters provide more detailed information regarding the level of processing that occurs. 7. Legitimacy Criteria The ANPRM discussed the following legitimacy criteria specific to fuel products that are used in combustion processes: (1) Handled as valuable commodities; (2) have meaningful heating value; (3) and contain contaminants that are not significantly higher in concentration than traditional fuel products. Likewise, for ingredients, the ANPRM listed the following criteria: (1) Handled as a valuable commodity; (2) the non-hazardous secondary material provides a useful contribution; (3) the recycling results in a valuable product; and (4) the product does not contain contaminants that are significantly higher in concentration than traditional products. We requested VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00027 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31870 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 48In EPA’s final definition of solid waste rule regarding hazardous secondary materials, EPA codified a ‘‘legitimate recycling provision.’’ See 40 CFR 260.43. This legitimacy provision has two parts. The first part includes two factors that must be considered and met, which are considered the core of the legitimacy factors. The second part of the legitimacy provision consists of two factors that must be considered, but need not be met because the Agency is aware of situations where a legitimate recycling process exists, but may not conform to one or both of these factors. For further discussion of the legitimacy factors in the hazardous waste rules, see section VII.C.7 of this preamble and the final definition of solid waste rule (October 30, 2008 beginning on 73 FR 64700). Thus, the application of the legitimacy provision proposed in this rule is different than that promulgated in the final definition of solid waste rule in that all of the criteria to be considered in today’s proposed rule must both be considered and met. comment on the criteria themselves and whether they are reasonable for non- hazardous secondary materials. a. General Comments: Application of Legitimacy Criteria: Commenters provided various viewpoints on the appropriateness of the legitimacy criteria for non- hazardous secondary materials that are used as fuels or ingredients. Several commenters disagreed with the application of the same subtitle C legitimacy definition for determining whether non-hazardous secondary materials are solid waste under RCRA subtitle D because non-hazardous secondary materials do not pose the same hazards. However, many of the commenters agreed with the application of the subtitle C legitimacy principles, but also argued that the criteria must be flexible to account for increasing use and changes in commodities, technologies, markets, and fuel prices and should not be more onerous than the legitimacy test codified at 40 CFR 260.43. Commenters also requested clarification as to whether all criteria need to be met, but urged EPA to recognize that legitimate uses are possible even if not all criteria are met. EPA’s Response: Application of Legitimacy Criteria: First, we would note that there are two questions that the Agency needs to answer: (1) Whether or not the non-hazardous secondary material is a fuel product or ingredient product, or whether the material has been discarded and is therefore a solid waste, which includes waste-derived fuels or ingredients and (2) whether the non-hazardous secondary material is being legitimately and beneficially used or recycled. With respect to the legitimacy question, EPA believes it important and crucial to develop a set of legitimacy criteria to make sure that the fuel product and ingredient product are being legitimately and beneficially used and not simply being discarded via sham recycling. The definition of legitimate recycling developed for subtitle C hazardous secondary materials carefully considered the history surrounding the uses of materials, as well as the applicable case law with respect to the meaning of discard. Likewise, those same principles are pertinent to how a non-hazardous secondary material is determined not to be a solid waste. Therefore, we are proposing to codify general legitimacy criteria that use the same basic framework that has been established for the subtitle C hazardous waste regulations, but that are also tailored specifically for application to non- hazardous secondary materials that are used as fuels or ingredients in combustion units. See 40 CFR 241.3(d) for the proposed regulatory text of the legitimacy criteria and, for comparison see 40 CFR 260.43 in final regulations for the DSW hazardous waste legitimacy provisions. The rationale for the non- hazardous secondary materials legitimacy provisions (including comparisons to the DSW legitimacy provision) is discussed in section VII.D.6. Commenters also suggested that the legitimacy criteria must be flexible to account for increasing use and changes in commodities, technologies, markets, and fuel prices and should not be more onerous than the legitimacy definition codified at 40 CFR 260.43. We agree with these commenters and have proposed qualitative criteria that we believe provide the flexibility needed in evaluating these secondary materials that will accommodate such changes. The legitimacy criteria are structured to distinguish between legitimate reuse/ recycling and disposal (i.e., sham recycling), while at the same time not impose restrictions on the types of non- hazardous secondary materials that may be of value in the future. For a detailed discussion of the proposed legitimacy criteria, see section VII.D.6. In regard to the commenters who requested clarification on whether all criteria need to be met, we believe that each of the criteria is important and addresses certain issues that need to be assessed. Therefore, each criterion must be met in order for the non-hazardous secondary material to be considered to be a legitimate non-waste fuel or ingredient. Thus, today’s proposal requires that in evaluating the legitimacy criteria, the owner/operator of the combustion unit must assure that the non-hazardous secondary material meets all of the criteria.48 See section VII.D.6 for additional discussion. Comment: Ingredients (General): We also received one general comment regarding the legitimacy criteria for ingredients. The commenter argued that the determination is not applicable for any material that is within a process and is being recycled in that process, and should not have to be justified as a secondary material, since closed-loop systems do not manage solid waste. EPA’s Response: Ingredients (General): We generally agree with the commenter. That is, to the extent that the non-hazardous secondary material has not been discarded in the first instance, which we presume it would not be as part of a closed-loop system, and such secondary material meets the legitimacy criteria, it would not be considered a solid waste when combusted. Thus, as an example, where CKD is recycled back into the cement kiln, and meets the legitimacy criteria, it is not solid waste. b. Fuels or Ingredients Being Managed as Valuable Commodities Comments: For this criterion, most commenters generally agreed with the Agency that such non-hazardous secondary materials should be managed as a valuable commodity, but argued that a specified containment system should not be a mandatory part of the criteria. One commenter suggested that rather than focus on containment, the focus should be on whether the non- hazardous secondary material has value for future use. Another commenter suggested that a more appropriate requirement is that the non-hazardous secondary material should be stored in a manner that preserves their economic value and avoids damaging releases to the environment. Another commenter thought that EPA should look to state requirements for containment, handling, and storage. Similarly, another commenter suggested that EPA should recognize that if a non-hazardous secondary material is managed pursuant to federal requirements that also apply to raw materials (e.g., coal refuse compared to coal), the criteria are satisfied. Lastly, one commenter argued that the concept of ‘‘speculative accumulation’’ of one year can prevent accumulation of enough non-hazardous secondary materials to make recovery economical and thus, is not an appropriate criterion to conclude that a non-hazardous secondary material isn’t being reused and is a solid waste. EPA’s Response: We generally agree with those commenters who argued that a specific containment system should not be required and, therefore, are proposing a qualitative approach in line with the same principle as the VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00028 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31871 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules commenter who suggested that non- hazardous secondary materials should be stored in a manner that preserves their economic value, while preventing damaging releases to the environment. We also are proposing to incorporate the concept that non-hazardous secondary materials be ‘‘contained’’ in the same manner as its analogous fuel or raw ingredient. Thus, we are proposing that where there is an analogous fuel or ingredient, the non-hazardous secondary material used would be required to be managed in a manner consistent with the management of the analogous fuel or ingredient or otherwise must be adequately contained so as to prevent releases to the environment. As explained in section VII.D.6, an analogous ingredient or fuel’’ is an ingredient or fuel for which the non-hazardous secondary material substitutes and which serves the same function and has similar physical and chemical properties as the non- hazardous secondary material. Where there is no analogous fuel or ingredient, the non-hazardous secondary material must be adequately contained so as to prevent damaging releases to the environment. ‘‘Adequately contained’’ is when a non-hazardous secondary material is stored in a manner that adequately prevents releases to the environment considering the nature and toxicity of the non-hazardous secondary material. In regard to the comment on speculative accumulation, we are not proposing a specific timeframe, because states already require varied timeframes and we will leave this up to the state’s discretion. c. Fuels Must Have Meaningful Heating Value. The ANPRM discussed the meaningful heating value criterion for legitimate alternative fuel, and outlined a qualitative approach rather than a ‘‘bright-line’’ cutoff for heating value. The ANPRM requested comment as to whether it was possible or appropriate to establish a specific heating value cutoff. Comments: Several commenters favored the ANPRM approach, while others recommended either a lower Btu benchmark or replacing the Btu benchmark with a case-by-case analysis. No commenters recommended deleting the criterion. Commenters emphasized that innovations and advancements in technology can efficiently produce energy from non-hazardous secondary materials with lower heating value content. EPA’s Response: We are proposing a qualitative approach for a meaningful heating value criterion as outlined in the ANPRM. The proposed regulatory text specifies that ‘‘the material must have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy’’. See proposed 241.3(d)(1)(ii). We are clarifying in this proposal, that non-hazardous secondary materials with a heating value of greater than 5,000 Btu/lb, as fired, would be considered to satisfy the criterion. However, non-hazardous secondary materials with a heating value lower than 5,000 Btu/lb, as fired, may also be considered to have a meaningful heating value if the unit can cost-effectively recover meaningful energy. See section VII.D.6.a. for an explanation of the factors that may be considered in determining whether an energy recovery unit can cost-effectively recover energy from a non-hazardous secondary material. Also, as outlined in the same section, this criterion is an appropriate factor, since it expresses the principle that non-hazardous secondary materials used as a fuel with a meaningful heating value provides a useful contribution to the manufacturing process. The Agency believes a 5,000 Btu/lb benchmark, as fired, identifying when a non-hazardous secondary material, by definition, provides fuel value is appropriate since it is consistent with determinations expressed in previous RCRA and CAA rulemakings, including the RCRA comparable fuels rule (63 FR 33781), the RCRA subtitle C boilers and industrial furnaces rule (48 FR 11157–59), and the CAA NESHAP for Hazardous Waste Combustors NODA (62 FR 24251). We request comment on whether it would be appropriate to also identify a lower Btu/lb threshold, below which non-hazardous secondary materials would not be considered to have meaningful heating value and thus, would be a solid waste by definition. d. Fuel/Ingredient Contaminant Levels. To address the possible presence of waste-like contaminants in non- hazardous secondary materials, the ANPRM stated that such secondary materials used as fuels should not contain contaminants that are significantly higher than those contained in traditional fuels. For ingredients, the ANPRM stated that products that use non-hazardous secondary materials as ingredients in combustion units should not contain contaminants that are significantly higher in concentration than the product produced without the non- hazardous secondary material. For both ingredients and fuels, the ANPRM suggested that a qualitative approach may be more appropriate to use than numerical specifications. In addition, we requested comment on whether the contaminants evaluated should be the hazardous constituents listed in Appendix VIII to 40 CFR part 261, or whether a different list of contaminants would be more appropriate. Comments: Commenters were evenly divided on whether the presence of contaminants was an appropriate legitimacy criterion. For commenters favoring the criterion, most believed that a qualitative approach was preferable; stating that little risk exists for environmental exposure and numerical specifications may be impractical due to the multiplicity of fuels or ingredients. However, a minority of commenters favored a quantitative approach. For commenters recommending that the presence of contaminants not be included as a criterion, most emphasized that emissions will be controlled under either CAA sections 112 or 129. They stated that comparative contaminant concentrations are inappropriate, and that the Agency should recognize the lower risks posed by non-hazardous secondary materials. One commenter stated that the amount of contamination acceptable in an alternative fuel depends on how much is fired with the main boiler fuel, the type of contaminant (organic vs. inorganic), and the emission controls used. Specifically with respect to the use of ingredients in combustion units, one commenter agreed that the assessment should involve the final recycled product and not the ingredient itself. However, another commenter countered that the assessment should be a comparison of post combustion emission levels, not the product made with non-hazardous secondary materials to those in a product made with virgin materials. This commenter reasoned that combustion will destroy many of the substances that EPA considers possible contaminants and basically eliminates any environmental concern. Another commenter recommended an analysis of appropriate total constituent concentrations, leachable constituent concentrations, and a comparison to traditional ingredients (as outlined in the Solid Waste RCRA subtitle D groundwater protection constituent list). EPA’s Response: Based on our assessment of all of the comments, we believe it appropriate to include contaminant levels as a legitimacy criterion. Thus, we do not agree with those commenters’ that assert that contaminant comparisons are not appropriate to require as part of the legitimacy criteria. The Agency believes the criterion is necessary because non- hazardous secondary materials that contain contaminants that are not comparable in concentration to those contained in traditional fuel products or VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00029 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31872 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 49The five ways include: (i) The secondary material contributes valuable ingredients to a product or intermediate; or (ii) replaces a catalyst or carrier in the recycling process; or (iii) is the source of a valuable constituent recovered in the recycling process; or (iv) is recovered or regenerated by the recycling process; or (v) is used as an effective substitute for a commercial product. ingredients would suggest that these contaminants are being combusted as a means of discarding them, and thus the non-hazardous secondary material should be classified as a solid waste. In some cases, this can also be an indicator of sham recycling. For example, non- hazardous secondary materials that may not contain comparable concentrations of contaminants include chromium-, copper-, and arsenic (CCA)-treated lumber, polyvinyl chloride (PVC) plastics which can contain up to 60 percent halogens (chlorine), lead-based painted wood, and fluorinated plastics. Also, we disagree with the commenter who argued that any assessment should only include a comparison of post- combustion emission levels because the combustion unit will destroy many of the substances that EPA considers possible contaminants (and thereby eliminate any environmental concern). The Agency believes that this post- combustion assessment of contaminants further supports the principle that contaminant levels (before and after combustion) are important indicators of legitimacy. The legitimacy criterion for fuel/ ingredient contaminants outlined in today’s rule has changed from the criterion outlined in the ANPRM. In the ANPRM, non-hazardous secondary materials used as fuel could not contain contaminants that were significantly higher than traditional fuel products. For ingredients, the non-hazardous secondary material could not result in products that contain contaminants that are significantly higher in concentration than found in traditional products. Under today’s proposed rule, non- hazardous secondary material used as fuels in combustion units must contain contaminants (defined as HAP listed under CAA section 112(b) and the nine pollutants listed under CAA section 129) at levels ‘‘comparable’’ to those in traditional fuels which the combustion unit is designed to burn. For use as an ingredient, the non-hazardous secondary material must result in products that contain contaminants at levels that are ‘‘comparable’’ in concentration to those found in traditional products that are manufactured without the non- hazardous secondary material ingredients. As discussed in section VII.C.7., requiring that the secondary material have contaminants at levels comparable to traditional fuels would ensure that the burning of any secondary materials in combustion units will not result in discard of materials and will not result in increased releases to the environment that could impact the health and environment of the local community. Ensuring that the level of contaminants in the non-hazardous secondary material is comparable to traditional fuels would prevent secondary materials from being discarded and be the most protective of human health and the environment. Today’s proposed rule also requests comment on an approach, consistent with the ANPRM approach, which would only compare contaminants at levels that are significantly higher than traditional fuel products. Similar to the ANPRM, the assessment of whether the non- hazardous secondary material used as a fuel has contaminants comparable to traditional fuel products is to be made by directly comparing the numerical contaminant levels in the non- hazardous secondary material to the contaminant levels in traditional fuels. See section VII.C.7., for a complete discussion of contaminant assessments. The assessment of whether products produced from the use of non-hazardous secondary material ingredients in combustion units that have contaminants that are comparable in concentration to traditional products can be made by a comparison of contaminant levels in the ingredients themselves to traditional ingredients they are replacing, or by comparing the contaminant levels in the product itself with and without use of the non- hazardous secondary material ingredient. See section VII.D.6.b. e. Ingredients Must Provide Useful Contribution. The ANPRM cited (from the October 2008 DSW Final Rule for hazardous waste) five ways 49 in which a secondary material can add value and usefully contribute to a recycling process and solicited comment on whether they are appropriate for non- hazardous secondary materials. Comment: Only one commenter responded and indicated that the five criteria are too narrow and should be broadened to apply to the non- hazardous secondary material uses (i.e., processes not considered recycling) since using the criteria for hazardous waste as a model is too limiting. EPA’s Response: After review of the comment, we understand that there is some interest in broadening those criteria for non-hazardous secondary material use, but the commenter did not provide any information to merit the development of a separate or additional criteria for non-hazardous secondary material use to describe how they can ‘‘add value and usefully contribute to a recycling process’’ (or broaden to non- recycling uses as suggested by the commenter). However, the Agency solicits comments on this point; in particular, what the separate criteria would be and how a non-hazardous secondary material would or can ‘‘add value and usefully contribute to a recycling process.’’ f. Ingredients Must Produce a Valuable Product. For this criterion to be met, the ANPRM indicated that a product or intermediate is valuable if it is (i) sold to a third party or (ii) used by the recycler or generator as an effective substitute for a commercial product or as an ingredient or intermediate in an industrial process. We then requested comment on whether this description of valuable product/intermediate is an appropriate way to consider this criterion in the context of non- hazardous secondary materials used as ingredients. Comments: One commenter responded that they support this criterion, but caution that it be broad enough so that it addresses the value obtained by both its use on-site and off- site by a third party. The commenter also suggested that the provision be interpreted broadly to also include traditional recycling markets and the products generally in which such secondary materials are utilized. EPA’s Response: We believe that the criteria described in the ANPRM are broad enough to address the value obtained by both its use on-site and off- site by a third party. With regard to interpreting the criterion broadly enough to include traditional recycling markets and the products in which the secondary materials are utilized, we do not agree that it would be appropriate. Specifically, this rule is addressing a particular issue within the context of RCRA—that is, which non-hazardous secondary materials are or are not solid wastes when used in a combustion unit. We have tailored the legitimacy criteria to apply specifically to the use of these non-hazardous secondary materials as fuels or ingredients in combustion units only. An assessment of uses beyond those in combustion units is beyond the scope of this rulemaking. 8. De Minimis Concept Although we did not discuss the concept of de minimis in the ANPRM, commenters argued strongly that EPA allow for de minimis amounts of solid VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00030 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31873 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 50As we noted earlier in the preamble, traditional fuels also are not considered solid wastes when burned in a combustion unit. Therefore, we will not discuss the use of traditional fuels further since we believe it is understood that they are legitimate products and not wastes. 51Black liquor is burned in a pulping liquor recovery furnace and then reused in the pulping process, while spent sulfuric acid is used to produce virgin sulfuric acid; in both these instances, these hazardous secondary materials are considered to be an integral part of the manufacturing process. With respect to comparable fuel, these hazardous secondary materials are considered a legitimate non-waste fuel because they meet the chemical and physical specifications of a traditional benchmark fuel. Commercial chemical products that are themselves fuels, such as off- specification fuels, including gasoline, jet fuel, kerosene, diesel, etc., are not solid wastes when burned as fuels if that is their intended purpose (40 CFR 261.2(c)(2)(ii)). 52See Definition of Solid Waste Final Rule, January 4, 1985 at 50 FR 641–642, covering both black liquor and spent sulfuric acid. 53See ‘‘RCRA Comparable Fuels Exclusion’’ Final Rule, June 19, 1998, 63 FR 33782. 54See 50 FR 614 ‘‘Amendments to the Definition of Solid Waste’’ (Final Rule), January 4, 1985 at 50 FR 618, 629. See also Hazardous Waste Management System; Definition of Solid Waste; Corrections, April 11, 1985 at 50 FR 14219. waste to be burned without being subject to the CAA 129 requirements. Comments: Several commenters believe that any regulatory construct should include a de minimis exemption that excludes from the definition of solid waste for purposes of CAA section 129, those materials (i.e., solid waste) that, when combusted, result in de minimis emissions. An example provided by the commenters of a waste material is boiler chemical cleaning waste, which consists primarily of water, but also includes metal deposits from the boiler tubes, as well as spent solvent. Another example is oily rags which are generated in small quantities during routine maintenance activities. Air emissions associated with these practices is a small fraction compared to the emissions generated from fossil fuel combustion. Commenters also cited several court decisions that held that EPA retains the legal authority to promulgate de minimis exceptions for regulatory schemes. EPA’s Response: The issue of whether the burning of de minimis amounts of solid waste (i.e., because it results in de minimis emissions) can be exempted from CAA 129 regulation is outside the scope of this rulemaking, which is only concerned with identifying which non- hazardous secondary materials burned as fuels or ingredients in combustion units are or are not solid waste. D. Rationale for, and Detailed Description of, Proposed Approach Under this proposal, non-hazardous secondary materials used as fuels in combustion units would be considered solid waste unless: (1) The non- hazardous secondary materials remain under the control of the generator as discussed in section VII.D.1, and are legitimate fuels; or (2) they are legitimate fuels that are produced from the processing of discarded non- hazardous secondary materials as discussed in section VII.D.4. Non- hazardous secondary materials used as a fuel in combustion units that are transferred to a third party (and not considered to be managed within the control of the generator) are considered solid wastes unless a non-waste determination has been made pursuant to the proposed petition process (discussed below in section VII.D.5).50 Non-hazardous secondary materials used as ingredients in combustion units would not be considered solid waste if they have not been discarded in the first instance and if they are legitimate ingredients, irrespective of whether they have been transferred to a third party outside the control of the generator. Non-hazardous secondary materials that have been discarded may be processed into a non-waste ingredient that meets the legitimacy requirements as discussed in VII.D.4. The ANPRM also discussed another possible exclusion from being a solid waste—that is, hazardous secondary materials that are excluded from the definition of solid waste under RCRA subtitle C when combusted. However, EPA has concluded that it does not need to include this exclusion since these materials have already been excluded from the definition of solid waste as hazardous secondary materials and, therefore, are not subject to this rule, which deals with the definition of solid waste for non-hazardous secondary materials used in combustion units. As noted in the ANPRM, under the hazardous waste regulations, the Agency has evaluated a number of hazardous secondary materials that are recycled and determined that such materials, while they either met a listing description or exhibited one or more of the hazardous waste characteristics, were not ‘‘solid wastes’’ for purposes of the RCRA Subtitle C hazardous waste regulations when they were combusted. Specifically, the following materials may be burned under certain conditions and are not defined as solid wastes for purposes of the hazardous waste regulations—black liquor, spent sulfuric acid, comparable fuels and commercial chemical products that are themselves fuels.51 These secondary materials are not solid wastes provided they are handled under the applicable conditions of the exclusions specified under the RCRA subtitle C hazardous waste regulations, and are not considered solid wastes for purposes of CAA section 129. The rules covering the determinations for black liquor, spent sulfuric acid,52 comparable fuels,53 and commercial chemical products that are themselves fuels54 are not being reopened in this proceeding and EPA is no longer requesting comment on those solid waste definitions for purposes of this rule. Except for the petition process, the proposed criteria are designed to be self implementing in nature, i.e. they do not require prior Agency approval. 1. Non-Hazardous Secondary Materials Used as Fuel Within the Control of the Generator We are proposing to use the general framework finalized in the Definition of Solid Waste Rule to determine circumstances under which non- hazardous secondary materials remaining under the control of the generator that are used as fuels in combustion units are not considered to have been discarded. a. Scope and Applicability. EPA is proposing that non-hazardous secondary materials used as fuels in combustion units that remain within the control of the generator and that meet the legitimacy criteria specified in section VII.D.6 would not be solid waste. Non-hazardous secondary materials that remain within the control of the generator and meet these criteria are referred to as legitimate (non-waste) fuel products. The proposed conditions that must be satisfied to qualify as ‘‘under the control of the generator’’ are found in proposed 40 CFR part 241.3. Nevertheless, EPA is seeking comment on whether such secondary materials should be considered solid wastes and thus, be subject to the CAA section 129 requirements if combusted. There are two scenarios where non- hazardous secondary materials used as fuels can be demonstrated to remain within the control of the generator. As such, the proposal consists of two parts in determining whether these secondary materials qualify for being ‘‘under the control of the generator.’’ The first part applies to non-hazardous secondary material generated and used as fuels at the generating facility. For purposes of this proposed criteria, ‘‘generating facility’’ means all contiguous property owned, leased, or otherwise controlled by the secondary material generator, and VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00031 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31874 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules ‘‘secondary material generator’’ means any person whose act or process produces non-hazardous secondary materials at the generating facility. A facility that collects non-hazardous secondary materials from other persons (for example, used tires collected through a collection program) is not the secondary material generator of those materials. This is consistent with the approach taken in the DSW final rule, which specified that a facility that collects hazardous secondary materials from other persons (for example, when mercury-containing equipment is collected through a special collection program), would not be considered the hazardous secondary material generator for purposes of eligibility for the generator-controlled exclusion. See 73 FR at 64715. If a generator hires or contracts with a different company to use the non- hazardous secondary materials at the generator’s facility as fuel, either temporarily or permanently, these materials remain under the control of the generator. However, generators sometimes contract with a second company to collect non-hazardous secondary materials at the generating facility and such materials are subsequently used as fuels in a combustion unit at another facility. In that situation, if the facility that burns the non-hazardous secondary material is not ‘‘within the control of the generator’’ as defined below in the second part of the definition, then the non-hazardous secondary material fuel would be considered a solid waste unless a non- waste determination has been granted pursuant to the petition process. The second part of the proposed definition applies to non-hazardous secondary material generated and used as fuels at a different facility that is controlled by the generator (or if a person as defined in proposed §241.2 controls both the generator and the facility using the fuel in a combustion unit). For purposes of this proposed criteria, ‘‘control’’ means the power to direct the policies of the facility, whether by ownership of stock, voting rights, or otherwise, except that contractors who operate facilities on behalf of a different person as defined in proposed §241.2 shall not be deemed to ‘‘control’’ such facilities. Thus, when a contractor operates two facilities, each of which is owned by a different company, non-hazardous secondary materials generated at the first facility and used as a fuel at the second facility is not considered ‘‘under the control of the generator.’’ We note that the DSW final rule includes a third part of the definition that applies to hazardous secondary materials that are generated pursuant to a written contract between a tolling contractor and a toll manufacturer and legitimately reclaimed by the tolling contractor. For purposes of that exclusion, a tolling contractor is a person who arranges for the production of a product or intermediate made from specified raw or virgin materials through a written contract with a toll manufacturer. The toll manufacturer is the person who produces the product or intermediate made from the specified raw or virgin materials pursuant to a written contract with a tolling contractor. We view this as a very specific type of arrangement where, for example, a chemical manufacturer outsources a step in the manufacturing process to another company (typically a ‘‘batch’’ manufacturer), and then the batch manufacturer sends both the product and the residuals back to the main company (and the residuals are then reclaimed by the main company). Although there are two companies, there is only one manufacturing operation, and the main company keeps control over (and liability for) everything through the tolling contract. We do not believe that tolling contracts are relevant to non-hazardous secondary materials used as fuels in combustion units as we are unaware of these types of contractual arrangements where both products and secondary material fuel are sent to what we are calling tolling contractors. As a result, we are not including this type of arrangement under the proposed definition for non-hazardous secondary material fuels that remain under the control of the generator. However, the Agency requests comments on whether to include this option in the final rule; those persons who provide comments supporting the addition of this option to the final rule should provide specific instances or examples of where non- hazardous secondary materials are managed under tolling arrangements and the frequency that such arrangements are used, and how these arrangements remain ‘‘under the control of the generator.’’ b. Restrictions and Requirements Legitimate Use. Under this proposed rule, non-hazardous secondary materials used as fuels in combustion units that remain under the control of the generator must meet the legitimacy criteria proposed in §241.3(d). To satisfy the legitimacy criteria, the non- hazardous secondary material (non- waste) fuel must be handled as a valuable commodity, have meaningful heating value and be used as a fuel, in a combustion unit that recovers energy, and contain contaminants at levels comparable to those in traditional fuels which the combustion unit is designed to burn. The details of the legitimacy criteria are discussed in Section VII.D.6. of this proposal. Notification. We are not proposing to require facilities that use non-hazardous secondary material fuels within the control of the generator to notify EPA as part of this proposal. We believe this would be duplicative of the CAA 112 regulatory notification and record keeping requirements being proposed for boilers and process heaters today. That proposal would require specific notifications from sources subject to the standards including notifications of compliance status, test results and descriptions of applicable air pollution control devices. In addition, for sources that have made a non-waste self- determination under §241.3, the proposal for boilers and process heaters requires that records be maintained which document how the fuel meets legitimacy criteria and the definition of processing as appropriate. However, we solicit comment on this and specifically request comment on whether the Agency should require, at least initially, if not on a periodic basis, notification and recordkeeping under RCRA by those persons who both generate or combust non-hazardous secondary materials that are not solid wastes, including documentation that explains or provides the basis for the non- hazardous secondary material meeting the legitimacy criteria, and thus, is not a solid waste. 2. Non-Hazardous Secondary Materials Used as Fuel Outside the Control of the Generator Non-hazardous secondary materials used as a fuel in combustion units that are not considered to be managed within the control of the generator would be considered solid wastes unless they have been processed into a legitimate non-waste fuel product (discussed in section VII.D.4. below) or unless a non a non-waste determination has been made pursuant to the proposed petition process (discussed in section VII.D.5. below). This proposed approach differs from the ANPRM approach, which specified that non-hazardous secondary materials, such as used tires collected at tire dealerships and transferred to a third party would not be considered discarded if, for example, they were managed pursuant to state tire collection programs. As previously discussed, comments received from the states suggested that non-hazardous VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00032 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31875 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 55U.S. EPA An Assessment of Environmental Problems Associated With Recycling of Hazardous Secondary Materials (Docket # EPA–HQ–RCRA– 2002–0031–0355), January 2007. 56See 51 FR 21054, June 10, 1986. 57U.S. EPA Scrap Tire Clean-Up Handbook: A Resource for Solid Waste Managers Across the United States EPA–905–B–06–001, January 2006. 58U.S. EPA Description of Non-Hazardous Secondary Material Events that Resulted in Adverse Environmental Impacts (Docket # EPA–HQ–2008– 0329), September 2009. 59U.S. EPA A Study of the Potential Effects of Market Forces on the Management of Hazardous Secondary Materials Intended for Recycling (Docket # EPA–HQ–RCRA–2002–0031–0358), November 2006. While the study focuses on hazardous secondary materials, the underlying economic theory would apply equally to non-hazardous secondary materials. secondary material fuels that are transferred to a third party have entered what is traditionally considered to be the ‘‘waste stream’’ (and have been regulated by the states as wastes) and therefore should appropriately be considered to be solid wastes (e.g., scrap tires) unless/until they are processed into non-waste fuel products. However, the Agency seeks comment on whether the approach described in the ANPRM would be more appropriate. In submitting comments supporting a broader approach, we request that commenters provide the basis for why such secondary materials have not been discarded. When non-hazardous secondary material fuels are transferred to another party, we generally believe that the material is discarded since the generator has relinquished control of the secondary material and the entity receiving such materials may not have the same incentives to manage them as a useful product, which results in the materials being discarded. (Note: As indicated above, the Agency is proposing a petition process to allow any person to demonstrate that non- hazardous secondary material fuels transferred to another party outside the control of the generator have not been discarded, and thus, are not a solid waste. See section VII.D.5. below for details on the petition process.) This lack of incentive to manage as a useful product has been well- documented in the context of hazardous secondary material recycling as evidenced by the results of the environmental problems study performed in support of the DSW final rule.55 (This scenario does not apply to transfers taking place under the transfer- based exclusion for hazardous secondary materials that are generated and then transferred to another company for the purpose of reclamation.) However, this finding also holds true for non-hazardous secondary materials that are used as fuel. For example, the over-accumulation of scrap tires is well known and has resulted in massive piles of discarded tires that have contributed to the overall solid waste management problem due to the threat of fires, such as the Rhinehart Tire Fire Dump,56 and because they provide an ideal breeding ground for mosquitoes and rodents. It is estimated that 275 million tires remained in stockpiles across the United States in 2003 and that approximately 290 million new scrap tires are generated each year.57 Other non-hazardous secondary materials destined for use as a fuel that were accumulated, but then discarded have similarly contributed to the overall solid waste management problem.58 As discussed in the DSW final rule,59 this pattern of discard at off-site, third party reclaimers appears to be a result of inherent differences between commercial recycling and normal manufacturing. As opposed to manufacturing, where the cost of raw materials or intermediates (or inputs) is greater than zero and revenue is generated primarily from the sale of the output, secondary materials recycling, including when used as a fuel, can involve generating revenue primarily from receipt of the secondary materials. Recyclers of secondary materials in this situation may thus respond differently than traditional manufacturers to economic forces and incentives, accumulating more inputs (secondary materials) than can be processed and generating stockpiles with sometimes little incentive to perform actual recycling. However, this pattern of discard does not hold true for materials that are more commodity-like than waste like, such as traditional fuels and non-hazardous secondary materials used as ingredients in manufacturing processes that utilize combustion systems. As previously discussed, traditional fuels have been burned historically as fuels and have been managed as valuable products, are considered unused products and therefore are not solid wastes. Also see discussion in section VIII.D.6.b below that explains EPA’s rationale as to why ingredients that are not managed within the control of the generator are determined not to be discarded. In some cases, a non-hazardous secondary material may be transferred to another entity to be burned for energy and still more closely resemble a product than a waste, despite the fact it is neither a traditional fuel nor has it been processed into a legitimate fuel. In such cases, the Agency has included a petition process where a person may petition EPA for a case-specific determination that the non-hazardous secondary materials are not discarded and therefore not solid wastes. See section VIII.D.5. for a more detailed discussion of the petition process. In the proposed regulatory language, EPA is not specifying whether particular materials are or are not solid wastes. However, as discussed previously, whole tires that originate from tire dealerships and automotive shops (that are overseen by state tire collection oversight programs) would be considered to be discarded unless and until they are processed into TDF that has removed the steel belts and wire, or a case-specific non-waste determination petition is granted. EPA believes tires that are collected from tire dealerships and automotive shops, especially if overseen by a state tire collection oversight program that collects fees and regulates the process under state ‘‘waste’’ authorities, generally meet the plain meaning of discard; such materials can be considered as having been ‘‘discarded’’ by the original owner of the tire. This is further supported by the fact that many state agencies regulate tires as wastes, either pursuant to their solid waste authority or pursuant to statutory authority that specifically addresses the management of used tires (some use both authorities). The level of regulation ranges from state to state, but many states directly regulate used tires, for example, with storage requirements, such as speculative accumulation and fire suppression requirements, up until their final use as a fuel in combustion units. In addition, many states subsidize certain end-use applications, suggesting that used tires, even if managed pursuant to state oversight programs, are discarded materials once they are generated at tire collection points, such as tire dealerships. 3. Non-Hazardous Secondary Materials Used as Ingredients in Combustion Units Non-hazardous secondary materials used as ingredients in combustion units would not be solid wastes provided they satisfy the legitimacy criteria discussed in section VIII.D.6.b below. We are not differentiating between ingredients that are used within the control of the generator from those that are not since we believe that the use of non- hazardous secondary materials as ingredients is considered to be more integral or akin to use in a commercial manufacturing process and thus, these non-hazardous secondary materials VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00033 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31876 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules should not be considered discarded provided they satisfy the legitimacy criteria. 4. Non-Hazardous Secondary Materials Processed Into Non-Waste Fuel/ Ingredient Products EPA is proposing that legitimate fuel or ingredient products that result from the processing of discarded non- hazardous secondary materials are not solid wastes. Of course, the legitimacy criteria specified in section VII.D.6. below must be met. Because the fuel/ ingredient products meeting these legitimacy criteria are, in effect, reclaimed products from a recycling process, EPA considers such materials to be new products that have not been discarded and therefore are not solid wastes. Until the non-hazardous secondary materials have been processed into a non-waste fuel or ingredient product meeting the legitimacy criteria, the discarded non- hazardous secondary material are considered solid wastes and would be subject to all appropriate federal, state and local requirements. Similar to the proposed approach for non-hazardous secondary materials that are used as fuels within the control of the generator, we are not proposing to require facilities that combust non- hazardous secondary materials that have been processed into non-waste fuel/ ingredient products to notify EPA as part of this proposal. We believe this would be duplicative to the CAA 112 regulatory notification and record keeping requirements being proposed for boilers and process heaters today. That proposal would require specific notifications from sources subject to the standards including notifications of compliance status, test results and descriptions of applicable air pollution control devices. In addition, for sources that have made a non-waste determination under 40 CFR 241.3, the proposal for boilers and process heaters requires that records be maintained which document how the fuel meets legitimacy criteria and the definition of processing as appropriate. However, we solicit comment on this and specifically request comment on whether the Agency should require, at least initially, if not on a periodic basis, notification and recordkeeping under RCRA by those persons who both generate or combust non-hazardous secondary materials that are not solid wastes, including documentation that explains or provides the basis for the non- hazardous secondary material meeting the legitimacy criteria, and thus, is not a solid waste. a. Proposed Definition of Processing. The proposed definition of processing means any operations that transform discarded non-hazardous secondary material into a new fuel or new ingredient product. Minimal operations, such as operations that result only in modifying the size of the material by shredding, do not constitute processing for purposes of this definition. Processing includes, but is not limited to, operations that: remove or destroy contaminants; significantly improve the fuel characteristics of the material, e.g., sizing or drying the material in combination with other operations; chemically improve the as-fired energy content; and improve the ingredient characteristics. While today’s rule proposes a definition of operations that constitute processing, the level of processing that is necessary to render a discarded non-hazardous secondary material into a non-waste product is dependent on the material. We note, however, that discarded non-hazardous secondary materials that are not processed or minimally processed (as discussed above i.e., processed in a manner that does not meet our definition of processing) would be considered a waste-derived fuel or ingredient, and thus a solid waste, no matter how legitimate their use is as a fuel or ingredient. In addition, non- hazardous secondary materials that are processed and used as fuels or ingredients in combustion units, but do not meet the legitimacy criteria, would be considered to be sham use and thus a solid waste. The Agency seeks comment on the proposed definition of processing, including whether such definition provides sufficient clarity that it can be implemented under the self-implementing provision in today’s proposed rule (this approach is discussed further in this section). b. Rationale for Processing Discarded Material Into Non-Waste Products. Today’s proposed rule identifies circumstances where materials that have been discarded in the first instance, and are thus solid wastes, can be rendered into new non-waste products through legitimate processing consistent with the definition outlined above. The basic principle that must be satisfied is that the discarded material must undergo sufficient processing that produces either a new fuel or ingredient product. The new product must have properties that provide the end user the assurance that the material consistently satisfies the fuel/ingredient product criteria based on the type of combustion unit the secondary material is used in (e.g., as a fuel in a boiler or as an ingredient in a cement kiln). The principle that products can be produced from a waste is common to industrial processes and commercial recycling markets. Newspaper and aluminum cans discarded by consumers are then collected, sorted and processed into new recycled paper and aluminum products that are not considered solid waste. Collected plastic is generally sent to a reclaimer, who will sort, grind, and clean the plastic. The cleaned and sorted plastic is sent to a manufacturer who will use it as feedstock. These are clear examples where discarded materials are processed into legitimate non-waste products. Recycled fuel products are no different from recycled paper and aluminum cans with respect to discard. If non-hazardous secondary materials that are discarded by being abandoned, disposed of or thrown away, but are later collected, segregated, and processed into a homogenous fuel product that is marketed and sold as a valuable commodity and are no different that traditional fuels used today, then they should no longer be considered solid waste, just as recycled paper is not a solid waste. There are other examples beyond consumer recycled materials where discarded materials are processed into new products. These examples include specific exclusions from the hazardous waste regulations, which provide insight into how secondary materials can be processed into valuable products. For instance, discarded spent solvents are commonly recycled via distillation into legitimate, newly usable solvents. These regenerated solvents are clearly considered to be products, not wastes. See 50 FR 634, January 4, 1985. Scrap metal that has been discarded is another example of a non-hazardous secondary material that is processed into a non- waste. (EPA specifically exempted scrap metal that has been processed from the definition of solid waste (see 261.4(a)(13).) For scrap metal to be considered ‘‘processed,’’ it must have been ‘‘manually or physically altered to either separate it into distinct materials to enhance the economic value or improve the handling of these materials. Processed scrap metal includes * * * scrap metal which has been baled, shredded, chopped, crushed, flattened, cut, melted, or separated by metal type (i.e. sorted) * * *’’ (see 40 CFR 261.1(c)(10)). We believe this is a good example of where the level of processing necessary to convert a waste material to a non-waste material is dependent on the material itself. VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00034 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31877 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 60Once used oil is claimed to be on-spec and the marketer complies with the requirements for analysis and record retention, notification, and record tracking shipment to on-specification burners, it is no longer subject to the management standards. 61As discussed previously, today’s proposal only addresses non-hazardous secondary materials that are used in combustion process, and not in other applications. 62We note that most cement kilns use whole tires as fuels, as opposed to TDF chips, because their process does not require the TDF to be in the form of small chips to use it as a fuel, and does not require removal of the metal (since they use the metal as an ingredient). Under today’s proposal, cement kilns that burn whole tires would be subject to the CAA section 129 requirements, unless the tires were processed to produce TDF or a non-waste determination was issued by EPA regarding the burning of whole tires. 63With regard to the legitimacy criteria discussed in Section VII.B.3, the heating value of scrap tires (12,000 Btu/lb to 16,000 Btu/lb) is the highest of all secondary materials, except used oil (17,800 Btu/ lb), and higher than typical coal values. Contaminants of potential concern have been measured for both materials: Mercury is below detectable levels for TDF, and average 0.11 ppm for coal; barium is also below detectable levels in TDF; cadmium, chromium, lead and manganese levels are comparable; zinc is present in higher concentrations in TDF than coal. Off-spec used oil is another example of a secondary material which we believe is discarded, but can be processed into a non-waste product (see section VII.C.5.d.). Once used oil is determined to be on-spec, we do not view it to be a solid waste since it is no longer regulated under the used oil management standards of 40 CFR part 279 and can be managed as a traditional fuel.60 One of the difficulties the Agency faces with determining whether non- waste fuels can be processed from discarded materials is that the combustion of materials is commonly associated with disposal, whether it is waste disposal in incinerators or waste disposal in energy recovery devices (e.g., municipal waste combustors that recover energy by producing electricity). Therefore, many equate the burning of any secondary material to discard, as some commenters have argued. This approach does not take into account that the secondary material has in fact been produced in a process that uses the discarded material as a feed stream to produce a safe fuel product that is a valuable commodity and sold in the marketplace no differently than traditional fuels. We view such an approach being a common sense interpretation of the statutory definition of solid waste under RCRA. Again, fuel produced from discarded non- hazardous secondary materials should not be considered solid waste just as recycled newspapers are not considered solid waste, since the material has been processed or ‘‘manufactured’’ into a new fuel product. The use of these energy containing secondary materials can be an effective substitute for traditional fuels. Such materials can provide economic efficiencies due to lower overall resource use, while still protecting human health and the environment. Another difficulty the Agency faces is the misconception that discarded material that is burned, either for destruction or energy recovery, by definition has high levels of contaminants. We do not believe this is the case for many of the non-hazardous secondary materials we are assessing. The manner in which the secondary material is managed is a key factor that determines discard (abandoned, disposed of, or thrown away); contaminant levels are part of that consideration, such that if a secondary material has high levels of contaminants, it would be considered sham recycling, which is one type of way a material can be ‘‘disposed of.’’ Clean materials can be discarded just like contaminated materials can. This, combined with the perception that combustion of secondary materials is equated to discard, results in the perception that there needs to be a very high threshold with respect to the level of processing that must take place to render a discarded material into a non- waste product. We believe, however, that a strict, but appropriate level of processing is necessary which is reflected in the processing definition outlined in today’s proposed rule. We also note that in order for any secondary material to be considered a non-waste fuel, it must contain contaminants at levels that are comparable to traditional fuels in use today. To put this into context, we believe it would help to include examples of processing of discarded non-hazardous secondary materials—those which we believe are clearly adequate processing to render the material into a non-waste fuel or ingredient product in accordance with the definition of processing in §241.2 and those that do not. c. Examples of Adequate Processing Examples of non-hazardous secondary materials that have been discarded, but can be processed into a non-waste fuel or ingredient product include, but are not limited to, used tires, solid waste processed in gasifiers to produce synthesis gas, off-spec used oil (discussed above), sewage sludge processed into pellets, painted wood, and coal fines and biomasss processed into pellets with the impurities removed. Each of these are described in more detail below. Used Tires. EPA views used tire processers as facilities that take solid waste that can produce valuable non- waste products. Used tires undergo various processing steps to meet certain specifications that are necessary for a particular end use, whether it be for use as TDF, or for use in other non- combustion applications, such as ground rubber applications (e.g., for use in sidewalks).61 Used tire processors typically enter into contracts with the end users of these tire derived products that specify that the processed tires meet certain specifications (i.e. size of tire pieces, wire content) to ensure the material consistently meets the needs of that particular end use. This is common for TDF. Used tires are often processed by shredding and removing dirt or other contaminants to produce TDF. Processing scrap tires into TDF can involve two physical processing steps: chipping/shredding (usually ranging in size from 1 to 4 inches) and (in some cases) metal removal, with the amount of metal in TDF varying depending on how much of the tires have been processed. For some units, such as cement kilns, metal in the wire can be used in the manufacturing process.62 However, most other units benefit from TDF that has been processed to minimize the amount of metal and improve heating efficiency. EPA considers used tires that have been shredded/chipped into TDF and with the metal belts or wire removed, to meet the definition of processing discussed above. Thus, used tires that have been shredded/chipped without the removal of the metal belts or wire would not be considered to have been sufficiently processed, and any TDF that is generated in such a fashion would be considered a waste-derived fuel. Removing the metal belts or wire will help reduce metal contaminants in the emissions and ash, and may improve the burning characteristics for some uses of the TDF. As is the case for all types of solid fuel, proper characterization of the size and composition of TDF are important factors that combustion unit operators assess to determine if TDF is a suitable fuel for their specific combustion unit design.63 For example, ASTM Standard 6700–01, describes standard practices for using TDF as fuels, and also specifies sampling and analysis methods and procedures that apply to TDF that cover composition, and fuel characterization analyses. The standards also address the size of the tire pieces VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00035 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31878 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 64Evergreen Energy Company Web site. http:// www.evgenergy.com/k_fuel.php. and metal content in order to optimize combustion. The standards for metals range from wire free, to relatively wire free to no wire removed. To meet the processing definition for combusting scrap tires, those materials should have the metal belts or wire removed consistent with the ASTM standard for relatively wire free. However, as noted in footnote 62, certain types of combustion units, such as cement kilns also use the wire in the tire as an ingredient to producing cement clinker. Therefore, we are soliciting comment on whether to adopt an additional definition for processing that would not require the metal belts or wire to be removed for those combustion units, such as cement kilns where the metals serve a useful purpose in the process of making clinker. Syngas Produced from Gasification of Solid Waste. Although not specifically discussed in the ANPRM, synthesis gas (or syngas as it is commonly referred) produced from the gasification of solid waste is a material that can also meet the requirements of a fuel product produced from processing discarded non-hazardous secondary materials, provided the syngas has been adequately processed to remove contaminants. A variety of solid waste streams are available for conversion to energy, including conversion through gasification technologies. Gasification is a chemical production process that converts carbonaceous material into a synthesis gas that can be used for energy production (or as a building block for other chemical manufacturing processes). In general, gasification systems are designed to react carbon- containing materials and steam at high temperatures to produce a synthesis gas composed mainly of carbon monoxide and hydrogen. Gasification systems include two basic components. The first is the reactor or gasifier and the second is a gas cleanup or polishing system used to remove various contaminants from the raw (un-polished) synthesis gas. At a minimum, syngas cleanup generally includes removal of sulfur and metals. These two components work together producing a synthesis gas that can be used as a fuel in a combustion turbine. Other Non-Hazardous Secondary Materials That are Processed. Sewage sludge can be processed into fuel pellets by biosolid drying that destroys pathogens and bacteria. Specifically, raw sewage sludge is moved to digesters where microbes decompose the organic solids. The resulting biosludge is pressed with wide fabric belts into sheets and water is removed. This sludge cake is then baked in ‘‘tumble- drying’’ ovens that destroy the pathogens and bacteria, removing any remaining water, and rotate the sludge into the final pelletized product. Although we consider this to meet our definition of processing, the fuel pellets would still have to meet the legitimacy criteria to be considered a non-waste fuel. As discussed in section VII.C.5.f., we generally believe sewage sludge itself has contaminant levels that are higher than traditional fuels in use today, and thus would not satisfy the contaminant part of the legitimacy criteria. Wood with lead-based paint that is shaved to remove the lead-based paint is another example of processing a discarded non-hazardous secondary material to produce a legitimate product; in this case, the underlying wood can be used as a non-waste, traditional fuel, and the lead-based paint can be safely disposed of or sent for lead recovery. Coal fines, biomass, and other materials can be mixed and processed into pellets (or other forms) that have the consistency and handling characteristics of coal. For example, the K-Fuel process employs heat and pressure to transform coal into a cleaner, more efficient fuel by removing water and polluting impurities, thus increasing combustion efficiency. When applied to different lower-rank sub- bituminous and lignite coals, the K-Fuel process removes, on average, almost 70 percent of the coal’s elemental mercury.64 In the examples above, we view the non-hazardous secondary materials to have been sufficiently processed to produce a fuel product that would not be a solid waste if it met the legitimacy criteria specified in section VII.D.6; however, as noted previously, the non- hazardous secondary materials would be considered solid wastes prior to processing and would be subject to appropriate federal, state, and local requirements. d. Examples of Minimal Processing That Would Not Meet Proposed Definition of Processing. Sewage sludge, and other non- hazardous secondary materials that have a high moisture content can be dewatered to effectively increase the Btu/lb of the material prior to burning as a fuel. We do not consider dewatering, by itself, to meet our definition of adequate or sufficient processing. For example, dewatering sewage sludge would likely be required processing as part of normal waste management activities (e.g., prior to landfilling, or prior to burning the sludge for disposal in an incinerator). As such, we do not view this to be sufficient processing to convert discarded materials into non-waste fuel products. Whole tires that are, for example, removed from waste tire piles or collected and managed pursuant to state tire collection programs, that are marketed to cement kilns or other industrial furnaces and used as fuels absent processing into what we consider processed TDF would be another example of insufficient processing to produce a non-waste fuel. However, we are also requesting comment on whether discarded materials that have been collected and that otherwise have not been processed (as defined in this proposal), should not be considered solid wastes if they are indistinguishable in all relevant aspects from a product (again, of course they must be legitimate), and such whole tires are marketed to cement kilns or other industrial furnaces and are used as fuels. For example, if a discarded non- hazardous secondary material that has not been processed based on our proposed definition can be shown to be no different than other non-waste fuels in use today, could that secondary material be considered a non-waste fuel/ ingredient product even though it was discarded in the first instance? Commenters should provide the rationale supporting this approach. e. Alternative Approach for Addressing Non-Hazardous Secondary Materials That Are Processed Into Non-Waste Fuels or Ingredients As proposed, this particular provision is self-implementing, where each person would make the determination whether or not the non-hazardous secondary material has been ‘‘sufficiently processed’’ to produce a non-waste fuel or ingredient. The Agency believes that such an approach is appropriate considering the large number of non- hazardous secondary materials that are generated that may be processed into a non-waste fuel or ingredient. However, there is also the question of whether the definition of processing is sufficiently clear so that the regulated community can appropriately apply the definition. Therefore, the Agency is also considering and requests comment on whether this particular provision should be addressed through the non-waste determination process under §241.3(c) (rather than as a self-implementing provision), such that the Agency would VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00036 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31879 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 6540 CFR 260.20 allows any person to petition the Administrator of EPA to modify or revoke any provision of the hazardous waste rules. A similar ‘‘general rulemaking authority’’ could also be promulgated under RCRA subtitle D. consider and evaluate each type of processing activity on a case-by-case basis and approve it before the processed fuel or ingredient would be considered a non-waste fuel or ingredient. We also request comment on whether the Agency should promulgate a general rulemaking provision, similar to 40 CFR 260.20,65 that would allow EPA to evaluate various processing activities generally, as opposed to on a site-by-site basis, such that the Agency would identify in the regulations which processing activities would produce a non-waste fuel or ingredient. While such an approach would put a much greater burden on EPA, it would also provide greater certainty to the regulated community as to which non- hazardous secondary materials have been sufficiently processed to produce a non-waste fuel or ingredient. 5. Non-Waste Determination Process This proposal would establish a non- waste determination process that provides persons with an administrative process for receiving a formal determination from EPA that non- hazardous secondary material fuel that has not been managed within the control of the generator has not been discarded, and is indistinguishable in all relevant aspects from a fuel product, and thus, is not a solid waste when used as a fuel in a combustion unit. For example, a facility that is not affiliated with the generator of the non-hazardous secondary material fuel (and thus is ‘‘outside the control of the generator’’) can petition EPA to determine that the secondary material they burn as fuel is not a solid waste because the material has not been discarded and is indistinguishable in all relevant aspects from a fuel. This proposed process would be voluntary. The non-waste determination process would require the petitioner to request such a case-specific non-waste determination from EPA. Any petition that is submitted to EPA that requests that the non-hazardous secondary material be considered a non-waste fuel would need to demonstrate that the material has not been discarded in the first instance, as well as describe how the non-hazardous secondary material satisfies the five proposed criteria outlined in §241.3(c). To demonstrate that the non- hazardous secondary material used a fuel has not been discarded in the first instance, the petitioner would need to demonstrate that the non-hazardous secondary material was not initially abandoned or thrown away by the generator of the material. It may not always be clear whether secondary materials would be considered to be discarded in the first instance. For example, secondary material retrieved from a landfill or tires retrieved from waste tire piles would be considered materials that are discarded in the first instance. We may not, however, consider used tires collected from tire dealerships and managed pursuant to state tire collection programs to be discarded in the first instance, depending on how they are managed. After demonstrating that the material has not been discarded in the first instance, the petitioner must then demonstrate that the material is indistinguishable in all relevant aspects from a fuel product by showing that it satisfies the following five criteria: (1) Whether market participants handle the non-hazardous secondary material as a fuel rather than a waste; (2) whether the chemical and physical identify of the non-hazardous secondary material is comparable to a commercial fuel; (3) whether the capacity of the market would use the non-hazardous secondary material in a reasonable timeframe; (4) whether the constituents in the non- hazardous secondary material are released to the air, water or land from the point of generation to the combustion of the secondary material at levels comparable to what would otherwise be released from traditional fuels; and (5) other relevant factors. Specifically, the first criterion for a non-waste determination is whether market participants handle the non- hazardous secondary material as a fuel rather than a solid waste. This would include consideration of likely markets for the non-hazardous secondary materials used as fuels (e.g., based on the current positive value of the secondary material, stability of demand, and any contractual arrangements). This evaluation of market participation is a key from a fuel products standpoint rather than as negatively-valued wastes. The second criterion for a non-waste determination is the chemical and physical identity of the non-hazardous secondary material and whether it is comparable to commercial fuels. This ‘‘identity principle’’ is a key factor that the Court of Appeals for the DC Circuit cited in Safe Foods in determining whether a material is indistinguishable from a product. It is important to note that the identity of a material can be comparable to a fuel product without being identical. However, to qualify for a non-waste determination, any differences between the non-hazardous secondary material in question and the commercial fuel should not be significant from a health and environmental risk perspective. The third criterion for making a non- waste determination is the capacity of the market to use the non-hazardous secondary material as a fuel in combustion units in a reasonable time frame and ensure that it will not be abandoned. For the non-waste determination, a person will need to provide sufficient information about the non-hazardous secondary material and the market demand for it to demonstrate that such non-hazardous secondary materials will in fact be used as a fuel in combustion units in a reasonable time frame. EPA is not proposing to explicitly define ‘‘reasonable time frame’’ because such time frames could vary according to the non-hazardous secondary material and industry involved, and therefore determining this time frame should be made on a case- specific basis. However, the Agency solicits comments on whether it should propose a specific timeframe as part of this criterion. The fourth criterion for a non-waste determination is whether the constituents in the non-hazardous secondary material fuels are released to the air, water, or land water at concentrations comparable to what would otherwise be released from traditional fuels. The process that the Agency would be considering would encompass the point of generation of the material, management and storage prior to use through combustion and the end use of the secondary material. The Agency believes that to the extent the constituents are an extension of the original secondary material, their release to the environment is a possible indicator of risk and discard. The Agency recognizes that combustion using traditional fuels also result in a certain level of release and, in evaluating this criterion, would not deny a non-waste determination if the increase in release is not significant from either a statistical or a health and environmental risk perspective. However, when relatively high levels of the constituents in the non-hazardous secondary material are released to the environment in looking from the point of generation of the secondary material to its combustion, then that may be an indication that the non-hazardous secondary material is not being handled as a commercial fuel. The fifth and final criterion for a non- waste determination includes any other relevant factors that demonstrate that the non-hazardous secondary material is VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00037 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31880 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 66We note, however, that non-hazardous secondary materials that satisfy the legitimacy criteria would still be considered a solid waste if they were discarded (abandoned, disposed of, or thrown away), unless they were processed into legitimate non-waste fuel products. not a solid waste. This catch-all criterion is intended to allow the person to provide any case-specific information considered important and relevant in making the case that its non-hazardous secondary material used as a fuel in a combustion unit is not a solid waste. Any non-hazardous secondary material used as a fuel must also satisfy our proposed legitimacy criteria in order to be considered a non-waste fuel. In order for a non-waste determination to be granted, the applicant must also therefore show that the material satisfies the proposed legitimacy criteria. We note that there is overlap between the legitimacy criteria and the five petition criteria discussed above. Thus, the same rationale used to demonstrate that the non-hazardous secondary material contains contaminants at levels comparable to traditional fuels in combination with the argument that such secondary material contains meaningful heating value can be used to satisfy petition criterion number 2 above. Similarly, the rationale used to demonstrate that the secondary material contains contaminants at levels comparable to traditional fuels can be used as the rationale for petition criterion number 4 above. Non-Waste Determination Process. EPA is proposing that the process for the non-waste determination be similar to that for the solid waste variances found in §260.33, except that such requests can only be addressed by EPA. In order to obtain a non-waste determination, a facility that manages non-hazardous secondary materials that would otherwise be regulated must apply to the Regional Administrator per the procedures described in proposed §241.3(c). The application must address the relevant criteria discussed above. The Regional Administrator for the EPA Region where the facility combusting the material will evaluate the application and issue a draft notice tentatively granting or denying the application. Notification of this tentative decision will be provided by newspaper advertisement or radio broadcast in the locality where the recycler is located. The Regional Administrator will accept comment on the tentative decision for at least 30 days, and may also hold a public hearing upon request or at his discretion. The Regional Administrator will issue a final decision after receipt of comments and after the hearing (if any). The Agency recognizes that many states have programs in place to make such determinations under state statute, and EPA would support the states to also make such determinations—that is, allow the states to act on behalf of EPA in making such case-specific determinations. Therefore, we are specifically soliciting comment as to whether the Agency can (and if so) should allow a state, for example, under a state’s beneficial use program, to also make case-specific determinations without EPA’s approval. We note that under the Revisions to the Definition of Solid Waste Rule (70 FR 64668), a non- waste determination may be granted by the state if the state is either authorized for this provision or if the following conditions are met: (1) The state determines the hazardous secondary material meets the applicable criteria for the non-waste determination; (2) the state requests that EPA review its determination; and (3) EPA approves the state determination. Should EPA allow this type of non-waste determination process in determining whether or not such non-hazardous secondary material is or is not a solid waste? We note that states may submit these determinations on behalf of the petitioner for EPA to evaluate under the proposed non-waste determination criteria in proposed §241.3(c)(1). If EPA determines through the petition process that the secondary material in the state determinations are not solid waste, then they would not be subject to the CAA section 129 standards, but instead would be subject to the CAA section 112 standards. Conversely, EPA may make a non-waste determination for non- hazardous secondary materials under the Federal regulations that still remains subject to the state solid waste regulations. After a formal non-waste determination has been granted, if a change occurs that affects how a non- hazardous secondary material meets the relevant criteria contained in proposed §241.3(c)(1), persons must re-apply to the Regional Administrator for a formal determination that the non-hazardous secondary material continues to meet the relevant criteria and is not discarded and therefore, not a solid waste. 6. Legitimacy Criteria a. Legitimacy Criteria for Fuels. This notice is proposing that non-hazardous secondary materials used as fuels in combustion units must meet the legitimacy criteria specified in proposed §241.3(d)(1) in order to be considered a non-waste fuel.66 To meet the fuel legitimacy criteria, the non-hazardous secondary material must be handled as a valuable commodity, have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy, and contain contaminants at levels comparable to those in traditional fuels which the combustion unit is designed to burn. These criteria are discussed below. Manage as a Valuable Commodity. We are proposing to require that non- hazardous secondary materials used as fuels be managed as valuable commodities, including being stored for a reasonable timeframe. See proposed 241.3(d)(1)(i). Where there is an analogous fuel, the secondary material used as a fuel must be managed in a manner consistent with the management of the analogous fuel or otherwise be adequately contained so as to prevent releases to the environment. Where there is no analogous fuel, the secondary material must be adequately contained so as to prevent releases to the environment. An ‘‘analogous fuel’’ is a traditional fuel for which the non- hazardous secondary material substitutes and which serves the same function and has similar physical and chemical properties as the non- hazardous secondary material. With respect to how long a non- hazardous secondary material can be stored before the material is not considered to be ‘‘managed as a valuable commodity,’’ we are not specifying a specific timeframe, but requiring that the non-hazardous secondary material be stored for a reasonable timeframe. EPA is not proposing to specifically define ‘‘reasonable timeframe’’ because such timeframes could vary according to the non-hazardous secondary material and industry involved. On the other hand, the Agency also recognizes that with this flexibility, also comes the potential for non-hazardous secondary materials to be over-accumulated, which has been demonstrated to be a problem with hazardous secondary materials. It also could raise questions from an implementation standpoint since the question of ‘‘reasonable timeframe’’ may differ depending on each person’s perspective. Thus, while we think that ‘‘reasonable timeframe’’ is an appropriate standard, considering the large number of non-hazardous materials that may be subject to this rule, and is flexible enough to allow accumulation to be cost-effective, the Agency solicits comment on whether it should define a specific timeframe or range of timeframes as part of this criterion. For example, one approach is to adopt the speculative accumulation provision (see 40 CFR 261.1(c)(8)) that VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00038 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31881 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 67Examples of materials that are adequately contained would include liquid fuels stored in a tank. Examples of other hazards include tire fires resulting from improper storage of scrap tires (see section VII.D.2.). 68See October 30, 2008; 73 FR 64681. 69We note that incinerators that burn waste for purposes of destruction that have a waste heat recovery boiler would not be considered a combustion unit that satisfies this legitimacy criterion. is defined in the hazardous waste regulations for determining how much secondary material must be recycled within a specific timeframe before the material is considered to have been discarded. Another approach would be for the Agency to determine how long fuels are generally held before they are used, and adopt such a standard. To this end, the Agency specifically solicits comment on the time period or range of time periods that fossil fuels are typically held before they are used as a fuel. We are proposing that this legitimacy factor apply to both the nonhazardous secondary materials burned under the generator-controlled exclusion, as well as to materials that have been processed into a product fuel. For the generator- controlled provision, the non-hazardous secondary material must be managed as a valuable commodity upon generation through its end use as a fuel—that is, from the initial point of generation of the non-hazardous secondary material to the time it is actually burned as a fuel either on-site or at another facility that is under the control of the generator. For non-hazardous secondary materials that are processed to produce a fuel product, the processed material must be managed as a valuable product from the point that it is first produced through its end use. As noted previously, before the fuel product is produced, the non-hazardous secondary materials are solid wastes, and must comply with any federal, state, or local requirements. This criterion requires that the non- hazardous secondary material be managed appropriately before its end use as a fuel. In EPA’s view, a company will value non-hazardous secondary materials used as fuels that provide an important contribution and, therefore, will manage those secondary materials in a manner consistent with how it manages traditional fuels. If, on the other hand, a company does not manage the non-hazardous secondary material as it would a traditional fuel, that behavior may indicate that the non- hazardous secondary material is being discarded. This factor addresses the management of non-hazardous secondary materials used as fuels in two distinct situations. The first situation is when the non- hazardous secondary material is analogous to a traditional fuel that otherwise could be burned. In this case, the non-hazardous secondary material must be managed prior to use as a fuel similarly to the way traditional fuels are managed or otherwise must be adequately contained so as to prevent releases to the environment. For example, for liquid non-hazardous secondary materials that are used as a fuel that are similar to liquid fossil fuels, the Agency would expect that such non-hazardous secondary materials would be managed in tanks or similar type devices to control the release of the secondary materials. The Agency would also expect that the types of controls that would typically be part of a tank or similar type device for fossil fuels would also be part of any tank system that is used to manage non- hazardous secondary material. The second situation the factor addresses is the case where there is no analogous traditional fuel that otherwise could be burned. This could be either because the process is designed around a particular non-hazardous secondary material fuel, or because physical or chemical differences between the secondary material and the traditional fuel are too significant for them to be considered ‘‘analogous.’’ Non-hazardous secondary materials that have significantly different physical or chemical properties when compared to traditional fuels would not be considered analogous even if they serve the same function because it may not be appropriate to manage them in the same way. In this situation, the non- hazardous secondary material would have to be adequately contained so as to prevent releases to the environment for this factor to be met. A non-hazardous secondary material is ‘‘adequately contained’’ if it is stored in a manner that both adequately prevents releases or other hazards to human health and the environment, considering the nature and toxicity of the secondary material.67 We note that this definition of ‘‘contained’’ differs slightly from the description used in the DSW final rule preamble, which defined ‘‘contained’’ to mean placing the material in a unit that controls the movement of that material out of the unit.68 We believe this slightly revised definition is appropriate because of the wide range of non- hazardous secondary materials that are used as fuels, some of which may not need to be ‘‘contained’’ in a dedicated storage unit. However, the Agency solicits comment on this aspect of this criterion, including whether a ‘‘contained’’ standard, which is a general performance standard, provides sufficient direction to the regulated community. Other approaches that EPA is considering is whether to provide a more specific definition of ‘‘contained’’ in the rules, or whether the Agency should include specific technical standards or limit the types of units that such non-hazardous secondary materials may be managed, in order for them to be considered to be ‘‘managed as a valuable commodity.’’ The definition of legitimacy in the DSW final rule required that this factor be considered, but not necessarily met. Under that rule, the Agency was aware of situations in which the contained factor is not met, but the secondary material is still being managed as a valuable commodity. One example given was a hazardous secondary material that is a powder-like material that is shipped in a woven super sack and stored in an indoor containment area that has an analogous raw material that is shipped and stored in drums. A strict reading of this factor may determine that the hazardous secondary material is not being managed in a manner consistent with the analogous secondary material even if the differences in management are not actually impacting the likelihood of a release. This proposal includes a requirement for analogous raw materials to ‘‘*** be managed in a manner consistent with the analogous fuel or otherwise be adequately contained to prevent releases to the environment’’ (§241.3(d)(1)(i)(B)). This is similar to the DSW final rule provision, but is also different in that the requirement in today’s proposal has to be met (not just considered). Thus, today’s proposal would require that this factor be met (not optional) because we believe that in all situations where the factors in §241.3(d)(1)(i) are not met, the material would be discarded. Meaningful Heating Value and Use as a Fuel. We are proposing that non- hazardous secondary materials have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy. See proposed §241.3(d)(1)(ii). We are proposing the requirement for the non-hazardous secondary material to be used as a fuel in a combustion unit that recovers energy for two reasons. First, we want to be clear that non- hazardous secondary materials having a meaningful heating value, but that are not burned in a combustion device specifically for energy recovery (e.g., are burned in an incinerator) are solid wastes.69 We recognize that incinerators and similar type units may accept non- hazardous secondary materials with a meaningful heating value and use that VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00039 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31882 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules fuel value to limit the other types of fuels it needs to burn. However, the intent of an incinerator, and similar type units, is to destroy wastes, and thus, such non-hazardous secondary materials that are burned in such units are considered discarded, and thus a solid waste. Second, since these provisions are intended to apply only to non-hazardous secondary materials that have a specific end use (in this case, use as a fuel in an energy recovery device), we believe it appropriate to highlight that point by adding that restriction directly to this legitimacy criteria. With respect to the requirement that the non-hazardous secondary material have a meaningful heating value, in the context of the hazardous waste regulations, EPA addressed this concept—that is, whether a hazardous secondary material has an adequate, meaningful heating value, in the so- called ‘‘comparable fuels’’ rule (63 FR 33781) by defining it with a benchmark Btu content of 5,000 Btu/lb. EPA has also previously stated that industrial furnaces (i.e., cement kilns and industrial boilers) burning hazardous wastes with an energy value greater than 5,000 Btu/lb may generally be said to be burning for energy recovery; however, we have also indicated that hazardous wastes with a lower Btu content could conceivably be burned for energy recovery due to the devices’ general efficiency of combustion. ‘‘Thus, the 5,000 Btu level is not an absolute measure of burning for energy recovery ***’’ (see 62 FR 24251, May 2, 1997). We believe these same concepts may also be appropriate in determining whether non-hazardous secondary materials have a meaningful heating value since traditional fuels have a range of heating values in general from 4,000 to 23,000 Btu/lb, and since we recognize that new technologies may be developed in the future that can cost- effectively produce energy from secondary materials with lower energy content. As a result, for purposes of meeting the legitimacy criteria for fuels, we would consider non-hazardous secondary materials with an energy value greater than 5,000 Btu/lb, as-fired, to have a meaningful heating value, and satisfy this legitimacy criterion. For facilities with energy recovery units that use non-hazardous secondary materials as fuels with an energy content lower than 5,000 Btu/lb, as fired, it may also be appropriate to allow a person to demonstrate that a meaningful heating value is derived from the non-hazardous secondary material if the energy recovery unit can cost-effectively recover meaningful energy from the non-hazardous secondary materials used as fuels. Factors that may be important in determining whether an energy recovery unit can cost-effectively recover energy from the non-hazardous secondary material include, but are not limited to, whether the facility encounters a cost savings due to not having to purchase significant amounts of traditional fuels they otherwise would need, whether they are purchasing the non-hazardous secondary material to use as a fuel, whether the secondary material they are burning can self-sustain combustion, and whether their operation produces energy that is sold for a profit (e.g., a utility boiler that is dedicated to burning a specific type of non- hazardous secondary material that is below 5,000 Btu/lb could show that their operation produces electricity that is sold for a profit). However, the Agency requests comment on whether it should promulgate a bright-line test for determining what is considered a meaningful heating value in an effort to provide greater certainty to both the regulated community and regulatory officials. For example, the Agency could establish 5,000 Btu/lb or some other value as the bright-line test. Commenters that suggest that the Agency establish a bright-line test should indicate what value the Agency should select, as well as the basis or rationale for selecting that value. We also request comment on whether we should identify a Btu/lb cutoff below which the Agency would assume that the non-hazardous secondary material is burned for destruction as opposed to energy recovery. Under this approach, non-hazardous secondary materials between this lower level and 5,000 Btu/ lb (assuming there is a difference) could pass this criterion provided the facility demonstrates the energy recovery unit can cost-effectively recover meaningful energy from the non-hazardous secondary materials used as fuels. EPA views this proposed legitimacy criterion to encompass the useful contribution and valuable product legitimacy factors used to evaluate hazardous secondary materials in the DSW final rule. In that rule, with respect to useful contribution, EPA said that legitimate recycling must involve a hazardous secondary material that provides a useful contribution to the recycling process or to a product of the recycling process. See §260.43(b)(1). This factor expresses the principle that the non-hazardous secondary materials should contribute value to the manufacturing process—legitimate use is not occurring if the secondary materials being used do not add anything to the process. This factor is intended to prevent the practice of using secondary materials in a manufacturing operation simply as a means of disposing or discarding them. We believe that non-hazardous secondary materials that are used as a fuel in a combustion unit that have meaningful heating value provide a useful contribution. With respect to the other mandatory legitimacy factor, the DSW final rule stated the recycling process must produce a valuable product or intermediate. The product or intermediate is valuable if it is (i) sold to a third party or (ii) used by the recycler or the generator as an effective substitute for a commercial product or as an ingredient or intermediate in an industrial process.’’ See §260.43(b)(2). This factor expresses the principle that the secondary material should be a material of value, as demonstrated by someone purchasing the material, or using it as an effective substitute for a commercial product that it would otherwise have to buy or obtain for its industrial process. We believe non- hazardous secondary materials that have meaningful heating value that are used as fuels in combustion units are valuable products since they would be replacing traditional fuels that otherwise would have to be burned. Contaminant Levels. We are proposing a legitimacy criterion under which non-hazardous secondary materials used as fuels in combustion units must contain contaminants at levels that are comparable to those in traditional fuel products which the combustion unit is designed to burn (e.g., cellulosic biomass, fossil fuels and their derivatives, as identified elsewhere in this preamble). See proposed §241.3(d)(1)(iii). This criterion is important to ensure that a non- hazardous secondary material being used as a fuel is not being combusted or otherwise released to the environment wholly or in part for the purpose of disposing of or discarding of unwanted materials. Combustion of non-hazardous secondary material with elevated levels of contaminants results in the contaminants being discarded either through incineration, or by being released to the environment. We also believe that requiring that the secondary material have contaminants at levels comparable to traditional fuels would ensure that the burning of any secondary materials in combustion units will not have increased releases to the environment that could impact the health and environment of the local community. Thus, ensuring that the level of contaminants in the non- VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00040 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31883 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 70See 40 CFR 261.38 as an example of maximum contaminant levels EPA has promulgated to determine whether a material is a comparable fuel for purposes of EPA’s subtitle C hazardous waste regulations. hazardous secondary material is comparable would be the most protective of human health and the environment. We are proposing to define the term ‘‘contaminants’’ to mean the HAP listed under CAA section 112(b), as well as the nine pollutants required to be regulated under CAA section 129. We believe this is reasonable because this legitimacy criterion is intended to ensure that materials are not being combusted as a means of disposing of them, so the health and environmental impacts of concern will be those resulting from air emissions, and the air emissions of concern identified in the CAA include the listed HAP, as well as the section 129 pollutants. However, the Agency solicits comment on whether the list of contaminants should be narrower or broader, or whether the Agency should look at other possible lists. In particular, since the Agency is determining which non-hazardous secondary materials are considered solid waste under RCRA, the Agency could consider the list of hazardous constituents promulgated in Appendix VIII of part 261, which is a list of hazardous constituents that have been shown in scientific studies to have toxic, carcinogenic, mutagenic or teratogenic effects on humans and other life forms. In determining which traditional fuel(s) the owner or operator of the boiler unit would make a comparison with respect to contaminant levels, the Agency is proposing to allow any traditional fuel(s) that can be or is burned in the particular type of boiler. For example, if the boiler burns fuel oil, the level of contaminants to be compared would be the level of contaminants in fuel oil or other liquid traditional fuels that is or can be burned in such unit, while for gas-fired boilers, the level of contaminants in the non- hazardous secondary material fuels would be compared to natural gas. The Agency believes that this approach is most appropriate since the non- hazardous secondary material would be replacing the use of a particular type(s) of fuel. In addition, as discussed in the preamble to the proposed boiler MACT, boilers designed to combust different types of fuels (e.g., coal vs. oil) cannot easily be modified to burn another fuel. Therefore it would not be appropriate to compare the contaminants in a secondary material that is to be combusted in a boiler designed to burn oil to the contaminant levels of coal. EPA is not proposing to establish specific numerical maximum contaminant levels that a non-hazardous secondary material would have to meet, but rather the proposal allows the owner or operator to make the comparison based on information he has or can acquire regarding the level of contaminants found in traditional fuels he burns. However, the Agency solicits comment on whether it would be more appropriate for the Agency to establish bright-line levels of various contaminants in the various traditional fuels or a single set of contaminant levels that would apply regardless of the type of traditional fuel that is burned (as EPA promulgated in the hazardous waste Comparable Fuel Rule 70) so that the regulated community would have certainty as to whether a particular non- hazardous secondary material met this legitimacy criterion. The assessment of whether the non- hazardous secondary material has contaminants comparable to traditional fuel products is to be made by directly comparing the numerical contaminant levels in the non-hazardous secondary material to the contaminant levels in traditional fuels. In making this comparison, the Agency solicits comment on whether the comparison should be based upon the total level of contaminants, or on the level of contaminants per Btu of heat value. In either case, we believe that a direct numerical comparison is necessary since the level of contaminants must be comparable to the level of contaminants in traditional fuels. The Agency also solicits comments on how EPA should interpret ‘‘comparable.’’ For example, should comparable mean the same as or lower, taking into consideration natural variations in sampling events? The Agency recognizes that there may be instances where the contaminant levels in non-hazardous secondary materials may be somewhat higher than found in traditional fuels, but the resulting air pollutant emissions would be inconsequential in terms of risks to human health and the environment in relation to the burning of traditional fuel products and thus possibly not indicative of discard. Therefore, the Agency requests comment on whether, instead of requiring that contaminant levels in non-hazardous secondary materials be comparable to traditional fuels, the Agency should adopt a criterion under which contaminants in non-hazardous secondary material used as a fuel in combustion units could not be significantly higher in concentration than contaminants in traditional fuel products. Under such an approach, the Agency believes that a qualitative approach would be appropriate in determining whether such secondary materials contain ‘‘significantly higher concentrations of contaminants’’ compared to traditional fuels. That is, a contaminant concentration could be elevated without indicating the secondary material is discarded and without posing an unacceptable risk, and therefore, may not be considered ‘‘significantly higher’’ for the purposes of determining whether the non-hazardous secondary material is legitimately being burned as a fuel in a combustion unit. The proposed rule contemplates that this legitimacy criterion must be met, rather than merely considered. The proposed legitimacy criterion is tailored specifically to the use of these non- hazardous secondary materials as fuels in combustion units. As a result, we believe that contaminant levels in secondary materials must be comparable to be legitimately used as a non-waste fuel product. We are therefore proposing that this legitimacy criterion be a requirement for the secondary material to be considered a legitimate fuel. Since these requirements are self implementing in nature (i.e., they do not need up front approval from the regulatory agency), facilities may choose to keep supporting documentation on- site in the event they are inspected by regulatory officials. EPA is not proposing to require that such documentation be maintained, since the proposed definition of non-hazardous solid waste is intended to be self- implementing. However, the Agency solicits comment on whether we should require owners and operators of combustion units to prepare and maintain documentation that this particular legitimacy criterion has been met. b. Legitimacy Criteria for Ingredients. Today’s notice is proposing that non- hazardous secondary materials used as ingredients in combustion units meet the legitimacy criteria specified in proposed 40 CFR 241.3(d)(2). An ingredient used in a combustion unit must be managed as a valuable commodity, provide a useful contribution, be used to produce a valuable product or intermediate, and must result in products that contain contaminants at levels that are comparable in concentration to those found in traditional products that are manufactured without the non- hazardous secondary material. These criteria are discussed below. Managed as Valuable Commodities. We are proposing to require that non- hazardous secondary materials used as ingredients in combustion units be managed as valuable commodities and VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00041 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31884 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules be stored for a reasonable timeframe. See proposed 241.3(d)(2)(i). Where there is an analogous ingredient, the non- hazardous secondary material used as an ingredient must be managed in a manner consistent with the management of the analogous ingredient, or otherwise be adequately contained so as to prevent releases to the environment. Where there is no analogous ingredient, the non-hazardous secondary material must be adequately contained so as to prevent releases to the environment. An ‘‘analogous ingredient,’’ is a manufacturing process ingredient for which the secondary material substitutes and which serves the same function and has similar physical and chemical properties as the non- hazardous secondary material. We are proposing the same storage time and containment requirements that were discussed earlier for the legitimacy criteria for fuels, and are also proposing that this criterion be met. Consistent with the legitimacy criteria for fuels, this criterion addresses the management of non-hazardous secondary materials used as ingredients in two distinct situations. The first situation is when the non-hazardous secondary material is analogous to an ingredient that otherwise would be used in the production process. In this case, the non-hazardous secondary material should be managed prior to use as an ingredient similarly to the way analogous ingredients are managed in the course of normal manufacturing, or otherwise be adequately contained. The second situation this criterion addresses is the case where there is no analogous ingredient that otherwise would be used in the production process. This could be either because the process is designed around a particular non-hazardous secondary material, or because physical or chemical differences between the non- hazardous secondary material and the ingredient are too significant for them to be considered ‘‘analogous.’’ See Managed as a Valuable Commodity under the legitimacy criteria for fuels for additional discussion of this criterion, as well as the specific issues on which EPA is soliciting comment. That is, to the extent that changes are made to this criterion with respect to those non- hazardous secondary materials that are used as fuels, we would likewise make the same changes with respect to those non-hazardous secondary materials used as an ingredient, unless comments are submitted which explain, and provide appropriate data and information, on why this criterion should be different between those non- hazardous secondary materials that are used as a fuel and those that are used as ingredients. Useful Contribution. We are proposing that the non-hazardous secondary materials used as ingredients in combustion units provide a useful contribution to the production/ manufacturing process. See proposed 241.3(d)(2)(ii). A non-hazardous secondary material used as an ingredient in combustion systems provides a useful contribution if it contributes valuable ingredients to the production/manufacturing process or to the product or intermediate of the production/manufacturing process. This criterion is an essential element in the determination of legitimate use as an ingredient because legitimate use is not occurring if the non-hazardous secondary materials being added do not add anything to the process. This criterion is intended to prevent the practice of adding non-hazardous secondary materials to a manufacturing operation simply as a means of disposing of them, which EPA would consider sham recycling. The ANPRM listed five ways in which a non-hazardous secondary material can add value and usefully contribute to a recycling process: (i) The secondary material contributes valuable ingredients to a product or intermediate; or (ii) replaces a catalyst or carrier in the recycling process; or (iii) is the source of a valuable constituent recovered in the recycling process; or (iv) is recovered or regenerated by the recycling process; or (v) is used as an effective substitute for a commercial product. Since today’s proposal addresses non-hazardous secondary materials that are used as ingredients in combustion units, we believe that only items (i) and (v) are specifically relevant to our assessment of whether these non- hazardous secondary materials provide a useful contribution in combustion scenarios. We request comment, however, on whether this is correct, or whether the secondary materials we are assessing as ingredients can provide useful contribution in other ways. For purposes of satisfying this proposed criterion, not every constituent or component of the non- hazardous secondary material has to make a contribution to the production/ manufacturing activity. That is, non- hazardous secondary materials used as ingredients may contain some constituents that are needed in the manufacturing process, such as, for example, zinc in non-hazardous secondary materials that are used to produce zinc-containing micronutrient fertilizers, and satisfy this criterion (although we would also note that the constituents not directly contributing to the manufacturing process could still result in the material failing the contaminant part of the legitimacy criteria). The Agency is not defining quantitatively how much of the non- hazardous secondary material needs to provide a useful contribution for this criterion to be met, since we believe that defining such a level would be difficult and is likely to be different, depending on the non-hazardous secondary material. The Agency recognizes, however, that this could be an issue if persons argue that a material is being legitimately used as an ingredient, but in fact, only a small amount or percentage of it is used. Because of the differences in the emission standards that the non-hazardous secondary material would be subject to—between CAA section 112 and 129, persons may argue that such non-hazardous secondary materials are not wastes, when in fact, the operation is really discard—that is sham recycling. Therefore, the Agency solicits comment on whether the Agency should quantitatively define how much of the non-hazardous secondary material must provide a useful contribution, or alternatively, how much constituents or components in a non-hazardous secondary material there would need to be, before the material would not be considered to provide a useful contribution. Valuable Product. We are proposing that the non-hazardous secondary materials used as ingredients in combustion units must be used to produce a valuable product or intermediate. See proposed 241.3(d)(2)(iii). The product or intermediate is valuable if it is (i) sold to a third party or (ii) used as an effective substitute for a commercial product or as an ingredient or intermediate in an industrial process. This criterion expresses the principle that the product or intermediate of the manufacturing/production process should be a material of value, either to a third party who buys it from the manufacturer, or to the same manufacturer that subsequently uses it as a substitute for another material that it would otherwise have to buy or obtain for its industrial process. This criterion is an essential element of the concept of legitimate use of secondary materials as ingredients because legitimate use cannot be occurring if the product or intermediate is not of use to anyone and, therefore, has no real value. This criterion is intended to prevent the practice of running a non-hazardous secondary material through an industrial process to make something VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00042 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31885 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules just for the purpose of avoiding the costs of disposal. Such a practice would be sham recycling. One way that the use of the non- hazardous secondary material as an ingredient in the production/ manufacturing process that involves a combustion unit can be shown to produce a valuable product would be to have documentation on the sale of the product to a third party. Such documentation could be in the form of receipts or contracts and agreements that establish the terms of the sale or transaction. This transaction could include money changing hands or, in other circumstances, may involve trade or barter. A manufacturer that has not yet arranged for the sale of its product to a third party could establish value by demonstrating that it can replace another product or intermediate that is available in the marketplace. Production/manufacturing processes that use non-hazardous secondary materials as ingredients in combustion systems may produce outputs that are not sold to another party, but are instead used by the same manufacturer. These products or intermediates may be used as a feedstock in a manufacturing process, but have no established monetary value in the marketplace. Such products or intermediates would be considered to have intrinsic value, though demonstrating intrinsic value may be less straightforward than demonstrating value for products that are sold in the marketplace. Demonstrations of intrinsic value could involve showing that the product or intermediate of the production/ manufacturing process replaces another material that would otherwise have to be purchased or could involve a showing that the non-hazardous secondary material meets specific product specifications or specific industry standards. Another approach could be to compare the non-hazardous secondary material’s physical and chemical properties or efficacy for certain uses with those of comparable products or intermediates made from raw materials. Some production/manufacturing processes that use non-hazardous secondary materials as ingredients in combustion systems may consist of multiple steps that may occur at separate facilities. In some cases, each processing step will yield a valuable product or intermediate. When each step in the process yields a valuable product or intermediate that is salable or usable in that form, the activity would conform to this criterion. Contaminant Levels. We are proposing that the non-hazardous secondary material used as an ingredient must result in products that contain contaminants at levels that are comparable in concentration to those found in traditional products that are manufactured without the non- hazardous secondary material. See proposed §241.3(d)(2)(iv). The term ‘‘contaminants’’ refers to constituents in non-hazardous secondary materials that will result in emissions of the air pollutants identified as HAP listed under CAA section 112(b) and the nine pollutants listed under CAA section 129(a)(4)) when such secondary materials are burned as fuel or used as ingredients, including those constituents that could generate products of incomplete combustion. The Agency requests comments on whether we should have a different definition of contaminants that applies specifically to ingredients. Since contaminant comparisons for the contaminant legitimacy criterion apply to a comparison of the products rather than to the secondary material, we request comment on whether a different list of contaminants should apply, or whether we should generically define contaminants to be constituents that may be a concern with respect to the product that is produced (e.g., clinker). The assessment of whether products produced from the use of non-hazardous secondary material ingredients in combustion units that have contaminants that are comparable in concentration to traditional products can be made by a comparison of contaminant levels in the ingredients themselves to traditional ingredients they are replacing, or by comparing the contaminant levels in the product itself with and without use of the non- hazardous secondary material ingredient. The Agency recognizes that there may be instances where the contaminant levels in the products manufactured from non-hazardous secondary material ingredients may be somewhat higher than found in the traditional products that are manufactured without the non- hazardous secondary material, but the resulting concentrations would not be an indication of discard and would not pose a risk to human health and the environment. Therefore, the Agency requests comment on whether, instead of requiring that contaminant levels in products manufactured from secondary material ingredients be comparable in concentration, the Agency should adopt a criterion under which contaminants in the product could not be significantly higher than found in the traditional products that are manufactured without the non-hazardous secondary material. Under such an approach, the Agency believes that a qualitative approach would be appropriate in determining whether such products contain ‘‘significantly higher concentrations of contaminants.’’ That is, a contaminant concentration could be elevated without indicating the secondary material is discarded and without posing an unacceptable risk, and therefore, may not be considered ‘‘significantly higher’’ for the purposes of determining whether the non-hazardous secondary material is legitimately used as an ingredient in a combustion unit. Similar to fuels, we are proposing that the legitimacy criterion addressing contaminant levels in non-hazardous secondary materials used as an ingredient in combustion systems be one that must be met, as opposed to one that must only be considered. As we noted in the legitimacy criteria for fuels, this criterion is tailored specifically to the use of these non-hazardous secondary materials in combustion units, and thus, we do not believe that there are case-specific situations where this criterion could not be met, but the material would still be considered legitimately used as an ingredient. E. Alternative Approach In addition to the proposed approach described in Section VII.D., the Agency is identifying an alternative approach for consideration and comment. As explained below, this alternative approach, which is broader than the proposed solid waste definition discussed above, we believe could be constructed in a manner consistent with RCRA and relevant caselaw although it may raise important policy questions. This alternative may be adopted by the Agency in the final rule if warranted by information presented during the public comment period or otherwise available in the rulemaking record. Under this alternative, traditional fuels that we have identified earlier, which includes clean biomass, and that have been burned historically as fuels and managed as valuable products (as discussed in section VII.C.5.) would not be solid wastes. In addition, non- hazardous secondary materials used as fuels or ingredients are excluded from the definition of solid waste if they both remain within the control of the generator and meet the legitimacy criteria. In contrast to the proposed approach described above, all other non- hazardous secondary materials that are burned as a fuel or used as an ingredient in the combustion process would be solid wastes subject to the CAA section 129 standards if burned in a combustion VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00043 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31886 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules unit. Also, all materials that result from processing of discarded non-hazardous secondary materials would be solid wastes. As with the proposed approach, wastes would include those secondary materials used as a fuel or ingredient not passing the legitimacy criteria, and those secondary materials used as a fuel that are managed outside the control of the generator. This solid waste designation would include materials, such as secondary wood products combusted on-site, coal refuse, and tires processed into TDF, on-spec used oil, and all secondary materials used as ingredients managed outside the control of the generator in combustion units. No petition process would be offered under this alternative. We request comment on all aspects of this alternative. Comments are specifically requested related to the potential impact this alternative may have on traditional non-combustion recycling activities, potential changes in the quantity of non-hazardous secondary materials that may be landfilled, and any collateral regulatory impacts, such as the impact on the MACT floors proposed today for the Commercial and Industrial Solid Waste Incinerators if a significant number of additional sources are subject to that rule. This alternative approach is closer to the views expressed by some commenters that any secondary material combusted for energy recovery is a solid waste and should be regulated under CAA section 129. Thus, only traditional fuels and clean biomass may be burned in a combustion unit under CAA section 112. These commenters believe that the combustion of non-hazardous secondary materials by definition constitutes discard, and therefore all such materials are solid wastes. They have also expressed concerns that section 129 mandates stringent requirements for emissions control, monitoring and reporting for all sources irrespective of size, while section 112 allows EPA discretion to treat smaller sources differently by setting standards based on generally available control technology for sources emitting less than 10 tons per year or more of any single HAP or 25 tons per year or more of any combination of HAPs (i.e. area sources). If non-hazardous secondary materials burned on site for energy recovery are excluded from the definition of solid waste, these commenters argue that many smaller facilities that burn such materials will not be subject to any significant pollution control, monitoring, or reporting requirements. As a result, they believe such an exclusion could have significant adverse health and welfare effects on communities across the country that are located near area sources burning such secondary materials on site for energy recovery. We solicit comment on whether EPA should include such non-hazardous secondary materials as solid waste, and whether such a definition is consistent with or required by RCRA and/or the CAA. Further, as explained below, while we believe that the approach favored by the commenters may raise legal concerns as to the definition of ‘‘discard,’’ as we have discussed previously and further discuss in this section of the preamble, we solicit comment on whether the Agency has the authority to regulate all non- hazardous secondary materials that are burned in combustion units either as a fuel or ingredient as solid wastes. In providing comments on this approach, we specifically request that commenters provide the basis for their recommended position in light of the existing case law on the issue of ‘‘discard.’’ Some commenters have also argued that, as more non-hazardous secondary materials would be subject to CAA section 129 standards when combusted, this option would help promote traditional recycling, while ensuring more stringent emissions standards under CAA section 129 for those sources that elect to continue to burn these secondary materials. Depending upon local disposal and virgin material costs, increased recycling may occur as a result of market adjustments in response to higher materials management costs. EPA wishes to clarify, however, that simply because a waste has, or may have, value does not mean the material loses its status as a solid waste. See API I, 906 F.2d at 741 n.16; United States v. ILCO Inc., 996 F.2d 1126, 1131–32 (11th Cir. 1993); Owen Steel v. Browner, 37 F.3d 146, 150 (4th Cir. 1994). Wastes may be used beneficially. Even assuming beneficial reuse takes place, therefore, a material once discarded cannot cease to be a waste solely by being beneficially reused. In the case of this rule, beneficial resuse would be, for example, use as a fuel—as opposed to incineration, where the material is combusted primarily to be destroyed. It is also important to note that a secondary material could still be a waste even if it is recycled on site or under the control of the generator. See ‘‘API II,’’ 216 F.3d at 55–58, where the DC Circuit overturned EPA’s determination that certain recycled oil bearing wastewaters are wastes. The court overturned this decision and remanded it to EPA for a better explanation. Importantly for the rule we are considering today, the court neither accepted EPA’s view nor the contrary industry view, noting that the relevant determination that had to be made was whether primary treatment of wastewater is simply a step in the act of discarding or the last step in a production process before discard. 213 F.3d at 57. The court rejected both EPA’s and industry’s views because they were only stated in broad generalities. Relevant for today’s alternative approach, we note that oil bearing wastewaters discussed in API II were in fact recycled on-site, but that the court could not determine whether they were wastes or not. Clearly, the issue was not whether the recycling occurred on site, or even under the control of the generator. Rather, the relevant determination is whether the material is discarded or not. To remedy the ‘‘on-site’’ problem raised by API II, EPA for this proposed rule also requires that for the material not to be a waste it must be a legitimate fuel or ingredient. This means, to summarize the legitimacy criteria very generally, if used as a fuel, it is handled as though it is a valuable product (loss must be minimal), it is a true fuel with legitimate heating value, and the material has comparable levels of contaminants to those contained in traditional fuels. In particular, if there are higher than comparable levels of contaminants, that would be an indication that the material is really a waste and it is being combusted to destroy the waste materials. If the material is used as an ingredient, under the proposed rule it must be managed as a valuable commodity, must provide a useful contribution to the production or manufacturing process, must be used to produce a valuable product or intermediate, and cannot result in products that contain contaminants that are not comparable to the concentrations found in traditional products. For details on the legitimacy requirement, see section VII.D.6, above. In fact, as noted below, EPA has determined, for purposes of this alternative approach, that certain secondary materials [see wood residuals and pulp and paper sludge below], even though they are recycled on-site or under the control of the generator, they are still considered solid wastes. The key point regarding the legal basis of this alternative approach is that EPA is accounting for the likelihood that material recycled within a continuous industrial process by being burned for energy recovery or as an ingredient is not a solid waste. The alternative approach, accordingly, requires that the secondary material VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00044 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31887 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules material is both recycled under the control of the generator and complies with the legitimacy criteria to ensure that it is in fact not handled as a waste and is a truly beneficial fuel or ingredient product. An example of a material burned for energy recovery under the control of the generator and meeting the legitimacy requirements is on-spec used oil generated on-site and combusted in an industrial boiler. With respect to other examples, such as pulp and paper sludge and wood manufacturing residuals burned on-site for energy recovery, the Agency may reach a different conclusion. Specifically, commenters to the ANPRM indicated that these materials are primarily composed of biomass and that emissions from burning these materials are essentially the same as emissions from burning other biomass fuels, such as bark or unadulterated wood (see section VII.C.5.). For purposes of the primary proposal, EPA has determined that wood residuals and pulp and paper sludge are not wastes based on limited contaminant data collected to date and the on-site use of the secondary material. However, for this alternative approach, for the reasons described below, EPA is proposing to classify these materials as solid waste. This alternative acknowledges that for some categories of secondary materials, it is difficult to determine whether those materials may or may not be discarded. The DC Circuit has also acknowledged the ambiguity of the term ‘‘solid waste’’ under RCRA as applied to particular situations. Specifically, the court stated that ‘‘[the] term may be ambiguous as applied to some situations, but not as applied to others.’’ ABR at 1056. Thus, there could be some secondary materials that are clearly legitimately recycled within a continuous industrial process and others that are less clear. EPA believes that wood residuals and pulp and paper sludges are just the kinds of materials that present this kind of ambiguity. Based on information the Agency has received, pulp and paper sludges are generally used on-site by generators to fuel their boilers and are treated like valuable commodities. However, there appear to be questions with respect to contaminants in the sludges that give EPA pause as to whether the combustion of these materials is primarily a waste treatment activity— specifically because of levels of chlorine in pulp and paper sludge. The Agency has similar concerns with levels of formaldehyde in wood residuals. Accordingly, EPA believes that with respect to contaminant levels the wood residuals and pulp and paper sludge present a situation in which reasonable persons can disagree as to whether they are discarded materials or not. EPA solicits comments on whether these secondary materials should be classified as wastes or non-wastes. EPA believes that its formulation that secondary material recycled or reused legitimately under the control of the generator will cover all, or almost all, secondary material recycled or reused in a continuous industrial process. The Agency requests comment on the adequacy of this formulation and any data commenters may have indicating whether particular secondary materials that will fall within or outside of this framework and whether, and why, those materials are discarded or not. Comments are specifically requested related to the potential impact this alternative may have on traditional non- combustion recycling activities and potential changes in the quantity of non- hazardous secondary materials that may be landfilled. In addition, we request comment as to whether this alternative approach should include a petition process that provides persons with an administrative process for a formal determination that their non-hazardous secondary material fuel or ingredient is indistinguishable in all relevant aspects from a fuel or ingredient, and thus is not discarded and not a solid waste. EPA believes that an even more far reaching regulatory approach, as suggested by some comments, in which only traditional fuels are not solid wastes and all secondary materials burned for energy recovery or as an ingredient are considered discarded may not be legally acceptable in that the approach provides too broad a definition of solid waste in light of the RCRA case law on the definition of solid waste. Specifically, EPA is concerned about the case law holding that, the RCRA definition of solid waste does not extend to secondary material beneficially reused in a continuous industrial process, as that material has not been discarded and is not a solid waste. See ‘‘AMC I,’’ 824 F.2d 1177 at 1190 in which the court stated that the term ‘‘discarded materials’’ could not include materials ‘‘* * * destined for beneficial reuse or recycling in a continuous process by the generating industry itself.’’ Accord, Association of Battery Recyclers v. EPA, 208 F.3d 1047 (DC Cir. 2000) (‘‘ABR’’). The provisions under consideration in AMC I and ABR dealt specifically with material ‘‘reclaimed’’ in a continuous process— that is, material regenerated from a secondary material in a continuous process. It seems highly likely the courts would extend this same reasoning to secondary materials that are otherwise reused or recycled in a continuous industrial process, such as material used, or combusted, to recover energy or as an ingredient. Thus, EPA is hesitant to define all reused or recycled secondary materials as solid waste under RCRA. F. Effect of Today’s Proposal on Other Programs The construct of this proposed rule for determining when non-hazardous secondary materials are legitimately burned as non-waste fuels or ingredients has applicability to the universe of facilities subject to CAA sections 112 and 129, as well as other rules and agency regulatory programs. 1. Clean Air Act As discussed in Section IV, the CAA section 129 definition of solid waste incineration unit states that the term ‘‘solid waste’’ will have the meaning established by the Administrator of EPA under RCRA. Today’s proposed rule would establish under RCRA which non-hazardous secondary materials constitute ‘‘solid waste.’’ This proposed definition of ‘‘solid waste’’ has been used by EPA in its concurrent proposed CAA emissions standards for CISWI units (under CAA section 129) and boilers and process heaters (under CAA section 112). Any unit combusting ‘‘solid waste’’ under today’s proposed definition would be regulated as a ‘‘solid waste incineration unit’’ under CAA section 129. If a non-hazardous secondary material is not a ‘‘solid waste’’ under the proposed definition and such material is burned as a legitimate fuel or used as a legitimate ingredient in a manufacturing process, the combustion unit would be regulated pursuant to CAA section 112 (by statute, a source cannot be regulated under both CAA sections 112 and 129). 2. Renewable Energy This proposal may impact how some non-hazardous secondary materials could be used to help supply renewable energy to the U.S. and through state programs. Given the Congressional mandate for renewable energy, it is important to assess the impact of this proposed regulation on those programs. Congress has passed several laws, such as the Energy Independence and Security Act of 2007 (Pub. L. 110–140), that support the development and use of renewable sources of energy, both for power generation and for the production of transportation fuels. Qualified sources would include wind, solar, and geothermal power, but could also include power generated by the VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00045 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31888 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 71If EPA determines through the petition process that the secondary materials in the state determinations are not solid waste per 40 CFR 241.3(c), then the units that burn such materials would not be subject to the CAA section 129 requirements. combustion of biogenic materials, which may include some non-hazardous secondary materials burned for energy recovery. Biogenic materials are materials that result from the activity of living organisms. A number of non- hazardous secondary materials are partially or completely biogenic. For example, woody biomass contains recoverable energy and would be considered biogenic in origin. Energy from biogenic sources is generally preferable to fossil fuels. In addition to these federal programs that may be impacted, Renewable Portfolio Standards (RPS) currently provide states with a mechanism to increase renewable energy generation using renewable energy sources (including biofuels) and a cost-effective, market-based approach. An RPS requires electric utilities and other retail electric providers to supply a specified minimum amount of customer load with electricity from eligible renewable energy sources. The goal of an RPS is to stimulate market and technology development so that, ultimately, renewable energy will be economically competitive with conventional forms of electric power. States create RPS programs because of the energy, environmental, and economic benefits of renewable energy and sometimes other clean energy approaches, such as energy efficiency and combined heat and power. Today’s proposed rule determining which non-hazardous secondary materials constitute solid waste may impact the requirements for secondary materials that may be burned for energy generation under the RPS program. 3. Subtitle C Hazardous Waste Program The result of this rulemaking effort will have no effect on the subtitle C Hazardous Waste Program. The RCRA subtitle C hazardous waste federal program has a long regulatory history in defining ‘‘solid waste’’ for purposes of the hazardous waste regulations. However, the 40 CFR 261.2 definition of solid waste explicitly applies only to wastes that also are hazardous for purposes of the subtitle C regulations (see 40 CFR 261.1(b)(1)). CAA section 129 also specifically excludes subtitle C units from coverage under that section. EPA emphasizes that it is not modifying or reopening its hazardous waste regulations; EPA does not intend to respond to any comments directed to those regulations. RCRA section 7003 gives EPA the authority to compel actions to abate conditions that may present an ‘‘imminent and substantial endangerment’’ involving both solid and hazardous wastes. EPA uses this authority on a case-by-case basis. The Agency can determine in a specific factual context whether a secondary material which causes an endangerment is discarded. RCRA Sections 3007 and 3008 establish EPA’s inspection and Federal enforcement authority to address violations of the Subtitle C hazardous waste regulations. Nothing in this proposed rule shall impact EPA’s ability to act pursuant to RCRA sections 3007, 3008 and 7003. The proposed rule also does not limit or otherwise affect EPA’s ability to pursue potentially responsible persons under section 107 of CERCLA for releases or threatened releases of hazardous substances. VIII. State Authority Subtitle D of RCRA establishes a framework for state, federal, and local government cooperation in controlling the management of non-hazardous solid waste. The federal role in this arrangement is to establish the overall regulatory direction, by providing minimum nationwide standards for protecting human health and the environment, and to provide technical assistance to states for planning and developing their own solid waste management practices. The actual planning and direct implementation of solid waste programs under RCRA subtitle D, however, remains largely a state and local function, and states have authority to devise programs to deal with state specific conditions and needs. EPA has not promulgated detailed regulations of what is included in the definition of solid waste for the RCRA subtitle D (non-hazardous) programs. States have promulgated their own laws and regulations as to what constitutes solid waste and have interpreted those laws and regulations to determine what types of non-hazardous secondary material activities involve the management of a solid waste. Many states have a process or promulgated regulations to determine when these materials are wastes, and when they can be used beneficially and safely in products in commerce. Through this rulemaking, EPA is articulating the narrow definition of which non-hazardous secondary materials are or are not solid waste when used as fuel for energy recovery or as ingredients in combustion units. We are not making solid waste determinations that cover other possible secondary material end uses. A. Applicability of State Solid Waste Definitions and Beneficial Use Determinations CAA Section 129 states that the term ‘‘solid waste’’ shall have the meaning ‘‘established by the Administrator pursuant to the Solid Waste Disposal Act’’ Id. at 7429(g)(6). Accordingly, the state’s definitions of solid waste would not be applicable in determining whether the section 129 standards apply. Specifically, state determinations regarding a material’s beneficial use that may exempt that non-hazardous secondary material from the state solid waste standards would not necessarily impact the status of that secondary material under EPA’s solid waste definition as it relates to which combustion units are subject to the CAA section 129 standards, except perhaps as discussed in section VII.D.5, where we discuss a state’s ability to submit, on behalf of the petitioner, a petition for EPA to evaluate under the proposed non-waste determination criteria.71 Likewise, non-hazardous secondary materials that are exempted from being a solid waste by EPA’s proposed rule, if finalized, would be exempt from the CAA section 129 standards, even though the state standards may define the non- hazardous secondary material as a solid waste. The language in CAA section 129, however, may be interpreted to provide the Administrator with flexibility in determining the meaning of solid waste under that section. EPA is requesting comment on an option where, to determine applicability of the CAA section 129 requirements, the Agency would rely on a determination through a state’s beneficial use program that certain secondary materials are or are not solid waste. Such state programs are meant to encourage the use of non- hazardous secondary materials, provided that the uses maintain the specified state’s acceptable level of risk, protect human health and the environment, and are managed in accordance with the conditions of the determination. Generally, for a secondary material to be beneficially used and thus no longer a solid waste, it would have chemical and physical properties similar to the raw material it is replacing or, when incorporated into another product, its use would be beneficial to the final product. Relying on these beneficial use determinations VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00046 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31889 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 72See AMC II, 907 F.2d at 1186; API I, 906 F.2d at 741 n.16; United States v. ILCO Inc., 996 F.2d at 1131–32; Owen Steel v. Browner, 37 F.3d at 150. 73Excluding minor administrative burden/cost (e.g. rule familiarization) and voluntary petition costs. 74National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers; National Emission Standards for Hazardous Air Pollutants for Industrial/Commercial/Institutional Boilers and Process Heaters; and, Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration (CISWI) Units. would recognize state interests in defining solid waste in the context of their own solid waste program, as well as help to mitigate potential inconsistencies between federal and state solid waste determinations. Consideration of this option, however, where the Agency could rely on determinations by a state’s beneficial use program in deciding whether certain materials are solid wastes when used as fuels or ingredients in combustion units, must take into account the current legal rationale for defining solid waste under EPA authority. Specifically, the courts have held that a secondary material that has been discarded is a solid waste regardless of whether it may be reused at some time in the future and simply because a waste has, or may have, beneficial value does not mean the secondary material loses its status as a solid waste.72 See the ANPRM for this rulemaking for the complete discussion of case law pertaining to the solid waste definition (74 FR 51). B. State Adoption of the Rulemaking No federal approval procedures for state adoption of today’s proposed rule are included in today’s proposal under RCRA subtitle D. Although EPA does promulgate criteria for solid waste landfills and approves state municipal solid waste landfill permitting programs, RCRA does not provide EPA any additional authority to approve state programs beyond municipal solid waste. While states are not required to adopt today’s rule, some states incorporate federal regulations by reference or have specific state statutory requirements that their state program can be no more stringent than the federal regulations. In those cases, EPA anticipates that the changes in today’s rule will be adopted by these states, consistent with state laws and state administrative procedures. IX. Costs and Benefits of the Proposed Rule The value of any regulatory action is traditionally measured by the net change in social welfare that it generates. This action alone does not directly invoke any costs 73 or benefits. This proposal is being developed and published in conjunction with the upcoming Boiler MACT and CISWI proposed rules.74 Costs to the regulated community and corresponding benefits to human health and the environment fall under the jurisdiction of these rules. As such, the Agency has not prepared a separate economic assessment in support of this proposal. However, we recognize that this action, as proposed, may affect various State materials management programs, and we are sensitive to these concerns. The Agency encourages comment on any potential direct impacts this action may have on State materials management programs. The costs and benefits indirectly associated with this action are the corresponding impacts assessed in the regulatory impact analyses prepared in support of the CAA proposed rules. These independent regulatory impact analyses measure, among other factors, the estimated net change in social welfare associated with these actions. In the development of these analyses, EPA worked to ensure that the methodologies and data applied in these assessments captured appropriate RCRA related costs (e.g., secondary material diversions). These assessments were designed to adhere to Agency and the Office of Management and Budget (OMB) guidelines and procedures. The Agency has also prepared a general executive summary document that addresses overall impacts of this rulemaking package. These documents are available in the docket established for today’s action. The reader is encouraged to review and comment on all aspects of these documents. X. Statutory and Executive Order Reviews A. Executive Order 12866: Regulatory Planning and Review Under Executive Order (EO) 12866 (58 FR 51735, October 4, 1993), this action is a ‘‘significant regulatory action.’’ Pursuant to the terms of Executive Order 12866, the Agency, in conjunction with the Office of Management and Budget (OMB) has determined that this proposed rule is a significant regulatory action because it contains novel policy issues, as defined under part 3(f)(4) of the Order. Accordingly, EPA submitted this action to OMB for review under EO 12866. Any changes made in response to OMB recommendations have been documented in the docket for this action. B. Paperwork Reduction Act The information collection requirements in this proposed rule have been submitted for approval to the Office of Management and Budget (OMB) under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. The Information Collection Request (ICR) document prepared by EPA has been assigned EPA ICR number 2382.01. This proposal establishes a voluntary non-waste determination petition process for materials identified as solid wastes. Facilities claiming this non- hazardous solid waste exclusion are required to seek approval from the Agency through the submission of a petition prior to operating under this exclusion. Sufficient information about the secondary material and the market demand for this material will be necessary to demonstrate that the non- hazardous secondary material will in fact be used as a fuel or ingredient in the combustion process. Specifically, the petition will need to contain information to assess the following criteria: (1) Whether market participants handle the non-hazardous secondary material as a fuel rather than a waste; (2) whether the chemical and physical identify of the non-hazardous secondary material is comparable to a commercial fuel; (3) whether the capacity of the market would use the non-hazardous secondary material in a reasonable timeframe; (4) whether the constituents in the non-hazardous secondary material are not discarded to the air, water or land from the point of generation through combustion of the secondary material at significantly higher levels from either a statistical or from a health and environmental risk perspective than would otherwise be released; and (5) other relevant factors. The facility-level burden associated with this voluntary petition option is uncertain. However, we estimate an average total one-time burden of approximately 700 hours per facility, with a total cost per facility of approximately $71,400. The total number of facilities likely to take advantage of this option is undetermined, but we would expect that only a limited number of facilities may submit such a petition. The Agency requests comment on the number of petitions that are likely to be submitted to EPA for consideration. Burden is defined at 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a currently valid OMB VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00047 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31890 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules 75National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers; National Emission Standards for Hazardous Air Pollutants for Industrial/Commercial/Institutional Boilers and Process Heaters; and, Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration (CISWI) Units. control number. The OMB control numbers for EPA’s regulations in 40 CFR are listed in 40 CFR part 9. To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, EPA has established a public docket for this rule, which includes this ICR, under Docket ID number EPA–HQ–RCRA–2008–0329. Submit any comments related to the ICR to EPA and OMB. See the ADDRESSES section at the beginning of this notice for where to submit comments to EPA. Send comments to OMB at the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW., Washington, DC 20503, Attention: Desk Office for EPA. Since OMB is required to make a decision concerning the ICR between 30 and 60 days after June 4, 2010, a comment to OMB is best assured of having its full effect if OMB receives it by July 6, 2010. The final rule will respond to any OMB or public comments on the information collection requirements contained in this proposal. C. Regulatory Flexibility Act The Regulatory Flexibility Act (RFA) generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. For purposes of assessing the impacts of today’s rule on small entities, small entity is defined as: (1) A small business, as defined by the Small Business Administration’s (SBA) regulations at 13 CFR 121.201; (2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and (3) a small organization that is any not- for-profit enterprise which is independently owned and operated and is not dominant in its field. After considering the economic impacts of today’s proposed rule on small entities, I certify that this action will not have a significant economic impact on a substantial number of small entities. No small entities are directly regulated by this proposed rule (see discussion above under costs and benefits). Small entities potentially affected indirectly by this action include: major source industrial, commercial, and institutional boilers and process heaters, area source industrial, commercial, and institutional boilers and commercial and industrial solid waste incineration units. We estimate that these units operate in approximately 50 different industry categories based on the NAICS three digit sector code level. These sectors include: crop production; forestry and logging; support activities for agriculture and forestry; oil and gas extraction; mining (except oil and gas); utilities; heavy and civil engineering construction; food manufacturing; beverage and tobacco product manufacturing; textile mills and textile product mills; wood product manufacturing; paper manufacturing; petroleum and coal products manufacturing; chemical manufacturing; plastics and rubber products manufacturing; nonmetallic mineral product manufacturing; primary metal manufacturing; fabricated metal product manufacturing; machinery manufacturing; computer and electronic product manufacturing; transportation equipment manufacturing; furniture and related product manufacturing; merchant wholesalers; motor vehicle and parts dealers; air, rail, and pipeline transportation; warehousing and storage; waste management and remediation services; educational services; hospitals; accommodation; repair and maintenance; and public administration. Any potential impacts to small entities under these and any other potentially affected sectors are addressed in the regulatory flexibility analysis prepared in support of the CAA proposed rules that are linked to this action.75 We have determined that, because no small entities are directly impacted by this proposed action, there will not be a significant economic impact on a substantial number of small entities. This determination is based on the findings, as discussed above. Although this proposed rule will not have a significant economic impact on a substantial number of small entities, EPA nonetheless has tried to reduce the (indirect) impact of this rule on small entities through the careful and targeted identification of solid waste materials. We continue to be interested in the potential impacts of the proposed rule on small entities and welcome comments on issues related to such impacts. D. Unfunded Mandates Reform Act This proposed rule does not contain a Federal mandate that may result in expenditures of $100 million or more for State, local, and tribal governments, in the aggregate, or the private sector in any one year. Because this action is linked to the CAA rules (see footnote under section C), this rule alone will not result in significant economic impacts on States, local and tribal governments, in the aggregate, or the private sector in any one year. Thus, this rule is not subject to the requirements of sections 202 or 205 of UMRA. This proposed rule is also not subject to the requirements of section 203 of UMRA because it contains no regulatory requirements that might significantly or uniquely affect small governments. As described above, this action alone does not result in unique effects, or significant economic impacts. E. Executive Order 13132: Federalism This action does not have federalism implications. It will not have substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government, as specified in Executive Order 13132. This action, independent of the CAA rules, as proposed (see footnote 81), will not result in substantial direct effects on the states. Furthermore, this action will not preempt state laws related to the affected materials. States will remain free to manage these materials as appropriate under their Subtitle D programs. Thus, Executive Order 13132 does not apply to this action. Although we believe that this action, as proposed, will not result in substantial direct effects on the states, we are sensitive to the perceptions States may have of this action in regard to their solid waste management programs. On January 2, 2009 we published an ANPRM (Identification of Non-Hazardous Materials That Are Solid Waste) that presented the Agency’s anticipated approach for this action. We received numerous comments on this ANPRM, many of which came from States. Furthermore, we have reached out to the States with various informational conference calls throughout the development of this proposal. . In the spirit of Executive Order 13132, and consistent with EPA policy to promote communications between EPA VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00048 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31891 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules and State and local governments, EPA specifically solicits comment on this proposed action from State and local officials. F. Executive Order 13175: Consultation and Coordination With Indian Tribal Governments Subject to the Executive Order 13175 (65 FR 67249, November 9, 2000) EPA may not issue a regulation that has tribal implications, that imposes substantial direct compliance costs, and that is not required by statute, unless the Federal government provides the funds necessary to pay the direct compliance costs incurred by tribal governments, or EPA consults with tribal officials early in the process of developing the proposed regulation and develops a tribal summary impact statement. EPA has concluded that this action may have tribal implications. However, it will neither impose substantial direct compliance costs on tribal governments, nor preempt Tribal law. The proposed rule may have minor tribal implications to the extent that entities generating or burning solid wastes on tribal lands could be affected. EPA consulted with tribal officials early in the process of developing this regulation to permit them to have meaningful and timely input into its development. EPA specifically solicits additional comment on this proposed action from tribal officials. G. Executive Order 13045: Protection of Children From Environmental Health and Safety Risks This action is not subject to EO 13045 (62 FR 19885, April 23, 1997) because it is not economically significant as defined in EO 12866, and because the Agency does not believe the environmental health or safety risks addressed by this action present a disproportionate risk to children. This action’s health and risk assessments related to this action are contained in the support documents prepared for the CAA section 129 CISWI and section 112 boiler MACT proposed rules. H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution or Usage This action is not a ‘‘significant energy action’’ as defined in Executive Order 13211 (66 FR 28355 (May 22, 2001)), because it is not likely to have a significant adverse effect on the supply, distribution, or use of energy. This action, independent of the CAA rules, as proposed, is not expected to directly affect energy use or use patterns. Energy impacts resulting for the CAA (see rule identification in footnote 72) application of this action are assessed and discussed in the preambles and supporting materials for those rules. I. National Technology Transfer Advancement Act Section 12(d) of the National Technology Transfer and Advancement Act of 1995 (‘‘NTTAA’’), Public Law 104–113, 12(d) (15 U.S.C. 272 note) directs EPA to use voluntary consensus standards in its regulatory activities unless to do so would be inconsistent with applicable law or otherwise impractical. Voluntary consensus standards are technical standards (e.g., materials specifications, test methods, sampling procedures, and business practices) that are developed or adopted by voluntary consensus standards bodies. NTTAA directs EPA to provide Congress, through OMB, explanations when the Agency decides not to use available and applicable voluntary consensus standards. This proposed rulemaking does not involve technical standards. Therefore, EPA is not considering the use of any voluntary consensus standards. J. Executive Order 12898: Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Populations Executive Order (EO) 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive policy on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the United States. EPA is evaluating the question of whether this proposed rule will or will not have disproportionately high and adverse human health or environmental effects on minority or low-income populations. We have completed preliminary environmental justice analyses, in conjunction with the Boiler MACT and CISWI proposed rules (see section IV.A.). These preliminary environmental justice analyses are compiled in the ‘‘Review of Environmental Justice Impacts’’ for both this proposal and the Boiler MACT and CISWI proposed rules. This document is available in the docket for today’s rule (Docket ID No: EPA–HQ–RCRA–2008– 0329). EPA is committed to addressing environmental justice concerns and has assumed a leadership role in environmental justice initiatives to enhance environmental quality for all citizens of the United States. The Agency’s goals are to ensure that no segment of the population, regardless of race, color, national origin, income, or net worth, bears disproportionately high and adverse human health and environmental impacts as a result of EPA’s policies, programs, and activities. Our goal is to ensure that all citizens live in clean and sustainable communities. In response to Executive Order 12898, and to the concerns voiced by many groups outside the Agency, EPA’s Office of Solid Waste and Emergency Response (OSWER) formed an Environmental Justice Task Force to analyze the array of environmental justice issues specific to waste programs and to develop an overall strategy to identify and address these issues (OSWER Directive No. 9200.3–17). The Environmental Justice analysis in today’s proposal includes two main parts: (1) Demographic analysis and environmental impacts; and (2) outreach. Demographics Analysis and Environmental Impacts For this proposal, the demographic analysis focuses on the management of secondary materials that have been proposed to be solid waste under this proposed rule (versus the emissions from the combustion of the non- hazardous secondary materials which will be covered in the Boiler MACT and CISWI proposed rules). Specifically, the analysis focuses on the populations around the facilities accepting non- hazardous secondary materials that under the proposal would be considered to be solid waste. These wastes would be diverted from units previously combusting materials in accordance with the CAA section 112 standards for non-wastes according to today’s proposed rulemaking. The analysis includes a demographic evaluation (focusing on the presence of low-income and minority populations) and possible impacts associated with solid waste being sent to municipal waste combustors and landfills (which are projected to receive the majority of the diverted materials as assessed by the impacts of the CISWI and Boiler MACT proposed rules using the least cost approach). The analysis also covers additional diversion implications. The assessment includes impacts on the abatement of scrap tire piles, stockpiling of secondary materials, and the disposal of used oil not in compliance with applicable standards. The impacts of the new proposed emissions standards are included in the VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00049 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31892 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules Boiler MACT and CISWI proposed rules. The analysis in those proposals includes the following efforts: identification of sources, identification of demographic characteristics near sources, evaluation of area wide air quality, estimation of Boiler MACT/ CISWI emission reductions of HAPs from the proposed standards and work practices. Outreach The outreach aspect of the environmental justice analysis will help stakeholders participate in the rulemaking process and build a dialog during the comment period for the proposed rule. The first step in the outreach process took place at the EPA Community Engagement in Rulemaking Roundtable Discussion in New Orleans, LA on January 28, 2010. This discussion was held concurrently with the National Environmental Justice Advisory Council public meeting. At the roundtable meeting, the basics of the advanced notice of proposed rulemaking were discussed, including how it interacts with EPA’s upcoming CAA section 112 and section 129 rulemakings, and provided an educational forum to bring together EPA technical experts, community leaders, nonprofit groups, and others to discuss key themes of the proposed rulemaking. Based on the results of the roundtable meeting, the Agency developed an approach for public participation and outreach during the comment period for the proposal (including planned forums to discuss the proposed rules and/or learn more about environmental impacts of the rule). The activities associated with the outreach are posted at http:// www.epa.gov/waste/nonhaz/ definition.htm. List of Subjects in 40 CFR Part 241 Environmental protection, Air pollution control, Waste treatment and disposal. Dated: April 29, 2010. Lisa P. Jackson, Administrator. For the reasons stated in the preamble, title 40, chapter I of the Code of Federal Regulations, is proposed to be amended by adding part 241 to read as follows: PART 241—SOLID WASTES USED AS FUELS OR INGREDIENTS IN COMBUSTION UNITS Subpart A—General Sec. 241.1 Purpose. 241.2 Definitions. Subpart B—Identification of Non-Hazardous Secondary Materials That Are Solid Wastes When Used as Fuels or Ingredients in Combustion Units 241.3 Standards and procedures for identification of non-hazardous secondary materials that are solid wastes when used as fuels or ingredients in combustion units. Authority: 42 U.S.C. 6903, 6912, 7429. Subpart A—General §241.1 Purpose. This part identifies the requirements and procedures for the identification of solid wastes used as fuels or ingredients in combustion units under section 1004 of the Resource Conservation and Recovery Act and section 129 of the Clean Air Act. §241.2 Definitions. For the purposes of this subpart: Contained means the non-hazardous secondary material is stored in a manner that both adequately prevents releases or other hazards to human health and the environment considering the nature and toxicity of the material. Contaminants means any constituent in non-hazardous secondary materials that will result in emissions of the air pollutants identified in CAA section 112(b) and the nine pollutants listed under CAA section 129(a)(4)) when such secondary materials are burned as fuel or used as ingredients, including those constituents that could generate products of incomplete combustion. Control means the power to direct the policies of the facility, whether by the ownership of stock, voting rights, or otherwise, except that contractors who operate facilities on behalf of a different person as defined in this section shall not be deemed to ‘‘control’’ such facilities. Generating facility means all contiguous property owned, leased, or otherwise controlled by the non- hazardous secondary material generator. Intermediate product means a finished product traded usually among producers or suppliers rather than end users. Non-hazardous secondary material means a secondary material that, when discarded, would not be identified as a hazardous waste under part 261 of this chapter. Person is defined as an individual, trust, firm, joint stock company, Federal agency, corporation (including government corporation), partnership, association, State, municipality, commission, political subdivision of a state, or any interstate body. Processing means any operations that transform discarded non-hazardous secondary material into a new fuel or new ingredient product. Minimal operations, such as operations that result only in modifying the size of the material by shredding, do not constitute processing for purposes of this definition. Processing includes, but is not limited to, operations that: remove or destroy contaminants; significantly improve the fuel characteristics of the material, e.g., sizing or drying the material in combination with other operations; chemically improve the as- fired energy content; and improve the ingredient characteristics. Secondary material means any material that is not the primary product of a manufacturing or commercial process, and can include post-consumer material, off-specification commercial chemical products or manufacturing chemical intermediates, post-industrial material, and scrap. Solid waste means the term solid waste as defined in 40 CFR 258.2. Within control of the generator means that the non-hazardous secondary material is generated and burned in combustion units at the generating facility; or that such material is generated and burned in combustion units at different facilities, if the facility combusting the material is controlled by the generator; or if both the generating facility and the facility combusting the material are under control of the same person as defined in this section. Subpart B—Identification of Non- Hazardous Secondary Materials That Are Solid Wastes When Used as Fuels or Ingredients in Combustion Units §241.3 Standards and procedures for identification of non-hazardous secondary materials that are solid wastes when used as fuels or ingredients in combustion units. (a) Except as provided in paragraph (b) of this section, non-hazardous secondary materials that are combusted are solid wastes, unless a petition is submitted to, and a determination granted by, the Regional Administrator pursuant to paragraph (c) of this section. The criteria to be addressed in the petition, as well as the process for making the non-waste determination, are specified in paragraph (c) of this section. (b) The following non-hazardous secondary materials are not solid wastes when combusted: (1) Non-hazardous secondary materials used as a fuel in a combustion unit that remains within the control of the generator (as defined in §241.2) and that meets the legitimacy criteria specified in paragraph (d)(1) of this section. VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00050 Fmt 4701 Sfmt 4702 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 31893 Federal Register /Vol. 75, No. 107/Friday, June 4, 2010/Proposed Rules (2) Non-hazardous secondary materials used as an ingredient in a combustion unit and that meets the legitimacy criteria specified in paragraph (d)(2) of this section. (3) Fuel or ingredient products that have undergone processing (as defined in §241.2) from discarded non- hazardous secondary materials and that are used as fuels or ingredients in a combustion unit, and that meet the legitimacy criteria specified in paragraph (d)(1) of this section, with respect to fuels, and paragraph (d)(2) of this section, with respect to ingredients. (c) The Administrator may grant a non-waste determination that a non- hazardous secondary material used as a fuel is not discarded and therefore not a solid waste when combusted. The criteria and process for making such non-waste determinations includes the following: (1) Submittal of an application to the Regional Administrator for the EPA Region where the facility combusting the non-hazardous secondary material is located by an applicant for a determination that the non-hazardous secondary material, even though it has been transferred to a third party, has not been discarded and is indistinguishable in all relevant aspects from a product fuel. The determination will be based on whether the non-hazardous secondary material has been discarded, is a legitimate fuel as specified in paragraph (d)(1) of this section and on the following criteria: (i) Whether market participants treat the non-hazardous secondary material as a fuel rather than a solid waste; (ii) Whether the chemical and physical identity of the non-hazardous secondary material is comparable to commercial fuels; (iii) Whether the non-hazardous secondary material will be used in a reasonable time frame given the state of the market; (iv) Whether the constituents in the non-hazardous secondary material are released to the air, water or land from the point of generation to the combustion of the secondary material at levels comparable to what would otherwise be released from traditional fuels; and (v) Other relevant factors. (2) The Regional Administrator will evaluate the application based on the following procedures: (i) The applicant must apply to the Regional Administrator for the non- waste determination addressing the relevant criteria in paragraphs (c)(1)(i) through (v) of this section. (ii) The Regional Administrator will evaluate the application and issue a draft notice tentatively granting or denying the application. Notification of this tentative decision will be published in a newspaper advertisement or radio broadcast in the locality where the facility combusting the non-hazardous secondary material is located, and be made available on EPA’s Web site. (iii) The Regional Administrator will accept comment on the tentative decision for at least 30 days, and may also hold a public hearing upon request or at his discretion. The Regional Administrator will issue a final decision after receipt of comments and after the hearing (if any). (iv) If a change occurs that affects how a non-hazardous secondary material meets the relevant criteria contained in paragraphs (c)(1)(i) through (v) of this section after a formal non-waste determination has been granted, the applicant must re-apply to the Regional Administrator for a formal determination that the non-hazardous secondary material continues to meet the relevant criteria and is not discarded and is thus not a solid waste. (d) Legitimacy criteria for non- hazardous secondary materials. (1) Legitimacy criteria for non- hazardous secondary materials used as fuels in combustion units include the following: (i) The non-hazardous secondary material must be managed as a valuable commodity based on the following factors: (A) The storage of the non-hazardous secondary material prior to use must not exceed reasonable time frames; (B) Where there is an analogous fuel, the non-hazardous secondary material must be managed in a manner consistent with the analogous fuel or otherwise be adequately contained to prevent releases to the environment; (C) If there is no analogous fuel, the non-hazardous secondary material must be adequately contained so as to prevent releases to the environment; (ii) The non-hazardous secondary material must have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy. (iii) The non-hazardous secondary material must contain contaminants at levels comparable or lower to those in traditional fuels which the combustion unit is designed to burn. Such comparison is to be based on a direct comparison of the contaminant levels in the non-hazardous secondary material to the traditional fuel itself. (2) Legitimacy criteria for non- hazardous secondary materials used as an ingredient in combustion units include the following: (i) The non-hazardous secondary material used as an ingredient must be managed as a valuable commodity based on the following factors: (A) The storage of the non-hazardous secondary material prior to use must not exceed reasonable time frames; (B) Where there is an analogous ingredient, the non-hazardous secondary material must be managed in a manner consistent with the analogous ingredient or otherwise be adequately contained to prevent releases to the environment; (C) If there is no analogous ingredient, the non-hazardous secondary material must be adequately contained to prevent releases to the environment; (ii) The non-hazardous secondary material used as an ingredient must provide a useful contribution to the production or manufacturing process. The secondary material provides a useful contribution if it contributes a valuable ingredient to the product or intermediate or is an effective substitute for a commercial product. (iii) The non-hazardous secondary material used as an ingredient must be used to produce a valuable product or intermediate. The product or intermediate is valuable if: (A) The material is sold to a third party, or (B) The material is used as an effective substitute for a commercial product or as an ingredient or intermediate in an industrial process. (iv) The non-hazardous secondary material used as an ingredient must result in products that contain contaminants at levels that are comparable or lower in concentration to those found in traditional products that are manufactured without the non- hazardous secondary material. [FR Doc. 2010–10837 Filed 6–3–10; 8:45 am] BILLING CODE 6560–50–P VerDate Mar<15>2010 15:08 Jun 03, 2010 Jkt 220001 PO 00000 Frm 00051 Fmt 4701 Sfmt 9990 E:\FR\FM\04JNP2.SGM 04JNP2erowe on DSK5CLS3C1PROD with PROPOSALS2 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 12, 2010 MSD Contract No. 2009145 B&V File 44.000 Appendix B Water Environment Federation Comments on Proposed Rule Dated August 2, 2010 August 2, 2010 Re: WEF Comments on the Proposed Rule on Identification of Non-Hazardous Secondary Materials That Are Solid Wastes, ATTN: RCRA Docket ID No. EPA– HQ–RCRA–2008–0329 (Federal Register / Vol. 75, No. 107 / Friday, June 4, 2010 / Proposed Rules, pages 31844-31893 The Water Environment Federation (WEF) would like to submit comments on the proposed rule for Identification of Non-Hazardous Secondary Materials That Are Solid Waste that was issued in the June 4, 2010 Federal Register. WEF is a not-for-profit association that has provided technical education and training for the world‟s water quality professionals since 1928. The Federation has 36,000 individual members and 75 affiliated Member Associations who support its mission to preserve and enhance the global water environment.WEF is supportive of regulations that are science based, achievable, and protective of human health and the environment. The requirements stipulated in 40 CFR Part 503, Standards for the Use or Disposal of Sewage Sludge, meet this objective for biosolids treatment and management. A summary of our comments and concerns with the proposed rulemaking are focused as follows: While the proposal states that the specific intent of regulation is to apply the designation of “solid waste” to wastewater solids (biosolids) processed in sewage sludge incinerators (SSI), WEF would like confirmation that this proposed ruling is not intended to impact any other forms of biosolids management. The legitimacy criteria are not suitable for biosolids incineration. o Information used by EPA from the Materials Characterization Paper to test whether biosolids meets the contaminant criteria is outdated in terms of biosolids composition, as well as intended uses, which leads to biased conclusions. o The meaningful heating value and energy recovery criteria are arbitrary, developed for other industries, and not consistent with renewable energy policy to encourage energy recovery and reduction of greenhouse gas emissions at POTWs. o The proposed regulations requirements for adequate processing are limiting and could have negative ramifications on biosolids-to-energy projects either ongoing or planned. There may be unintended consequences for other forms of biosolids management as this approach will result in more landfilling of a valuable nutrient and energy rich material that could otherwise be used as a renewable resource. EPA may not have sufficient SSI operating data (for either multiple hearth or fluid bed incinerators) to establish science based MACT standards required by the proposed regulation. Each of these concerns is discussed in more detail below: Intent of Regulation The intent of the proposed ruling is classifying biosolids (or sewage sludge) as a solid waste to impose additional regulation on sewage sludge incinerators. WEF is concerned that there may be unintended consequences to this approach. Section VII of 40 CFR Part 241 states “Through this rulemaking, EPA is articulating the narrow definition of which non-hazardous secondary materials are or are not solid waste when used as fuel for energy recovery or as ingredients in combustion units. We are not making solid waste determinations that cover other possible secondary end uses (VIII 3rd par).” WEF is concerned s that this language is y vague and will inappropriately applied to all biosolids management programs, resulting in harm to beneficial programs for biosolids reuse. WEF believes that the science based 503 Regulations were promulgated to be protective of public health and the environment for all biosolids programs including incineration. If the intended EPA focus is narrow, WEF requests that EPA acknowledge land application and other biosolids programs (other than incineration) are protective of public health and the environment if 503 Regulations are followed. EPA views incineration as a disposal process; however, in essence it is a stabilization and volume reduction process for sewage sludge, that has been historically used for decades as an integral part of the overall wastewater treatment process. The solid waste rule should only apply to the ash byproduct from the incineration process, if it is land-filled and not beneficially reused, as that is the residual waste being disposed of or discarded. Sewage sludge used as a legitimate fuel should not be considered as discarded. WEF proposes a more appropriate definition of a legitimate fuel below. EPA assumes by this proposed rulemaking that sewage sludge (non-hazardous waste material) is discarded, and utilities and facilities practicing sewage sludge incineration are required to prove otherwise. Section VII.D explains the process: “Non-hazardous secondary materials (sewage sludge) used as fuels in combustion units would be considered solid waste unless: (1) the non-hazardous secondary materials remain under the control of the generator as discussed in section VII.D.1, and are legitimate fuels; or (2) they are legitimate fuels that are produced from the processing of discarded non-hazardous secondary materials into a non-waste fuel as discussed in section VII.D.4. Non- hazardous secondary materials used as a fuel in combustion units that are transferred to a third party (and not considered to be managed within the control of the generator) are considered solid wastes unless a non-waste determination has been made pursuant to the proposed petition process discussed in section VII.D.5.” Why does EPA give third party processors the option to a non-waste determination per the petition process and not give the same petition process to the generators where the non-waste determination was based only on the legitimate criteria discussed in section V.II.6.a.? EPA views the sewage sludge exemption as only applying to solids entering the plant and not those produced within the plant. Is it EPA‟s intent to only consider secondary or mixed primary/secondary sludge as solid waste since no solids are generated within the primary sedimentation process? WEF would request EPA to clarify their position on this matter. How would EPA view sewage sludge imported to a merchant incineration facility? Legitimacy Criteria EPA has established three legitimacy criteria for materials including sewage sludge not to be considered a solid waste: (1) It is managed as a valuable commodity; (2) It has a meaningful heating value; and (3) It contains contaminants at levels comparable to those in traditional fuels for which the combustion unit was designed to burn. We will discuss these in reverse order. Contaminants. WEF believes that EPA should acknowledge the significant strength and impact of Clean Water Act pretreatment programs on the quality and composition of sewage sludge. Unfortunately, this was not the case when EPA used out of date information in the proposed rulemaking. In EPA‟s own publication, Targeted National Sewage Sludge Survey (EPA, 2009), samples from 74 randomly selected publicly owned treatment works in 35 states indicate that the contaminant levels in sewage sludge have been decreasing for a number of constituents. A summary of the results, alongside the corresponding contaminant values for coal, is shown in the table below. The contaminant values are derived from Table 2-1 of the document Preliminary Characterization Study, Traditional Fuels and Key Derivatives, Prepared in Support of the Proposed Rulemaking – Identification of Nonhazardous Secondary Materials That Are Solid Waste. While some of the 2009 contaminant values for sewage sludge remain higher than the single coal values, the overall values are nearing parity compared to the 1989 values. When median values are considered, the results demonstrate the wastewater treatment facilities efforts to improve sewage sludge quality for beneficial uses including energy recovery. This trend would indicate that (depending on the source), biosolids have contaminant levels on par with traditional fuels and can be expected to continue falling based on the success of pretreatment programs. Element Wastewater Treatment Sludge Coal (mg/kg) Coal in “Fuel” Document (mg/kg) 40-City Study (1980) mg/kg dry weight National Sewage Sludge Study (1989) mg/kg dry weight Targeted National Sewage Sludge Survey (2009) mg/kg dry weight AVERAGE Targeted National Sewage Sludge Survey (2009) mg/kg dry weight MEDIAN Arsenic 9.9 6.7 6.76 4.95 10 0.5 – 80 Cadmium 69 6.9 2.48 1.72 0.5 0.1 – 3.0 Chromium 429 119 78.2 30.6 20 0.5 – 6.0 Copper 602 741 559 449 Not available Not available Lead 369 134.4 74 44.4 40 2 – 80 Mercury 2.8 5.2 1.27 0.83 0.1 0.1 – 1.8 Molybdenum 17.7 9.2 15 11 Not available Not Available Nickel 135.1 42.7 47.4 22.8 20 0.5 – 50 Selenium 7.3 5.2 7.1 6.2 1 0.2 – 10 Zinc 1,594 1,202 970 764 Not available Not Available Note that this comparison does not consider the significantly greater greenhouse gas emissions impacts of burning coal as a fossil fuel versus biosolids as a biogenic fuel source. Downgrading biosolids to a “solid waste” classification is flawed and misleading, given that coal burning is in fact more destructive to the environment. Meaningful Heating Value. WEF believes that sewage sludge has a meaningful heating value that can be used to reduce the use of fossil fuels and lower greenhouse gas emissions. In order to best benefit from this inherent heating value of biosolids, WEF recommends that EPA focus on the net recovery of energy within the incineration process as opposed to defining the minimum heating value of the sewage sludge input. The limitation of 5,000 BTU per pound of wet feed appears arbitrary and is not appropriate for sewage sludge applications. In many cases, sewage sludge can be processed by incineration without supplemental fossil fuel, with heating values as low as 1,800 to 2,200 BTU per pound. The minimum heating value restriction should be eliminated and replaced by a process requirement that the sewage sludge heating value should represent at least 90% (or some other mutually agreeable number) of the total fuel input to the system. In this way, the focus is better placed on maximizing the use of the heating value of biosolids for net energy benefit. Valuable Commodity. Sewage sludge is handled as a valuable commodity in that it is prepared in at least one of the following processes: stabilization, dewatering, or drying before being used as a fuel. The majority of biosolids produced in the US has for decades been beneficially used for its nutrient and organic value in land application, demonstrating its value as a commodity and not as a discard. Biosolids should be considered a renewable energy resource, which can be an important component of the country‟s renewable energy portfolio. Defining a resource as a solid waste is contradictory to the advancement of biosolids as a sustainable, renewable energy resource. Incineration facilities can recover useful energy and reduce greenhouse gas (GHG) emissions which significantly reduces the need for landfilling. Furthermore, addressing public questions or about „solid waste‟ being applied for agricultural purposes will increase management and application costs, and may result in additional landfilling. Based on EPA‟s proposed rule and approach, it is unclear how increased landfilling can advance renewable energy and reduced GHG emissions policy goals. Many states have adopted renewable portfolio standards for biomass (biosolids are included in some states definitions for biomass) and the proposed ruling will have a detrimental effect on the implementation of those programs. Energy Recovery Criteria WEF has been supportive of energy conservation, renewable energy generation, and efficiency improvements in how municipal wastewater treatment agencies treat and handle wastewater and biosolids. Many wastewater utilities have plans, permits, and projects in place with the goal of maximizing renewable energy resource potential of biosolids and minimizing greenhouse gas emissions. Although these proposed facilities will fulfill this renewable energy goal by becoming net producers of electricity within the incineration process, net energy production alone will not be sufficient to meet the requirements of the proposed rule. EPA states in their proposal that “Although waste heat boilers are useful devices for providing energy in the form of steam for secondary processes, the Agency does not regard them as legitimate energy recovery devices because they receive their energy input from the combustion of off-gases via a separate chamber. Under the RCRA program, a legitimate energy recovery device is one that meets the definition of a boiler or an industrial furnace (see 40 CFRA 260.10)”. The definition of a boiler as an enclosed device is outdated and not appropriate for modern fuel-burning technologies. In many cases, particularly units burning solid fuels, it is necessary to construct a separate combustion chamber for the fuel, with no removal of heat via transfer to another medium (steam, heated fluids, or heated gases) to provide adequate “controlled flame combustion” conditions and meet current emission regulations (presumably the reason for the process heater and fluidized bed combustion unit exemption). The use of close-coupled downstream components, such as heat exchangers or heat recovery boilers should be viewed no differently than related heat-recovery components, such as economizers or air preheaters, which are not required under the current definition to be all part of a single chamber. Limiting a boiler system to one single integrally-manufactured or assembled unit and excluding systems assembled as a combustion chamber joined by ductwork to separate heat recovery boilers or heat exchangers is illogical. This is particularly evident in cases where no bypass duct is provided around the heat recovery equipment, demonstrating that combustion and heat recovery are clearly parts of an integral system where the principal process intent is the combustion of a fuel for the purpose of recovering and exporting energy. In 40 CFR 260.10, the limitations on the thermal efficiency of the combustion unit (60%), and the requirement that at least 75% of the recovered energy be exported and utilized is overly restrictive and will severely limit the application of proven technology to recover energy from sewage sludge or biosolids. Due to the inherently high moisture content of dewatered biosolids, a significant component of the thermal value is consumed in evaporating this moisture and supporting the combustion process in lieu of using fossil fuel for this purpose. Nevertheless, it is usually practical to recover up to 50% of the energy for export and utilization. WEF recommends that EPA recognize the unique characteristics of biosolids and revise its definition to allow waste heat boilers connected by ducts and require the incineration process to be a net exporter of energy and utilize at least 40% of the recovered energy. Advanced Processing EPA suggests that dried biosolids pellets would be an acceptable and valuable fuel commodity but that dewatered biosolids alone is not. WEF considers this to be an unfounded distinction and recommends that EPA to focus on the net energy value of the material, considering all processing steps involved regardless of the process location. EPA acknowledges gasification processes, which produce syngas, to be an adequate process for producing a non-waste fuel product. As such, EPA acknowledges that sewage sludge would be a legitimate fuel and not a solid waste when processed by gasification. This acknowledgement is within the intent of the proposed regulation since the gasification process is used to recover or produce energy from the biosolids and not discard it as EPA stipulates for sewage sludge incinerators. Note that EPA qualified this position with “provided the syngas has been adequately processed to remove contaminants.” The definition of gasification systems as stated in the proposed rule limits itself to only two-stage gasification where the syngas is cleaned to remove impurities prior to using it for energy production. The two-stage system as described in the proposed rule is only one of two gasification systems for energy recovery as described in a recent report published in July 2009 by National Research Energy Laboratories entitled “Market Assessment of Biomass Gasification and Combustion Technology for Small- and Medium-Scale Applications, NREL/TP-7A2-46190.” WEF recommends that EPA to modify its definition of the gasification system to include the close-coupled variety, which does not require syngas cleaning to remove impurities. Unintended Consequences WEF is concerned with the following unintended consequences of the proposed regulation: The narrow intent of the proposed regulation will become lost and will have an impact on land application and other forms of biosolids nutrient and energy recycling; The proposed regulation may have a detrimental effect on the energy recovery of wastewater solids which are a carbon neutral renewable energy source; The proposed regulation could significantly increase the amount of biosolids that are landfilled, thereby wasting the inherent nutrient and energy value of our biosolids; and The proposed regulation may significantly increase the cost for compliance for many wastewater agencies. EPA‟s consideration that landfilling is more economical than incineration fails to consider a number of factors. Incineration facilities are predominantly located in larger urban areas where hauling distances are long and roads are congested. For urban areas it is likely the average hauling distance is 100 to 150 miles each direction which could add approximately 50 million heavy truck miles to our roads each year. This notable traffic will increase fossil fuel use and the resulting emissions of greenhouse gases, particulate matter, nitrogen oxides, sulfur dioxides and other emissions. In addition, an increase in vehicular miles will statistically result in more traffic related injuries and deaths. EPA should also consider the environmental impact sewage sludge would have on greenhouse gas emissions at landfills. Fugitive emissions from even the best managed landfills would have a significant environmental impact. MACT Standards If the proposed rule is promulgated, EPA will be required to develop maximum achievable control standards for sewage sludge incinerators. WEF is concerned that EPA does not have sufficient data for either multiple hearth or fluid bed incinerators to properly develop standards that are achievable and statistically valid. The development of these standards is important to maintain sewage sludge incinerators as a viable biosolids management option. WEF notes the long and painful experience the medical waste incinerator industry underwent when EPA issued numerical emission limits that were not achievable. If MACT standards are proposed, WEF recommends that separate standards be developed for multiple hearth and fluid bed incinerators. In conclusion, WEF believes that EPA‟s focus should be the acceptable methods for managing biosolids that are protective of the environment and socially and economically beneficial rather than an arbitrary definition of biosolids which limits local management alternatives and could foster adverse environmental consequences. WEF thanks EPA for the opportunity to submit comments. If you have questions or require additional information concerning these comments, please contact Tim Williams at 703-684-2437 or Sam Hadeed at 703-684-2418. WEF Comments of the on the Proposed Rule on Identification of Non-Hazardous Secondary Materials That Are Solid Wastes. Electronically submitted on August 2, 2010 to: RCRA Docket ID No. EPA–HQ–RCRA–2008–0329 (Federal Register / Vol. 75, No. 107 / Friday, June 4, 2010 / Proposed Rules, pages 31844-31893. Sincerely, Tim Williams Senior Managing Director, Public Policy Water Environment Federation 601 Wythe Street Alexandria, VA 22314 twilliams@wef.org 703-684-2437 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 12, 2010 MSD Contract No. 2009145 B&V File 44.000 Appendix C National Association of Clean Water Agencies Comments on Proposed Rule Dated August 3, 2010 NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 2 of 18 EXECUTIVE COMMITTEE PRESIDENT Jeff Theerman Executive Director Metropolitan St. Louis Sewer District Saint Louis, MO VICE PRESIDENT David R. Williams Director of Wastewater East Bay Municipal Utility District Oakland, CA TREASURER Suzanne E. Goss Government Relations Specialist JEA (Electric, Water & Sewer) Jacksonville, FL SECRETARY Julius Ciaccia, Jr. Executive Director Northeast Ohio Regional Sewer District Cleveland, OH PAST PRESIDENT Kevin L. Shafer Executive Director Milwaukee Metropolitan Sewerage District Milwaukee, WI EXECUTIVE DIRECTOR Ken Kirk August 3, 2010 Proposed Rulemaking–Identification of Non-Hazardous Secondary Materials That Are Solid Waste U.S. Environmental Protection Agency Mailcode: 28221T 1200 Pennsylvania Ave., NW Washington, DC 20460 AttentionAttentionAttentionAttention:::: Docket IDDocket IDDocket IDDocket ID No. EPANo. EPANo. EPANo. EPA––––HQHQHQHQ––––RCRARCRARCRARCRA––––2008200820082008––––0329032903290329 Dear Sir or Madam: The National Association of Clean Water Agencies (NACWA) appreciates this opportunity to provide comments on the United States Environmental Protection Agency’s (“EPA” or “the Agency”) proposed rule titled “Identification of Non- Hazardous Secondary Materials That Are Solid Waste” (Proposed Rule). 75 Fed. Reg. 31844 (Jun. 4, 2010). NACWA represents the interests of nearly three hundred of the nation’s publicly owned wastewater treatment utilities (POTWs), which collectively serve the majority of the sewered population in the United States. For forty years, NACWA has maintained a leadership role in legal and policy issues affecting clean water agencies, and has been at the forefront of the development and implementation of scientifically-based, technically-sound, and cost-effective environmental programs for protecting public and ecosystem health. EPA’s Proposed Rule, if finalized, will have an immediate and significant impact on the ability of many of NACWA’s members to manage the thousands of tons of sewage sludge they generate on a daily basis. NACWA’s members rely on having multiple options for the management of this sludge, but the list of available options has slowly shrunk over the years for many municipalities. EPA’s proposed action will have a devastating impact on sewage sludge incineration – which is used to manage approximately a fifth of the sludge generated annually in the U.S. – and eviscerate progress toward a new, viable source of renewable energy for the country. Accordingly, NACWA requests that EPA: 1. Exercise its discretion and exclude or exempt sewage sludge that is combusted from the final rule’s definition of non-hazardous solid waste and preserve the current successful regulatory framework for sewage sludge and sewage sludge incinerators (SSIs) pursuant to the regulations contained within 40 C.F.R. Part 503 (Part 503). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 2 of 18 2 2. Recognize that sewage sludge and scum (a.k.a. skimmings, the floatable materials removed during wastewater treatment) are legitimate fuels. 3. Classify the energy recovery and energy production devices employed by POTWs, both as elements of the incineration process and as stand-alone processes, as legitimate energy recovery systems. 4. Strengthen the language in the Proposed Rule to clearly indicate that its determination that sewage sludge is a non-hazardous solid waste does not apply to, and will not impact, other sewage sludge management options regulated under Part 503. With these comments, NACWA urges EPA to adhere to Congress’ clear intent to provide for the safe use and disposal of sewage sludge, to preserve local control over these management choices, to promote the beneficial use of sewage sludge, and to preserve incineration as a safe, viable, and cost-effective management practice for sewage sludge. NACWA also requests that EPA decouple finalization of the Proposed Rule from the finalization of the proposed Commercial/Industrial Solid Waste Incinerators (CISWI) Definitions Rule, 75 Fed. Reg. 31938, and the proposed Boiler Maximum Achievable Control Technology (MACT) Rule, 75 Fed. Reg. 32005, both issued in the Federal Register on June 4, 2010. Finalization of the proposed rules in tandem is inappropriate as stakeholders must know what solid wastes are covered under the new rule before they can meaningfully comment on the solid waste incineration and boiler rules. I. EPA Should Preserve the Current Successful Regulatory Framework for Burning Sewage Sludge Pursuant To Part 503 A. EPA Can Exclude or Exempt Sewage Sludge from the Proposed Rule The Agency should provide a regulatory exclusion for sewage sludge burned in incinerators, which it sought comment on in the Proposed Rule. This will preserve the current framework for regulating sewage sludge under Part 503, which was developed under the authority of Clean Water Act (CWA) § 405 and the Resource Conservation and Recovery Act (RCRA).1 EPA clearly has discretion to take such action, and has exercised it to create several other RCRA definitional exclusions. 40 C.F.R. § 261.4 (excluding materials from regulation as hazardous wastes). EPA also has the discretion to exempt sewage sludge burned in incinerators. RCRA § 1006(b) requires EPA to integrate RCRA requirements with the requirements of the CWA and the Clean Air Act (CAA), as well as other laws. To prevent regulatory duplication, EPA has a non-discretionary duty to consider all environmental laws when promulgating regulations under RCRA. EPA has repeatedly exercised this discretion to ensure that waste management regimes created under other laws are not disrupted. For example, EPA exempted certain PBA- contaminated wastes from RCRA regulation because they are already managed under the Toxic Substances Control Act (TSCA). 40 C.F.R. § 261.8; 55 Fed. Reg. 11798, 11841 (Identification and Listing of Hazardous Waste) (March 29, 1990) (finding that “new regulation of these wastes under RCRA may be disruptive” and “does not appear to be necessary,” as “the regulation of these wastes under TSCA is adequate to protect human 1 75 Fed. Reg. 31866 (inviting comments on whether “it is within [EPA’s] discretion . . . . to provide a regulatory solid waste exclusion for sewage sludge burned in incinerators that would preserve the current framework for regulating sewage sludge managed under section 405 of the CWA to avoid redundancy”). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 3 of 18 3 health and the environment”). Similarly, EPA has exempted industrial ethyl alcohol from RCRA regulation because such regulation “was considered redundant” in light of comprehensive regulations already implemented by the Bureau of Alcohol, Tobacco and Firearms. 40 C.F.R. § 261.6(a)(3)(i); see 51 Fed. Reg. 28664, 28671 (Exports of Hazardous Waste) (August 8, 1986). Both Congress and EPA gave comprehensive and careful thought to the proper regulation of the use and disposal of sewage sludge under the CWA, the CAA and RCRA. Deeming sewage sludge a solid waste when incinerated for promulgation of a rule under CAA § 129 violates EPA’s non-discretionary duty to harmonize environmental laws under RCRA because emissions from SSIs are already comprehensively regulated under other statutes. EPA has both the authority and the duty to maintain the comprehensive sewage sludge management programs already in place under these laws and, accordingly, must exclude or exempt sewage sludge that is combusted from the Proposed Rule. B. EPA Should Exclude or Exempt Sewage Sludge from the Proposed Rule and Preserve the Current Successful Regulatory Structure for SSIs Since the 1960s, federal regulation of publicly owned treatment works (POTWs) and sewage sludge has evolved under the CWA, the CAA, and RCRA, culminating in recent decades in a complete and comprehensive program that proactively regulates all facets of the use of sewage sludge. In particular, the Part 503 regulations and CAA § 112 form a cohesive, time-tested regulatory framework that provides for the safe use and disposal of sewage sludge, including incineration and other beneficial uses. America’s clean water agencies have invested heavily in and depend on this clear regulatory system. 1. Sewage Sludge Quality and Incineration Is Strictly Regulated under the CWA Since 1993, POTWs that practice incineration have been subject to a comprehensive, risk-based program for reducing the potential environmental risks of sewage sludge pursuant to CWA § 405 and the implementing regulations set forth in Part 503. Section 405(d) of the CWA requires EPA to establish numeric limits and management practices that protect public health and the environment from the adverse effects of pollutants in sewage sludge. Section 405(e) of the CWA prohibits any person from disposing of sewage sludge from a POTW through any use or disposal practice for which regulations have been established pursuant to Section 405, except in compliance with the Part 503 regulations. In the Part 503 regulations, EPA has specified the management practices for the utilization and disposal of sewage sludge that are protective of public health and the environment. As established by the risk assessment for Part 503, emissions from the incineration of sewage sludge are low and do not pose a risk to public health or the environment. 58 Fed. Reg. 9248, 9249 (Feb. 19, 1993) (Standards for the Use or Disposal of Sewage Sludge) (“even when sludge is incinerated and the population potentially exposed to the incinerator emissions is greater, the effects are small”). To ensure the safety of sewage sludge incineration, Part 503 requires risk-based limitations for arsenic, cadmium, chromium, lead, and nickel; compliance with the National Standards for Hazardous Air Pollutants (NESHAPs) for mercury and beryllium; operational emission limits for total hydrocarbon (the surrogate for all potentially toxic organic compounds) or an alternative emission limit for carbon monoxide; and numerous other general management, monitoring, recordkeeping and reporting requirements. 40 C.F.R. Part 503, Subpart E. The numeric emission limits and management practice requirements established under the Part 503 regulations are based on one of the Agency’s largest risk assessments that was conducted in the late 1980s and NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 4 of 18 4 early 1990s to protect human health and the environment from any reasonably anticipated adverse effects from pollutants that may be present in sewage sludge.2 As a result, SSIs demonstrate that the emissions from their units are not adversely impacting human health and the environment by demonstrating compliance with the Part 503 requirements. Moreover, the Part 503 regulations are continually reviewed as EPA regularly identifies and performs risk assessments on newly identified pollutants. See, e.g., 66 Fed. Reg. 66228 (Dec. 21, 2001) (evaluating dioxin levels in sewage sludge and determining that “no further regulation of sewage sludge that is placed in a surface disposal unit or incinerated in a SSI is needed to protect public health and the environment from any reasonably anticipated adverse effects of dioxins”); 68 Fed. Reg. 75531 (responding to the National Research Council’s recommendations based on its review under Section 405(d)(2)(C)). Pursuant to 40 C.F.R. Part 403 (Part 403), POTWs additionally implement, through local regulatory authority, pretreatment standards to prevent discharge of pollutants to the POTW that may pass through or interfere with treatment processes. Pretreatment reduces harmful constituents in the sewage sludge combusted by incinerators. Pretreatment has dramatically reduced the contaminants in sewage sludge and accordingly emissions from SSIs have become cleaner. Comparison of the sewage sludge quality measured in the 1980s3 with the measurements in 2006-2007 Targeted National Sewage Sludge Survey shows a clear improvement in sewage sludge quality since Part 403 and 503 were implemented.4 Specifically, the Northeast Ohio Regional Sewer District (NEORSD), which serves the City of Cleveland and 61 suburban communities, has seen significant decreases in the concentrations of heavy metals in both its influent, attributable to the Part 403 regulations, and its effluent, attributable to both Part 403 and 503.5 Between 1980 and 2004, NEORSD has seen the concentration of lead in the influent reduced by 95% while the concentration of lead in the effluent was reduced by 100%.6 Given the reduction in metals entering wastewater treatment plants due to effective pre-treatment programs and the implementation of Part 503, there has been a significant reduction in air emissions from SSIs since the early 1970s. Many POTWs are able to lower emissions far below the site-specific metal concentration limits for burned sewage sludge calculated using the Part 503 risk-based formula because of improvements in scrubber devices and in operational techniques developed by POTWs to comply with the Part 503 limits including higher exhaust gas temperatures, lower burning zone temperatures, and higher pressure drops. For example, at NEORSD’s Southerly and Westerly wastewater treatment plants (Plants), emissions are only a fraction the of the Plants’ Part 503 regulatory limits for actual maximum metal and total hydrocarbon:7 2 EPA, A Guide to the Biosolids Risk Assessments for the EPA Part 503 Rule (1995), at 107 (“[T]he risk assessments quantitatively identified allowable concentrations or application rates of pollutants in biosolids that are used or disposed that protect human health and the environment from reasonably anticipated adverse effects.”). 3 See EPA, 40 City Study (1982); EPA, National Sewage Sludge Survey (1988). 4 See infra at Section II(c)(2)(b). 5 See Lita Laven, Frank Foley and Robert Dominak, Improvements in Biosolids Quality Due to EPA’s Pretreatment and Biosolids Programs, Residuals and Biosolids Management Conference 2006, at 142-147 [Attachment 1]. 6 Id. at 147, Table 1. 7 Southerly and Westerly Plants’ Part 503 Reports for 2009 provide additional details. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 5 of 18 5 Highest Actual Emissions as a Percentage of Regulatory Limit Southerly 2009 Westerly 2009 Arsenic 1% 3% Cadmium 4% 3% Chromium 1% 1% Lead 1% 7% Nickel 0.02% 0.03% Total Hydrocarbon 27% 6% The Plants’ beryllium and mercury emissions, as tested in 1993 and 1995 are also a fraction of the NESHAPS limits: Highest Actual Emissions as a Percentage of Regulatory Limit Southerly Westerly Beryllium 1% 0.4% Mercury 4% 2% The NEORSD Plants are not unique in their performance and use widely adopted technologies and operational standards. The dramatic decrease in metal concentrations in sewage sludge and the low metal and total hydrocarbon emission levels demonstrate that the CWA’s regulation of sewage sludge from pretreatment to incineration is both exhaustive and protective of human health and the environment. 2. Current Clean Air Act Regulation of Incineration of Sewage Sludge Is Effective and Should Not Be Abrogated Further reason for EPA to promulgate an exclusion or an exemption to the new solid waste definition that preserves the current regulatory regime for sewage sludge is that Congress wrote CAA § 112 to directly regulate sewage sludge emissions. Section 112(e)(5), promulgated in the 1990 CAA amendments, requires EPA to establish emission standards for hazardous air pollutants (HAPs) for POTWs. In particular, CAA § 112(e)(5) states: The Administrator shall promulgate standards pursuant to subsection (d) of this section applicable to publicly owned treatments works (as defined in Title II of the Federal Water Pollution Control Act [33 U.S.C.A. § 1281 et seq.]) not later than 5 years after November 15, 1990. 42 U.S.C. § 7412(e)(5). Congress’ express inclusion of POTWs, including SSIs, under CAA § 112 demonstrates express intent to regulate air emissions from SSIs under the CAA’s § 112 framework. EPA should implement this Congressional intent through an exclusion or exemption or under the rule. EPA has already regulated the incineration of sewage sludge as intended under CAA § 112, by identifying SSIs as an area source category under CAA § 112. In 2002, EPA determined that the SSI category does not have any sources with the potential to emit HAPs at a level approaching major source levels,8 and included SSIs as an 8 See National Emission Standards for Hazardous Air Pollutants: Revisions of Source Category List under Section 112 of the Clean Air Act, 67 Fed. Reg. 6521 (Feb. 12, 2002). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 6 of 18 6 additional area source category under CAA §§ 112(c)(3) and 112(k)(3)(B)(ii).9 EPA implemented these CAA § 112 requirements as Congress intended. The fact that EPA determined there was no basis under CAA § 112 to issue substantive air emission requirements for SSIs, because they all were area sources, is simply a recognition that the burning of sewage sludge did not trigger such regulation under the requirements established by Congress. Moreover, since 1974, EPA has also imposed New Source Performance Standards (NSPS) for SSIs under CAA § 111. See 40 C.F.R. Part 60, Subpart O. Under the existing NSPS for SSIs, regulated incinerators must comply with emission limits for particulate matter and opacity, as well as operational, monitoring, testing and reporting requirements. In addition to the federal requirements applicable to SSIs outlined above, public agencies operating SSIs are also required to obtain a Title V operating permit if they are “major sources” as defined by the CAA. States also have authority to regulate and, in fact, do regulate air emissions from SSIs under their respective CAA State Implementation Plans. Together, the CWA, CAA § 111 and CAA § 112 SSI emission regulations have protected human health and the environment for over twenty years. Defining sewage sludge that is combusted as a solid waste will result in the regulation of many SSIs under CAA § 129, which is contrary to Congressional mandate, is not appropriate or necessary for the protection of human health and the environment, and will impose huge costs on municipal agencies that are struggling to meet other environmental mandates. C. Supplanting Part 503 with a New Regulatory Regime Will Disrupt America’s Sewage Sludge Infrastructure with No Significant Improvements to Public Health EPA correctly recognized that the Proposed Rule will impose indirect costs through the Boiler MACT and CISWI proposed rules, which will, as currently proposed, compel regulation of SSIs under CAA § 129.10 The costs imposed will be huge and are not tied to clear environmental benefits or public health benefits for residents near SSIs. NACWA estimates total capital costs associated with SSI MACT standards imposed as a direct result of the Proposed Rule would be in excess of $3 billion, along with a substantial increase in operating expenses. There is no pressing public health rationale for saddling public agencies that incinerate with enormous new costs for upgrades and/or alternative management of sewage sludge. Moreover, while EPA assumes a certain public health benefit from a move away from incineration, the reality is that some of the other management options required if incineration is no longer a viable option may actually result in substantially higher emissions than incineration. NACWA estimates that 17%-22% of all sewage sludge generated in the U.S. is incinerated, which could be in the range of 4 to 6 million wet tons per year. Incineration results in complete destruction of all pathogens, emerging contaminants, pharmaceuticals and many other undesirable trace constituents of sewage sludge. Upgrades for compliance with CAA § 129 to incinerators that already safely and efficiently process nearly a quarter of the nation’s sewage sludge will be cost-prohibitive for many POTWs. Each incinerator would need to be outfitted with numerous different technologies to comply with the MACT standards.11 Roughly dividing the 9 See National Emission Standards for Hazardous Air Pollutants: Revisions of Area Source Category List under Sections 112(c)(3) and 112(k)(3)(B)(ii) of the Clean Air Act, 67 Fed. Reg. 43,112 (June 26, 2002). 10 75 Fed. Reg. 31889 (analyzing the costs under the Boiler MACT and CISWI proposed rules). 11 The necessary systems may include advanced scrubbing systems and/or wet electrostatic precipitators for reducing particulate matter and particulate-based metal emissions, the addition of sodium hydroxide and/or ammonia for reducing emissions of sulfur dioxide and (Continued …) NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 7 of 18 7 estimated costs among the 230 operative POTW incinerators, upgrades to each incinerator unit could cost over $13 million. POTWs operate on budgets that cannot accommodate tens of millions of dollars in additional capital costs and sizable increase in operating costs – with no appreciable environmental gain – particularly at a time of great economic distress coupled with the struggle of meeting other major regulatory obligations, including sewer overflow controls and nutrient reductions. For POTWs that cannot upgrade because of a lack of space or an inability to fund upgrades, the alternative management options are problematic. Land applying or landfilling sewage sludge are more expensive than incineration in the long term and provide no benefits such as energy recovery, decreased transportation costs, and decreased transportation emissions. For POTWs that currently incinerate all of their sewage sludge, significant resources would be necessary just to develop the loading, storage, and stabilization infrastructure required for land applying or landfilling. One wastewater treatment agency estimates that it will cost $9 million just to develop such infrastructure. Even where the infrastructure is already in place, the cost necessary to land apply or landfill more or all of a facility’s sewage sludge is prohibitive. The following are a few telling examples of the costs of incineration versus landfilling sewage sludge: · An agency in Minnesota estimates that the operations and maintenance (O&M) costs associated with incineration of sewage sludge are $200.00 per dry ton, including thickening. Because landfilled sewage sludge in Minnesota, like certain other states, must meet the Part 503 Class B pathogen reduction standards, the cost of landfilling is much higher. Minn. R. 7035.2535, Subp. 1, Item B. The estimated O&M costs necessary to prepare sewage sludge for landfill (i.e. alkaline stabilization) are $300.00 per dry ton, including thickening and landfill disposal fees ($100.00 per dry ton more expensive than incineration). · In North Carolina, one agency estimates that incineration costs $22 per wet ton, while landfilling costs $95 per wet ton ($73.00 per dry ton more expensive than incineration). · In Ohio, it was reported that the current cost for incineration is $157 per dry ton, while landfilling costs $312 per dry ton ($155.00 per dry ton more expensive than incineration). · At the NEORSD’s Southerly Plant, it costs over twice as much to landfill or land apply sewage sludge than to incinerate it. Moreover, land filling unit cost will substantially increase if incineration is no longer a viable option, and there are concerns about the remaining service life of the landfills in the area. · According to an EPA report, one California POTW “indicated that the cost of incinerating its waste treatment sludge is, on an annual basis, $4.3 million less than the cost of landfilling this material.”12 In addition, some states have limits on how much sewage sludge can be landfilled or eliminate in-state landfilling as a management option.13 Increased reliance on landfills and limits to landfill use will force (Continued …) oxides of nitrogen, activated carbon absorbing systems and/or activated carbon injection system for reducing mercury emissions, and internal or external afterburners for reducing carbon monoxide emissions. 12 EPA, Materials Characterization Paper on Wastewater Treatment Plants, March 18, 2010, p. 7. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 8 of 18 8 facilities to truck sewage sludge to increasingly distant landfills resulting in higher transportation costs, including fuel costs. Further increasing the burden on POTWs is the expectation that the cost differential between incineration and other management options will increase significantly in the coming years. NEORSD estimates that in 2013, the cost of incineration will be $4 less than it is today while the cost of landfilling will increase by $21 (per wet ton). Speaking in broad terms, in 2013 it will cost the facility $9 million per year more to landfill its sewage sludge than to incinerate it. Moreover, it will cost $10 to $11 million per year more for land application than incineration. This would substantially impact the NEORSD’s current O&M budget of $40 to $45 million per year. Particularly for the numerous large cities that rely on incineration, landfilling and land application will always be more expensive alternatives. The significant costs to POTWs will be passed on to the rate payers. In the immediate future, rates are expected to increase dramatically even without the implementation of the Proposed Rule because of the well-documented funding challenges facing POTWs as they expand infrastructure and meet EPA mandates for prevention of overflows and nutrient loading. NEORSD estimates that its rates will double within six years due to the implementation of a $3 billion combined sewer overflow control program and currently required improvements at its three treatment plants. In addition to increased costs, land application and landfilling may actually result in higher emissions than those produced during incineration because of the distances sewage sludge must be transported. Through a detailed analysis of priority pollutant emissions associated with incineration, landfilling and land application, NEORSD and its consultants found that emissions of carbon monoxide, nitrogen oxide, and organics from three new fluidized bed incinerators being constructed at the Southerly Plant will be lower or equal to the emission levels from land application and landfilling, as follows: PollutantPollutantPollutantPollutant Three Fluidized Three Fluidized Three Fluidized Three Fluidized Bed IncineratorsBed IncineratorsBed IncineratorsBed Incinerators Total EmissionsTotal EmissionsTotal EmissionsTotal Emissions Trucks Trucks Trucks Trucks EmissionsEmissionsEmissionsEmissions LandfillLandfillLandfillLandfills s s s (round(round(round(round----trip)trip)trip)trip) Trucks Trucks Trucks Trucks Emissions Emissions Emissions Emissions Land Application Land Application Land Application Land Application SitesSitesSitesSites (round(round(round(round----trip)trip)trip)trip)**** Carbon Monoxide 3 4 7 Oxides of Nitrogen 44 46 71 Sulfur Dioxide 6 4 6 Organic Compounds 1 3 4 The calculated emissions above include only the projected air emissions from the three new fluidized bed incinerators and the trucks that would be used to transport the sewage sludge from the Southerly Plant to landfills or land application sites. It does not include any additional emissions once the sewage sludge reaches the landfill or land application site. In addition, since the Southerly Plant does not have digesters, nor the room to construct them, the only way to produce a land applicable product is through alkaline stabilization, which will increase emissions even further due to the emissions associated with the trucking of the lime from the quarry to the plant. (Continued …) 13 See State of Connecticut Solid Waste Management Plan at 4-64 (“Sewage sludge, which is generated by the 111 wastewater treatment plants located in Connecticut, is managed in three ways: shipped out-of-state for management, composted at one of two composting sites in-state, or sent to one of the six sewage sludge incinerators located within Connecticut.”). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 9 of 18 9 By forcing a switch to landfilling, the Proposed Rule also negatively affects the environment by placing recyclables in landfills, which will significantly impact landfill capacity/life. Organizations including the National League of Cities, U.S. Conference of Mayors, and the Association of State and Territorial Solid Waste Management Officials have already expressed concerns to EPA regarding the Agency’s presumption that many SSIs will be abandoned in favor of landfilling and the associated cost assumptions in the context of the proposed SSI MACT standards. In preliminary discussions over the proposed standards, EPA confirmed that it has not factored dwindling landfill capacity and the significant cost to construct new landfills into its economic analysis on the MACT standard proposal. Incineration may also be the best management option for minimizing greenhouse gas emissions. Faced with potential regulatory changes and potential increases in all of its wastewater residuals management costs, in 2008 the NEORSD asked a Blue-Ribbon Panel (Panel) of seven internationally renowned sewage sludge management professionals to evaluate sewage sludge management alternatives.14 The Panel determined that the installation of new fluidized bed incinerators at the Southerly Plant was the most viable, cost-effective and environmentally friendly option for sewage sludge management. The following is a summary of the Panel’s greenhouse gas emissions analyses: Sewage Sludge Sewage Sludge Sewage Sludge Sewage Sludge ProcessingProcessingProcessingProcessing Greenhouse Gas EmissionsGreenhouse Gas EmissionsGreenhouse Gas EmissionsGreenhouse Gas Emissions (Metric Tons CO(Metric Tons CO(Metric Tons CO(Metric Tons CO2222----equivelent/year)equivelent/year)equivelent/year)equivelent/year) Fluidized Bed Incineration with Energy Recovery and Electricity Production ----10,500*10,500*10,500*10,500* Fluidized Bed Incineration without Energy Recovery 5,700 Landfilling (transport fuel + decay) 25,000 * Includes reduced emissions from purchased power (i.e., reduced power plant emissions). The Panel also noted that greenhouse gas emissions associated with land application would likely be higher than incineration for NEORSD, but did not have time to conduct the analysis. While the emissions reported above are specifically for the Southerly Plant, conversion from incineration to landfilling or land application will also result in an increase in greenhouse gas emissions for numerous other POTWs. Ultimately, the elimination of incineration as a viable, cost-effective and environmentally friendly sewage sludge management option will result in substantial increases in capital expenditures, operating and maintenance costs, emissions of priority pollutants and/or emissions of greenhouse gases for many POTWs. II. Sewage Sludge Is a Legitimate Fuel and Not a Solid Waste Pursuant to RCRA, and the preamble to the Proposed Rule, legitimate use and recycling are critical factors in determining whether a material is not “discarded” and therefore is not a solid waste. 75 Fed. Reg. 31844, 31851. If EPA does not grant an exclusion or exemption for sewage sludge, it should determine based on the data provided in these comments that sewage sludge is a legitimate fuel and that it is being recycled for beneficial uses. 14 Residuals Management Validation Panel, Summary of Findings and Recommendations (Aug. 29, 2008) [Attachment 3]. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 10 of 18 10 A. Sewage Sludge Incineration Is a Valuable Energy Recovery Source Sewage sludge and scum incineration for energy recovery embodies the concept of legitimate use and recycling and the proposed Rule did not address these important RCRA concepts. Sewage sludge is an organic, renewable resource with the potential to become an important component of the country’s renewable energy portfolio. Sewage sludge contains approximately 8,000 Btu/lb on a dry basis (2,000 Btu/lb on an as received basis assuming 25% solids) and can generate 2.3 kWh/lb.15 In reliance on the current Part 503 regulatory structure, significant technological innovation is underway involving energy production from the combustion of sewage sludge, both as a component of the incineration process and through stand-alone combustion processes. The Proposed Rule would halt the advancement of these technologies as they come under the onerous requirements of CAA § 129 and undermine Congressional directives to limit greenhouse gas emissions.16 In addition, implementation of the Proposed Rule could disrupt carefully crafted state regulatory schemes that encourage beneficial use.17 Sewage sludge can provide significant amounts of power for facility operations and for the nation’s energy grid. At one facility, for example, heat from the incineration of sewage sludge is converted into high pressure steam, in boilers, that powers a steam turbine generator producing over 5 megawatts of electricity. While the potential for energy production is high, POTWs need support from EPA to promote the use of this sustainable and renewable energy resource.18 Not only does the Proposed Rule fail to promote the use of alternative fuels, but the Proposed Rule serves as a major disincentive for many current and developing energy recovery projects. In addition to the loss of the beneficial use from these projects, there will also be an addition of fuel use and costs to replace recovered energy. Many facilities are currently maximizing sewage sludge utilization while minimizing fossil fuel use: · A sanitary district in California reports that incineration of wastewater treatment sludge saves the district $320,000 per year in energy costs by avoiding natural gas costs.19 · The NEORSD’s Southerly Plant reports that it saves $600,000 to $700,000 per year in natural gas costs by operating waste heat boilers. In October 2000, U.S. EPA presented the NEORSD with a special beneficial use of sewage sludge award for energy conservation due to the use of a waste heat recovery system during incineration of sewage sludge at the Southerly Plant. The efforts of these agencies to beneficially use sewage sludge may no longer be viable if the Proposed Rule is implemented. Furthermore, agencies in the process of constructing infrastructure to maximize sewage sludge energy recover may find their investments negated by the Proposed Rule: 15 See NACWA, Renewable Energy Resources: Banking on Biosolids (2010) at p. 3 [Attachment 2]. 16 See, e.g., Energy Independence and Security Act (EISA), 42 U.S.C § 17001 et seq. (2007). 17 Some states currently exempt from solid waste regulations incinerators or energy recovery facilities that incinerate wastes generated by the facility that owns the incinerator or energy recovery facility. See, e.g., Ohio Administrative Code 3745-27-03(A)(5). The Proposed Rule opens the door for revocation of these exemptions and the potential for states to impose additional solid waste regulations on SSIs. 18 See NACWA, Renewable Energy Resources (detailing sewage sludge energy products, technologies, and barriers to widespread adoption of these technologies). 19 EPA, Materials Characterization Paper on Wastewater Treatment Plants, March 18, 2010, p. 7. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 11 of 18 11 · NEORSD is in the process of constructing a new Renewable Energy Facility at its Southerly Plant that will include three new waste heat boilers and a steam turbine generator in conjunction with three new fluidized bed incinerators. The cost to purchase and install this equipment and to construct the steam turbine generator building was $22 million with payback expected in 11 years. High pressure steam produced by new waste heat boilers will power a steam turbine generator that produces electricity, which will be used to run the incinerators and ancillary equipment. The steam turbine generator will produce 2.6 megawatts, while the plant’s electrical demand is 13 megawatts. During the first year of operations, the cost savings associated with the steam turbine generator will be $1.5 million, while greenhouse gas emissions associated with the reduced electrical power demands will be 16,000 metric tons CO2e. The Proposed Rule could dramatically impact the Southerly Plant’s $149 million Renewable Energy Facility. First, because there is only a limited amount of space around the new building, there may not be enough room to install all of the additional equipment that may be necessary to meet the final MACT Standards. Second, depending on the final MACT Standards, the layout of the equipment in the new building may need to be altered to facilitate compliance. Third, if for some reason the new MACT Standards are unachievable, the NEORSD’s only viable management option would be landfilling. The cost to construct new sludge storage and truck loading facilities to fill 10,500 trucks per year could be in excess of $50 million. In addition, hauling costs and tipping fees would be approximately $18 million per year, far more than it costs to use the sewage sludge for energy recovery. In sum, implementation of the Proposed Rule could eliminate energy recovery options for POTWs, create disincentives for POTWs to use energy recovery in the future, increase POTW dependence on fossil fuels, and increase reliance on less beneficial uses for sewage sludge management. B. Sewage Sludge Incinerated for Energy Recovery Is Not Discarded As described in detail above, incineration of sewage sludge is an important source of energy and plainly meets the flexible criteria courts have established for when a waste is not “discarded” and, therefore, not a solid waste. When this process is compared to the dictionary definition of “discard,” it is clear that sewage sludge incinerated for energy recovery is not discarded because it is not cast aside, rejected, abandoned or given up.20 In addition, this sewage sludge is beneficially reused in a continuous process of water treatment by the water treatment industry, American Mining Congress v. EPA, 824 F.2d 1177, 1186 (D.C. Cir. 1987); the sewage sludge is beneficially used shortly after its production and it is not stored for potential reuse, American Mining Congress v. EPA, 907 F.2d 1179, 1186 (D.C. Cir. 1990); and, the sewage sludge is being used by its producers, and not by a reclaimer, United States v. ILCO, 996 F.2d 1126, 1131 (11th Cir. 1993).21 Sewage sludge, a largely organic fuel that satisfies EPA’s standards for a valuable product, is a legitimate fuel rather than a discarded waste. 20 Safe Air For Everyone v. Waynemeyer (Safe Air), 373 F.3d 1035, 1041 (9th Cir. 2004) citing The New Shorter Oxford English Dictionary 684 (4th ed. 1993). 21 Through assessment of the definition of “discard” and the above test derived from relevant rulings of the circuit courts, the Ninth Circuit recently held that Kentucky bluegrass residuals are not solid wastes when they are burned in the fields as part of the continuing growing process. Safe Air, 373 F.3d 1035. Sewage sludge incineration for energy recovery is analogous to the burning of Kentucky bluegrass because the heat created is used to power onsite sewage management operations. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 12 of 18 12 C. Sewage Sludge Is a Legitimate Fuel EPA has long-recognized that under RCRA a fuel is not discarded and is not a solid waste. EPA’s legitimacy criteria for qualification of a waste as a fuel are easily satisfied by sewage sludge and scum. NACWA in these comments is providing data and context to demonstrate that sewage sludge indeed meets the legitimacy criteria and its combustion, via incineration or some other process, for energy recovery is legitimate reuse and recycling. 1. Sewage Sludge Has a Meaningful Heating Value and Is Managed as a Valuable Commodity EPA is proposing that non-hazardous secondary materials must have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy to be considered legitimate fuels. Proposed Rule § 241.3(d)(1)(i). First as previously discussed, sewage sludge has a heating value of approximately 2,000 Btu/lb as received. EPA’s proposed minimum of 5,000 Btu/lb as received22 overlooks the significant energy recovery potential at lower levels of Btu/lb. Combustion of dewatered sewage sludge in an incinerator provides net energy that can reduce or eliminate fossil fuel usage within the incinerator unit and provide heat for energy recovery and/or energy production purposes. NACWA requests that EPA eliminate the arbitrary minimum heating value restriction to enable the significant heating value of sewage sludge to be captured and beneficially reused via incineration. Those sludges that are not incinerated and that are further dried and processed for burning in other combustion units would meet the proposed minimum Btu/lb criterion. Second, EPA’s determination that waste heat boilers do not qualify as “combustion unit[s] that recover[] energy” is arbitrary and does not recognize the significant value of waste heat boilers and their role in energy generation and beneficial use of sewage sludge. At the Southerly Plant, for example, four waste heat boilers have replaced the need for significant amounts of natural gas resulting in substantial reductions in air emissions and $14 million in natural gas related cost saving over a 25 year period. Consistent with RCRA, this sewage sludge was burned to produce heat for boilers and is not discarded solid waste. EPA’s reliance on the definition of energy recovery combustion units for hazardous waste management overlooks the fact that the Proposed Rule is focused on non-hazardous wastes, which can be burned with much less risk than hazardous wastes and can greatly reduce reliance on fossil fuels. Further, EPA’s determination of what constitutes a legitimate fuel should not hinge on how the energy recovery is made. EPA’s categorical exclusion of waste heat boilers as a legitimate energy recovery unit is too broad and must be eliminated or narrowed to ensure valuable renewable energy sources can remain in operation. EPA is also proposing that non-hazardous secondary materials used as fuels be managed as valuable commodities. Proposed Rule § 241.3(d)(1)(i). NACWA believes sewage sludge meets this criterion based on a review of the factors listed in Section 241.3(d)(1)(i). Specifically, sewage sludge is not stored for unreasonable times. In fact, for most POTWs that practice incineration, there is no storage at all of the sewage sludge. Sludge is transferred directly to the SSI via pipe. An equalization tank may be used to dampen diurnal variation in sludge production, but there is no storage. Some agencies, including those that digest their sludge before incineration, may have storage capabilities, but SSIs are operated based on a constant, stable feed of sludge. Sludge handling and feed systems are managed as just another process stream in a steady-state wastewater treatment and incineration operation, with no storage required. Where storage is necessary for short periods, sewage sludge is adequately contained to prevent releases to the environment. 22 See 75 Fed. Reg. 31844, 31871. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 13 of 18 13 2. The Proposed Contaminant Level Criterion Is Inadequate and EPA’s Assessment of Sewage Sludge under this Criterion Is Flawed In addition to meeting the heating value and management as a valuable commodity criteria, sewage sludge also meets the contaminant level criterion proposed by EPA. In the preamble to the Proposed Rule, however, EPA indicates that contaminant levels preclude sewage sludge from designation as a legitimate fuel. 75 Fed. Reg. 31844, 31867. NACWA’s comments demonstrate that sewage sludge meets the contaminant level criterion as proposed and that EPA’s determination that sewage sludge does not meet this criterion is based on outdated data. NACWA also believes that EPA’s contaminant level criterion is too simplistic and excludes valuable, clean burning alternative materials from use as a legitimate fuel. Sewage sludge – a safe, organic fuel that has undergone a thorough risk assessment with its few contaminants currently regulated and evaluated – is a legitimate fuel. (a) The Proposed Contaminant Level Criterion Is Inadequate EPA is proposing a legitimacy criterion under which non-hazardous secondary materials used as fuels in combustion units must contain contaminants at levels that are comparable to those in traditional fuel products. Proposed Rule § 241.3(d)(1)(iii). According to the Agency, the contaminant level criterion “is necessary because non-hazardous secondary materials that contain contaminants that are not comparable in concentration to those contained in traditional fuel products or ingredients would suggest that these contaminants are being combusted as a means of discarding them.” 75 Fed. Reg. 31844, 31871-72 (emphasis added). The suggestion of an intent to discard is not sufficient to categorize an entire class of non-hazardous secondary material as a solid waste particularly when there is ample evidence that the material is used beneficially for energy recovery. The application of this contaminant criterion to sewage sludge must also be reevaluated because the Proposed Rule is not predicated on any sewage sludge incinerator emissions data. If the burning of a non-hazardous secondary material replaces the use of a traditional fuel and has lower emissions than that traditional fuel, its use should be encouraged. EPA should assess the legitimacy of non-hazardous secondary materials as a fuel on the basis of emissions. The premise of EPA’s Emission-Comparable Fuel Exclusion would work very well with non-hazardous secondary materials because EPA would not need to impose regulations that obliterate the usefulness of the exclusion. Because the materials dealt with here are non-hazardous, there would be none of the combustion and storage concerns that led to the recent withdrawal of the Emission-Comparable Fuel Exclusion Under RCRA for Hazardous Wastes.23 It is only logical that a non-hazardous secondary material should be considered a legitimate fuel if emissions from an incinerator burning this material is comparable to the emissions from an industrial boiler burning traditional fuels. (b) EPA’s Assessment of Sewage Sludge under the Contaminant Level Criterion Is Flawed 23 75 Fed. Reg. 33712 (June 15, 2010) (Final Withdrawal); see also 74 Fed. Reg. 64643, 64647 (Dec. 8, 2009) (Proposed Withdrawal) (finding that the exclusions “require more resources and more attention from the regulatory agency than a subtitle C approach to reach a comparable level of assurance that appropriate combustion conditions are met” and that some hazardous wastes “pose a greater storage hazard than fuel oil”). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 14 of 18 14 EPA’s assessment of sewage sludge under the proposed contaminant criterion is based on outdated data and EPA must reevaluate its position in light of more recent data. EPA stated that it does not believe sewage sludge can meet the contaminant level criterion. 75 Fed. Reg. 31844, 31867 (“[M]unicipal sewage sludge contains metals that are typically higher in concentrations when compared to traditional fuels (e.g., coal and fuel oil) . . . . As such, the Agency does not believe that sewage sludge would meet the legitimacy criteria for contaminants.”). EPA based this determination on one summary-level table, which contains sewage sludge contaminant levels from outdated sources. EPA’s flawed determination rests on the 1982 40 City Study and the 1988 National Sewage Sludge Survey (NSSS), not the much more recent 2006-2007 Targeted National Sewage Sludge Survey (TNSSS), which shows dramatically lower contaminant levels: ElementElementElementElement 40 City Study40 City Study40 City Study40 City Study24 1982198219821982 NSNSNSNSSSSSSSSS25 1988198819881988 TNSSSTNSSSTNSSSTNSSS26 2006200620062006----2002002002007777 CoalCoalCoalCoal27 mg/dry kg Arsenic 9.9 6.7 6.9 10 Cadmium 69 6.9 2.6 0.5 Chromium 429 119 80 20 Lead 369 134.4 76 40 Mercury 2.8 5.2 1.2 0.1 Nickel 135.1 42.7 48 20 Selenium 7.3 5.2 7 1 Clearly, the older data do not reflect the significant advances in pretreatment, the decline of heavy polluting manufacturing processes, and the implementation of the Part 503 regulations in the mid-1990s, all of which make sewage sludge much cleaner for fuel purposes and protect public health. EPA’s own documents acknowledge the significant reductions in pollutant loadings were made in the late 1980s and early 1990s – after the sewage sludge studies relied upon for the Proposed Rule were conducted.28 EPA’s flawed determination also overlooks the fact that sewage sludge quality is already heavily regulated by the CWA. The National Pretreatment Standards in Part 403 prevent the introduction of pollutants into POTWs and are meant to “improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.” 40 C.F.R. § 403.2. In addition, Part 503 regulations provide risk-based limits for incinerated sewage sludge contaminants and that the Agency has previously determined that when contaminant levels are below these limits, no significant public health or environmental risk exists.29 Other non-hazardous secondary 24 Cited by EPA at 75 Fed. Reg. 31867. 25 Id. 26 All values are based on the mean of aggregated samples from Appendix B-3 of the TNSSS Statistical Analysis Report available at http://epa.gov/waterscience/biosolids/appendixb.pdf. 27 Cited by EPA at 75 Fed. Reg. 31867. 28 OIG, EPA Needs to Reinforce its National Pretreatment Program, Report No. 2004-P-00030 (Sept. 28, 2004). 29 58 Fed. Reg. 9249 (“EPA is confident that the regulations it is promulgating today adequately protect public health and the environment from all reasonably anticipated adverse effects, as required by section 405(d), for several reasons” including that “even when sludge is incinerated and the population potentially exposed to the incinerator emissions is greater, the effects are small”). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 15 of 18 15 materials considered in the Proposed Rule do not have these highly researched and restrictive contaminant levels in place including the biomass group, construction and demolition materials, scrap tires, scrap plastics, spent solvents, coal refuse, and used oil. Through the Part 403 pretreatment program and the Part 503 regulations, sewage sludge contaminants are already managed to levels sufficient for sewage sludge to be classified as a legitimate fuel. Further, when current sewage sludge contaminant level data is examined, there is no significant difference in the metal content of sewage sludge and traditional fuels. The coal contaminant values relied on by EPA do not demonstrate that coal contaminants are significantly lower than those in sewage sludge. In addition, the coal contaminant values, as presented by EPA, do not show the large range of contaminant levels in coal used for fuel. As stated in the Clarke and Sloss report from which the coal contaminant values were derived, “[t]race element concentrations vary enormously between coals from different sources, and even between coals from the same seams. The overall physical and chemical properties of a feed coal may be greatly altered by the mining, handling and cleaning processes prior to combustion or gasification.”30 The “enormous” variability in coal contaminant values indicates that much of the coal combusted in the U.S. is likely to have one or more of the above contaminants at a higher concentration than the “typical” coal contaminant values EPA cites. When making its determination regarding contaminant levels, EPA also overlooked the variability in sewage sludge contaminant levels. Because contaminant concentrations vary from plant to plant due to differences in industrial loadings and background concentrations, it is inappropriate to categorize all sewage sludge based on mean contaminant values. Accordingly, EPA’s blanket determination that sewage sludge contains metals that are typically higher in concentration when compared to coal is flawed. NACWA requests that EPA reevaluate the comparableness of sewage sludge to coal in light of the TNSSS survey. In addition, if necessary, EPA should consider a facility-by-facility determination of whether this criterion is met. III. EPA Should Explicitly Limit the Scope of the Proposed Rule NACWA and the regulated community are concerned that defining sewage sludge that is combusted as a solid waste in the Proposed Rule could have unintended effects on other forms of sewage sludge management, particularly at the state level. NACWA appreciates that EPA already has explicitly limited the purpose of the Proposed Rule to “identification of the requirements and procedures for the identification of solid wastes used as fuels or ingredients in combustion units under section 1004 of the Resource Conservation and Recovery Act and section 129 of the Clean Air Act.”31 While it appears to be EPA’s view that this Proposed Rule does not affect Part 503 and state analogs, there is, however, a potential that the Proposed Rule will affect the states’ ability to implement state biosolids management programs. There is also the potential that the Proposed Rule could lead to an unnecessary increase in lawsuits challenging other forms of sewage sludge management. Accordingly, if EPA decides not to exercise its discretion and exclude or exempt sewage sludge from its regulatory definition of non-hazardous solid waste for combustion, EPA must more explicitly state that the final rule has no regulatory effects or implications for sludge that is not incinerated. Without clear and definitive limitations on the designation of sewage sludge as a solid waste for this rule only, state regulators may mistakenly modify or eliminate current exemptions that allow for beneficial use of 30 Clarke, L.B. and Sloss, L.L., Trace Elements-Emissions from Coal Combustion and Gasification, International Energy Agency Report CR/49, London (1992), p. 26. 31 Proposed Rule § 241.1. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 16 of 18 16 biosolids at the state level. Moreover, state regulators may react differently to implementation of the Proposed Rule because states allocate the responsibility for sewage sludge management to different divisions of each state’s environmental agency. As of 2008, twenty-nine states regulate sewage sludge under the water program, eight states regulate sewage sludge under the solid waste program, and eight states regulate sewage sludge under both the water and solid waste programs.32 States that exempt sewage sludge from regulation under their solid waste programs – relying expressly or implicitly on their understanding of a broad federal exemption – may face the most uncertainty.33 Such states may be compelled to revoke the exemption and reclassify sewage sludge as solid wastes, which could significantly alter the state’s sewage sludge management scheme. States that have created specific regulations for sewage sludge separate from the solid waste regulations may also face difficulties should the Proposed Rule be finalized as drafted.34 Furthermore, for states that currently manage sewage sludge as a solid waste, there are questions regarding at what point in the treatment process sewage sludge becomes a solid waste and states could determine that RCRA obligations attach at different points in the treatment process. The current Proposed Rule only stands to further complicate these management questions. Because of this uncertainty, NACWA requests that EPA more explicitly state that the final rule shall have no regulatory impact on sewage sludge that is not incinerated. IV. The Domestic Sewage Exemption Prevents EPA from Regulating Sewage Sludge as a Solid Waste Finally, NACWA believes the Domestic Sewage Exemption (DSE) in RCRA makes the Proposed Rule inapplicable to sewage sludge and that accordingly EPA lacks the legal authority to promulgate the rule. RCRA defines “solid waste” as: any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities, but does not include solid or dissolved material in domestic sewage . . . . RCRA § 1004(27) (emphasis added). Accordingly, sewage sludge from POTWs is exempt from the definition of “solid waste” as “solid or dissolved material in domestic sewage.” Through the DSE, Congress recognized that treated sewage sludge does not qualify as a solid waste. See also 40 C.F.R 261.4(a)(1). 32 See 2008 NEBRA National Biosolids Regulation, Quality, End Use & Disposal Survey at 19 (5 states were not classified). 33 See, e.g., Ohio Administrative Code 3745-27-03(A)(8)(b) (excluding land applied sewage sludge from regulation under the state solid waste rules and defining sewage sludge as “as a solid, semi-solid or liquid residue generated during the treatment of sewage in a treatment works”) (emphasis added); North Carolina General Statutes 130A-290(c)(35)(b)(1) (excluding from the definition of solid waste “solid or dissolved material in [d]omestic sewage and sludges generated by treatment thereof in sanitary sewage collection, treatment and disposal systems which are designed to discharge effluents to the surface waters.”). 34 For example, in Minnesota, “waste” is defined in Minn. Stat. 115A.03, subd. 34 as “solid waste, sewage sludge and hazardous waste.” Each term is then defined separately (Minn. Stat. 116.06, subd. 22, Minn. Stat. 115A.03 and Minn. Stat. 116.06, subd. 11, respectively), creating separate regulatory universes for each. Minn. R. chapters 7035, 7041 and 7045. NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 17 of 18 17 This concept of a broad POTW exemption was established by Congress as early as 1965 in the Solid Waste Disposal Act.35 This was an early recognition that a comprehensive solid waste program, designed primarily to address hazardous wastes, did not apply to POTWs as long as they were effectively regulated under the CWA, which has always been and remains the primary statutory authority for comprehensive regulation of POTW operations. The Solid Waste Disposal Act and RCRA included the Domestic Sewage Exclusion in explicit recognition of this critical policy choice.36 Indeed, as EPA began its long efforts to define “solid waste” and “hazardous waste” for purposes of Subtitle C of RCRA, the Agency explicitly understood and discussed the importance of the comprehensive federal sewage sludge management program. For example, in the 1980 preamble to EPA’s development of the Subtitle C regulations, EPA describes the importance, scope and ultimate supremacy of the to-be developed CWA § 405 program, indicating that, once this program was in place, it would serve as the comprehensive regulations for use and disposal of sewage sludge. 45 Fed. Reg. 33084, 33102 (May 19, 1980) (“Once such a regulation is in place, sewage sludge will be exempted from coverage under other sets of regulations.”). EPA has similarly interpreted the scope of the DSE to include sewage sludge generated by POTWs in the preamble to the Agency’s 1990 Final Rule to identify and list hazardous wastes for petroleum refinery process wastewaters. EPA concluded that POTW sewage sludge falls within the DSE: These wastes [P038 and K048 wastes] are being added to the list of [hazardous] wastes . . . in order to regulate sludges generated at wastewater treatment facilities on site at petroleum refineries as well as sludges generated at off-site wastewater treatment facilities.14. . . 14 It should be noted that if wastewaters generated at petroleum refineries are discharged to a POTW and such wastewaters are mixed with domestic sewage from nonindustrial sources, the sludges generated in the POTW are covered under the domestic sewage exclusion and are not included in today’s listings. 55 Fed. Reg. 46354, 46364 (Nov. 2, 1990) (emphasis added). Thus, there has been a clear recognition for over 30 years that sewage sludge is different than solid waste for regulatory purposes, and that sewage sludge is primarily regulated under the CWA, not RCRA. Furthermore, when Congress incorporated RCRA’s definition of “solid waste” in CAA § 129 in 1990, Congress was well aware that the DSE was encompassed in the definition of “solid waste” and that CAA § 129 would not apply to sewage sludge. This statutory exemption for sewage sludge – the subject of broad consensus and reliance in the regulated community – can not be abrogated by subsequent rule making or preamble statements. Moreover, the 1987 CWA amendments and the subsequent Part 503 rules established a management program for sewage sludge dependent on its exclusion from RCRA regulation. Lastly, the statutory and regulatory provisions that implement the sewage sludge management program distinguish between sewage sludge and solid waste, and thereby demonstrate that they are different types of material. For example, the preamble to the Part 503 rules states that: 35 Solid Waste Disposal Act, Pub. L. 89-272, 79 Stat. 992 (1965). 36 Solid Waste Disposal Act, Pub. L. No. 89-272, § 203(4), 79 Stat. 992, 998 (1965) (defining the term “solid waste” to exclude “solids or dissolved material in domestic sewage or other significant pollutants in water resources . . . .”); accord Resource Conservation and Recovery Act, Pub. L. No. 94-580, § 1004, 90 Stat. 2795, 2801 (1976). NACWA Comments on Definition of Solid Waste Rule August 3, 2010 Page 18 of 18 18 The standards also do not apply to sewage sludge that is co-incinerated with large amounts of solid waste . . . . However, the standards established in the rule do apply to sewage sludge that is incinerated in a sewage sludge incinerator with incidental amounts of solid waste use as an auxiliary fuel (i.e., 30 percent or less solid waste by weight). 58 Fed. Reg. 9248, 9253. In keeping with the distinctions drawn by Congress between sewage sludge and solid waste, EPA’s careful regulatory approach in the Part 503 regulations distinguishes between sewage sludge and solid waste. The DSE under RCRA is implemented through and supported by the comprehensive programs for sewage sludge management that have been carefully developed under CWA § 405 and RCRA. The proposed abrogation of the DSE places RCRA regulatory responsibilities on POTWs that Congress fully intended would not apply due to strict regulation of POTWs under the CWA. Losing the DSE will “federalize” decisions over how sewage sludge must be managed, which directly contravenes Congress’ preservation in the CWA of local control over sewage sludge management options. * * * In summary, NACWA requests that EPA: 1. Exercise its discretion and exclude or exempt sewage sludge that is combusted from the final rule’s definition of non-hazardous solid waste. 2. Recognize that sewage sludge and scum are legitimate fuels. 3. Classify the energy recovery and energy production devices employed by POTWs as legitimate energy recovery systems. 4. Clearly state that the rule does not apply to and will not impact other sewage sludge management options regulated under Part 503. Please contact Chris Hornback at chornback@nacwa.org or 202-833-9106 with any questions regarding NACWA’s comments. Sincerely, Ken Kirk Executive Director Attachments BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 1 TECHNICAL MEMORANDUM NO. 8 GREENHOUSE GAS EMISSIONS To: Metropolitan St. Louis Sewer District From: Patricia Scanlan, Jane Yang, Bently C. Green _____________________________________________________________________________ This Technical Memorandum (TM) provides a discussion of greenhouse gas (GHG) emissions projected for each solids processing alternative considered for the current biosolids evaluation. Section 2 defines the organizational and operational boundaries of the evaluations. Section 3 reviews the emission factors methodology used to calculate emissions from each source. Final emission values for each alterative are given in Section 5. These results are discussed in Section 6. Table of Contents Table of Contents ............................................................................................................................ 1 1. Background .......................................................................................................................... 2 a. Basis for Considering Greenhouse Gas Emissions .......................................................... 2 b. Purpose of Greenhouse Gas Emission Calculations ..................................................... 5 c. Overview of LGO Protocol .............................................................................................. 6 2. GHG Boundary Conditions.................................................................................................. 7 a. Organizational Boundary (Operational Control Approach) ............................................. 7 b. GHG’s Emissions Included in Evaluation .................................................................... 9 c. Biogenic Emissions ........................................................................................................ 10 3. GHG Emissions Evaluation Calculation Methodology ..................................................... 11 4. Uncertainty Analysis .......................................................................................................... 12 a. Uncertainty Analysis Overview ..................................................................................... 12 b. Scope 1 Process Emissions ......................................................................................... 13 c. Scope 2 Electricity Consumption Emissions ................................................................. 13 d. Scope 3 Biosolids Disposal Emissions ....................................................................... 14 e. Overall Evaluation Uncertainty ...................................................................................... 14 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 2 5. MSD GHG Emissions Evaluation ..................................................................................... 15 a. Base Case Definitions .................................................................................................... 15 b. Assumptions and Hauling Distances .......................................................................... 19 c. GHG Emissions Inventories by Facility ........................................................................ 20 6. Discussion of Results ......................................................................................................... 27 References ..................................................................................................................................... 28 Appendix A: Emission Factors ..................................................................................................... 29 Appendix B: Process Emission Sources ....................................................................................... 30 Appendix C: Emissions Breakdown by Source ............................................................................ 33 1. Background a. Basis for Considering Greenhouse Gas Emissions Greenhouse gases have become widely recognized as significant contributors to global climate change. Major initiatives have already been undertaken as part of an overall global effort to curb the production of greenhouse gases and mitigate to as great an extent possible the impacts that global climate change could have in the 21st century. The process by which greenhouse gases become entrapped in the earth’s atmosphere is illustrated in Figure 8-1. Global climate change is measured by significant changes in temperature or weather patterns that last for an extended period of time (measured in terms of decades). In general, greenhouse gases become entrapped when the sun’s radiation is partially absorbed by the earth and then reflected back to the atmosphere. Greenhouse gas molecules partially absorb the reflected radiation and re-direct it back to the earth; thus entrapping the energy within the atmosphere. Climate change can result from: • Changes in the sun's intensity or slow changes in the Earth's orbit around the sun • Natural processes within the climate system BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 3 • Human activities that change the atmosphere's composition (e.g., through burning fossil fuels) and the land surface (e.g., deforestation, reforestation, urbanization, desertification) Figure 8-1 Greenhouse Gas Entrapment in the Earth’s Atmosphere Although global climate change has been the source of debate for some time, there is a generally well-documented consensus within the scientific community that anthropogenic air pollution is a heavy contributor to this issue. Atmospheric carbon dioxide levels have increased significantly over the last 50-plus years in large part due to the rapid increase in industrial manufacturing processes (emitting carbon dioxide as well as other gases), as well as from de-forestation (limiting the absorption of carbon dioxide) from the atmosphere. This has led to significantly BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 4 greater carbon dioxide levels in the atmosphere over the last 50 years, as illustrated in Figure 8-2 below. Figure 8-2 Atmospheric CO2 Levels from Mauna Loa Observatory in Hawaii In 2007, more than 600 mayors (including Mayor Francis Slay of St. Louis) signed on to the U.S. Conference of Mayors Climate Protection Agreement, supporting a pledge to reduce carbon dioxide emissions by 7 percent below 1990 levels by 2012. Under the Agreement, participating cities commit to take following three actions: • Strive to meet or beat the Kyoto Protocol targets in their own communities, through actions ranging from anti-sprawl land-use policies to urban forest restoration projects to public information campaigns; • Urge their state governments, and the federal government, to enact policies and programs to meet or beat the greenhouse gas emission reduction target suggested for the United States in the Kyoto Protocol -- 7% reduction from 1990 levels by 2012; and BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 5 • Urge the U.S. Congress to pass the bipartisan greenhouse gas reduction legislation, which would establish a national emission trading system Other initiatives and programs are also in place to encourage the reduction of greenhouse gas production, although most of them are voluntary. However, reporting greenhouse gas emissions are increasingly falling under mandatory programs, such as that established by California Assembly Bill 32. In general, current trends point towards future mandatory reductions in GHG emissions. According to the United States Energy Information Agency (USEIA), domestic and wastewater treatment facilities accounted for 24.4 million metric tons of carbon dioxide equivalent GHG’s in 2006. Wastewater treatment plants are significant contributors of GHG’s and are anticipated to be one of the first entities regulated for future reductions; and will offer promising opportunities for future emissions reductions projects; particularly once established protocol for estimating GHG’s have been in place for a sustained period of time, and the reduction programs can potentially be used to generate GHG offsets and potentially sold on the open market through programs such as the Chicago Climate Exchange, the Climate Action Reserve, and the Voluntary Carbon Reduction Standard. As the protocol for estimating wastewater GHG reductions become more robust and widely accepted, they will be viewed as more credible by offset buyers and can thus attract higher prices. On April 10, 2009, the Environmental Protection Agency published a proposed rule on mandatory GHG reporting in the Federal Registrar for those facilities emitting over the equivalent of 10,000 metric tons of carbon dioxide equivalent per year. b. Purpose of Greenhouse Gas Emission Calculations Greenhouse gases are defined by the US Environmental Protection Agency (EPA) as gases that trap heat in the atmosphere. Under the Kyoto Protocol, there are six internationally-recognized GHGs: Carbon Dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O), Hydroflurocarbons (HFCs), Perflurocarbons (PFCs), and Sulfur Hexafluoride (SFC). Of the six internationally- recognized GHG regulated under the Kyoto Protocol, only three, CO2, CH4, and N2O are BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 6 emitted in significant quantities through wastewater and biosolids treatment processes. Consequently, this inventory was limited to these three GHGs. Greenhouse gas inventories are based on the Kyoto Protocol, which became effective, for those countries that ratified it, in 2005. The Intergovernmental Panel on Climate Change (IPCC) has published guidelines for performing GHG inventories. These guidelines, which provide the standard methodology for performing these evaluations, have been expanded upon by a number of governmental and non-governmental organizations, including the U.S. Environmental Protection Agency (USEPA) and the California Air Resources Board, California Climate Action Registry, ICLEI – Local Governments for Sustainability, and The Climate Registry, which developed the Local Government Operations (LGO) Protocol. The purpose of calculating GHG emissions for this evaluation is for use in the Triple Bottom Line screening process. As such, the GHG emission values are high level estimations, to help identify relative GHG emissions. Consequently, the calculations focus on processes that differ among alternatives. The GHG emission values presented in this TM do not represent total emissions for any process. c. Overview of LGO Protocol The LGO Protocol was developed to enable local governments to assess emissions inventories following internationally-recognized, consistent, and comparable GHG accounting and reporting principles. These principles are the following:1 • Relevance: The GHG inventory should be organized to reflect the areas over which the reporting entity exerts control and holds responsibility. • Completeness: All GHG emissions sources and emissions-causing activities within the chosen boundary should be included. Any specific exclusion should be justified and disclosed. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 7 • Consistency: Consistent methodologies should be used in the identification of boundaries, analysis of data, and quantification of emissions. • Transparency: All relevant data sources and assumptions should be disclosed with descriptions of methodologies and data sources in order to provide a trail for future review and replication. • Accuracy: Accuracy should be sufficient to enable users to make decisions with reasonable assurance as to the integrity of the reported information. The LGO Protocol has been used as the primary guidance for this GHG evaluation. The five facilities and regional plant approach assessed for GHG emissions are listed in Table 8-1. The facility codes listed in the table are used throughout the remainder of this TM. Table 8-1: Facilities Codes for MSD GHG Emissions Evaluation Facility Facility Code Bissell Point Wastewater Treatment Plant Bissell Lemay Wastewater Treatment Plant Lemay Coldwater Wastewater Treatment Plant Coldwater Lower Meramec Wastewater Treatment Plant Lower Meramec Missouri River Wastewater Treatment Plant MO River Regional Wastewater Treatment Plant Regional 2. GHG Boundary Conditions a. Organizational Boundary (Operational Control Approach) The LGO Protocol “operational control” approach was used to quantify MSD’s GHG emissions. This approach requires reporting all GHG emissions that directly result from equipment and processes over which the MSD has operational control. Operational control is defined by the LGO Protocol as either: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 8 1. Owning an operation, facility, or source; or 2. Having the full authority over operational and health, safety and environmental policies for a particular operation or facility. Since the purpose of these GHG calculations is to differentiate among alternatives for the TBL screening, all biosolids processes under MSD operational control have not been included; rather, the evaluation includes only processes that significantly differ among alternatives. The LGO Protocol uses a system that allows ready comparison between organizations, based on “Scope” categories. Separating the emissions into discrete categories helps minimize the potential for double-counting of emissions. Scope 1 and Scope 2 represent processes over which MSD has operational control, while Scope 3 is an “optional” reporting category. A summary of the scopes is presented on Figure 8-3. Figure 8-3: GHG Emission Scopes (Courtesy of World Resources Institute GHG Protocol) The definitions of the scope categories are as follows: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 9 ▪ Scope 1 includes direct GHG emissions from sources that are owned and controlled by the organization. These include process emissions, such as nitrous oxide (N2O) emissions from liquid stream treatment, combustion of natural gas or biogas, methane (CH4) and N2O from biosolids combustion, emissions from liquid stream processes, and vehicle use for company business. Direct CO2 emissions from biogenic sources are not included in this scope (Biogenic emissions are discussed in Section 2.3). Scope 1 includes fugitive emissions from flares and other processes if they are owned/operated by the organization. If the utility generates power on- site using biogas, emissions associated with the generation process are included in this section. Non-GHG emissions, such as NOx, are not included in this section. ▪ Scope 2 is limited to indirect emissions associated with purchased electricity. While the GHG emissions occur at the facility where the electricity is generated rather than the point of use, the using organization is responsible for inclusion of the emissions in its GHG inventory. ▪ Scope 3 is an optional reporting area, but may include large inventories of GHG emissions. Scope 3 includes all indirect GHG emissions, other than electricity use. Scope 3 emissions are a result of the operations and practices of the organization, but the sources of the emissions are not owned or controlled by the organization. Since tracking and accounting for Scope 3 emissions is optional, all items do not need to be included. However, tracking activities that are major emissions sources can provide valuable information to help with process and technology decisions. It can be difficult to accurately assess Scope 3 emissions, since there may not be a direct “cause and effect” relationship between the organization’s actions and these emissions. Since the scope definition concept allows optional reporting of items in Scope 3, organizations can limit the items tracked in Scope 3 to those that have a significant contribution to the total GHG inventory. b. GHG’s Emissions Included in Evaluation Table 8-2 lists the sources of the GHG emissions included in this evaluation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 10 Table 8-2 Emission sources taken into account in GHG evaluation Source Category Emission Source Stationary Combustion • Combustion of petroleum products • Incineration of biosolids • Combustion of biogas Fugitive Emissions • N2O emissions from biosolids land application • CH4 emissions from biosolids disposal at the landfill • CH4 emissions from digester units Process Emissions • Release of N2O and CH4 from composting Mobile Combustion • Combustion of gasoline and diesel to fuel vehicle fleet • Combustion of diesel to fuel trucks hauling biosolids to final end-use facilities Electricity Consumption • Select processes are included in the evaluation Chemical Use • Polymer use in dewatering Carbon Credits • Electricity generation from gas utilization and incineration Some of the alternatives use various final use outlets for biosolids, including landfill, composting, and land application. However, only landfill disposal has been included in this evaluation to serve as a basis of comparison among alternatives. A breakout of source type and scope for each facility and process are listed in Table B-1 in Appendix B. c. Biogenic Emissions Not all GHGs emitted by an organization or industry are expected to increase the greenhouse effect and are therefore not included in the GHG inventory. Based on the LGO Protocol, a GHG inventory includes only anthropogenic carbon dioxide emissions resulting from the use of fossil fuels and other – non CO2 - GHGs produced by fossil or biogenic fuels. However, since the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 11 handling and combustion of biogenic material can generate fugitive CH4 and N2O from leaks and incomplete combustion that would not normally occur under natural degradation processes, CH4 and N2O GHG emissions from biogenic combustion are included in the inventory as Scope 1 or Scope 3 items. Carbon dioxide from the combustion of biogenic material (such as biosolids or biogas) is not included in the inventory; however, the LGO Protocol requires separate reporting of biogenic CO2 emissions. 3. GHG Emissions Evaluation Calculation Methodology Greenhouse gas assessments involve performing an inventory or estimating all GHGs emitted by the organization or industry. The emission factors (EF) method was used to calculate GHG emissions from the MSD sources. EF’s are defined by the LGO Protocol as calculation ratios used as proxies for activity from an emissions source. The LGO Protocol provides default values for EF’s derived from references such as the US Environmental Protection Agency (EPA) “Inventory of Greenhouse Gases and Sinks: 1990-2008”, IPCC Guidelines for National Greenhouse Gas Inventories, EPA Climate Leaders, Mobile Combustion Guidance, and other sources. Any other EF’s required not provided in the LGO Protocol were derived from peer-reviewed reports. The References section lists all cited sources. Emissions of CO2, N2O, and CH4 were individually calculated and then combined using Equation 1 to give final emissions in units of metric ton (tonne) CO2e, thus allowing for all GHG to be compared on a common basis. (Eq. 1) The GWP is a measurement of the amount a specific GHG contributes to global warming based on its radiative effect (ability to trap heat in the atmosphere) of 1 kilogram of the gas over a period of 100 years. The GWP is a relative value, based on CO2 having a value of 1. Although the GWPs of the GHGs have been updated in 2001 and 2007 IPCC reports, the GWP values presented in the Second Assessment Report (SAR) from the IPCC, published in 1996, are used BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 12 as the standard values. The GWP values are listed in Table 8-3. As shown in the table, the GWP varies significantly, depending on the type of gas. Consequently, a small quantity of emitted gas with a high GWP can have a great effect on the GHG inventory. Table 8-3 Global Warming Potential of GHGs Chemical Name Atmospheric Life (years) 2001 IPCC GWP Carbon Dioxide CO2 50-200 1 Methane CH4 12 21 Nitrous Oxide N2O 120 310 4. Uncertainty Analysis The LGO Protocol was designed to reduce reporting uncertainty such that it is less than the minimum quality standard for the organizations involved in the protocol’s development (i.e., California Air Resources Board, California Climate Action Registry, ICLEI-Local Governments for Sustainability, and The Climate Registry). Though not specifically mentioned in the LGO Protocol, uncertainty analysis is an important element in any GHG inventory due to its role in assessing inventory quality and helping to set priorities for investments. The uncertainty analysis also helps to identify calculation methodologies or improvements in data accuracy that are most subject to significant change. a. Uncertainty Analysis Overview Uncertainties associated with GHG inventories can be broadly categorized as scientific uncertainty and estimation uncertainty as defined below: • Scientific Uncertainty: An example of scientific uncertainty is that which arises from many of the direct and indirect EFs associated with GWP values. These values have been determined by the IPCC and are based on highly complex BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 13 scientific theories from a wide variety of disciplines. Analysis of such scientific uncertainty is beyond the scope of this GHG emissions inventory. • Estimation Uncertainty: Estimation uncertainty can be classified into model uncertainty and parameter uncertainty. Model uncertainty is associated with the use of mathematical equations used to characterize the relationships between various parameters and emissions processes. For example, model uncertainty may arise due to the use of an incorrect mathematical model or inappropriate inputs in the model. Parameter uncertainty refers to the uncertainty associated with the input data itself and can be evaluated through statistical analysis, determining measurement equipment precision, and expert judgment. The following is a qualitative assessment of the estimation uncertainties associated with MSD’s more significant GHG emissions. b. Scope 1 Process Emissions The major Scope 1 process emissions arise from on-site fuel consumption and biosolids combustion. The emission factors for fuel sources were based on those presented in the LGO Protocol. This source does not provide emission factors specific to a wastewater facility, which adds a level of uncertainty to the GHG emissions estimate. Fuel consumption was based on projected solids quantities for the 2020 annual average condition, which also introduces a degree of uncertainty. Overall, Black & Veatch considers the GHG emissions for Scope 1 process sources to be of moderate uncertainty. c. Scope 2 Electricity Consumption Emissions Electricity usage quantities were made based on estimated equipment loads. While actual electrical consumption information is not available, power use is based on horsepower estimates and expected operating schedules. Electrical consumption activity data uncertainty is considered to be moderate. The accuracy of estimating emissions from BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 14 purchased electricity was determined by the output emission rates provided as default factors in the U.S. EPA Emissions & Generation Resource Integrated Database (eGRID). eGRID is based on available plant-specific data provided by U.S. electricity-generating plants that report data to the U.S. government. These emission rates are not completely accurate because the rates vary by time of day and season based on base load versus peaking load operation. However, the EFs provide a reasonable average value for use in computations. Overall, Black & Veatch considers the GHG emissions estimate for electricity consumption to have moderate uncertainty. d. Scope 3 Biosolids Disposal Emissions All biosolids final end-use and disposal emissions were made with parameter assumptions based on project mid-point average process parameters. GHG emissions from final use processes have numerous uncertainties, based on a number of factors, including process operation and fugitive emission assumptions. Black & Veatch considers the uncertainty associated with the GHG emissions estimate for Scope 3 biosolids final use as very high. For more accurate estimations, additional system information would be required; however, little of this information is available without significant measuring and monitoring programs. e. Overall Evaluation Uncertainty The overall MSD GHG evaluation has a moderate level of uncertainty. Scope 3 emissions have a much higher level of uncertainty but were not included in the overall evaluation consideration because those emissions do not lie within the MSD ownership/operational boundary. The Scope 3 emissions are provided as a general reference to aid MSD in the biosolids final use decision process. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 15 5. MSD GHG Emissions Evaluation a. Base Case Definitions GHG emissions were estimated for all alternatives described in TM 1 through TM 6, based on the midpoint solids quantities listed in Table 8-5. All options include landfill disposal as the biosolids final use. GHG emission calculations were performed based on LGO Protocol and emission factors. For processes that are not addressed by the LGO Protocol, the Biosolids Emissions Assessment Model (BEAM) (SYLVIS, 2009) was used as the basis of the GHG calculations. Table 8-5 Biosolids quantities (total solids in ppd) used in GHG emission calculations Alt. Solids Type Bissell Lemay Coldwater Lower Meramec Mo River Regional 1 Primary 123,855 42,000 14,100 19,550 50,800 123,855 WAS 49,000 60,200 14,100 19,550 31,000 49,000 FOG 5,380 2 Primary 14,100 19,550 58,200 WAS 14,100 19,550 37,400 FOG 5,380 3 Primary 14,100 WAS 14,100 FOG BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 16 Table 8-6 lists the alternatives and processes included in the GHG estimated for the individual treatment plant systems. For Bissell and Lemay, this basically differentiates between the type of incineration system utilized, as well as the type of dewatering system. Steam generation is assumed for energy recovery. For the county facilities, the primary differentiators are whether or not anaerobic digestion is used, and what type of dewatering system is used. Engine generation is assumed for all power/heat recovery. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 17 Table 8-6: Processes Included in Individual Treatment Plant Alternative Evaluations Process Bissell Lemay Coldwater Lower Meramec MO River Alternative 1 2 1 2 1 2 3 1 2 1 2 Gravity Thickening GT1 GT GT PC2 Mechanical Thickening RDT3 RDT Digestion MAD4 MAD MAD MAD MAD w/ FOG Dewatering BFP5 Cent.6 BFP Cent. BFP, Cent., RP7 BFP, Cent., RP Incineration MHI8 FBI9 MHI FBI Gas Cleaning EG10 EG EG EG EG Energy Recovery Steam Generator Steam Generator Steam Generator EG EG EG EG EG Biosolids Disposal Landfill of Ash Landfill of Ash Landfill of Ash Landfill of Ash Pump to BP Landfill Cake Landfill Cake Landfill Cake Landfill Cake Landfill Cake Landfill Cake Note: Definition of terms provided on the following page. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 18 1 Gravity Thickening 2 Primary Clarifier 3 Rotary Drum Thickening 4 Mesophilic Anaerobic digestion 5 Belt Filter Press 6 Centrifuge 7 Rotary Press 8 Multiple Hearth Incinerator 9 Fluid Bed Incinerator 10 Engine Generator Table 8-7 lists evaluated alternatives and processes for the regional system concept. Essentially, biosolids disposal options are the same for each of the treatment plants except for Lemay, where two separate options are being considered: 1) Haul solids to the Regional Plant at Bissell; and 2) Pump solids to the Bissell Point collection system for processing at the Bissell Point Wastewater Treatment Plant. Table 8-7 Processes Included in Regional Treatment Plant Alternative Evaluations Process Bissell Lemay Coldwater Lower Meramec Mo River Gravity Thickening PC PC PC Dewatering Cent BFP Incineration FBI Biosolids Disposal Landfill of Ash Haul to Bissell Pump to Bissell Haul to Bissell Haul to Bissell Biosolids Disposal (R-2) Landfill of Ash Pump to Bissell Pump to Bissell Haul to Bissell Haul to Bissell BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 19 b. Assumptions and Hauling Distances The GHG emission calculations were based on information on biosolids processing and energy use developed for each treatment alternative, as discussed in TM 1 through TM 6. Electrical consumption value were based on historical data (when available), vendor quotes, or engineering experience. Vehicle use values for hauling were based on the distances presented in Table 8-8. Table 8-8 Summary of Round Trip Hauling Distances (mi) Destination Bissell Lemay Coldwater Lower Meramec Mo River Bissell Landfill 52 56 38 30 4 52 Land/Application N/A N/A 50 50 50 N/A Composting N/A N/A 46 62 26 N/A Regional - 26 24 58 46 - Process assumptions used in this evaluation were as follows: • 4 percent nitrogen content of biosolids • A land application nitrogen loading rate appropriate for corn (0.9 lb/bushel) assuming yields of 165 bushels/acre (Brown, 1995). • Composting fertilizer offsets based only on nitrogen use, because compost users typically do not readjust their fertilizer habits in accordance with phosphorus loading. • For Lower Meramec analysis, a midpoint solids quantity based on the average solids production between 2010 and 2030, to simplify the staggered solids quantity increase from Fenton and Grand Glaze plants. • Scope 2 GHG emissions, which are associated with purchased power generation, were based on the SRMW region of the U.S. EPA Emissions & Generation Resource BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 20 Integrated Database (eGRID); as shown in Figure 8-4 below. Correction factors for regional differences in CO2, CH4, and N2O production rates are applied according to location. Figure 8-4 U.S. EPA Emissions and Generation Resource Integrated Database Regions c. GHG Emissions Inventories by Facility Tables 8-9 through Table 8-13 summarize the GHG emissions inventories for each MSD facility for the individual plant system. A more detailed breakdown of emissions by scope can be found in Appendix C: Emissions Breakdown by Source. Abbreviations for each of the alternatives are defined below: AEC  Advanced emission controls BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 21 BFP  Belt filter press dewatering MAD  Mesophilic Anaerobic Digestion CFG  Centrifuge dewatering FBI  Fluidized bed incinerator FOG  Fats, oils and greases MHI  Multiple hearth incinerator RP  Rotary press dewatering ST  Steam system heat recovery, used for the plant or transferred to steam utility STG  Steam turbine generator to produce electrical power GHG emissions for the Bissell Point facility are provided in Table 8-9 below. The alternatives are defined in more detail under TM’s 1 through 6. Alternative B-1 (B for “Bissell”) establishes the base case scenario from a GHG perspective for the existing system; multiple hearth incineration with belt filter press dewatering. Alternative B-2 assesses fluidized bed incineration technology in combination with centrifuge dewatering. GHG levels for the incineration emissions of biosolids are the same for each alternative. However, the power and fuel use requirements for operating FBI’s and MHI’s vary inversely, with more power required by the FBI’s for operation, but less auxiliary fuel use (due to the fact that the FBI’s run predominantly autogenously). Additionally, centrifuges require more energy and polymer as compared to BFP’s for dewatering, producing more GHG’s for this alternative. Alternatives B-2-A, B-2-B, and B-2-C consider variations of steam heat recovery, steam turbine generation, and advanced emission controls. Of these, adding steam turbine generation results in the most significant GHG offset via the production of nearly 8,000,000 kW-hr/year of electricity. Advanced emission controls (included in Alternative B-2-C) result in a slight increase in overall GHG production due to the increased power consumption from an additional induction fan and cooling tower (with air compressors). It should be noted that no GHG offset is taken in this evaluation for the production of steam, although in reality the production of steam would in fact reduce consumption of other energy sources; and if sold on the open market, could in fact be an GHG offset to the purchasing entity. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 22 Table 8-9 GHG Emissions for Bissell Point – Individual System Alternative No. Alternative Total Emissions (tonne CO2e/yr) B-1 MHI+BFP 18,698 B-2 FBI+CFG 20,566 B-2-A FBI + ST 20,701 B-2-B FBI + STG 15,060 B-2-C FBI+AEC 22,558 GHG emissions for the Lemay Wastewater Treatment facility are provided in Table 8-10 on the following page. As noted, GHG production for all alternatives considered ranged from 9,000 to 17,000 tonne CO2e per year. Alternative L-1 (L for “Lemay”) establishes the base case for existing conditions (i.e., MHI technology with belt filter press dewatering); Alternative L-2 considers FBI’s with belt filter presses for dewatering; while L-3 considers FBI’s with centrifuges for dewatering. For each of these three primary alternatives, there are multiple versions of energy recovery and advanced emission control options considered. As compared to the Bissell Point facility, overall GHG emissions are somewhat less due to the lower solids production at the Lemay plant. As with the Bissell Point facility, FBI’s produce slightly more GHG’s due to the increased power requirements, but this is offset by the reduction of auxiliary fuel. Steam turbine generation results in an offset of nearly 3,000,000 kW-hr/year of electricity. A number of alternatives were considered for the Coldwater facility, including the current option of pumping solids to the Bissell Point collection system. Additionally, hauling dewater solids to either a landfill or composting site using either BFP’s, centrifuges, or rotary presses were considered. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 23 Table 8-10 GHG Emissions for Lemay – Individual System Alternative No. Alternative Total Emissions (tonne CO2e/yr) L-1 MHI+BFP 10,827 L-2 FBI+BFP 14,829 L-3 FBI+CFG 15,797 L-1-A MHI+STG 9,188 L-1-B MHI+AEC 10,827 L-2&3-A FBI+STG 17,178 L-2&3-B FBI+AEC 16,602 A number of alternatives were considered for the Coldwater facility, as summarized in Table 8-11 on the following page. Alternative C-1 (C for “Coldwater”) consists of the current option of pumping solids to the Bissell Point collection system. Alternative C-2 consists of discharging undigested dewatered solids to a local landfill using either centrifuges or rotary presses for dewatering; while Alternative C-3 consists of anaerobically digesting the biosolids, followed with either landfilling, land-application, or composting of the dewatered solids (via either centrifuges or rotary presses). Continuing to discharge to the Bissell Point collection system has by far the lowest GHG impact for Coldwater, although in reality the GHG impact for this option is simply transferred to the Bissell Point plant. The GHG impact for all options for disposing of the solids in a landfill is essentially the same, irrespective of the type of dewatering system used; due almost entirely to the GHG’s produced from the hauling operations. With alternative C-3, C-3-A, and C-3-B, GHG off-sets gained from the production of energy through anaerobic digestion significantly lowers overall GHG production. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 24 Table 8-11 GHG Emissions for Coldwater– Individual System Alternative No. Alternative Total Emissions (tonne CO2e/yr) C-1 Current Operation 690 C-2 BFP / Landfill 8,478 C-2-A CFG /Landfill 8,548 C-2-B RP /Landfill 8,442 C-3 MAD / BFP 1,234 C-3-A MAD / CFG 1,211 C-3-B MAD / RP 1,240 The overall GHG assessment for alternatives for the Lower Meramec treatment plant is summarized in Table 8-12. LM-1 (LM for “Lower Meramec”) consists of a continuation of the existing operation (i.e., thickening, dewatering, and hauling to landfill). Alternative LM-2 adds digestion facilities, reducing the overall solids volume to be disposed of, while also gaining GHG offsets through the production of energy from anaerobic digestion. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 25 Table 8-12 GHG Emissions for Lower Meramec– Individual System Alternative No. Alternative Total Emissions (tonne CO2e/yr) LM-1 Existing 3,044 LM-2 Thickening / Digestion 616 GHG assessments for the Missouri River treatment facility are provided in Table 8-13 below, for two primary options considered: M-1, which consists of the current digestion and dewatering operation, and M-2, which adds Fats, Oils, and Grease (FOG) operations to the anaerobic digestion process. Under each of these scenarios, the biosolids portion of the plant operates with a negative GHG impact, due to the energy recovered via the anaerobic digestion process. The addition of FOG lowers the GHG impact slightly. Table 8-13 GHG Emissions for Missouri River– Individual System Alternative No. Alternative Total Emissions (tonne CO2e/yr) M-1 Current Operation -1,432 M-2 Co-Digestion w/ FOG -1,665 Table 8-14 and Table 8-15 present the GHG emissions for a regional biosolids treatment system option. During workshops for this evaluation completed during Phase 1, the decision was made to locate the regional facility at the Bissell Point facility. Table 8-14 provides the GHG estimates for each of the plants under the regional facility option, wherein all solids produced at the plant or either hauled or pumped to the Bissell Point system. For each of the other treatment facilities, this significantly reduces the overall GHG impact. However, as can be seen in Table 8-15, the GHG BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 26 impact is simply transferred to the regional facility (regardless of which treatment option is considered). Table 8-14 GHG Emissions for Contributing Facilities (Regional System) Total Emissions (tonne CO2e/yr) L-1 (Regional) 685 C-1 690 LM-1 (Regional) 312 M-1 (Regional) 291 Subtotal 1,978 Of the options considered for a regional facility, the GHG offsets gained from steam turbine generation of electricity reduce the overall impact of this option significantly in comparison to the others; although for this analysis, GHG offsets for the generation of steam are not accounted for. Advanced emission controls (Alternative R-1-C) have the highest GHG impact; slightly higher than Alternative R-1 (FBI with centrifuge dewatering) and Alternative R-1-A (FBI with steam dewatering and steam recovery). Table 8-15 GHG Emissions for Bissell Point (Regional System) Alternative No. Alternative BP Total Emissions (tonne CO2e/yr) Remaining System Total Emissions (tonne Co2e/yr) Total Emissions (tonne CO2e/yr) R-1 FBI+CFG 53,513 1,978 55,500 R-1A FBI+ST 53,765 1,978 55,752 R-1B FBI+STG 35,551 1,978 37,538 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 27 Alternative No. Alternative BP Total Emissions (tonne CO2e/yr) Remaining System Total Emissions (tonne Co2e/yr) Total Emissions (tonne CO2e/yr) R-1C FBI+AEC 55,900 1,978 57,887 R-2 (To be added) 6. Discussion of Results The total emissions associated with each alternative are also listed by scope, as detailed in Appendix C: Emissions Breakdown by Source. With the exception of the incineration options, Scope 1 emissions are relatively low. Incineration options have significant Scope 1 emissions resulting from solids combustion. Scope 2 emissions, which are solely based on energy use, are high for high- energy processes such as incineration. Energy recovery systems, included for select alternatives at all the existing plants as well as the regional system, reduced the energy use and associated emissions by 50 percent or more. In the case of the regional facility (R1B), the generated power more than offsets the energy use at the plant. The introduction of a Regional facility would replace some biosolids treatment processes and all final use practices at the other MSD facilities. All dewatered products would be sent to Regional to be incinerated. Consequently, this option results in large reductions of GHG emissions for plants that are currently processing biosolids that would be diverted to Regional Facility; however, total system GHG emissions increase with the use of a regional facility. Some of the increase is a result of greater hauling distances for some of the County plants (such as Lower Meramec and Missouri River) when hauling to the Bissell Point facility as compared to landfill disposal. However, the greatest impact on the GHG emissions is the use of incineration on all MSD biosolids. Incineration has significant N2O emissions, which increase in proportion to the quantity of solids being BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 28 incinerated. Conversion to a regional operation will increase the total quantity of biosolids incinerated, subsequently increasing the total GHG emissions. References California Air Resources, California Climate Action Registry, ICLEI, The Climate Registry. (2010). Local Government Operations Protocol: for the quantification and reporting of greenhouse gas emissions inventories. Version 1.1. EPA. (2010, 6 7). Clean Energy. Retrieved 6 1, 2010, from eGRID: http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html EPA. (2010, 16 2010). Green Vehicle Guide. Retrieved 6 3, 2010, from Green Vehicle Guide: http://www.epa.gov/greenvehicles/ EPA. (2010). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2008. Washington, DC. IPCC. (2001). Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories. SYLVIS. (2009). The Biosolids Emissions Assessment Model (BEAM): A Method for Determining Greenhouse Gas Emissions from Canadian Biosolids Management Practices. New Westminster: Canadian Council of Ministers of the Environment (CCME). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 29 Appendix A: Emission Factors The tables in Appendix A give the emission factors used in our GHG module to calculate emissions for the MSD facilities. Table A-1 Emissions Factors for Stationary Combustion Fuel Sources Table A-2 Emissions Factors for Fugitive Emission Sources EF CO2 CH4 N2O Biogas EF(1) 52.07 kg/mmBtu 0.003 kg/mmBtu 0.00063 kg/mmBtu (1)Values for biogas fuels (LGO Protocol Tables G.2-3). Table A-3 Emissions Factors for Chemical Use Emission Sources EF CO2 CH4 N2O Polymer Use (1) 0.82 kg/ lb polymer 0 kg// lb polymer 0 kg/ lb polymer (2) (EPA, 2010) Table A-4 Emissions Factors for Mobile Combustion Fuel Sources EF CO2 CH4 N2O Diesel EF(1) 1.46 kg/mi 5e-6 kg/mi 5e-6 kg/mi (1)Values for US weighted average (LGO Protocol Tables G.11-13). Table A-5 Emissions Factors for Electricity Use Sources and Power Offsets EF CO2 CH4 N2O Electricity(1) 1135 lb / MWh 0.024 lb / MWh 0.02 lb / MWh (1) eGridweb (EPA, 2010) EF CO2 CH4 N2O Biogas EF(1) 52.07 kg/mmBtu 0.003 kg/mmBtu 0.00063 kg/mmBtu Diesel EF(2) 1.46 kg/mi 5e-6 kg/mi 5e-6 kg/mi Biosolids Combustion EF 4.85e-5/dry tonne Based on BEAM calc (1)Values for biogas fuels (LGO Protocol Tables G.2-3). (2)Values for US weighted average (LGO Protocol Tables G.11-13). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 30 Appendix B: Process Emission Sources Table B-1 lists the emissions taken into account in the GHG Module broken down by process and source type. Table B-1 Scope classification of operational boundaries by process Process Specific Facilities Source Type Scope Gravity Thickening Coldwater Lower Meramec Electricity Consumption 2 Mechanical Thickening Coldwater Lower Meramec Electricity Consumption Polymer Use 2 3 Digestion MO River Coldwater Lower Meramec Process Emissions Fugitive Emissions Electricity Consumption Biogenic CO2 Emissions 1 1 2 3 Dewatering MO River Coldwater Lemay Bissell Lower Meramec Regional Electricity Consumption Polymer Use 2 3 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 31 Process Specific Facilities Source Type Scope Incineration Lemay Bissell Regional Stationary Combustion Electricity Consumption Generated Electricity Biogenic CO2 Emissions 1 2 2 3 Gas Cleaning MO River Coldwater Lower Meramec Electricity Consumption 2 Gas Utilization MO River Coldwater Lower Meramec Stationary Combustion Electricity Consumption Generated Electricity Biogenic CO2 Emissions 1 2 2 3 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 32 Process Specific Facilities Source Type Scope Biosolids Disposal MO River Coldwater Lemay Bissell Lower Meramec Regional Mobile Combustion (hauling by truck to landfill and land application) Fugitive Emissions (methane release at landfill) Biogenic CO2 Emissions 1 3 3 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 33 Appendix C: Emissions Breakdown by Source The following tables list the estimated GHG emissions broken out by process and source type. Additional rows provide the emissions resulting from modifications to the base case. Tables C1 through C5 represent the individual facility system. Table C-1: GHG Emissions for Bissell Point – Individual Facility System Case Alt. Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) B-1 MHI+BFP 13,293 5,221 184 42,503 B-2 FBI+CFG 11,946 8,302 318 42,503 B-2-A FBI + ST 11,946 8,436 318 42,503 B-2-B FBI + STG 11,946 2,796 318 42,503 B-2-C FBI+AEC 11,946 10,294 318 42,503 Table C-2: GHG Emissions for Lemay – Individual Facility System Case Alt. Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) L-1 MHI+BFP 7,907 2,807 113 24,731 L-2 FBI+BFP 7,373 7,343 113 24,731 L-3 FBI+CFG 7,373 8,234 190 24,731 L-1-A MHI+STG 7,907 4,728 113 24,731 L-1-B MHI+AEC 7,907 5,925 113 24,731 L-2&3-A FBI+STG 7,373 7,919 113 24,731 L-2&3-B FBI+AEC 7,373 9,116 113 24,731 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 34 Table C-3: GHG Emissions for Coldwater – Individual Facility System Case Alt. Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) C-1 Current Operation 0 690 0 0 C-2 BFP / Landfill 0 818 7,660 0 C-2-A CFG /Landfill 0 850 7,698 0 C-2-B RP /Landfill 0 744 7,698 0 C-3 MAD / BFP 362 294 578 2,767 C-3-A MAD / CFG 362 254 595 2,767 C-3-B MAD / RP 362 283 595 2,767 Table C-4: GHG Emissions for Lower Meramec – Individual Facility System Case Alt. Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) LM-1 MAD 266 (288) 818 2,849 LM-2 Thickening / Digestion 386 (589) 818 3,149 Table C-5: GHG Emissions for Missouri River – Individual Facility System Case Alt. Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) M-1 Current Operation 980 (3,943) 1,531 7,668 M-2 Co-Digestion w/ FOG 1,205 (4,989) 2,119 9,204 Tables C-6 through C-11 represent the regional facility system. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 35 Table C-6: GHG Emissions for Lemay – Regional Facility System Case Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) L-1 Regional 0 504 181 0 L-2 Regional 0 TBD TBD 0 Table C-7: GHG Emissions for Coldwater – Regional Facility System Case Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) C-1 0 690 0 0 Table C-8: GHG Emissions for Lower Meramec – Regional Facility System Case Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) LM-1 0 148 164 0 Table C-9: GHG Emissions for Missouri River – Regional Facility System Case Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) M-1 Regional 0 0 291 0 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Greenhouse Gas Emissions August 25, 2010 MSD Contract No. 2009145 B&V File 44.000 36 Table C-10: GHG Emissions for Regional Plant at Bissell Point – Regional Facility System Case Scope 1 (tonne CO2e/yr) Scope 2 (tonne CO2e/yr) Scope 3 (tonne CO2e/yr) Biogenic (tonne CO2/yr) R-1 39,765 13,369 379 108,312 R-1-A 39,765 13,621 379 108,312 R-1-B 39,765 (4,633) 379 108,312 R-1-C 39,765 15,756 379 108,312 R-2 (TBD) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 1 TECHNICAL MEMORANDUM NO. 9 OPINIONS OF COSTS FOR ALTERNATIVES To: Metropolitan St. Louis Sewer District From: Cecil Stegman, Patricia Scanlan, Jim Rowan, Hari Santha, Gustavo Queiroz,Yinan Qi, Bently Green _____________________________________________________________________________ Update: This technical memorandum (TM) summarizes the costs for various scenarios considered for each of the District’s wastewater treatment plants. Modifications to each of the alternatives considered were developed as part of TM’s 1 through 6. A workshop was conducted on September 10, 2010 to review the costs and concepts developed. Comments and modifications resulting from this workshop were incorporated into this TM and re-issued on January 19, 2011. However, in the meantime, USEPA had published draft emission limits for Sewage Sludge Incinerators (SSIs), which were being challenged by a number of utilities and organizations (via the public hearing process as well as written comments). As a result of these on-going regulatory issues, and the level of uncertainty that prevailed in being able to properly assess the level of improvements necessary to achieve compliance, the District requested that additional cost estimates be developed that considered relaxed limits for Mercury and utilized the existing multiple hearth incinerators indefinitely. This update to Technical Memorandum No. 9 has been completed to include those costs and is hereby re-issued as final. Table of Contents Table of Contents ............................................................................................................................ 1 List of Tables .................................................................................................................................. 2 1. Introduction ............................................................................................................................. 3 2. Cost Factors ............................................................................................................................ 5 a. Construction Cost Factors ................................................................................................ 6 b. Operation and Maintenance Cost Factors ..................................................................... 7 3. Equipment and Process Considerations ................................................................................ 10 4. Project Capital Costs ............................................................................................................. 15 5. Operation / Maintenance Costs and Revenues Generated .................................................... 27 6. Overview of Alternatives Costs ............................................................................................ 36 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 2 List of Tables Table 9-1 Summary of Alternatives Considered ................................................................ 3 Table 9-2 Construction Factors Used ................................................................................. 7 Table 9-3 Unit Costs and Revenues Used ........................................................................... 9 Table 9-4 Equipment and Modifications for Bissell, Lemay and Regional Plants .......... 11 Table 9-5 Equipment and Modifications for County Plant Alternatives .......................... 12 Table 9-6 Equipment and Modifications for the Regional Systems ................................. 13 Table 9-7 Equipment and Modifications for the Regional Systems Assuming Reduced Mercury Limits ......................................................................................... 14 Table 9-8 Capital Costs for the Bissell Point WWTP ....................................................... 17 Table 9-9 Capital Costs for the Lemay WWTP ................................................................ 19 Table 9-10 Capital Costs for the Coldwater WWTP ........................................................ 20 Table 9-11 Capital Costs for the Missouri River WWTP ................................................. 22 Table 9-12 Capital Costs for the Lower Meramec WWTP .............................................. 23 Table 9-13 Capital Costs for the Regional Plant .............................................................. 24 Table 9-14 Capital Costs for the Regional Systems ......................................................... 26 Table 9-15 Annual Costs and Revenues for Bissell Point WWTP Alternatives ............. 27 Table 9-16 Annual Costs and Revenues for Lemay WWTP Alternatives ....................... 28 Table 9-17 Annual Costs and Revenues for Coldwater WWTP Alternatives .................. 30 Table 9-18 Annual Costs and Revenues for Missouri River WWTP Alternatives .......... 32 Table 9-19 Annual Costs and Revenues for Lower Meramec Plant Alternatives ............ 33 Table 9-20 Annual Costs and Revenues for the Regional Plant Alternatives ................. 34 Table 9-21 Annual Costs and Revenues for the Regional Systems .................................. 35 Table 9-22 Summary of Cost Opinions for Bissell Plant Alternatives 1 .......................... 37 Table 9-23 Summary of Cost Opinions for Lemay Plant Alternatives 1 ......................... 38 Table 9-24 Summary of Cost Opinions for Coldwater Plant Alternatives 1 ................... 39 Table 9-25 Summary of Cost Opinions for Missouri River Plant Alternatives 1 ............. 40 Table 9-26 Summary of Cost Opinions for Lower Meramec Plant Alternatives 1 ........... 41 Table 9-27 Summary of Cost Opinions for Regional Facility Alternatives 1 .................. 42 Table 9-28 Summary of Cost Opinions for the Regional Evaluation ............................... 43 Table 9-29 Summary of Cost Opinions for the Regional Evaluation Assuming Relaxed Mercury Limits and Extending MHI Usage ............................................. 44 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 3 1. Introduction This Technical Memorandum (TM) presents the Engineer’s Opinions of Costs for construction, operations and maintenance, benefits with use of biosolids, and Present Worth costs. These costs are determined for the plant alternatives as defined in Technical Memorandums No. 1 through No. 6. Those alternatives were developed as part of Phase 1 of this study and refined as part of Phase 2 workshop conducted on June 2, 2010. Additional comments and direction from the District regarding specific elements of these alternatives were reconciled in subsequent group discussions. The costs presented here are used for comparisons, evaluations and selections of alternatives as defined in Technical Memorandum No. 10 Alternatives Selection Process and Result Table 9-1 s. A summary of the alternatives considered is provided in . Abbreviations used in the table are provided at the end of the table. Table 9-1 Summary of Alternatives Considered Alternative No. Alternative Description Bissell Point B-1 MHI+BFP Multiple hearth incineration with AEC and belt filter press dewatering. B-2 FBI+CFG Fluidized bed incineration with AEC and centrifuge dewatering. B-2-A FBI + ST Fluidized bed incineration with steam recovery. B-2-B FBI + STG Fluidized bed incineration with steam turbine power generation. Lemay L-1 MHI+BFP Multiple hearth incineration with AEC and belt filter press dewatering. L-2 FBI+BFP Fluidized bed incineration with AEC and belt filter press dewatering. L-3 FBI+CFG Fluidized bed incineration with AEC and centrifuge dewatering. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 4 Table 9-1 Summary of Alternatives Considered Alternative No. Alternative Description L-1-A MHI+STG Multiple hearth incineration with steam turbine power generation. L-2&3-A FBI+STG Fluidized bed incineration with steam turbine power generation. BFP & Centrifuge dewatering. Coldwater C-1 Current Operation Discharge of solids to Bissell collection system. C-2 BFP / Landfill Belt filter press dewatering with disposal to landfill. C-2-A CFG /Landfill Centrifuge dewatering with disposal to landfill. C-2-B RP /Landfill Rotary press dewatering with disposal to landfill. C-3 MAD / BFP Mesophilic anaerobic digestion with belt filter press dewatering. C-3-A MAD / CFG Mesophilic anaerobic digestion with centrifuge dewatering. C-3-B MAD / RP Mesophilic anaerobic digestion with rotary press dewatering. Lower Meramec LM-1 Current Operation Thickening with landfill disposal. LM-2 Thickening / Digestion Thickening with digestion and landfill disposal. Missouri River M-1 Current Operation Mesophilic anaerobic digestion with landfill disposal. M-2 Co-Digestion w/ FOG Co-digestion with fats, oils, and greases with landfill disposal. Regional R-1 FBI+CFG Fluidized bed incineration with AEC and centrifuge dewatering. R-1A FBI+ST Fluidized bed incineration with steam recovery. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 5 Table 9-1 Summary of Alternatives Considered Alternative No. Alternative Description R-1B FBI+STG Fluidized bed incineration with steam turbine power generation. Notes: Abbreviations used: AEC Advanced emission controls BFP Belt filter press dewatering MAD Mesophilic Anaerobic Digestion CFG Centrifuge dewatering FBI Fluidized bed incinerator FOG Fats, oils and greases MHI Multiple hearth incinerator RP Rotary press dewatering ST Steam system heat recovery, used for the plant or transferred to steam utility STG Steam turbine generator to produce electrical power 2. Cost Factors Costs and cost factors were developed for use in assessing overall capital and operations/maintenance costs. Costs for equipment and materials used are based on the following components and assumptions:  Support equipment and utilities including water supplies, electrical, and instrumentation and controls.  Building modifications, structural changes, new grating floors and access platforms for equipment.  Demolition of replaced equipment.  Instrumentation and controls to support new or modified equipment.  Manufacturer vendor quotes for significant equipment.  Engineer’s experience with similar projects, including power generation boilers and emissions controls.  Quantity take-offs and unit costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 6  In cases where existing belt filter presses are being retained, costs include maintenance repairs and overhauls for the existing presses through the life of the project.  In cases where existing incinerators are being retained, costs include new wet scrubbers to replace existing scrubbers. a. Construction Cost Factors Construction and design factors are applied to capital costs to generate total expected project costs. Capital costs include equipment, buildings, sitework, electrical, instrumentation, contingency, construction management/general conditions, bonding and insurance, and engineering costs. The cost factors used are listed in Table 9-2. . • Since the recommended incineration equipment facilities at the Bissell Point WWTP and the Lemay WWTP are similar, similar construction and design factors are used for both plants. • New buildings are assumed to have a 24 percent salvage value at the end of the project life. • Existing buildings and facilities are not assigned salvage values. • Equipment is generally assumed to have no salvage value at the end of the 20 year period but may be rebuilt or otherwise renewed to provide service for the design timeframe. • For Coldwater, Missouri River and Lower Meramec alternatives where equipment costs are large in comparison to overall costs, percentages used for electrical, instrumentation, and contractor costs have been reduced. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 7 Table 9-2 Construction Factors Used Bissell Point and Regional Facility Lemay Coldwater, Missouri River Lower Meramec Electrical 10 10 7 Instrumentation Existing Plant New Plant 4 3 4 3 3 3 Contingencies 25 25 25 Contractor Mobilization/General Requirements 10 10 6 Bonds, Insurance, Fees 5 5 5 Engineering and Legal 20 20 20 b. Operation and Maintenance Cost Factors Annual operation and maintenance (O&M) costs, disposal costs, and revenues are based on processing average annual solids production at the midpoint of the 20 year life of the projects. Power, labor, natural gas, chemicals and final use hauling and tipping costs are based on cost information supplied by MSD. Hauling costs for ash or dewatered cake to a landfill are estimated based on a 50 mile round trip and tipping fees provided by MSD. Annual benefits or savings are evaluated for alternatives where electrical power or steam is produced. If the energy is used at the plant, the value of the energy is considered to be the same as purchased energy. That is, a kilowatt of power generated on-site has the same value as a kilowatt of purchased electricity. For energy that is transferred to a third party vendor, such as steam, the value of the steam is estimated to be 75 percent of the rate charged to the vendor’s customers. The operating costs include the following:  Electricity used for process equipment and controls. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 8  Natural gas and fuel oil used for the incinerators (when required).  Operations and maintenance labor as defined for each alternative in the Alternatives Evaluation TMs.  Maintenance materials allowance for equipment (2 percent of equipment costs).  Chemicals, including thickening and dewatering polymer and odor control chemicals as identified defined in the Alternatives Evaluation TMs...  Ash disposal for the incineration alternatives.  Final use for biosolids, including composting, land application, or landfill disposal, as defined in the Alternative Evaluation TMs. Equalized unit costs for utilities and labor costs, disposal costs, and revenue sources used in the development of costs, are based on a 4 percent escalation rate and 5 percent discount rate over a 20-year period, are listed in Table 9-3. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 9 Table 9-3 Unit Costs and Revenues Used Units Bissell Point and Regional Facility Lemay Coldwater, Missouri River, & Lower Meramec Unit Costs Power $/kWh 0.102 0.012 0.102 Labor (includes benefits) Supervisor $/hr 35 35 35 Operator $/hr 30 30 30 Maintenance $/hr 32 32 32 Stationary Engineer $/hr 35 35 - Fuel Natural gas $/mmBtu 14.54 14.54 - Fuel oil $/gal 2.91 2.91 - Chemicals Polymer $/active lb 0.84 0.84 0.84 Odor control $/lb Disposal Costs Hauling $/cy 14.0 14.0 6.0 (MO River) 14.0 Landfill tipping fee $/wt - - 25.6 Hauling to Regional Facility from plant $/cy - 11.0 14.0 Ash lagoon cleanout $/cy 2 2 2 Revenue Sources Steam production $/1000 lbs -7.27 -7.27 -7.27 Power production $/kWh -0.131 -0. 131 -0. 131 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 10 3. Equipment and Process Considerations Capital costs are based on equipment and facility sizing for design year maximum month conditions for each alternative, with the exception of a few instances in which sizing or quantities were adjusted due to the available equipment size or to improve turn-down requirements. Costs are based on quotations from equipment vendors and include equipment installation, required ancillary or support equipment, repairs and replacements of existing equipment where needed, and building modifications or new buildings. Capital costs were developed for specific processes at each treatment facility; with consideration given to the potential for a future regional biosolids facility that would provide stabilization and end-use systems for all of the District’s treatment plants. Equipment modifications for each alternative considered for Bissell Point, Lemay, and a Regional Facility are shown in Table 9-4. Equipment modifications for the county facilities are provided in Table 9-5. The equipment modifications required under the regional concept are summarized in Table 9-6. Update: Table 9-7 was added to consider the impacts of reduced Mercury limits and the costs for upgrading the facilities by using the existing MHI’s for as long as possible. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives May 17, 2011 MSD Contract No. 2009145 B&V File 44.000 11 Table 9-4 Equipment and Modifications for Bissell, Lemay and Regional Plants Plant Bissell Point Lemay Regional Alternative No. B-1 B-2 B-2-A B-2-B L-1 L-2 L-3 L-1-A L-2&3-A R-1 R-1-A R-1-B Fog receiving - - - - - - - - - - - Cake Receiving R N N N - - - - - N N N Thickening R R R R R R R R R R R R Pump station and force main - - - - NR NR NR NR NR - - - Anaerobic Digestion - - - - - - - - - - - - Digester gas cleaning - - - - - - - - - - - - Dewatering R N N N R R R N R N N N Cake Handling and Storage R N N N R N N N N N N N Cake Load Out - - - - - F F F F - - - Incineration E N N N E N N N N N N N Odor Control - N N N E E E N N N N Energy recovery– steam - - N N E - - N N - N - Energy recovery – power - - - N - - N N - - N Advanced emissions Controls N N N N N N N N N N N Stack for incinerators N N N N R R R N N N Abbreviation definitions are provided following Table 9-6 Equipment and Modifications for the Regional Systems BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives May 17, 2011 MSD Contract No. 2009145 B&V File 44.000 12 Table 9-5 Equipment and Modifications for County Plant Alternatives Plant Coldwater Mo. River Lower Meramec Alternative No. C-1 C-2 C-2-A C-2-B C-3 C-3-A C-3-B M-1 M-2 LM-1 LM-2 Fog receiving - - - - - - - - N - - Cake Receiving - - - - - - - - - - - Thickening R R R R N N N R R E N Pump station and force main E - - - - - - - - - - Anaerobic Digestion - - - - E E E E E N N Digester gas cleaning - - - - N N N E E N N Dewatering - N N N N N N R R E E Cake Handling and Storage - N N N N N N E E E E Cake Load Out - N N N N N N E E E E Incineration - - - - - - - - - - - Odor Control - N N N N N N E E E E Energy recovery– steam - - - - - - - - - - - Energy recovery – power - - - - N N N N N N N Advanced emissions Controls - - - - - - - - - - - Stack for incinerators - - - - - - - - - - - Abbreviation definitions are provided following Table 9-6 Equipment and Modifications for the Regional Systems BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives May 17, 2011 MSD Contract No. 2009145 B&V File 44.000 13 Reviewed by: W. Hoener Table 9-6 Equipment and Modifications for the Regional Systems Plant Decentralized (No Regional) S-1 Regional Total System S-2 (Lemay Haul) Regional Total System S-3 (Lemay Pump) Alternative No. Bissell (B-2) Lemay (1 - 3) Coldwater (C-1) MO River (M-1) Lower Meramec (LM-1) Lemay Coldwater (C-1) MO River Lower Meramec Regional (R-1) Lemay Coldwater (C-1) MO River Lower Meramec Regional Fog receiving - - - - - - - - - - - - - - - Cake Receiving N - - - - - - - - N - - - - N Thickening R R R R E R R R E R R R R E R Pump station and force main - - E - - - E - - - NR E - - - Anaerobic Digestion - - - E N - - - - - - - - - - Digester gas cleaning - - - E N - - - - - - - - - - Dewatering N R - R E R - R E N - - R E N Cake Handling and Storage N N - E E N - E E N - - E E N Cake Load Out - F - E E F - E E - - - E E - Incineration N N - - - - - - - N - - - - N Odor Control N E - E E E - E E N E - E E N Energy recovery– steam - - - - - - - - - - - - - - - Energy recovery – power - - - N N - - - - - - - - - - Advanced emissions Controls N N - - - - - - - N - - - - N Stack for incinerators N - - - - - - - - N - - - - N BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives May 17, 2011 MSD Contract No. 2009145 B&V File 44.000 14 Reviewed by: W. Hoener Table 9-7 Equipment and Modifications for the Regional Systems Assuming Reduced Mercury Limits Plant Decentralized (No Regional) S-4 Regional Total System S-5 (Lemay Haul) Regional Total System S-6 (Lemay Pump) Alternative No. Bissell (B-2) Lemay (1 - 3) Coldwater (C-1) MO River (M-1) Lower Meramec (LM-1) Lemay Coldwater (C-1) MO River Lower Meramec Regional (R-1) Lemay Coldwater (C-1) MO River Lower Meramec Regional Fog receiving - - - - - - - - - - - - - - - Cake Receiving N - - - - - - - - N - - - - N Thickening R R R R E R R R E R R R R E R Pump station and force main - - E - - - E - - - NR E - - - Anaerobic Digestion - - - E N - - - - - - - - - - Digester gas cleaning - - - E N - - - - - - - - - - Dewatering R R - R E R - R E N - - R E N Cake Handling and Storage N N - E E N - E E N - - E E N Cake Load Out - F - E E F - E E - - - E E - Incineration E - 4 units E - 3 units - - - - - - - E - 5 units - - - - E - 5 Units Odor Control N E - E E E - E E N E - E E N Energy recovery– steam - - - - - - - - - - - - - - - Energy recovery – power - - - N N - - - - - - - - - - Advanced emissions Controls N - 4 units N - 3 units - - - - - - - N - 5 units - - - - N - 5 Units Stack for incinerators - - - - - - - - - N - - - - N BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 15 Abbreviations for the equipment modifications tables are based on the following definitions and considerations: Tag Explanation Comments E Existing equipment and process. May require modifications or upgrades F Future equipment Not included in alternative but may be required in future N New equipment or process Additional or may replace existing NR New equipment or process required for Regional Facility Only applies if Regional Facility is implemented O Optional Additional equipment for selected option R Reuse existing equipment or process Considered in good operating condition - Not required Not used for alternative 4. Project Capital Costs Table 9-8 through Table 9-14 provide capital costs for each alternative developed per treatment plant. Table 9-8 provides the capital costs for the Bissell Point facility. Alternatives B-1 and B- 2 summarize the differences between upgrading the existing MHI’s compared to abandoning the MHIs altogether and replacing them with new FBIs. The total project cost for alternative B-1 includes costs associated with a major re-build for the MHI equipment at year 10 of the project. It should be noted that during the development of feasible technologies, it was decided that the FBI alternative would include new building construction in an area between the existing solids handling building and the existing ash lagoons. It was determined that constructing the FBI’s within the existing MHI building was not feasible. Advanced emission control system will be provided for both MHI and FBI alternatives. Energy recovery as steam and steam turbine generation are shown as additional options for consideration for the FBI alternative, but are not applicable to the MHI option. As shown in the table, the opinion of project costs for the FBI are considerably higher than for the MHI alternative. The MHI alternative does not include the sunk equipment and structural costs for facilities that have been in place for more than forty years. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 16 The FBI costs are comparable to new facilities being constructed elsewhere in the U.S. for similar sized facilities. Energy recovery options generate revenue, which offset some the capital costs for implementation. These revenues are summarized in the annual cost summaries included in the following section. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 17 Table 9-8 Capital Costs for the Bissell Point WWTP ($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG Sitework $0 $200 $0 $0 Steam Pipeline $0 $0 $3,876 $0 Structures $2,385 $14,167 $0 $2,060 Equipment $24,122 $59,011 $6,318 $14,514 Subtotal $26,507 $73,378 $10,194 $16,574 General Requirements $2,716 $7,184 $0 $0 Electrical Work $2,618 $4,514 $100 $2,177 Instrumentation and Control System $1,047 $1,934 $48 $726 Contingency $8,222 $21,753 $948 $3,629 Mid-Point of Construction $4,214 $11,148 $1,157 $2,157 Subtotal $45,324 $119,911 $12,447 $23,202 AEC $19,484 $25,843 $0 $0 Total Probable Construction Cost $64,808 $145,754 $12,447 $23,202 Engineering & Construction Services $11,331 $29,978 $3,112 $5,801 MHI Re-build (year 10) $24,145 $0 $0 $0 Total Project Cost $100,284 $175,732 $15,559 $29,003 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 18 Capital costs for the Lemay treatment facility are provided in Table 9-9. There are three primary alternatives being considered. The first alternative is an upgrade to the MHI’s for continued operation. If the MHI’s were replaced, two alternatives using new FBI’s (with variations on dewatering equipment) are also included. The total project cost for alternative L-1 includes costs associated with a major re-build for the MHI equipment at year 10 of the project. For these FBI alternatives, dewatering would be accomplished with either belt filter presses (existing technology) or with centrifuges. The additional dewatering capacity and dryer cake produced with the centrifuges impacts the overall assessment for the FBI’s, hence the variations for dewatered equipment considered. Various energy recovery and advanced emission control options are also included that could be added to the FBI option now or in the future. As with the estimates for Bissell Point, the MHI option results in the lowest capital cost, followed by the FBI with belt filter press dewatering (BFP). Alternative L-3, consisting of an FBI with centrifuge dewatering, had the highest capital cost of the three primary options considered. The BFP option assumes that the existing BFP’s will be used in the future, with periodic overhauls required. For the Lemay facility, advanced emission control will be provided for both MHI and FBI alternatives. Steam generation is considered as adders for the MHIs as well as the FBIs. The costs for these options for the MHI’s is about 20 percent higher than if used for the FBIs because of the number of heat recovery units required. The FBIs use larger, but fewer units. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 19 Table 9-9 Capital Costs for the Lemay WWTP ($1000) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-2&3-FBI +STG Sitework $0 $200 $200 $0 $0 Structures $225 $6,799 $10,927 $2,060 $2,060 Equipment $10,478 $39,527 $48,101 $12,987 $10,062 Subtotal $10,703 $46,526 $59,228 $15,047 $12,122 General Requirements $1,098 $4,606 $5,212 $0 $0 Electrical Work $1,070 $3,257 $4,146 $2,257 $1,818 Instrumentation and Control System $428 $1,396 $1,777 $752 $606 Contingency $3,325 $13,946 $17,591 $3,012 $3,031 Mid-Point of Structures $1,704 $7,147 $9,015 $2,160 $1,802 Subtotal $18,328 $76,878 $96,969 $23,228 $19,379 AEC $30,535 $23,642 $23,642 $0 $0 Total Probable Construction Cost $48,863 $100,520 $120,611 $23,228 $19,379 Engineering & Construction Services $4,582 $19,220 $24,242 $5,807 $4,845 MHI Re-build (year 10) $22,690 $0 $0 $0 $0 Total Project Cost $76,135 $119,740 $144,853 $29,036 $24,223 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 20 Capital costs for the Coldwater treatment facility are shown in Table 9-10 for three primary alternatives: 1) continuing existing operations; 2) hauling dewatered cake to a landfill; and 3) providing anaerobic digestion with disposal options consisting of composting, land application, or hauling to landfill. The dewatering options for Alternatives L-2 and L-3 consist of belt filter presses (base case); centrifuge dewatering, or rotary press dewatering. Based on costs presented, centrifuge and rotary press dewatering result in lower capital costs compared to using belt filter presses; primarily because of the additional odor control equipment required for the belt filter presses. Table 9-10 Capital Costs for the Coldwater WWTP ($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Sitework $3,361 $483 $483 $483 $572 $572 $572 Structures 0 $1,671 $1,671 $1,671 $3,243 $3,243 $3,243 Equipment $844 $6,331 $5,818 $5,525 $11,762 $11,587 $11,438 Subtotal $4,205 $8.485 $7,971 $7,679 $15,576 $15,401 $15,252 General Requirements $386 $840 $789 $760 $1,542 $1,525 $1,510 Electrical Work $59 $594 $558 $538 $1,090 $1,078 $1,068 Instrumentation and Control System $25 $255 $239 $230 $467 $462 $458 Contingency $308 $2,331 $2,190 $2,110 $4,280 $4,232 $4,191 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 21 Table 9-10 Capital Costs for the Coldwater WWTP ($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Mid-Point of Construction $511 $1,282 $1,204 $1,160 $2,353 $2,327 $2,304 Total Probable Construction Cost $5,494 $13,787 $12,953 $12,477 $25,309 $25,024 $24,782 Engineering & Construction Services $1,374 $3,447 $3,238 $3,119 $6,327 $6,256 $6,196 Total Project Cost $6,868 $17,233 $16,191 $15,596 $31,636 $31,281 $30,977 Project capital costs for the Missouri River treatment facility are provided in Table 9-11. There are two primary options for the Missouri River plant: 1) continue with existing operations with the addition of gas utilization equipment; and 2) add co-digestion with fats, oils and grease (FOG) to the existing anaerobic digestion facilities. As shown, the FOG facilities add about $1million to the overall costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 22 Table 9-11 Capital Costs for the Missouri River WWTP ($1000) Alternative M-1 Current Operation w/ Additional CHP M-2 Co-digestion with FOG Sitework $0 $60 Structures $792 $853 Equipment $530 $885 Subtotal $1,322 $1,738 General Requirements $131 $178 Electrical Work $93 $126 Instrumentation and Control System $40 $54 Contingency $363 $494 Mid-Point of Construction $200 $272 Total Probable Construction Cost $2,148 $2,921 Engineering & Construction Services $537 $730 Total Project Cost $2,685 $3,652 Table 9-12 provides the capital costs for the Lower Meramec treatment facility. There are two primary alternatives to consider: 1) co-thickening with anaerobic digestion; and 2) separate thickening with anaerobic digestion. Currently, solids are thickened and dewatered using belt filter presses and, then are hauled to a local landfill. Adding digestion facilities to the current treatment operations results in a significant overall modification to the plant; this is reflected in the capital cost shown in the summary. Alternative LM-1 assumes that the existing gravity thickeners are used; whereas Alternative LM-2 provides for new rotary drum thickeners for the waste activated sludge. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 23 Table 9-12 Capital Costs for the Lower Meramec WWTP ($1000) Alternative LM-1 Co-thickening and Digestion LM-2 Separate Thickening and Digestion Sitework $288 $288 Structures $12,913 $13,195 Equipment $6,766 $9,405 Subtotal $19,967 $22,887 General Requirements $1,977 $1,242 Electrical Work $1,398 $1,602 Instrumentation and Control System $599 $687 Contingency $5,486 $6,032 Mid-Point of Construction $3,016 $3,326 Total Probable Construction Cost $32,442 $35,776 Engineering & Construction Services $8,111 $8,944 Total Project Cost $40,553 $44,720 Table 9-13 summarizes the capital costs for the Regional Plant alternative which provides the base option for constructing a new FBI system on the site of the Bissell Point treatment plant in the area between the existing solids processing building and the existing ash lagoon area. Additional options for energy recovery and advanced emission controls are also included in the cost estimate. The overall base case cost includes centrifuge dewatering for improved cake solids. The regional facility is sized to accommodate solids from all seven of the District’s wastewater facilities. The capital costs for the regional facility exceeds other alternatives. However, this alternative also consolidates biosolids stabilization options for the District into one BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 24 location, and allows for greater energy recovery. This alternative also eliminates significant administrative work associated with regulatory compliance, and simplifies the District’s overall operations. Costs associated with energy recovery and advanced emission controls are also provided as adders to the base case alternatives (R-1). Table 9-13 Capital Costs for the Regional Plant ($1000) Alternative R-1 FBI+CFG R-1-A FBI+ST R-1-B FBI+STG Sitework $315 $0 $0 Structures $23,177 $0 $3,296 Steam Pipeline $0 $2,304 $0 Equipment $76,514 $10,868 $17,329 Subtotal $100,006 $13,172 $20,625 General Requirements $9,901 $0 $0 Electrical Work $7,000 $100 $3,094 Instrumentation and Control System $3,000 $48 $1,031 Contingency $29,977 $1,860 $5,156 Mid-Point of Construction $15,363 $1,532 $3,065 Subtotal $165,247 $16,482 $32,972 AEC $37,873 $0 $0 Total Probable Construction Cost $203,120 $16,482 $32,972 Engineering & Construction Services $41,312 $4,121 $8,243 Total Project Cost $244,432 $20,603 $41,215 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 25 Table 9-14 summarizes the capital costs for the regional systems alternatives. The regional system alternatives are developed to better account for hybrid plans which may include some but not all the alternatives for the individual plants with a regional solids facility. For comparison the S-1 alternative considers the total capital costs for all alternatives under a de-centralized scenario in which there is no regional facility. The hybrid regional alternatives are: S-2, consisting of a regional facility in which the Lemay plant hauls solids to the Bissell Point plant; and S-3, a regional facility in which the Lemay plant pumps their solids into the collection system for dewatering and incineration at the regional facility at the Bissell Point plant. The S-3 option is based on the assumption that a pump station is constructed in the area of the Lemay treatment facility where the belt filter press feed pumps are located (connected to the existing thickened sludge well), and that a force main conveys the Lemay solids to the Barton Drop Shaft in the Bissell Point collection system. This arrangement was determined in a meeting held on August 20, 2010 with MSD staff familiar with the collection system in this area. It was noted that although discharge of solids into the Barton Drop Shaft conveys the solids to the Bissell tunnel (Reach 4), that there are still periods of time during wet weather events (approximately 50-60 times per year) in which flow into the tunnel at this point could be conveyed to the New Mill tunnel and discharged as part of a combined system overflow. Therefore, this option may need to incorporate sludge holding facilities such that solids discharge would not occur during wet weather events. Sludge holding facilities have not been included in these costs. This decision is pending a subsequent workshop with MSD to assess the need for storage, since the existing plant can operate for up to a week without processing solids, using storage in the existing primary and secondary clarifiers. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 26 Table 9-14 Capital Costs for the Regional Systems ($1000) Alternative Decentralized (No Regional) S-1 Regional Total System S-2 (Lemay Haul) Regional Total System S-3 (Lemay Pump) Sitework $4,049 $3,971 $33,728 Structures $38,799 $28,069 $26,004 Steam Pipeline $0 $0 $0 Equipment $115,253 $87,180 $84,383 Subtotal $158,101 $119,220 $140,645 General Requirements $14,890 $11,627 $13,947 Electrical Work $10,210 $8,110 $7,594 Instrumentation and Control System $4,375 $3,475 $3,254 Contingency $45,501 $34,706 $32,531 Mid-Point of Construction $23,890 $18,156 $20,648 Subtotal $256,967 $195,293 $222,089 AEC $49,485 $37,873 $37,873 Total Probable Construction Cost $306,452 $233,166 $259,962 Engineering & Construction Services $64,242 $48,825 $55,523 Total Project Cost $370,694 $281,991 $315,485 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 27 5. Operation / Maintenance Costs and Revenues Generated A summary of the annual costs, disposal costs, and revenues for the alternatives for the various plants and facilities are provided in Table 9-15 through Table 9-20. Annual costs and revenues for the Bissell Point facility are shown in Table 9-15. Annual costs were developed for new facilities and existing costs for the dewatering and incineration equipment used to develop the costs presented. Alternative B-1 summarizes the cost for the existing MHI option; while Alternative B-2 summarizes the FBI option (with centrifuge dewatering). The overall annual cost of MHI is higher than that of FBI, primarily due to the MHIs are toward the end of their useful lives thus requiring much more maintenance than the FBIs. Chemical costs are higher for the FBI option due to the use of centrifuges that require more polymer to produce the dryer cake desired. The remaining two alternatives summarize costs associated with adding steam generation and power generation. Steam and power generation are anticipated to produce revenues that offset overall operational costs. Table 9-15 Annual Costs and Revenues for Bissell Point WWTP Alternatives ($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG Operation Costs Power $1,629 $2,484 $53 $118 Labor $2,184 $2,151 $186 $373 Fuel Maintenance $1,827 $2,433 $284 $1,175 $0 $119 $0 $175 Odor control $0 $50 $0 $0 Chemicals $512 $1,122 $25 Total operating costs $25 $8,585 $7,266 $383 $691 Hauling And Disposal $594 $594 $0 $0 Total Annual Costs $9,179 $7,860 $383 $691 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 28 Table 9-15 Annual Costs and Revenues for Bissell Point WWTP Alternatives ($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG Revenues Steam ($0) ($0) ($855) ($0) Power generation ($0) ($0) ($0) ($880) Total Annual Revenues ($0) ($0) ($855) ($880) Overall annual costs for the Lemay treatment facility are provided in Table 9-16 below. As shown, there are comparable annual costs for Alternatives L-1 and L-2 which summarize annual costs for operating MHIs and FBI’s respectively. Both alternatives use belt filter press dewatering. Costs for Alternative L-3 increase with centrifuge dewatering because of additional power and polymer use compared to the BFPs. Some of these costs are offset from revenue generated from steam sales or power generation, as summarized in Alternative L-1-A (for MHI’s) and Alternatives L-2 and l-3 (for FBI’s). Heat recovered and converted to steam for sale or power generation produces revenues that are similar for both types of incinerators, given the same solids feed and characteristics. Costs for hauling and disposal are the same for either major alternative for incineration and dewatering. Table 9-16 Annual Costs and Revenues for Lemay WWTP Alternatives ($1000) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-2&3-A FBI +STG Operation Costs Power $866 $1282 $1,720 $107 $107 Labor $1,689 $1,623 $1,623 $339 $339 Fuel Maintenance $723 $1,671 $298 $909 $82 $1,072 $0 $205 $0 $123 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 Reviewed by: W. Hoener 29 Table 9-16 Annual Costs and Revenues for Lemay WWTP Alternatives ($1000) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-2&3-A FBI +STG Odor Control $0 $0 $50 $0 $0 Chemicals $350 $350 $640 $25 Total operating costs $25 $5,299 $4,462 $5,190 $676 $594 Hauling And Disposal $396 $396 $396 $0 $0 Total Annual Costs $5,695 $4,858 $5,587 $676 $594 Revenues Steam ($0) ($0) ($0) ($0) ($0) Power generation ($0) ($0) ($0) ($429) ($432) Total Annual Revenues ($0) ($0) ($0) ($429) ($432) Table 9-17 provides a summary of the annual costs associated with alternatives considered for the Coldwater treatment facility. As shown in Alternative C-2, annual costs associated with hauling cake to a landfill rise are dramatically higher as compared to the existing alternative of discharging the solids into the collection system for the Bissell Point treatment facility. Alternative C-2 (base case) considers belt filter press dewatering. Alternatives C-2-A and C-2-B provide costs for centrifuge and rotary press dewatering in lieu of belt filter presses, and as shown, have significantly lower annual costs associated with them; primarily due to the differences in odor control that are required. Belt filter presses in this case are anticipated to have significantly greater odor control requirements. Alternative C-3 considers adding anaerobic digestion to the plant with belt filter presses used for dewatering. C-3-A and C-3-B show cost reductions with the use of centrifuges and rotary presses respectively. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 2009145 B&V File 44.000 30 Reviewed by: W. Hoener Table 9-17 Annual Costs and Revenues for Coldwater WWTP Alternatives ($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Operation Costs Power $121 $162 $190 $163 $436 $440 $434 Labor $37 $145 $145 $145 $431 $431 $431 Fuel $0 $0 $0 $0 $0 $0 $0 Maintenance $18 $208 $105 $101 $495 $388 $391 Chemicals $0 $81 $162 $162 $140 $239 $239 Digester Cleaning $0 $0 $0 $0 $26 $26 Total Operation Costs $26 $176 $596 $602 $571 $1,528 $1,524 $1,521 Hauling And Disposal $0 $898 $795 $795 $741 $630 $630 Total Annual Costs $176 $1,494 $1,397 $1,366 $2,269 $2,154 $2,151 Revenues Steam $0 $0 $0 $0 ($440) ($440) ($440) Power generation $0 $0 $0 $0 $0 $0 $0 Total Annual Revenues $0 $0 $0 $0 ($440) ($440) ($440) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 31 Reviewed by: W. Hoener Annual costs for anaerobic digestion are considerably greater than either the current option (discharge into the Bissell Point collection system) or hauling cake solids to a landfill. However, there is an offset associated with revenues generated from the production of gas with this option of about $440,000 per year. Dewatering options associated with using centrifuges and rotary presses instead of belt filter presses result in a lower annual costs due to the reduction in odor control costs associated with the latter two alternatives. Annual costs associated with the Missouri River treatment facility are summarized in Table 9-18 for Alternative M-1, consisting of the current operation of anaerobic digestion with gas utilization equipment added; and Alternative M-2, consisting of anaerobic digestion with the addition of a FOG receiving station and co-digestion of the FOG with the plant’s biosolids. The table shows additional labor and maintenance associated with co-digestion alternative but the FOG facilities result in more revenue received from the additional gas generated (and used to produce power). The predominant contributor to annual cost for either of these options is the cake hauling costs, which are the same for both alternatives. When considering both annual costs and revenues, the alternatives are comparable for total net costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 32 Reviewed by: W. Hoener Table 9-18 Annual Costs and Revenues for Missouri River WWTP Alternatives ($1000) Alternative M-1 Current Operation w/ Additional CHP M-2 Co-digestion with FOG Operation Costs Power $852 $8162 Labor $117 $186 Fuel $0 $0 Maintenance $396 $442 Chemicals $673 $678 Total operating costs $2,102 $2,234 Hauling And Disposal $1,788 $1,788 Total Annual Costs $3,892 $4,022 Revenues Steam $0 $0 Power generation ($1,370) ($1,603) Total Annual Revenues ($1,495) ($1,750) Annual costs and revenues for the Lower Meramec treatment facility are summarized in Table 9- 19. Alternative LM-1 consists of co-thickening with digestion; while Alternative LM-2 considers separate thickening with anaerobic digestion. Costs for dewatering polymer were also included. Operating costs for Alternative LM-1 are approximately 15 percent lower Alternative LM-2. Revenues generated from energy produced from the digester gas generated are the same for both alternatives. The predominant factors for each alternative are the costs for hauling and disposal, which are the same. Consequently, the two alternatives result in relatively similar overall annual costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 33 Reviewed by: W. Hoener Table 9-19 Annual Costs and Revenues for Lower Meramec Plant Alternatives ($1000) Alternative LM-1 Co-thickening and Digestion LM-2 Separate Thickening and Digestion Operation Costs Power $331 $279 Labor $117 $215 Fuel $0 $0 Maintenance $387 $328 Chemicals $151 $207 Digester Cleaning $86 $82 Total operating costs $1,061 $1,180 Hauling And Disposal $1,129 $1,129 Total Annual Costs $2,190 $2,309 Revenues Steam $0 $0 Power generation ($537) ($537) Total Annual Revenues ($537) ($537) Table 9-20 summarizes annual costs associated with the Regional Facility for the primary option of an FBI system using centrifuge dewatering. Costs associated with steam production (and revenues generated) and power generation from steam are summarized as Alternatives R-1-A and R-1-B, respectively. As expected, the overall annual cost associated with processing solids for all of the District’s wastewater treatment facilities at one regional plant are quite high comparatively. However, revenues generated from the recovery of energy provide significant offsets, with steam sales providing a 75 percent greater return than power. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 34 Reviewed by: W. Hoener Table 9-20 Annual Costs and Revenues for the Regional Plant Alternatives ($1000) Alternative R-1 FBI+CFG R-1-A FBI + ST R-1-B FBI + STG Operation Costs Power $3,792 $130 $302 Labor $2,151 $186 $373 Fuel Maintenance $559 $1,684 $0 $220 $0 $287 Odor Control $3,300 $0 $0 Chemicals $1,273 $30 Total operating costs $30 $12,759 $566 $992 Hauling And Disposal $1,473 $0 $0 Total Annual Costs $14,232 $566 $992 Revenues Steam ($0) ($2,760) ($0) Power generation ($0) ($0) ($2,861) Total Annual Revenues ($0) ($2,760) ($2,861) For a better assessment of a regional facility located at the Bissell Point plant, additional comparisons were developed to provide an evaluation of a regional facility option to a de- centralized, no-regional option. The annual costs and revenues for these comparisons are provided in Table 9-21. The annual costs for these three systems are similar. Annual revenues from power generation from digester gas at two of the plants reduce the costs of the decentralized alternative. Regional Alternative S-2, which uses hauling of dewatered solids from Lemay to the regional facility is more cost effective than for Alternative S-3 which uses pumping liquid solids into the Bissell Point collection system. For the Regional alternatives, annual costs are approximately the same at $16 million, with the majority of this cost associated with the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 35 Reviewed by: W. Hoener operation of odor control for the receiving facilities at regional facility. The remaining costs are associated with conveying (by pumping or hauling) solids from the remaining facilities to a regional facility located on the Bissell Point site. Additional information related to the regional alternative is provided in Appendix A. Table 9-21 Annual Costs and Revenues for the Regional Systems ($1000) Alternative Decentralized (No Regional) S-1 Regional Total System S-2 (Lemay Haul) Regional Total System S-3 (Lemay Pump) Operation Costs Power $5,564 $4,621 $4,476 Labor $4,045 $2,423 $2,765 Fuel $366 $558 $558 Maintenance $2,981 $1,816 $1,842 Odor Control $100 $3,350 $3,300 Digester Cleaning $153 $0 $0 Chemicals $2,590 $3,047 Total operating costs $2,630 $15,799 $15,815 $15,571 Hauling And Disposal $3,907 $4,294 $3,320 Total Annual Costs $19,706 $20,109 $18,891 Revenues Steam ($0) ($0) ($0) Power generation ($2,032) ($0) ($0) Total Annual Revenues ($2,032) ($0) ($0) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 36 Reviewed by: W. Hoener 6. Overview of Alternatives Costs Overall present worth costs for each alternative were developed based on the following assumptions:  20 year life of project, salvage values as defined for capital costs  Five (5) percent interest rate  Project capital costs from Table 9-8 through Table 9-14 for the various plants and alternatives.  Annual costs and revenues from Table 9-15 through Table 9-21 for the various plants and alternatives Summaries of capital costs, annual costs and revenues, and present worth costs for all the alternatives and plants are presented in the following tables. Values from the tables presented in this TM are used in the Triple Bottom Line evaluations, as described in Technical Memorandum No. 10 Alternatives Selection Process and Results. Table 9-22 summarizes the present worth costs for the Bissell Point facility for the two primary alternatives of MHI incineration versus FBI incineration; with costs associated with energy recovery provided as additional costs to the primary FBI alternative. The capital cost and total present worth cost for alternative B-1 includes costs associated with a major re-build for the MHI equipment at year 10 of the project. Total present worth costs are approximately $214 million for the MHI alternative compared to the $272 million shown for the FBI base alternative. The cost difference reflects additional equipment costs for the new facility compared to reuse of existing equipment with fully amortized costs. Revenues associated with the recovery of steam provide significant offsets, but still result in an increase in the overall present worth costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 37 Reviewed by: W. Hoener Table 9-22 Summary of Cost Opinions for Bissell Plant Alternatives 1 ($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG Capital Costs $100,284 $175,732 $15,559 $29,003 Salvage Value ($782) ($4,556) ($1,861) ($494) Annual O&M Costs $9,179 $7,860 $383 $691 Annual Revenue ($0) ($0) ($855) ($806) Present Worth Costs Capital $100,284 $175,732 $15,559 $29,003 Salvage ($295) ($1,717) ($701) ($186) O&M $114,393 $97,947 $4,773 $8,611 Revenue ($0) ($0) ($10,655) ($10,971) Total Present Worth Costs $214,382 $271,962 $8,976 $26,457 Table 9-23 summarizes the overall present worth costs for the Lemay treatment facility. Total present worth costs associated with the MHIs are approximately 80 percent of those for FBIs with existing belt filter press dewatering. The capital cost and total present worth cost for alternative L-1 includes costs associated with a major re-build for the MHI equipment at year 10 of the project. Replacement of the belt filter presses with centrifuges results in additional present BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 38 Reviewed by: W. Hoener worth costs. Addition of energy recovery for both MHI and FBI alternatives also increases the present worth costs. Table 9-23 Summary of Cost Opinions for Lemay Plant Alternatives 1 ($1000) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-2&3-A FBI +STG Capital Costs $76,135 $119,739 $144,853 $29,036 $24,223 Salvage Value ($3,093) ($2,625) ($3,616) ($494) ($494) Annual O&M Costs $5,695 $4,858 $5,587 $676 $644 Annual Revenue ($0) ($0) ($0) ($429) ($432) Present Worth Costs Capital $76,135 $119,739 $144,853 $29,036 $24,223 Salvage ($1,166) ($989) ($1,363) ($186) ($186) O&M $70,972 $60,536 $69,622 $8,424 $8,021 Revenue ($0) ($0) ($0) ($5,348) ($5,384) Total Present Worth Costs $145,941 $179,286 $213,112 $31,926 $26,056 1. See Technical Memorandum No. 2 for description of alternatives. Present worth costs for the Coldwater treatment facility are provided in Table 9-24. Alternative C-1 represents the lowest cost option with a present worth cost of $9M, followed by Alternative C-2 (hauling cake to a landfill) with a present worth cost of $36M using belt filter presses for dewatering. Present worth costs are reduced for Alternative 2 with centrifuge or rotary press dewatering. Alternative C-3 (anaerobic digestion with cake hauling) has the highest overall present cost at $54M. Again, as with Alternative C-2, digestion costs are offset with the utilization of centrifuge or rotary press dewatering in lieu of belt filter press dewatering (base case) due the reduced costs associated with odor control. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives May 17, 2011 MSD Contract No. 2009145 B&V File 44.000 39 Reviewed by: W. Hoener Table 9-24 Summary of Cost Opinions for Coldwater Plant Alternatives 1 ($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Capital Costs $6,868 $17,233 $16,191 $15,596 $31,636 $31,281 $30,977 Salvage ($601) ($401) ($401) ($401) ($584) ($584) ($584) Annual O&M Costs $176 $1,494 $1,397 $1,366 $2,269 $2,154 $2,151 Annual Revenue $0 $0 $0 $0 ($440) ($440) ($440) Present Worth Costs Capital $6,868 $17,233 $16,191 $15,596 $31,636 $31,281 $30,977 Salvage ($227) ($151) ($151) ($151) ($220) ($220) ($220) O&M $2,193 $18,619 $17,410 $17,024 $28,280 $26,847 $26,809 Revenue $0 $0 $0 $0 ($5,485) ($5,485) ($5,485) Total Present Worth Costs $8,830 $35,700 $33,450 $32,470 $54,210 $52,420 $50,080 1. See Technical Memorandum No. 3 for description of alternatives. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 40 Reviewed by: W. Hoener Overall present worth costs for the Missouri River Plant are summarized in Table 9-25. Alternative M-2 results in a higher capital cost with the inclusion of FOG facilities, but this is offset by the increased production of gas and power generation from the gas. Consequently, overall present worth costs for both options are comparable, differing by less than 2 percent. Table 9-25 Summary of Cost Opinions for Missouri River Plant Alternatives 1 ($1000) Alternative M-1 Current Operation w/ Additional CHP M-2 Co-digestion with FOG Capital Costs $2,686 $3,652 Salvage ($190) ($219) Annual O&M Costs $3,892 $4,022 Annual Revenue ($1,495) ($1,750) Present Worth Costs Capital $2,686 $3,652 Salvage ($72) ($83) O&M $48,508 $50,128 Revenue ($19,631) ($21,809) Total Present Worth Costs $32,490 $31,890 1. See Technical Memorandum No. 4 for description of alternatives. Present worth costs associated with the Lower Meramec treatment facility are shown in Table 9- 26 for Alternative LM-1 (consisting of co-thickening and digestion) and LM-2 (consisting of separate thickening and digestion). The Lower Meramec plant does not currently include BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 41 Reviewed by: W. Hoener anaerobic digestion, and as such, these facilities would result in a significant modification to the overall plant. Table 9-26 Summary of Cost Opinions for Lower Meramec Plant Alternatives 1 ($1000) Alternative LM-1 Co-thickening and Digestion LM-2 Separate Thickening and Digestion Capital Costs $40,553 $44,720 Salvage Value ($5,275) ($4,944) Annual O&M Costs $2,190 $2,309 Annual Revenue ($537) ($537) Present Worth Costs Capital $40,553 $44,720 Salvage ($1,988) ($1,863) O&M $27,292 $28,775 Revenue ($6,692) ($6,692 Total Present Worth Costs $59,170 $64,940 1. See Technical Memorandum No. 5 for description of alternatives. Present worth costs for the regional facility are shown in Table 9-27 with the primary alternative of an FBI system with centrifuge dewatering having a total cost of approximately $419 million. Additional alternatives for energy recovery and emission controls are also included. Alternative R-1-A with steam production and sale to Trigen (or another entity) results in the lowest overall present worth cost due to the revenues generated with this option. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 42 Reviewed by: W. Hoener Table 9-27 Summary of Cost Opinions for Regional Facility Alternatives 1 ($1000) Alternative R-1 FBI+CFG R-1-A FBI+ST R-1-B FBI+STG Capital Costs $244,432 $20,603 $41,215 Salvage Value ($7,075) ($1,106) ($791) Annual O&M Costs $14,232 $566 $992 Annual Revenue ($0) ($2,760) ($2,861) Present Worth Costs Capital $244,432 $20,603 $41,215 Salvage Value ($2,667) ($417) ($298) O&M $177,357 $7,054 $12,363 Revenue ($0) ($34,399) ($35,655) Total Present Worth Costs $419,122 ($7,159) $17,625 The overall present worth costs summary of a regional system versus a de-centralized system are provided in Table 9-28. As shown, the de-centralized alternative has the highest overall present worth cost associated with it. The lowest overall present worth cost consists of the regional concept where Lemay solids are hauled to the Bissell Point regional facility. Pumping of liquid from Lemay has additional present worth costs that increase the regional facility present worth costs. For the regional systems options, only the base case is considered with no revenue offsets are included for sale of steam or power generation. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 43 Reviewed by: W. Hoener Table 9-28 Summary of Cost Opinions for the Regional Evaluation ($1000) Alternative Decentralized (No Regional) S-1 Regional Total System S-2 Regional Total System S-3 Capital Costs $366,785,000 $274,488,000 $316,143,000 Salvage Value ($10,626,000) ($9,034,000) ($15,875,000) Annual O&M Costs $20,362,000 $20,109,000 $17,182,000 Annual Revenue ($2,032,000) $0 $0 Present Worth Costs Capital $366,785,000 $274,488,000 $316,143,000 Salvage Value ($4,005,000) ($3,405,000) ($5,983,000) O&M $253,756,000 $250,603,000 $214,126,000 Revenue ($25,323,000) $0 $0 Total Present Worth Costs $591,213,000 $521,686,000 $524,286,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 44 Reviewed by: W. Hoener Update: Table 9-29 provides the update for the evaluation of a regional system alternatives assuming that the Mercury limit is relaxed to the point that the existing MHI’s would continue to function indefinitely. Equipment modifications for this option were summarized in Table 9-7. As shown, capital costs are reduced significantly in comparison to the costs shown in Table 9-28. O&M costs for S-4 and S-5 (compared to S-1 and S-2) are significantly higher however, such that the overall present worth costs for those two basic alternatives are reasonably close. Alternative S-6 represents the lowest overall present worth cost of the six alternatives. Table 9-29 Summary of Cost Opinions for the Regional Evaluation Assuming Relaxed Mercury Limits and Extending MHI Usage ($1000) Alternative Decentralized (No Regional) S-4 Regional Total System S-5 Regional Total System S-6 Capital Costs $251,057,750 $166,674,000 $242,959,000 Salvage Value ($3,289,000) ($701,000) ($2,187,000) Annual O&M Costs $26,278,000 $25,247,000 $20,911,000 Annual Revenue ($2,032,000) $0 $0 Present Worth Costs Capital $251,058,000 $166,674,000 $242,959,000 Salvage Value ($1,240,000) ($264,000) ($824,000) O&M $327,482,000 $314,633,000 $260,597,000 Revenue ($25,323,000) $0 $0 Total Present Worth Costs $551,977,000 $481,043,000 $502,732,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Opinions of Costs for Alternatives August 30, 2010 MSD Contract No. 200914 Updated: January 19, 2011 Final: May 17, 2011 B&V File 44.000 45 Reviewed by: W. Hoener Appendix A Summary of Cost Opinions for the Regional Systems Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Thickening (New EQ) Force Main to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tank) Dewatering1 BFP Cake Storage and Loadout to Disposal1 (New Extra Capacity) Lemay Thickening Gravity Thickening GBT Dewatering Centrifuge Bissell Point Thickening Gravity Thickening GBT Dewatering Centrifuge Incineration FBI (New) Ash Dewatering (Ash Lagoon, upgrade to slurry system) Ash Loadout MSD Decentralized Treatment System (S-1) Solids Handling Process Flow Chart MO River Thickening RDT Thickening Anaerobic Digestion Dewatering Centrifuge Cake Storage and Loadout to Disposal CHP (New EQ) End Use End Use Incineration FBI (New) Ash Dewatering (Ash Lagoon, upgrade to slurry system) End Use End Use Ash Loadout Anaerobic Digestion (New) CHP (New) Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Thickening (New EQ) Force Main to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tank) Dewatering1 BFP Cake Storage and Loadout to Disposal1 (New Extra Capacity) Lemay Thickening Gravity Thickening GBT Dewatering BFP Bissell Point Thickening Gravity Thickening GBT Dewatering BFP Incineration MHI (Existing) Ash Dewatering (Ash Lagoon, upgrade to slurry system) Ash Loadout MSD Decentralized Treatment System (S-4) Solids Handling Process Flow Chart MO River Thickening RDT Thickening (New EQ) Anaerobic Digestion Dewatering Centrifuge Cake Storage and Loadout to Disposal CHP (New EQ) End Use End Use Incineration MHI (Existing) Ash Dewatering (Ash Lagoon, upgrade to slurry system) End Use End Use Ash Loadout Anaerobic Digestion (New) CHP (New) Bissell Point Lemay Coldwater Mo. River Lower Meramec TotalAlternativesCFG+2 FBI CFG+2 FBI PS+FM AD+DW AD+DW General General Requirements 7,184,000 5,212,000 386,000 131,000 1,977,000 14,890,000 Sitework 200,000 200,000 3,361,000 0 288,000 4,049,000 Structures Gravity Thickener 763,000 763,000 Thickening and Dewatering Building Digesters 8,306,000 8,306,000 Digester Building 2,037,000 2,037,000 Dewatering Building 4,128,000 4,128,000 8,256,000 Cake Loadout Building CHP Building 792,000 1,807,000 2,599,000 Incinerator Building 7,879,000 6,799,000 14,678,000 Sludge Receiving 2,160,000 2,160,000 Subtotal Structures 14,167,000$ 10,927,000$ -$ 792,000$ 12,913,000$ 38,799,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment 4,949,000 4,949,000 Dewatering Equipment 8,704,000 8,574,000 17,278,000 Digester Gas Utilization 530,000 1,194,000 1,724,000 Incinerator Equipment 41,082,000 39,303,000 80,385,000 Sludge Receiving 0 Conveyance Equipment Odor Control 3,300,000 2,240,000 5,540,000 Pump Station 480,000 480,000 Subtotal Equipment 53,086,000$ 50,117,000$ 844,000$ 530,000$ 6,767,000$ 111,344,000$ Electrical 4,514,000 4,146,000 59,000 93,000 1,398,000 10,210,000 Instrumentation & Control 1,934,000 1,777,000 25,000 40,000 599,000 4,375,000 Subtotal 81,085,000 72,379,000 4,675,000 1,586,000 23,942,000 183,667,000 Contingencies 21,753,000 17,591,000 308,000 363,000 5,486,000 45,501,000 Mid-Point of Construction 11,148,000 9,015,000 511,000 200,000 3,016,000 23,890,000 TOTAL Construction Cost 113,986,000$ 98,985,000$ 5,494,000$ 2,149,000$ 32,444,000$ 253,058,000$ Engineering 29,978,000 24,242,000 1,374,000 537,000 8,111,000 64,242,000 Advanced Emission Control 25,843,000 23,642,000 49,485,000 TOTAL PROJECT COST 169,807,000$ 146,869,000$ 6,868,000$ 2,686,000$ 40,555,000$ $366,785,000 Salvage 10,626,000$ Final Printed:10/20/2011 14:53 MSD Decentralized Treatment System (S-1) Solids Handling Process Capital Costs MSD Decentralized Treatment System (S-4) Solids Handling Process Capital Costs Bissell Point Lemay Coldwater Mo. River Lower Meramec TotalAlternativesBFP+ 4 MHIs BFP+ 3 MHIs PS+FM AD+DW AD+DW General General Requirements 3,892,000 1,418,000 386,000 131,000 1,977,000 7,804,000 Sitework 200,000 225,000 3,361,000 0 288,000 4,074,000 Structures Gravity Thickener 763,000 763,000 Thickening and Dewatering Building Digesters 8,306,000 8,306,000 Digester Building 2,037,000 2,037,000 Dewatering Building 0 0 0 Cake Loadout Building CHP Building 792,000 1,807,000 2,599,000 Incinerator Building 0 0 0 Sludge Receiving 0 0 Subtotal Structures -$ -$ -$ 792,000$ 12,913,000$ 13,705,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment 0 4,949,000 4,949,000 Dewatering Equipment 0 0 0 Digester Gas Utilization 530,000 1,194,000 1,724,000 Incinerator Equipment 13,637,000 10,478,000 24,115,000 Sludge Receiving 0 0 Conveyance Equipment 0 0 Odor Control 3,300,000 0 3,300,000 Pump Station 480,000 480,000 Subtotal Equipment 16,937,000$ 10,478,000$ 844,000$ 530,000$ 6,767,000$ 35,556,000$ Electrical 2,752,000 1,070,000 59,000 93,000 1,398,000 5,372,000 Instrumentation & Control 1,179,000 428,000 25,000 40,000 599,000 2,271,000 Subtotal 24,960,000 13,619,000 4,675,000 1,586,000 23,942,000 68,782,000 Contingencies 11,784,000 3,405,000 308,000 363,000 5,486,000 21,346,000 Mid-Point of Construction 6,039,000 1,745,000 511,000 200,000 3,016,000 11,511,000 TOTAL Construction Cost 42,783,000$ 18,769,000$ 5,494,000$ 2,149,000$ 32,444,000$ 101,639,000$ Engineering 10,695,750 4,692,000 1,374,000 537,000 8,111,000 25,409,750 Advanced Emission Control 33,318,000 30,535,000 63,853,000 Rebuild MHIs in year 10 32,194,000 22,690,000 54,884,000 Sludge Loadout 5,272,000 TOTAL PROJECT COST 118,990,750$ 81,958,000$ 6,868,000$ 2,686,000$ 40,555,000$ $251,057,750 Salvage $0 $0 $0 $190,000 $3,099,000 3,289,000$ Final Printed:10/20/2011 14:53 MSD Decentralized Treatment System (S-4) Solids Handling Process Capital Costs Bissell Point Lemay Coldwater Mo. River Lower Meramec TotalAlternativesCFG+FBI CFG+FBI PS+FM AD+DW AD+DW Power 2,484,000$ 1,720,000$ 121,000$ 852,000$ 387,000$ 5,564,000$ Fuel - Natural Gas 267,000 76,000 343,000 Fuel Oil 17,000 5,500 22,500 Other - Subtotal 284,000$ 81,500$ -$ -$ -$ 365,500$ Labor - Operations 1,179,000 786,000 33,000 66,000 66,000 2,130,000 Maintenance 666,000 400,000 4,000 33,000 33,000 1,136,000 Supervisor 306,000 306,000 18,000 18,000 648,000 Stationary Engineer - Other - Subtotal 2,151,000$ 1,492,000$ 37,000$ 117,000$ 117,000$ 3,914,000$ Maintenance - Equipment 1,175,000 1,671,000 18,000 396,000 320,000 3,580,000 Subtotal 1,175,000$ 1,671,000$ 18,000$ 396,000$ 320,000$ 3,580,000$ Chemicals - Polymer 1,024,000 294,000 673,000 151,000 2,142,000 Sodium Permanganate (OC)- Powdered Activated Carbon 98,000 56,000 154,000 Water treatment - Other - Subtotal 1,122,000$ 350,000$ -$ 673,000$ 151,000$ 2,296,000$ Digester Cleaning - Digester Cleaning 24,000 41,000 65,000 Digester Painting 8,000 10,000 18,000 Membrane Cover Replacement 35,000 35,000 70,000 Subtotal -$ 67,000$ 86,000$ 153,000$ Transportation and Disposal - Hauling Fee 594,000 775,000 426,000 411,000 2,206,000 Landfill Tip Fee 41,000 1,362,000 718,000 2,121,000 Land Application Fee -- Ash lagoon cleanout 62,000 62,000 Subtotal 594,000$ 878,000$ -$ 1,788,000$ 1,129,000$ 4,389,000$ Odor Control 50,000 50,000 100,000 Total Annual Costs 7,860,000$ 6,243,000$ 176,000$ 3,893,000$ 2,190,000$ 20,362,000$ - ANNUAL REVENUE ($ per annum)- - Power - ($1,495,000)($537,000)($2,032,000) Steam - - - - Hot Water - - - - Digester gas - - - - Dried pellets - - - - Other - - - - Total Annual Revenues $0 $0 $0 ($1,495,000)($537,000)($2,032,000) Printed:10/20/2011 14:53 MSD Decentralized Treatment System (S-1) Solids Handling Process O&M Costs Bissell Point Lemay Coldwater Mo. River Lower Meramec TotalAlternativesBFP + 4 MHIs BFP+ 3 MHIs PS+FM AD+DW AD+DW Power 2,609,000$ 1,154,000$ 121,000$ 852,000$ 387,000$ 5,123,000$ Fuel - Natural Gas 2,741,000 723,000 3,464,000 Fuel Oil - - - Other - Subtotal 2,741,000$ 723,000$ -$ -$ -$ 3,464,000$ Labor - Operations 1,310,000 786,000 33,000 66,000 66,000 2,261,000 Maintenance 699,000 466,000 4,000 33,000 33,000 1,235,000 Supervisor 306,000 306,000 18,000 18,000 648,000 Stationary Engineer - Other - Subtotal 2,315,000$ 1,558,000$ 37,000$ 117,000$ 117,000$ 4,144,000$ Maintenance - Equipment 2,572,000 2,359,000 18,000 396,000 320,000 5,665,000 Subtotal 2,572,000$ 2,359,000$ 18,000$ 396,000$ 320,000$ 5,665,000$ Chemicals - Polymer 1,529,000 294,000 673,000 151,000 2,647,000 Sodium Permanganate (OC)50,000 29,000 79,000 Powdered Activated Carbon 98,000 56,000 154,000 Water treatment - Other - Subtotal 1,677,000$ 379,000$ -$ 673,000$ 151,000$ 2,880,000$ Digester Cleaning - Digester Cleaning 24,000 41,000 65,000 Digester Painting 8,000 10,000 18,000 Membrane Cover Replacement 35,000 35,000 70,000 Subtotal -$ 67,000$ 86,000$ 153,000$ Transportation and Disposal - Hauling Fee 810,000 775,000 426,000 411,000 2,422,000 Landfill Tip Fee 41,000 1,362,000 718,000 2,121,000 Land Application Fee - Ash lagoon cleanout 194,000 62,000 256,000 Subtotal 1,004,000$ 878,000$ -$ 1,788,000$ 1,129,000$ 4,799,000$ Odor Control 50,000 50,000 Total Annual Costs 12,968,000$ 7,051,000$ 176,000$ 3,893,000$ 2,190,000$ 26,278,000$ - ANNUAL REVENUE ($ per annum)- - Power - ($1,495,000)($537,000)($2,032,000) Steam - - - - Hot Water - - - - Digester gas - - - - Dried pellets - - - - Other - - - - Total Annual Revenues $0 $0 $0 ($1,495,000)($537,000)($2,032,000) Printed:10/20/2011 14:53 MSD Decentralized Treatment System (S-4) Solids Handling Process O&M Costs Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Thickening Force Main to Regional Facility (New PS & FM) MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP Cake Storage and Loadout to Regional Facility1 Lemay Thickening Gravity Thickening GBT Dewatering BFP (Existing) Cake Storage and Loadout to Regional Facility Bissell Point Thickening Gravity Thickening GBT Dewatering Centrifuge (New) Dewatered Sludge Receiving (New) Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-2) Solids Treatment Process Flow Chart - Hauling Cake from Lemay Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Thickening Force Main to Regional Facility (New PS & FM) MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP Cake Storage and Loadout to Regional Facility1 Lemay Thickening Gravity Thickening GBT Dewatering BFP (Existing) Cake Storage and Loadout to Regional Facility Bissell Point Thickening Gravity Thickening GBT Dewatering BFP (Existing) Dewatered Sludge Receiving (New) Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-5) Solids Treatment Process Flow Chart - Hauling Cake from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives (See Regional)CFG+Loadout PS+FM DW DW ( 3 FBIs @Bissell) General General Requirements 0 1,173,000 386,000 9,900 156,800 9,901,000 11,626,700 Sitework 200,000 3,361,000 0 95,000 315,000 3,971,000 Structures Gravity Thickener 764,000 764,000 Thickening and Dewatering Building Digesters Digester Building Dewatering Building 4,128,000 4,128,000 Cake Loadout Building CHP Building Incinerator Building 0 7,052,000 7,052,000 Sludge Receiving 2,160,000 2,160,000 Subtotal Structures -$ 4,128,000$ -$ -$ 764,000$ 9,212,000$ 14,104,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment Dewatering Equipment 8,574,000 8,574,000 Digester Gas Utilization Incinerator Equipment 0 0 65,509,000 65,509,000 Sludge Receiving 8,895,000 Conveyance Equipment Odor Control 424,000 100,000 100,000 3,300,000 3,924,000 Pump Station 480,000 480,000 Subtotal Equipment -$ 8,998,000$ 844,000$ 100,000$ 724,000$ 77,704,000$ 88,370,000$ Electrical 0 933,000 59,000 7,000 111,000 7,000,000 8,110,000 Instrumentation & Control 0 400,000 25,000 3,000 47,000 3,000,000 3,475,000 Subtotal 0 15,832,000 4,675,000 119,900 1,897,800 107,132,000 129,656,700 Contingencies 0 3,958,000 308,000 27,500 435,000 29,977,000 34,705,500 Mid-Point of Construction 0 2,028,000 511,000 15,100 239,000 15,363,000 18,156,100 TOTAL Construction Cost -$ 21,818,000$ 5,494,000$ 162,500$ 2,571,800$ 152,472,000$ 182,518,300$ Engineering 0 5,455,000 1,374,000 40,600 643,000 41,312,000 48,824,600 Advanced Emission Control 37,873,000 37,873,000 Sludge Loadout 5,272,000 TOTAL PROJECT COST -$ 32,545,000$ 6,868,000$ 203,000$ 3,215,000$ 231,657,000$ 274,488,000$ Salvage 9,034,000$ Final Printed:10/20/2011 14:53 MSD Regional System (S-2) Solids Handling Process- Capital Costs - Hauling Cake from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives BFP + 5 MHIs BFP+Loadout PS+FM DW DW General General Requirements 0 475,000 386,000 9,900 156,800 2,622,000 3,649,700 Sitework 0 3,361,000 0 95,000 200,000 3,656,000 Structures Gravity Thickener 764,000 764,000 Thickening and Dewatering Building Digesters Digester Building Dewatering Building 0 0 0 Cake Loadout Building CHP Building Incinerator Building 0 0 0 Sludge Receiving 2,160,000 2,160,000 Subtotal Structures -$ -$ -$ -$ 764,000$ 2,160,000$ 2,924,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment Dewatering Equipment 0 0 0 Digester Gas Utilization Incinerator Equipment 0 0 17,524,000 17,524,000 Sludge Receiving 8,895,000 Conveyance Equipment 1,260,000 Odor Control 424,000 100,000 100,000 3,300,000 3,924,000 Pump Station 480,000 480,000 Subtotal Equipment -$ 424,000$ 844,000$ 100,000$ 724,000$ 30,979,000$ 33,071,000$ Electrical 0 16,000 59,000 7,000 111,000 3,334,000 3,527,000 Instrumentation & Control 0 7,000 25,000 3,000 47,000 1,334,000 1,416,000 Subtotal 0 922,000 4,675,000 119,900 1,897,800 40,629,000 48,243,700 Contingencies 0 181,000 308,000 27,500 435,000 10,157,000 11,108,500 Mid-Point of Construction 0 93,000 511,000 15,100 239,000 4,772,000 5,630,100 TOTAL Construction Cost -$ 1,196,000$ 5,494,000$ 162,500$ 2,571,800$ 55,558,000$ 64,982,300$ Engineering 0 249,000 1,374,000 40,600 643,000 13,890,000 16,196,600 Advanced Emission Control 0 0 39,981,000 39,981,000 Rebuild 5 MHIs in year 10 0 40,242,000 40,242,000 Sludge Loadout 5,272,000 TOTAL PROJECT COST -$ 6,717,000$ 6,868,000$ 203,000$ 3,215,000$ 149,671,000$ 166,674,000$ Salvage $0 $0 $0 $0 $183,000 $518,000 701,000$ Final Printed:10/20/2011 14:53 MSD Regional System (S-5) Solids Handling Process- Capital Costs - Hauling Cake from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives CFG + FBI BFP + Loadout PS+FM DW DW Power -$ 199,000$ 121,000$ -$ 15,000$ 3,792,000$ 4,127,000$ Fuel Natural Gas 533,000 533,000 Fuel Oil 25,000 25,000 Other - - Subtotal -$ -$ -$ -$ -$ 558,000$ 558,000$ Labor Operations 524,000 33,000 8,000 1,179,000 1,744,000 Maintenance 333,000 4,000 4,000 666,000 1,007,000 Supervisor 306,000 306,000 612,000 Stationary Engineer - Other - Subtotal -$ 1,163,000$ 37,000$ -$ 12,000$ 2,151,000$ 3,363,000$ Maintenance Equipment 909,000 18,000 14,000 1,684,000 2,625,000 Subtotal -$ 909,000$ 18,000$ -$ 14,000$ 1,684,000$ 2,625,000$ Chemicals Polymer 294,000 461,000 112,000 1,024,000 1,891,000 Sodium Permanganate (OC)29,000 116,000 80,000 225,000 Powdered Activated Carbon 154,000 154,000 Water treatment - Other - Subtotal -$ 323,000$ -$ 577,000$ 192,000$ 1,178,000$ 2,270,000$ Transportation and Disposal Hauling Fee 2,630,000 1,185,000 662,000 594,000 5,071,000 Landfill Tip Fee - Land Application Fee - Ash lagoon cleanout - Subtotal -$ 2,630,000$ -$ 1,185,000$ 662,000$ 594,000$ 5,071,000$ Odor Control 50,000 330,000 380,000 Total Annual Costs -$ 5,274,000$ 176,000$ 1,762,000$ 895,000$ 10,287,000$ 18,394,000$ ANNUAL REVENUE ($ per annum) Power - - - - - Steam - - - - - Hot Water - - - - - Digester gas - - - - - Dried pellets - - - - - Other - - - - - Total Annual Revenues -$ -$ -$ -$ -$ -$ -$ Printed:10/20/2011 14:53 MSD Regional System (S-2) Solids Handling Process O&M Costs - Hauling Cake from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives BFP + 5 MHIs BFP + Loadout PS+FM DW DW (Bissell) (AEC for MHIs) Power 394,000$ 199,000$ 121,000$ -$ 15,000$ 3,228,000$ 3,957,000$ Fuel Natural Gas 3,654,000 3,654,000 Fuel Oil - - Other - - Subtotal -$ -$ -$ -$ -$ 3,654,000$ 3,654,000$ Labor Operations 131,000 524,000 33,000 8,000 1,572,000 2,268,000 Maintenance 67,000 333,000 4,000 4,000 966,000 1,374,000 Supervisor 306,000 306,000 612,000 Stationary Engineer - Other - Subtotal 198,000$ 1,163,000$ 37,000$ -$ 12,000$ 2,844,000$ 4,254,000$ Maintenance Equipment 113,000 1,011,000 18,000 14,000 2,552,000 3,708,000 Subtotal 113,000$ 1,011,000$ 18,000$ -$ 14,000$ 2,552,000$ 3,708,000$ Chemicals Polymer 294,000 461,000 112,000 2,047,000 2,914,000 Sodium Permanganate (OC)29,000 116,000 80,000 50,000 275,000 Powdered Activated Carbon 98,000 56,000 154,000 Water treatment - Other - Subtotal 98,000$ 323,000$ -$ 577,000$ 192,000$ 2,153,000$ 3,343,000$ Transportation and Disposal Hauling Fee 2,630,000 1,185,000 662,000 1,085,000 5,562,000 Landfill Tip Fee - Land Application Fee - Ash lagoon cleanout 389,000 389,000 Subtotal -$ 2,630,000$ -$ 1,185,000$ 662,000$ 1,474,000$ 5,951,000$ Odor Control 50,000 330,000 380,000 Total Annual Costs 803,000$ 5,376,000$ 176,000$ 1,762,000$ 895,000$ 16,235,000$ 25,247,000$ ANNUAL REVENUE ($ per annum) Power - - - - - Steam - - - - - Hot Water - - - - - Digester gas - - - - - Dried pellets - - - - - Other - - - - - Total Annual Revenues -$ -$ -$ -$ -$ -$ -$ Printed:10/20/2011 14:53 MSD Regional System (S-5) Solids Handling Process O&M Costs - Hauling Cake from Lemay Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Force Main to Regional Facility MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP (New Add. EQ) Cake Storage and Loadout to Regional Facility1 Lemay Thickening Gravity Thickening Bissell Point Thickening Gravity Thickening Dewatering Centrifuge (New) Dewatered Sludge Receiving (New) Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-3) Solids Treatment Process Flow Chart - Pumping Sludge from Lemay Force Main to Regional Facility (New PS & FM) Note: 1 Additional equipment needed but not included in the cost evaluation. Coldwater Thickening Gravity Force Main to Regional Facility MO River Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Regional Facility Lower Meramec Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP (New Add. EQ) Cake Storage and Loadout to Regional Facility1 Lemay Thickening Gravity Thickening Bissell Point Thickening Gravity Thickening Dewatering Centrifuge (New) Dewatered Sludge Receiving (New) Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout MSD Regional System (S-6) Solids Treatment Process Flow Chart - Pumping Sludge from Lemay Force Main to Regional Facility (New PS & FM) Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional TotalAlternativesCFG +3 FBIs PS+FM PS+FM DW DW (Bissell) General General Requirements 0 2,905,000 386,000 9,900 156,800 10,490,000 13,947,700 Sitework 29,957,000 3,361,000 0 95,000 315,000 33,728,000 Structures Gravity Thickener 764,000 764,000 Thickening and Dewatering Building Digesters Digester Building Dewatering Building 6,191,000 6,191,000 Cake Loadout Building CHP Building Incinerator Building 0 7,052,000 7,052,000 Sludge Receiving 2,160,000 2,160,000 Subtotal Structures -$ -$ -$ -$ 764,000$ 15,403,000$ 16,167,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment Dewatering Equipment 13,190,000 13,190,000 Digester Gas Utilization Incinerator Equipment 0 65,509,000 65,509,000 Sludge Receiving 8,895,000 Conveyance Equipment Odor Control 0 100,000 100,000 3,300,000 3,500,000 Pump Station 2,316,000 480,000 2,796,000 Subtotal Equipment -$ 2,316,000$ 844,000$ 100,000$ 724,000$ 90,894,000$ 94,878,000$ Electrical 0 0 59,000 7,000 111,000 7,417,000 7,594,000 Instrumentation & Control 0 0 25,000 3,000 47,000 3,179,000 3,254,000 Subtotal 0 35,178,000 4,675,000 119,900 1,897,800 127,698,000 169,568,700 Contingencies 0 0 308,000 27,500 435,000 31,760,000 32,530,500 Mid-Point of Construction 0 3,606,000 511,000 15,100 239,000 16,277,000 20,648,100 TOTAL Construction Cost -$ 38,784,000$ 5,494,000$ 162,500$ 2,571,800$ 175,735,000$ 222,747,300$ Engineering 0 9,696,000 1,374,000 40,600 643,000 43,769,000 55,522,600 Advanced Emission Control 37,873,000 37,873,000 TOTAL PROJECT COST -$ 48,480,000$ 6,868,000$ 203,000$ 3,215,000$ 257,377,000$ $316,143,000 Salvage 7,832,000$ 601,000$ 367,000$ 7,075,000$ 15,875,000$ Final Printed:10/20/2011 14:53 MSD Regional System (S-3) Solids Handling Process Capital Costs - Pumping Sludge from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional TotalAlternativesBFP + 5 MHIs PS+FM PS+FM DW DW (AEC for MHIs) General General Requirements 0 2,905,000 386,000 9,900 156,800 2,622,000 6,079,700 Sitework 29,957,000 3,361,000 0 95,000 200,000 33,613,000 Structures Gravity Thickener 764,000 764,000 Thickening and Dewatering Building Digesters Digester Building Dewatering Building 6,191,000 6,191,000 Cake Loadout Building CHP Building Incinerator Building 0 0 0 Sludge Receiving 2,160,000 2,160,000 Subtotal Structures -$ -$ -$ -$ 764,000$ 8,351,000$ 9,115,000$ Equipment FOG receiving Cake Load Out Gravity Thickening Equipment 364,000 624,000 988,000 Mechanical Thickening Equipment Digester Equipment Dewatering Equipment 13,190,000 13,190,000 Digester Gas Utilization Incinerator Equipment 0 17,524,000 17,524,000 Sludge Receiving 8,895,000 Conveyance Equipment 1,260,000 Odor Control 100,000 100,000 3,300,000 3,500,000 Pump Station 2,316,000 480,000 2,796,000 Subtotal Equipment -$ 2,316,000$ 844,000$ 100,000$ 724,000$ 44,169,000$ 48,153,000$ Electrical 0 0 59,000 7,000 111,000 5,272,000 5,449,000 Instrumentation & Control 0 0 25,000 3,000 47,000 2,109,000 2,184,000 Subtotal 0 35,178,000 4,675,000 119,900 1,897,800 62,723,000 104,593,700 Contingencies 0 0 308,000 27,500 435,000 15,681,000 16,451,500 Mid-Point of Construction 0 3,606,000 511,000 15,100 239,000 4,772,000 9,143,100 TOTAL Construction Cost -$ 38,784,000$ 5,494,000$ 162,500$ 2,571,800$ 83,176,000$ 130,188,300$ Engineering 0 9,696,000 1,374,000 40,600 643,000 20,794,000 32,547,600 Advanced Emission Control 0 39,981,000 39,981,000 Rebuild 5 MHIs in year 10 0 40,242,000 40,242,000 Sludge Loadout 0 0 0TOTAL PROJECT COST -$ 48,480,000$ 6,868,000$ 203,000$ 3,215,000$ 184,193,000$ $242,959,000 Salvage $0 $0 $0 $0 $183,000 $2,004,000 2,187,000$ Final Printed:10/20/2011 14:53 MSD Regional System (S-6) Solids Handling Process Capital Costs - Pumping Sludge from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives CFG +FBIs PS+FM PS+FM DW DW Power -$ 233,000$ 121,000$ -$ 15,000$ 4,190,000$ 4,559,000$ Fuel Natural Gas 533,000 533,000 Fuel Oil 25,000 25,000 Other - - Subtotal -$ -$ -$ -$ -$ 558,000$ 558,000$ Labor Operations 524,000 33,000 8,000 1,507,000 2,072,000 Maintenance 333,000 4,000 4,000 866,000 1,207,000 Supervisor 306,000 306,000 612,000 Stationary Engineer - Other - Subtotal -$ 1,163,000$ 37,000$ -$ 12,000$ 2,679,000$ 3,891,000$ Maintenance Equipment 1,072,000 18,000 14,000 1,764,000 2,868,000 Subtotal -$ 1,072,000$ 18,000$ -$ 14,000$ 1,764,000$ 2,868,000$ Chemicals Polymer 461,000 112,000 1,612,000 2,185,000 Sodium Permanganate (OC)116,000 80,000 196,000 Powdered Activated Carbon 154,000 154,000 Water treatment - Other - Subtotal -$ -$ -$ 577,000$ 192,000$ 1,766,000$ 2,535,000$ Transportation and Disposal Hauling Fee 1,185,000 662,000 594,000 2,441,000 Landfill Tip Fee - Land Application Fee - Ash lagoon cleanout - Subtotal -$ -$ -$ 1,185,000$ 662,000$ 594,000$ 2,441,000$ Odor Control 330,000 330,000 Total Annual Costs -$ 2,468,000$ 176,000$ 1,762,000$ 895,000$ 11,881,000$ 17,182,000$ ANNUAL REVENUE ($ per annum) Power - - - - - Steam - - - - - Hot Water - - - - - Digester gas - - - - - Dried pellets - - - - - Other - - - - - Total Annual Revenues -$ -$ -$ -$ -$ -$ -$ Printed:10/20/2011 14:53 MSD Regional System (S-3) Solids Handling Process O&M Costs - Pumping Sludge from Lemay Bissell Point Lemay Coldwater Mo. River Lower Meramec Regional Total Alternatives BFP + 5 MHIs PS+FM PS+FM DW DW (Bissell) (AEC for MHIs) Power 394,000$ 233,000$ 121,000$ -$ 15,000$ 2,813,000$ 3,576,000$ Fuel Natural Gas 3,654,000 3,654,000 Fuel Oil - - Other - - Subtotal -$ -$ -$ -$ -$ 3,654,000$ 3,654,000$ Labor Operations 131,000 524,000 33,000 8,000 1,572,000 2,268,000 Maintenance 67,000 333,000 4,000 4,000 966,000 1,374,000 Supervisor 306,000 306,000 612,000 Stationary Engineer - Other - Subtotal 198,000$ 1,163,000$ 37,000$ -$ 12,000$ 2,844,000$ 4,254,000$ Maintenance Equipment 113,000$ 32,000$ 2,625,000$ 2,770,000$ Structures 60,000 18,000 14,000 92,000 Subtotal -$ 92,000$ 18,000$ -$ 14,000$ 2,625,000$ 2,862,000$ Chemicals Polymer - 461,000 112,000 2,047,000 2,620,000 Sodium Permanganate (OC)116,000 80,000 50,000 246,000 Powdered Activated Carbon 49,000 49,000 Water treatment - Other - Subtotal 49,000$ -$ -$ 577,000$ 192,000$ 2,097,000$ 2,915,000$ Transportation and Disposal Hauling Fee 1,185,000 662,000 1,084,000 2,931,000 Landfill Tip Fee - Land Application Fee - Ash lagoon cleanout 389,000 389,000 Subtotal -$ -$ -$ 1,185,000$ 662,000$ 1,473,000$ 3,320,000$ Odor Control 330,000 330,000 Total Annual Costs 754,000$ 1,488,000$ 176,000$ 1,762,000$ 895,000$ 15,836,000$ 20,911,000$ ANNUAL REVENUE ($ per annum) Power - - - - - Steam - - - - - Hot Water - - - - - Digester gas - - - - - Dried pellets - - - - - Other - - - - - Total Annual Revenues -$ -$ -$ -$ -$ -$ -$ Printed:10/20/2011 14:53 MSD Regional System (S-6) Solids Handling Process O&M Costs - Pumping Sludge from Lemay BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-1 TECHNICAL MEMORANDUM NO. 10 ALTERNATIVES SELECTION PROCESSES AND RESULTS To: Metropolitan St. Louis Sewer District From: Bently Green, Patricia Scanlan, Jim Rowan, Hari Santha, Gustavo Queiroz This Technical Memorandum (TM) presents information on the Triple Bottom Line (TBL) evaluation methodology, criteria, and weighting factors for the Phase II evaluation. A TBL evaluation was previously performed for the Phase I screening process. The TBL methodology is similar to that used in the Phase I screening; however, suggested criteria and criteria weights have been adjusted to better reflect the decision- making factors associated with the Phase II process. The TBL approach and representative results for the alternatives evaluation are presented. Alternatives and options are described in the respective TM’s for each plant. Refer to TM’s No. 2 through No. 6. Air emission requirements, greenhouse gases, and overall project costs are addressed in TM’s 7 through 9. Table of Contents Table of Contents ................................................................................................................ 1 List of Tables ...................................................................................................................... 2 Abbreviations ...................................................................................................................... 3 1. Triple Bottom Line Criteria and Weights ................................................................ 3 2. Criteria Importance Weighting ................................................................................ 4 3. Scoring of Alternatives ............................................................................................ 4 a. Alternatives Rating Scale ..................................................................................... 4 b. Summary of Criteria and Scoring Factors ........................................................ 5 4. Selection of TBL Factors ......................................................................................... 6 a. Economic Criteria ................................................................................................ 6 b. Social Criteria ................................................................................................. 10 c. Environmental Criteria ....................................................................................... 15 5. Selecting the Most Attractive Solutions ................................................................ 20 a. Bissell Point Alternatives Scoring and Selection ............................................... 20 b. Lemay Plant Alternatives Scoring and Selection ........................................... 22 c. Coldwater Plant Alternatives Scoring and Selection ......................................... 24 d. Missouri River Alternatives Scoring and Selection ....................................... 27 e. Lower Meramec Alternatives Scoring and Selection ......................................... 28 f. Regional Facility Alternatives Scoring and Selection........................................ 30 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-2 g. Total System Scoring...................................................................................... 31 List of Tables Table 10-1 Criteria Importance Weighting/Prioritization Scale ......................................... 4 Table 10-2 Alternatives Rating Scale ................................................................................. 4 Table 10-3 Summary of Criteria with Importance Weighting ............................................ 5 Table 10-4 Summary of Costs and Revenues for Alternatives ........................................... 6 Table 10-5 Capital Cost Rating Scale ................................................................................. 8 Table 10-6 Operating and Maintenance Cost Rating Scale ................................................ 8 Table 10-7 Operating Revenues Rating Scale .................................................................... 9 Table 10-8 Constructability Rating Scale ........................................................................... 9 Table 10-9 Private Party or Third Party Risk Rating Scale .............................................. 10 Table 10-10 Public Perceptions Rating Scale ................................................................... 11 Table 10-11 Nuisance Impacts Rating Scale .................................................................... 12 Table 10-12 Public and Employee Safety Rating Scale ................................................... 13 Table 10-13 Ease of Permitting Rating Scale ................................................................... 14 Table 10-14 Staffing/Operational Complexity Rating Scale ............................................ 15 Table 10-16 Summary of Greenhouse Gases for Alternatives (CO2 equivalents) ........... 16 Table 10-17 GHG Emissions Rating Scale ....................................................................... 18 Table 10-18 Biosolids Process Final Disposition Reliability Rating Scale ...................... 18 Table 10-20 Multiple Product Flexibility Rating Scale .................................................... 20 Table 10-21 Summaries of Scoring for Bissell Point Plant Alternatives .......................... 21 Table 10-22 Summaries of Scores for Lemay Plant Alternatives ..................................... 23 Table 10-23 Summaries of Scoring for Coldwater Plant Alternatives ............................. 25 Table 10-27 Summaries of Scoring for Total System Alternatives .................................. 32 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-3 Abbreviations AEC Advanced emission controls BFG Belt filter press dewatering CFG Centrifuge dewatering Current Continuing with current operation at plant FBI Fluidized bed incinerator FOG Fats, oils and greases MHI Multiple hearth incinerator RP Rotary press dewatering ST Steam system heat recovery, used for the plant or transferred to steam utility STG Steam turbine generator to produce electrical power SYSTEM Regional System consisting of central solids processing at Bissell and only modifications needed at other plants to send liquid or cake to Bissell 1. Triple Bottom Line Criteria and Weights As with the TBL process employed during the Phase I evaluation, the Phase II TBL process is based on the following three general categories: • An “economic” component that reflects the cash flow accounting stance of the utility (i.e., internal costs and revenues) • A “social” component that reflects the social impacts of the utility action (e.g., minimizing nuisance impact to the local community such as truck traffic, odor, and noise from plant operations.) • An “environmental” component that addresses environmental impacts of the utility actions and decision, such as reducing Green House Gas (GHG) emissions by reducing fossil fuel use and electricity purchases BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-4 2. Criteria Importance Weighting A priority importance weighting factor is applied to each of the criteria within the Economic, Social, and Environmental categories to reflect the relative importance of each in the screening process. Values of 1 to 3 used for the evaluation and are defined in Table 10-1 below: Table 10-1 Criteria Importance Weighting/Prioritization Scale Prioritization Weighting More or Most Important, optimum or above average, more beneficial 3 Moderate Importance, average, similar to others 2 Less or Least Important, minimum or below average, less beneficial 1 3. Scoring of Alternatives a. Alternatives Rating Scale Scores are applied to each alternative evaluated. The alternatives are rated on a 1 through 5 scoring system, as presented in Table 10-2. Since importance factors have already been applied to the criteria, the values applied for rating the alternatives should be independent of the importance of the criteria, and measured entirely on its own merit. Table 10-2 Alternatives Rating Scale Rating Score Most Favorable, highest performance, lowest cost, most beneficial 5 Moderately Favorable 4 Neutral, average performance, cost and or benefits 3 Less Favorable 2 Least Favorable, lowest performance, highest cost, least benefits 1 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-5 b. Summary of Criteria and Scoring Factors Table 10-3 summarizes the selected criteria for each category of the TBL with suggested importance factors. The “Total Weight” is the product of the “Category Weight” and the “Criteria Weight”. The “Total Weight” factor is applied to the criteria score for each alternative to determine a total score for the alternative. Table 10-3 Summary of Criteria with Importance Weighting Category Criteria Category Weighting % Criteria Weighting Total Weighting Overall Weight % Economic 53.3% overall weighting Capital cost 60% 3 1.50 13.3 Operating and maintenance costs 60% 3 1.50 13.3 Operating revenues 60% 3 1.50 13.3 Constructability 60% 2 1.00 8.9 Private party participation risk 60% 1 0.50 4.4 Social 22.2% overall weight Public perceptions 15% 2 0.50 4.4 Nuisance impacts 15% 2 0.50 4.4 Public and Employee Safety 15% 3 0.75 6.7 Ease of permitting 15% 1 0.25 2.2 Staffing/Operational Complexity 15% 2 0.50 4.4 Environmental 24.4% overall weight Air and water quality 25% 3 0.75 6.7 GHG emissions 25% 1 0.25 2.2 Biosolids final disposition reliability 25% 2 0.50 4.4 Proven experience 25% 3 0.75 6.7 Multiple product flexibility 25% 2 0.50 4.4 Total 11.25 100 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-6 4. Selection of TBL Factors The TBL factors suggested for the Phase II evaluation are similar to those used for the Phase I screening evaluation, but have some modifications and additions to better reflect the issues associated with each of the treatment plants and options. The criteria and factors are described in the following section: a. Economic Criteria The out of pocket costs borne by the utility are the direct costs associated with proposed biosolids alternatives. These reflect Present Worth costs and, thus, include capital, equipment and construction costs, operations and maintenance (O&M) costs, and administration and permit fees. Any revenues associated with the sale of energy produced from biosolids, or biosolids product is also considered in this category. For the Phase 2 screening process, values are based on opinions of probable costs developed for each alternative for construction, operations, and maintenance; and potential revenues from energy production or biosolids product. Costs and revenues are included in Technical Memorandum No. 9 Opinions of Costs for Alternatives. A summary of the costs and revenues used for this evaluation is shown as Table 10-4. Table 10-4 Summary of Costs and Revenues for Alternatives Plants and Alternatives Project Capital $1000 Annual O&M $1000 Annual Revenue $1000 Present Worth $1000 Bissell Point B-1 MHI B-2 FBI B-2-A ST B-2-B+ STG 80,800 175,732 15,559 29,003 9,179 7,860 383 691 -- -- (855) (806) 214,382 271,962 8,976 26,457 Lemay L-1 MHI L-2 FBI+BFP L-3 FBI+CFG L-1-A +STG L-2&3-A +STG 76,135 119,739 144,853 29,036 24,223 5,695 4,858 5,587 676 644 -- -- -- (429) (432) 145,941 179,286 213,112 31,926 26,056 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-7 Table 10-4 Summary of Costs and Revenues for Alternatives Plants and Alternatives Project Capital $1000 Annual O&M $1000 Annual Revenue $1000 Present Worth $1000 Coldwater C-1 Current C-2 R/Landfill C-2-A +CFG C-2-B +RP C-3 MAD C-3-A+ CFG C-3-B+ RP 6,868 17,233 16,191 15,596 31,636 31,281 30,977 176 1,494 1,397 1,366 2,269 2,154 2,151 -- -- -- -- (440) (440) (440) 8,830 35,700 33,450 32,470 54,210 52,420 50,080 Missouri River M-1 Current M-2 Co-Dig. FOG 2,686 3,652 3,892 4,022 (1,495) (1,750) 32,490 31,890 Lower Meramec LM-1 Current LM-2 Thicken 40,553 44,720 2,190 2,309 (537) (537) 59,170 64,940 Regional Facility R-1 FBI R-1-A+ST R-1-B+STG 244,432 20,603 41,215 14,232 566 992 -- (2,760) (2,861) 419,122 (7,159) 17,625 Total System S-1 Decentralized S-2 Lemay Haul S-3 Lemay Pump 370,694 281,991 315,485 19,706 20,109 18,891 (2,032) -- -- 586,946 529,189 544,926 All costs in 2010 US dollars. Present Worth costs based on 20 year life and 5 % interest rate. Source: TM 9 – Opinions of Costs for Alternatives (1) Capital Cost. Capital cost is defined as an opinion of cost for plant construction and infrastructure improvements required by an alternative or option. This also includes costs to implement project including planning, design and permitting costs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-8 Table 10-5 Capital Cost Rating Scale Rating Description Score Most Favorable Least cost 5 Moderately Favorable Less that average 4 Neutral Average or within 10% of others 3 Less Favorable Above average costs 2 Least Favorable Most cost 1 (2) Operating and Maintenance Costs. The opinion of operations and maintenance (O&M) recurring costs include those associated with on-site treatment and off-site disposal or final use of solids. Table 10-6 Operating and Maintenance Cost Rating Scale Rating Description Score Most Favorable Least costs 5 Moderately Favorable Less that average 4 Neutral Average or within 10 % of others 3 Less Favorable Above average costs 2 Least Favorable Most cost 1 (3) Operating Revenues. Opinion of revenues from the sale of energy produced from biosolids process or product such as fuel or fertilizer produced from biosolids. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-9 Table 10-7 Operating Revenues Rating Scale Rating Description Score Most Favorable Highest revenues 5 Moderately Favorable More than average 4 Neutral Average or within 10 % of others 3 Less Favorable Less than average revenues 2 Least Favorable Least or no revenues 1 (4) Constructability. This criterion involves the challenges related with construction of the proposed technology, particularly how the new construction integrates with existing infrastructure. This considers reuse of existing facilities, extent of new facilities, access for operation and maintenance of the plant and construction while continuing normal operation of the plant. Table 10-8 Constructability Rating Scale Rating Description Score Most Favorable Least complicated, easy integration, little or no concerns 5 Moderately Favorable Less complicated, some concerns 4 Neutral Average complications and concerns 3 Less Favorable More complicated, more integration concerns 2 Least Favorable Most complicated, difficult integration 1 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-10 (1) Private Party Participation or Third Party Reliance Risk. This criterion assesses the impact on the plant with implementation of private participation options such as sale of steam to a utility, production of power, or sale of product to fertilizer producer. This may include assessments of reliability of available landfills and private land application company participation. Table 10-9 Private Party or Third Party Risk Rating Scale Rating Description Score Most Favorable Least risk, no private party participation or reliance on third party 5 Moderately Favorable Less risk than average, contract term of 10 or more years with known party 4 Neutral Average risk, short term contract of 10 years or less with acceptable party 3 Less Favorable Greater risk than average, contract term of 5 years or less than average term 2 Least Favorable High risk, short term or contract with unknown party 1 b. Social Criteria This category includes the evaluation of an alternative’s social impacts for comparison with other alternatives and options. (1) Public Perceptions. This criterion reflects the public acceptance or anticipated public opposition to biosolids management practices proposed with implementation of an alternative. Public acceptance issues can arise from nuisance issues such as odors, truck traffic, noise or concerns over public health and environmental quality (i.e. concern about incineration air emissions or pathogens or metals in biosolids used for land application). This assessment is based on perceived nuisance issues. Actual nuisance potentials are addressed with other criteria. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-11 Table 10-10 Public Perceptions Rating Scale Rating Description Score Most Favorable High public acceptance, no public opposition, no public concerns 5 Moderately Favorable Good acceptance, some public opposition, and concern 4 Neutral Acceptance with minor oppositions and concerns 3 Less Favorable Poor acceptance, more than average public opposition and concern 2 Least Favorable Lowest acceptance, high public opposition and concern, may be difficult to implement 1 (2) Nuisance Impacts. Many utilities consider processes to minimize odors, truck traffic, and other nuisance effects on nearby residents. The rating for this criterion reflects the potential for neighbor impacts and complaints, based on proximity to the treatment plant, potential for offsite odors, number of trucks necessary to haul raw or final solids, and the requirements to use residential or non-industrial roadways. This criterion will include information from surveys of affected individuals conducted for MSD and summarized in the Public Acceptance Surveys section of TM 11 Implementation Plan. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-12 Table 10-11 Nuisance Impacts Rating Scale Rating Description Score Most Favorable Minimum of truck travel, little or no nuisance complaints, favorable rating on survey 5 Moderately Favorable Some truck travel, few complaints, “good neighbor” 4 Neutral Average truck travel comparable to current, no more or less complaints than current 3 Less Favorable More truck travel, more complaints, some unfavorable ratings 2 Least Favorable Maximum number of trucks, expected high number of complaints, unfavorable rating on survey 1 (3) Public and Employee Safety. This criterion reflects the effect of the alternative on health and safety for plant employees as well as the surrounding neighborhood. For example, the concerns related to biosolids land application on agricultural sites are often expressed in terms of pathogens, metals, and trace organics while those associated with other processes may include protection from hot surfaces, equipment noise abatement, and need for special safety equipment. Safety includes potential for hazards such as those present with handling high pressure steam and rotating equipment; and may include need to restrict access to plant by public. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-13 Table 10-12 Public and Employee Safety Rating Scale Rating Description Score Most Favorable Inherently safe process and low risk based on past experience. Limited or no public access required in high risk areas. Worker safety hazards identified and mitigated. 5 Moderately Favorable Better than average safety record and risk for worker and public with process and mitigations. 4 Neutral Acceptable safety risk for workers and public. 3 Less Favorable Lower than average safety record and risk for worker and public with process and mitigations. 2 Least Favorable Inherently unsafe process and high risk based on past experience. Unlimited or open public access in high risk areas. Unmitigated worker safety hazards identified. 1 (4) Ease of Permitting. This criterion reflects the relative ease in obtaining permits for construction and operation of an alternative. Although each of the technologies being considered will meet current regulatory requirements, some technologies used for alternatives may be more easily permitted than others based on the source of emissions or the amount of emissions. In addition, impacts of future permitting concerns, based on regulatory or non-regulatory drivers, will be included in this criterion. Permitting difficulties can increase the time and costs required to implement an alternative. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-14 Table 10-13 Ease of Permitting Rating Scale Rating Description Score Most Favorable Little or no emissions limits in place now and in future making permitting relatively easy to obtain. 5 Moderately Favorable Less stringent emissions than currently required but easily obtainable. 4 Neutral Little or no change in existing permitting requirements. New or renewed permits obtainable. 3 Less Favorable More stringent emissions than currently required but obtainable with additional effort. 2 Least Favorable Stringent emissions limits in place now and/ or in the future making permitting very difficult. 1 (5) Staffing/Operational Complexity. Complex systems will generally be more susceptible to downtime than less complex systems, which impacts reliability. Complexity also impacts the skill level required for the District’s operations and maintenance staff. Complex systems generally require a high level of operator attention and maintenance. Training is usually more frequent and rigorous. Use of contract operations or contract disposal/reuse may also be considered. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-15 Table 10-14 Staffing/Operational Complexity Rating Scale Rating Description Score Most Favorable Fewest operators needed. Moderate skills needed. Least operator complexity. 5 Moderately Favorable Fewer or same operators needed with comparable skills. Less complexity than current processes. 4 Neutral Comparable number of operators needed with skills comparable to those of current operators. Similar complexity to existing processes. . 3 Less Favorable More operators needed with more skills. Additional complexity over current processes. 2 Least Favorable Most operators needed. Highly complex skills needed. Most operator complexity. 1 c. Environmental Criteria This category includes the evaluation of the technologies’ environmental impacts. These include both local (air and water quality) and worldwide (GHG emissions) issues. In addition, this category evaluates the reliability of the technologies to sustain the environmental effort through employing of proven and flexible technologies. (1) Air and Water Quality. This criterion assesses the alternatives based on the byproducts from the processes including side stream water quality and air emissions. This may also include an assessment of how stringent the air and water quality regulations are, and the ability of mitigation to meet the requirements. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-16 Table 10-15 Air and Water Quality Rating Scale Rating Description Score Most Favorable Minimum air and water impacts on the environment. Controls and processes in place to easily meet requirements. 5 Moderately Favorable Exceeds minimum limits for air and water impacts with equipment that requires less effort and controls. 4 Neutral Meets limits for air and water impacts with comparable effort and equipment as current processes and controls. 3 Less Favorable Meets minimum limits for air and water impacts with equipment and provides small margin for error in compliance. May require more effort and controls as currently used. 2 Least Favorable Meet limits for air and water impacts on the environment with little or no margin for error in compliance. Minimum controls and processes in place to meet requirements 1 (2) GHG Emissions. This criterion reflects the expected GHG emissions from a final use alternative and associated treatment technology, including process emissions, fossil fuel energy use, and GHGs associated with beneficial use or landfill disposal. GHG emissions are calculated and shown in Technical Memorandum No. 8 Greenhouse Gas Emissions and summarized here for plant alternatives. Table 10-16 Summary of Greenhouse Gases for Alternatives (CO2 equivalents) Plants and Alternatives Description Total (tons/year) Bissell Point B-1 B-2 B-2- B-2-B MHI+BFP FBI+CFG FBI + ST FBI + STG 21,714 22,583 22,718 17,128 Lemay L-1 MHI+BFP 10,625 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-17 Table 10-16 Summary of Greenhouse Gases for Alternatives (CO2 equivalents) Plants and Alternatives Description Total (tons/year) L-2 L-3 L-1-A L-2&3-A FBI+BFP FBI+CFG MHI+STG FBI+STG 12,193 14,506 8,986 9,611 Coldwater C-1 C-2 R C-2-A C-2-B C-3 C-3-A C-3-B Curr. Operation BFP / Landfill CFG /Landfill RP /Landfill MAD / BFP MAD / CFG MAD / RP 690 8,478 8,663 8,442 1,234 1,300 1,240 Missouri River M-1 CURRENT M-2 Current Co-Digest + FOG -1,642 -1,875 Lower Meramec LM-1 LM-2 Current + MAD Thicken + MAD 796 616 Regional Facility R-1 R-1- A R-1 -B FBI+CFG FBI+ST FBI+STG 58,177 58,429 40,175 Alternatives that can minimize generation of GHGs are more favorable; as well as those that maximize the potential for GHG offsets - such as those available when producing energy from a renewable fuel source. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-18 Table 10-17 GHG Emissions Rating Scale Rating Description Score Most Favorable Lowest GHG emissions 5 Moderately Favorable Lower than average GHG emissions 4 Neutral Acceptable or average GHG emissions 3 Less Favorable Higher than average GHG emissions 2 Least Favorable Highest GHG emissions 1 (3) Biosolids Process Final Disposition Reliability. This criterion reflects the expected long-term access to a final use or disposal option. As an example, landfill disposal would be rated based on expected availability of landfill disposal, future restrictive regulations and local landfill practices. Rating includes consideration of contract life. If no contract time can be determined, determine rating based on access to public landfills or outlets anticipated for the product and region. As and example, ash from an incinerator is easier to dispose of than dewatered cake. Table 10-18 Biosolids Process Final Disposition Reliability Rating Scale Rating Description Score Most Favorable Most reliable, much higher than others, long term contracts of 20 years or more available 5 Moderately Favorable Better than average or acceptable, contract greater than 10 years but less than 20 years 4 Neutral Comparable to other processes, average or acceptable, short term contract of 10 years or more 3 Less Favorable Less than average or acceptable, less than 10 years contract but greater than 5 years 2 Least Favorable Least reliable, much lower than others, no contract or contract of 5 years or less 1 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-19 (4) Proven Experience. This criterion is an indicator of a technology’s overall reliability based on maturity of process. A technology that has been widely used with documented operational data is considered to be more reliable than technologies still in the development stage. The advantages of proven performance include better defined costs and known operational issues such as maintenance requirements and byproducts characteristics. Table 10-19 Proven Experience Rating Scale Rating Description Score Most Favorable Excellent or best record of known examples processing similar material, many facilities of similar size 5 Moderately Favorable Better than average or acceptable experience, more facilities of recommended size than average 4 Neutral Average or acceptable wastewater service with some operating examples of similar size 3 Less Favorable Less than average or acceptable but significantly less facilities of similar size than average 2 Least Favorable Poor or no record of known wastewater examples processing similar material, no operating examples at size required. 1 (5) Multiple Product Flexibility. This criterion reflects the number or diversity of outlets available for a final use alternative. Greater flexibility means that MSD can direct the biosolids to different final use outlets, based on availability and cost, with no or little impact on its equipment or operations. This generally favors multiple processes where product quantity can be allotted among the various processes. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-20 Table 10-20 Multiple Product Flexibility Rating Scale Rating Description Score Most Favorable Most flexible, multiple use product or two or more products from processes, many outlets for products 5 Moderately Favorable One or more products with two or more outlets for products 4 Neutral One or more products with one or two outlets available 3 Less Favorable One product with one or two outlets for products 2 Least Favorable Least flexible, single use product, no options for producing other product, limited to one outlet for product 1 5. Selecting the Most Attractive Solutions The alternatives that result in the highest total scores are considered the most attractive for implementation. A number of alternatives have been identified for evaluation in the Phase II Technical Memorandums for the MSD plants including in the study. These alternatives were reviewed and scored using the protocol described in this TM. The completed TBL evaluations and scoring for the alternatives developed as part of the Phase II evaluation are presented in the following sections for all the plants in the Phase II study and include discussions, conclusions and recommendations. a. Bissell Point Alternatives Scoring and Selection Scoring for the Bissell Point Plant biosolids alternatives is shown as Table 10-21 and is based on the criteria and scoring presented in previous sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-21 Table 10-21 Summaries of Scoring for Bissell Point Plant Alternatives Category Criteria Alternatives Scores B-1 MHI+BFP B-2 FBI+ CFG B-2-A FBI +ST B-2-B FBI +STG Economic 60.8% overall weighting Capital cost 5 3 2 2 Operating and maintenance costs 3 5 4 4 Operating revenues 1 1 4 4 Constructability 3 4 3 3 Private party participation risk 5 5 4 5 Social 13.8% overall weight Public perceptions 3 4 4 5 Nuisance impacts 3 3 4 4 Public and Employee Safety 5 5 3 3 Ease of permitting 2 3 3 3 Staffing/Operational Complexity 3 5 3 2 Environmental 25.3% overall weight Air and water quality 1 3 3 3 GHG emissions 4 4 4 5 Biosolids final disposition reliability 3 3 3 3 Proven experience 2 5 4 3 Multiple product flexibility 3 3 3 4 Total 46 56 52 53 Weighted Total 33.70 39.70 36.25 36.55 (1) Discussion of Bissell Point Plant Alternatives Selection The analysis shows that the basic FBI alternative B-2 scores higher than the MHI alternative B-1. The differences are: • Lower capital for the MHI • Higher O&M costs for the MHI BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-22 • Higher ratings for constructability for FBI alternative because of available space for new buildings to house incinerators and dewatering equipment. • Better air and water emissions with FBI because FBIs provide inherently better combustion that is more easily controlled. With changes in regulatory limits proposed and anticipated, MHIs are expected to be much more difficult to modify for emission controls needed. • Less staffing and simpler operations with FBIs because of fewer larger units. • Better current experience with FBIs with new units being built to replace existing MHIs. The addition of heat recovery and steam production for sale to a utility (B-2-A) increases the desirability of the FBI alternative because of the following: • Revenue in the sales of the steam. • Similar ratings for remainder of items with the base FBI alternative B-2. b. Lemay Plant Alternatives Scoring and Selection Scoring for the Lemay Plant biosolids alternatives is shown as Table 10-22 and is based on the criteria and scoring presented earlier. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 23, 2010 MSD Contract No. 2009145 B&V File 45.000 10-23 Table 10-22 Summaries of Scores for Lemay Plant Alternatives Category Criteria Alternatives Scores L-1 MHI+ BFP L-2 FBI+ BFP L-3 FBI+ CFG L-1-A MHI+ STG L-2&3-A FBI+ STG Economic 60.8% overall weighting Capital cost 4 2 1 2 1 Operating and maintenance costs 3 4 4 1 2 Operating revenues 1 1 1 5 5 Constructability 3 4 4 2 3 Private party participation risk 5 5 5 3 3 Social 13.8% overall weight Public perceptions 3 4 4 4 5 Nuisance impacts 4 4 4 4 4 Public and Employee Safety 4 4 5 3 3 Ease of permitting 2 2 2 2 2 Staffing/ Operational Complexity 3 4 5 2 3 Environ-mental 25.3% overall weight Air and water quality 1 3 3 1 3 GHG emissions 5 4 4 5 3 Biosolids final disposition reliability 3 3 3 3 3 Proven experience 2 5 5 2 3 Multiple product flexibility 3 3 3 4 4 Total 47 53 54 43 47 Weighted Total 32.45 35.65 34.60 27.25 30.80 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 23, 2010 MSD Contract No. 2009145 B&V File 45.000 10-24 (1) Discussion of Lemay Plant Alternatives Selections The analysis shows that the basic FBI alternative L-2 scores higher than the MHI alternative L-1. The differences are: • Lower capital costs for the MHI alternatives • Similar operating costs for both incinerator alternatives. • Higher ratings for constructability for FBI alternatives using new building to house incinerators and dewatering equipment. • Better air and water emissions with FBI because FBIs provide inherently better combustion that is more easily controlled. With changes in regulatory limits proposed and anticipated, MHIs are expected to be much more difficult to modify for emission controls needed. • Less staffing and simpler operations with FBIs because of fewer larger units. • Better current experience with FBIs with new units being built to replace existing MHIs. The addition of heat recovery and steam production for sale to a utility (B-2-A) increases the desirability of the FBI alternative because of the following: • Revenue in the sales of the steam. • Similar ratings for remainder of items with the base FBI alternative B-2. c. Coldwater Plant Alternatives Scoring and Selection Scoring for the Coldwater Plant biosolids alternatives is shown as Table 10-23 and is based on the criteria and scoring presented in previous sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 23, 2010 MSD Contract No. 2009145 B&V File 45.000 10-25 Table 10-23 Summaries of Scoring for Coldwater Plant Alternatives Category Criteria Alternatives Scores C-1 Current C-2 Raw + BFP C-2-A Raw + CFG C-2-B Raw + RP C-3 AD + BFP C-3-A AD + CFG C-3-B AD + RP Economic 62.9% overall weight Capital cost 5 3 3 3 1 1 1 Operating and maintenance costs 5 2 2 2 1 1 1 Operating revenues 1 1 1 1 5 5 5 Constructability 3 5 5 5 2 2 2 Private party participation risk 5 4 4 4 3 3 3 Social 13.1% overall weight Public perceptions 5 3 3 3 4 4 4 Nuisance impacts 4 1 2 2 3 3 3 Public and Employee Safety 4 3 3 3 4 4 4 Ease of permitting 4 5 5 5 3 3 3 Staffing/Operational Complexity 5 2 2 2 1 1 1 Environ-mental 24.0% overall weight Air and water quality 4 2 2 2 3 3 3 GHG emissions 5 1 1 1 3 3 3 Biosolids final disposition reliability 5 2 2 2 4 4 4 Proven experience 5 3 3 2 3 3 2 Multiple product flexibility 2 1 1 1 4 4 4 Total 62 38 39 38 45 45 44 Weighted Total 44.5 28.6 28.9 28.2 31.0 31.0 30.2 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-26 (1) Discussion of Coldwater Plant Alternatives Selections Of all the solids processing options for Coldwater, continuing the current practice of pumping thickened solids to Bissell scores higher than all other alternatives. The differences are: • Lower capital and O&M costs for the pumping alternative. • No additional staffing and simpler operations for pumping since it is the current practice. Addition of dewatering and/or digestion will increase the staffing requirements and make the operations more complex. • No reliance on third party for the pumping option. With the dewatering options, there is the possibility of contracting out hauling and disposal of dewatered solids to a private party, increasing the risk. With the anaerobic digestion options, the gas cleaning and cogeneration processes can also be contracted out. • Biosolids final disposition reliability is highest for the pumping option since it does not depend on external factors, such as weather. The other alternatives require dewatered solids to be hauled to end-use or disposal sites which can be weather dependent. • Raw solids dewatering scored the lowest on nuisance impacts because of the odor issues associated with handling undigested solids. • Anaerobic digestion options generate a revenue stream from the electricity generated, resulting in a high score for operating revenues. No potential for revenue from the other options. • Rotary press dewatering option scored lower than BFPs and centrifuges on experience since the technology is relatively new to the market. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-27 d. Missouri River Alternatives Scoring and Selection Scoring for the Missouri River Plant biosolids alternatives is shown as Table 10-24 and is based on the criteria and scoring presented in previous sections. Detailed weighted scores are presented in the Appendix. Table 10-24 Summaries of Scoring for Missouri River Plant Alternatives Category Criteria Alternatives Scores M-1 Current Operation M-2 Co-Digestion with FOG Economic 62.9% overall weighting Capital cost 3 2 Operating and maintenance costs 3 3 Operating revenues 3 4 Constructability 3 2 Private party participation risk 3 3 Social 13.1% overall weight Public perceptions 2 4 Nuisance impacts 3 2 Public and Employee Safety 3 2 Ease of permitting 3 3 Staffing/Operational Complexity 3 2 Environmental 24.0% overall weight Air and water quality 3 3 GHG emissions 5 5 Biosolids final disposition reliability 3 3 Proven experience 4 2 Multiple product flexibility 3 3 Total 47 43 Weighted Total 35.30 32.15 (1) Discussion of Missouri River Plant Alternatives Selections Co-digestion of FOG scored lower than the current practice based on the ratings. The differences are: • Higher capital costs for co-digestion. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-28 • More nuisance impacts and employee safety concerns with FOG receiving due to the potential for odors and the required manual cleaning of the rock traps. • Additional staffing requirement for the FOG receiving facility. • Experience with co-digestion of FOG is still minimal and there is additional cleaning and maintenance requirements with the FOG receiving facility. • Higher operating revenues from co-digestion due to the potential for more electricity generation. e. Lower Meramec Alternatives Scoring and Selection Scoring for the Lower Meramec Plant biosolids alternatives is shown as Table 10-25 and is based on the criteria and scoring presented in previous sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-29 Table 10-25 Summaries of Scoring for Lower Meramec Plant Alternatives Category Criteria Alternatives Scores LM-1 Co-thickening + AD LM-2 Mechanical Thickening + AD Economic 62.9% overall weighting Capital cost 3 3 Operating and maintenance costs 3 3 Operating revenues 3 3 Constructability 4 3 Private party participation risk 3 3 Social 13.1% overall weight Public perceptions 4 4 Nuisance impacts 2 3 Public and Employee Safety 4 4 Ease of permitting 3 3 Staffing/Operational Complexity 3 2 Environmental 24.0% overall weight Air and water quality 3 3 GHG emissions 4 5 Biosolids final disposition reliability 4 4 Proven experience 5 5 Multiple product flexibility 5 5 Total 53 53 Weighted Total 39.25 38.30 (1) Discussion of Lower Meramec Plant Alternatives Selections. Of the two WAS thickening options considered for Lower Meramec, the co-thickening option score marginally better than the mechanical thickening option. The potential for odors from the co-thickening operation is offset by the additional construction and staffing required for the mechanical thickening option. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-30 f. Regional Facility Alternatives Scoring and Selection Scoring for the Regional Plant biosolids alternatives is shown as Table 10-26 and is based on the criteria and scoring presented in previous sections. Detailed weighted scores are presented in the Appendix. Table 10-26 Summaries of Scoring for Regional Facility Alternatives Category Criteria Alternatives Scores R-1 FBI +CFG R-1-A FBI +ST R-1-B FBI +STG Economic 60.8% overall weighting Capital cost 3 2 1 Operating and maintenance costs 3 2 2 Operating revenues 1 4 4 Constructability 3 3 3 Private party participation risk 5 4 5 Social 13.8% overall weight Public perceptions 4 4 5 Nuisance impacts 3 4 4 Public and Employee Safety 5 3 3 Ease of permitting 3 3 3 Staffing/Operational Complexity 5 3 2 Environ-mental 25.3% overall weight Air and water quality 2 3 3 GHG emissions 3 3 5 Biosolids final disposition reliability 3 3 3 Proven experience 4 4 3 Multiple product flexibility 1 3 3 Total 48 48 49 Weighted Total 32.2 32.1 30.7 (1) Discussion of Regional Plant Alternatives Selections The analysis shows that the FBI alternative R-1 scores marginally higher than the other alternatives. However, the difference between scores for R-1 and R-1-A (steam generation and sale) is not considered significant at this level of evaluation. The differences are listed here: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-31 • Public and employee safety were rated highest for the basic FBI alternative R-1 because it does not include handling steam. • Under proven experience, the base alternative R-1 rates higher than the other FBI alternatives because it does not employ steam generation or power generation. • Alternatives R-1-A and R-1-B generate renewable energy that can be used as a revenue source. g. Total System Scoring Scoring for the Regional Total System alternatives is shown as Table 10-27and is based on the criteria and scoring presented in previous sections. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-32 Table 10-27 Summaries of Scoring for Total System Alternatives Category Criteria Alternatives Scores S-1 No Regional S-2 Lemay Haul S-3 Lemay Pump Economic 53.3% overall weighting Capital cost 2 4 3 Operating and maintenance costs 3 3 4 Operating revenues 5 1 1 Constructability 1 4 2 Private party participation risk 2 3 4 Social 22.2% overall weight Public perceptions 3 3 4 Nuisance impacts 2 3 4 Public and Employee Safety 2 3 4 Ease of permitting 4 3 3 Staffing/Operational Complexity 1 4 5 Environ-mental 24.4% overall weight Air and water quality 2 4 4 GHG emissions 3 3 3 Biosolids final disposition reliability 1 5 5 Proven experience 3 4 4 Multiple product flexibility 3 4 4 Total 37 51 54 Weighted Total 27.2 36.5 36.0 (1) Discussion of Total System Alternatives The analysis shows that the Total System Alternative S-2, involving hauling dewatered solids from Lemay to Bissell, scores slightly higher than the Total System Alternative S- BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Triple Bottom Line Evaluation August 31, 2010 MSD Contract No. 2009145 Re-Issued: January 19, 2011 B&V File 45.000 10-33 3 with pumping from Lemay and considerably higher than the No Regional option S-1. The differences are: • Lower capital costs for the total system option S-2. • Higher ratings for constructability for the total regional options compared to implementing improvements at individual plants. Hauling dewatered solids from Lemay to Bissell (Total System S-2) scored better that the pumping option (Total System S-3) because of the need for a new force main for pumping thickened solids from Lemay. • Better air and water emissions expected with the total system options S-2 and S- 3 since the number of emission sources are reduced by solids treatment at a central location. • Less staffing and simpler operations with the total system options S-2 and S-3 because of treating all the solids at one location. • Better final disposal reliability with regional treatment because the ash can is disposed of at a landfill and the total solids quantities are reduced by approximately 90 percent through incineration. The addition of heat recovery and steam production for sale will increase the desirability of the total system options S-2 and S-3 because of the revenue from the sale of steam. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 1 QA/QC: L. Warren TECHNICAL MEMORANDUM NO. 11 PHASING AND IMPLEMENTATION OF SELECTED ALTERNATIVES To: Metropolitan St. Louis Sewer District From: Bently C. Green; Matt Bond; Jim Rowan; Tom Ratzki; Patricia Scanlan Jessica Perkins (Communications Plan) _____________________________________________________________________________ This Technical Memorandum (TM) provides a discussion of the phasing and implementation plan for each solids processing alternative considered for the current biosolids evaluation. This memorandum is a culmination of the entire Phase 1 and Phase 2 elements of the study. Table of Contents Table of Contents .................................................................................................................................. 1 List of Tables ........................................................................................................................................ 3 List of Figures ....................................................................................................................................... 3 Executive Summary .............................................................................................................................. 4 1. Implementation Drivers ................................................................................................................ 7 a. Existing Plant Conditions .......................................................................................................... 8 i. Bissell Point............................................................................................................................ 8 ii. Lemay ............................................................................................................................... 11 iii. Coldwater.......................................................................................................................... 12 iv. Missouri River .................................................................................................................. 13 v. Lower Meramec ................................................................................................................ 15 b. Limitations of Prospect Hill Disposal ...................................................................................... 16 c. Regulatory Issues ..................................................................................................................... 17 2. Recommended Phasing and Implementation Schedule .............................................................. 25 a. Triple Bottom Line (TBL) Summary ....................................................................................... 25 b. Implementation Concerns ........................................................................................................ 28 c. Short-Term Plan (0-5 Years) – Regional FBI Alternative ....................................................... 30 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 2 QA/QC: L. Warren i. Bissell Point.......................................................................................................................... 32 ii. Lemay ............................................................................................................................... 32 iii. Coldwater.......................................................................................................................... 32 iv. Missouri River .................................................................................................................. 33 v. Lower Meramec ................................................................................................................ 33 vi. Costs ................................................................................................................................. 33 d. Short-Term Plan (0-5 Years) – Continued Use of MHIs ......................................................... 34 e. Intermediate Plan (6-10 Years) – Regional FBI Alternative ................................................... 39 i. Bissell Point.......................................................................................................................... 39 ii. Lemay ............................................................................................................................... 39 iii. Coldwater.......................................................................................................................... 39 iv. Missouri River .................................................................................................................. 40 v. Lower Meramec ................................................................................................................ 40 vi. Costs ................................................................................................................................. 41 f. Long-Term Plan (11-20 Years) – Regional FBI Alternative ................................................... 42 i. Bissell Point.......................................................................................................................... 42 ii. Lemay ............................................................................................................................... 42 iii. Coldwater.......................................................................................................................... 43 iv. Missouri River .................................................................................................................. 43 v. Lower Meramec ................................................................................................................ 43 vi. Costs ................................................................................................................................. 43 g. Triggers for Change ................................................................................................................. 44 h. Delivery Methods..................................................................................................................... 47 i. Traditional Design–Bid–Build ............................................................................................. 47 ii. Design-Build ..................................................................................................................... 47 iii. Construction Management at Risk ................................................................................... 48 3. Communication Plan ................................................................................................................... 49 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 3 QA/QC: L. Warren a. Marketing Strategy................................................................................................................... 50 b. Marketing Methods .................................................................................................................. 51 c. General Awareness Tactics ...................................................................................................... 51 d. Organizational Briefings .......................................................................................................... 51 List of Tables Table 11-1 - Final Emission Limits for SSI Units ...................................................................................20 Table 11-2 Modification Criteria for SSI Units ..................................................................................21 Table 11-3 Control Mechanisms for SSI Units ...................................................................................23 Table 11-4 Potential Emissions Issues for SSI Units ..........................................................................23 Table 11-5 Present Worth Cost Table for Regional Alternative S-2 (0-5 Year Period) ......................34 Table 11-6 Costs for AEC Equipment for MHI Units .........................................................................36 Table 11-7 Comparison of Costs for MHI Alternatives ......................................................................37 Table 11-8 Present Worth Cost Table for Regional Alternative S-2 (6-10 Year Period) ....................41 Table 11-9 Present Worth Cost Table for Regional Alternative S-2 (11-20 Year Period) ..................44 Table 11-10 Consideration of Triggers that Modify Solids Master Plan .............................................45 List of Figures Figure 11-1 Triple Bottom Line Results ........................................................................................ 27 Attachments Attachment 1: MSD Comments on EPA SSI MACT Rules Attachment 2: USEPA Final SSI MACT Rule Implementation BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 4 QA/QC: L. Warren Executive Summary The solids master plan update was undertaken by the District with the overall goal and purpose of assessing the capacity of the existing facilities to remain functional and achieve regulatory compliance for the next 20 to 30 year period. A secondary goal of this effort was to assess the benefits of alternative technologies, processes, and partnerships in conjunction with the District’s historical solids handling and disposal means and methods. As the study proceeded however, a number of regulatory drivers were evolving; often conflicting and counter-intuitive, such that the District’s optimum path forward was somewhat clouded, and in part dependent upon the resolution of legal challenges to the regulatory framework that is currently in place. As such, until there is ultimate clarity in the regulatory picture, a plan this is flexible and can be modified as needed is required. As this plan evolved, numerous options were considered for each of the District’s seven wastewater treatment facilities; both within the context of what could be done within each of the plants as stand- alone facilities, as well as from a more holistic and region-wide perspective. Ultimately, the District honed in on a regionalized solution for future solids handling processes, with fluidized bed incineration (FBI) facilities located at the Bissell Point plant that would serve as the regional solids handling facility for all of the Districts treatment facilities. However, as that decision-making process was being developed, the United States Environmental Protection Agency (USEPA) published proposed rules for emission guidelines for existing sewage sludge incinerators (SSIs) on October 14, 2010. These proposed emission standards were based on maximum achievable control technology (MACT) for SSIs, but in several instances, emission limits were proposed that were significantly below the MACT “ceiling” (i.e., the average stack emission for each pollutant achieved by the best performing 12% of SSIs across the country and for which information had been collected). This in essence threw much of the evaluation process into a state of disarray as it was unclear what the overall implications of these rules were going to be, if USEPA would re-consider and modify them, and if potential legal challenges would result in their modification. USEPA’s BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 5 QA/QC: L. Warren below the MACT ceiling emission limits effectively challenged the results and conclusions that had been developed up to that point in time (i.e., a “regionalized” solution utilizing FBIs), given that this solution was projected to cost in excess of $270M and it could no longer be stated with absolute certainty that such a solution would fully satisfy all future regulatory constraints. Given the level of uncertainty from a regulatory perspective, the District rightfully elected to re- consider its approach and evaluate a more fiscally conservative path forward, until the ramifications of the rules are fully known and understood. On March 21, 2011, the USEPA published its final performance standards for both new and existing SSIs. In it, the USEPA actually modified its originally proposed limits so that none were below the MACT ceiling. These modifications added some level of clarity to the emission standards, particularly in that it could be stated with reasonable certainty that existing technologies could achieve these limits with advance emission controls (AEC). However, there still exists a number of elements to the rules that are counter-intuitive and subject to legal challenges. For instance, existing multiple hearth incinerators (MHIs) that undergo a modification that exceeds 50% of the original cost of the unit (in today’s dollars) would be re- classified as “new” MHIs and subject to more stringent emissions limits that would be very difficult to achieve. USEPA has noted that AEC technologies and maintenance are not considered a modification. They have however, indicated that the incinerator structure itself, feed systems, conveyance systems, and waste heat recovery systems for the incinerator are part of a modification. In essence, the final rule interpretation by USEPA actually discourages and penalizes facilities that would consider implementation of new technologies and/or green solutions such as energy recovery. The regulatory framework for SSIs is subject to revision going forward, with the outcome influencing the District’s path forward. This implementation plan outlines a number of options that the District will consider depending on the ultimate resolution of legal challenges and interpretation of the SSI MACT standards. Primary options for the District’s consideration are outlined below based on several different regulatory scenarios; with capital costs presented in 2011dollars and referenced as a general order-of-magnitude value (Note: For more refined costs, reference costs tables in TM 9 and as further defined in this TM 11 for more exact estimates): BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 6 QA/QC: L. Warren • Full SSI MACT Compliance Achieved with MHI’s Immediately: Delay action indefinitely until regulatory clarification is achieved, or some future modification of the SSI MACT standards dictates additional action. Until further stack tests have been completed, it is unknown as to whether regulatory compliance will be achievable. Assuming that the stack tests indicate the MHIs can comply with the final SSI MACT standards on a consistent basis, the District could elect to delay proceeding with any improvement plans until further developments make it necessary. o Immediate Cost Impact: $0 for regulatory compliance. o Future Cost Impact: To be determined based on regulatory changes. If emission standards do not substantially change, the District could operate the MHIs indefinitely depending on their long-term structural and process integrity. Some modifications and improvements could be considered, so long as they do not exceed a threshold that triggers stricter and unachievable emission limits. • Partial SSI MACT Compliance Achieved with MHI’s Immediately: Invest in necessary AEC technologies for the MHIs at both Bissell Point and Lemay to achieve full compliance. Because the existing facilities do not appear to have sufficient room for these facilities, it appears that a building expansion would be necessary to implement this strategy. o Immediate Cost Impact: Ranges from $30M to in excess of $50M, depending on strategy. o Future Cost Impact: Could be in excess of $120M to the MHIs so long as the MHIs can maintain regulatory compliance. These costs would be for the long-term structural and process improvements to the existing MHIs – under the assumption that such improvements can be made without exceeding a threshold that triggers stricter regulations. Or, improvement costs could be as much as an additional $270M if MHIs are abandoned altogether and replaced with FBIs. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 7 QA/QC: L. Warren • SSI MACT Standards for MHIs Become Stricter in 5 Years: Assumes that the District is able to operate the existing MHIs for a five year period without having to make a substantial investment to achieve regulatory compliance, but that USEPA revises the standards in five years based on additional MHI compliance data and assesses stricter emission standards on existing facilities. o Cost Impact in 5 Years:  In excess of $50M if standards are achievable with limited AEC technology improvements to the MHIs.  In excess of $170M if MHIs can be improved such that they can meet stricter emission standards indefinitely and the District elects to invest in the MHIs long-term. These costs would be for AEC systems, as well as long-term structural and process improvements to the existing MHIs – under the assumption that such improvements can be made without exceeding a threshold that triggers stricter regulations.  Or, the District could elect to implement a regional solution with FBIs at a project capital cost of approximately $270M. In general, there are multiple scenarios that could prevail that warrant additional consideration, and will be dependent on the ultimate outcome of legal challenges to the SSI MACT standards, whether those standards become subsequently stricter, the Districts stack test results and the MHIs capacity for achieving compliance with the SSI MACT standards, and whether there are other drivers that emerge that dictate re-consideration of the District’s overall solids handling master plan. 1. Implementation Drivers MSD operates seven wastewater treatment facilities; two of which process approximately 85% of the total solids load the District receives. These two facilities; Bissell Point and Lemay, use multiple BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 8 QA/QC: L. Warren hearth incineration (MHI) to stabilize the solids and produce an ash end-product that is hauled to the MSD-owned Prospect Hill landfill site just north of the Bissell Point plant. MSD has successfully operated the MHI systems for both these plants for more than 40 years but now has regulatory concerns regarding new emissions limits for sewage sludge incinerators (SSIs), as well as concerns over the long-term viability of the Prospect Hill landfill as an ultimate end-use option. Based on these concerns, the District has decided to re-examine its biosolids program, to consider reasonable and feasible options that warrant evaluation. Going forward, the District desires a plan that is based on a sound assessment of economic, social, and environmental factors; and is flexible enough to consider the myriad issues that could be encountered. There are a number of outcomes that may ultimately prevail, with regulatory drivers that may not be entirely resolved for several years. As such, the plan will need to be periodically updated to re-assess the overall impact of those issues on the District’s capital planning process. Although most anticipated issues will have sufficient lead time to allow the District to adequately plan and account for them, it is also prudent to establish contingency plans to address any sudden or drastic changes that require major revisions to overall operations. a. Existing Plant Conditions As part of the Solids Master Plan (SMP) update, condition assessments were conducted for the solids handling equipment for each of the plants (refer to TM 5 of the Phase I Report). A summary of the District’s general plant conditions and operating strategies – both current and long-term – is provided below. i. Bissell Point The Bissell Point wastewater treatment plant has been in operation since 1970 and has a design average daily flow capacity of 250 mgd. The plant was designed to operate as a combined trickling filter – activated sludge facility, with secondary clarification before discharging treated flow to the Mississippi River. For nearly five years, the aeration basins associated with the activated sludge system have been decommissioned because a significant portion of the plant’s organic load (from a BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 9 QA/QC: L. Warren local industry) was eliminated when the industry implemented its own industrial pre-treatment facilities. As such, the Bissell Point plant achieves NPDES regulatory compliance via attached growth treatment with trickling filters and secondary clarification. The aeration basins may be put back into service if required for higher loadings or stricter treatment requirements, such as nutrient removal. The plant currently process approximately 92 dry tons per day (dtpd) of solids, and future projections indicate that this will exceed 110 dtpd within the 20 year study period. Biosolids stabilization is achieved via multiple hearth incinerators (MHIs) that have been in operation since the plant was commissioned. There are six incinerators, each rated at 60 dry tons per day (dtpd). Based on existing solids loads to the plant, only two incinerators are typically needed for normal operation. Dewatering is accomplished with belt filter presses located in the Solids Processing Building. The plant also has gravity belt thickeners (GBTs) for thickening the solids prior to dewatering. However, the GBTs were decommissioned for cost/benefit reasons in the 1990’s. Ash material produced from the incinerators is conveyed to an adjacent ash lagoon, which is then periodically dewatered. The remaining ash material is subsequently hauled to the Prospect Hill Landfill. As part of the Phase 1 evaluation, a condition assessment was completed of 561 solids handling assets to determine a general business-case risk rating for each item. The condition assessment considered probability of failure (POF) criteria as well as consequence of failure (COF) criteria to determine if each particular asset fell into the category of low-, medium- or high-risk. For the Bissell Point facility, the overall condition assessment yielded the following results: • Assets Considered Low-Risk: 22% • Assets Considered Medium-Risk: 69% • Assets Considered High-Risk: 9% Of the nine percent of Bissell Point’s assets that were categorized as high risk, the majority were associated with the incineration equipment. Additionally, the high-risk assets identified at the Bissell BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 10 QA/QC: L. Warren Point plant represented 62% of all the high-risk assets identified across all seven wastewater treatment plants. Clearly, the District has done a very good job of operating and maintaining its equipment since only 6% of the District’s overall solids handling assets fell into the high risk category. What makes this even more impressive is that much of the equipment is older than its original design life and requires a high degree of operator maintenance and attention. The need to upgrade or replace the existing incinerators for long-term prolonged use was one of the drivers for this study. As part of the cost assessment which considered upgrading the MHIs, it was assumed that significant MHI structural rehabilitation improvements will be required every 10 years going forward, given the advanced age and condition of the MHIs. As shown in TM 9, annual O&M costs are anticipated to be approximately 15-20% higher for MHIs as compared to newer technology fluidized bed incinerators (FBIs). Overall, it is anticipated that the incineration and dewatering systems are likely going to require upgrades and/or replacement within the next 10-20 years. On the other hand, the gravity belt thickeners appear to be in good condition, but would likely need to be re-furbished if they were going to be re-commissioned. End-use and disposal options for the Bissell Point plant consist of hauling ash material (stored in the ash lagoons on the plant site) to the Prospect Hill landfill (five miles north of the Bissell Point plant) on roughly an annual or bi-annual basis. No other ash disposal options for the plant have ever been used. The life of the Prospect Hill landfill was evaluated in Phase 1 of this study. Currently the District is considering options for distributing the ash material to a cement company that has expressed interest in using the material as an amendment to their product. At this time, these discussions are very preliminary, and it is not possible to accurately assess the long-term feasibility and interest of such a potential partnership. Although such agreement could extend the life of the Prospect Hill landfill, future regulatory changes may inhibit the feasibility of cement companies from using the ash material. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 11 QA/QC: L. Warren In the event that disposing incinerated solids to the ash lagoons or hauling to the Prospect Hill landfill was unavailable, either dewatered cake or incinerated ash could be hauled to the IESI-BFC Ltd. (formerly Fred Weber) landfill (approximately 20 miles away) or to the Milam landfill in Illinois (approximately 10 miles away). Load-out facilities for such an operation would need to be re-commissioned and/or replaced and upgraded. Overall upgrade recommendations for the Bissell Point facility, developed as part of the TM 1 and TM 9 of the Phase 2 Study, consisted of replacing the MHIs with FBIs. ii. Lemay The Lemay wastewater treatment plant was commissioned in 1968 and has an average daily capacity of 167 mgd and a peak capacity of 233 mgd (through the secondary system). The plant operates as an activated sludge facility with discharge to the Mississippi River. Recent plant expansions have increased the overall peak flow capacity of the plant to 340 mgd. Solids handling consists of belt filter press dewatering along with multiple hearth incineration. Four 60-dtpd capacity MHIs were constructed with the original plant and have been in operation ever since. As with the Bissell Point facility, ash material produced from the incinerators is conveyed to an adjacent ash lagoon, which is then periodically dewatered. The resulting material is hauled to the Prospect Hill landfill located just north of the Bissell Point plant. The Lemay plant processes approximately 47 dtpd total solids (average annual basis) with a maximum month load of 85 dtpd. Solids projections to the plant over the 20-year study period are expected to increase slightly with a maximum month load of 94 dtpd. Under normal operation, the District operates either one or two MHIs at a time. As part of the Phase 1 evaluation, a condition assessment was completed of 376 solids handling assets to determine a general business-case risk rating for each item. As previously described, probability of failure (POF) criteria and consequence of failure (COF) criteria helped determine if each individual asset fell into the category of low-, medium- or high-risk. For the Lemay facility, the overall condition assessment yielded the following results: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 12 QA/QC: L. Warren • Assets Considered Low-Risk: 24% • Assets Considered Medium-Risk: 68% • Assets Considered High-Risk: 8% As with the Bissell Point facility, most of the high risk assets were associated with the incineration equipment. Lemay’s high risk assets represented 35% of all the high-risk assets identified across all seven wastewater treatment plants. Overall, the incinerators represent the District’s most critical vulnerabilities from a solids processing standpoint. Significant O&M resources have been put into repairs to the incinerators over the years, and are anticipated to increase in the future if major rehabilitation upgrades to the units are undertaken. As with Bissell Point, no other means of disposal or end use has been used for the ash material other than hauling the wet ash to the Prospect Hill landfill. While potential opportunities to distribute ash material to a local cement company are worth considering, particularly since such an agreement could extend the life of the Prospect Hill landfill, the long-term viability of this option remains to be seen given that potential regulatory changes regarding mercury limits for emissions could make the ash less attractive to cement manufacturers. It should be noted that some potential cement manufacturers have advised the District that this is not a regulatory concern for them at this time. In an emergency situation where disposing to the ash lagoons or hauling to the Prospect Hill landfill was unavailable, either dewatered cake or incinerated ash could be hauled to the IESI-BFC Ltd. (formerly Fred Weber) landfill (approximately 20 miles away) or to the Milam landfill in Illinois (approximately 10 miles away). Load-out facilities for such an operation would need to be added. iii. Coldwater The Coldwater WWTP was commissioned in 1965 with a permitted design flow of 40 mgd. Recent improvements at the plant have increased the peak secondary treatment capacity to 55 mgd and the primary treatment capacity to 135 mgd. Until the early 1990’s, the Coldwater treatment plant utilized anaerobic digestion (with energy recovery) for solids stabilization prior to discharge. Since 2008, the BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 13 QA/QC: L. Warren District has conveyed solids from the plant to the Bissell Point collection system via pump station and force main. The major concerns for the Coldwater plant are based on redundancy and reliability of the force main. If the operation of the force main is disrupted for any reason, the Coldwater plant will need to store the solids until the problem is resolved. Options for improved reliability include a parallel force main or the addition of solids dewatering equipment to facilitate landfill disposal. As part of the Phase 1 evaluation, a condition assessment was completed of 82 solids handling assets to determine a general business risk rating for each item. The overall condition assessment yielded the following results: • Assets Considered Low-Risk: 0% • Assets Considered Medium-Risk: 96% • Assets Considered High-Risk: 4% A number of the medium risk assets would be re-classified as low-risk with the construction of a parallel force main for the solids discharge. Because there is no redundancy to the force main for Coldwater, conducting a force main assessment to confirm its overall condition is highly recommended and should be conducted as soon as possible. It is assumed that a parallel force-main would be a high priority. iv. Missouri River The Missouri River WWTP was commissioned in 1989 and has a permitted design flow of 28 mgd. The plant has recently undergone improvements to increase its wet weather capacity. With the completion of the wet weather expansion, the fine screens and grit removal facilities are sized to handle a peak flow of 190 mgd. Primary treatment (including pre-aeration basins and primary clarifiers) has been sized to handle 80 mgd. Wet weather storage basins will capture all flows greater than 80 mgd. The secondary treatment facilities will also be expanded to handle 80 mgd and include replacement of the trickling filters with an activated sludge treatment process. This design is ongoing BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 14 QA/QC: L. Warren with construction starting in the summer 2011. The new average day permitted design flow will be 38 mgd. The Missouri River plant utilizes anaerobic digestion for solids stabilization (with energy recovery). Major improvements to the digestion facilities have been designed and construction will take place in 2011. Because the plant is relatively new and has undergone enhancements, the Missouri River solids handling systems are in reasonably good condition. Even prior to these improvements, the overall condition assessment for this facility was very good from a statistical perspective. Digested solids are either hauled to the nearby IESI-BFC Ltd. (formerly Fred Weber) landfill, or trucked to the nearby community of St. Peters, where the solids are composted and distributed to the general public. The availability of the St. Peters composting option is contingent on available excess capacity at the St. Peters wastewater treatment plant. Although this has historically been an available option for the District; within the past year St. Peters has had essentially no need for additional solids for its composting operations. As such, barring a significant change in circumstances, it is not anticipated that this will continue to be a viable option for the Missouri River plant going forward except on an emergency basis and by agreement with St. Peters. As part of the Phase 1 evaluation, a condition assessment was completed of 82 solids handling assets in order to determine a general business risk rating for each item. The overall condition assessment yielded the following results: • Assets Considered Low-Risk: 46% • Assets Considered Medium-Risk: 54% • Assets Considered High-Risk: 0% Once currently planned improvements are completed, it is anticipated that a number of the medium- risk assets will be re-assessed as low-risk assets. There are currently no other viable end-use options for the Missouri River plant beyond hauling to the IESI-BFC Ltd. landfill. The end-product is a Class B material, per Part 503 regulations, which BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 15 QA/QC: L. Warren would be suitable for use in a land-application program or a composting program (as evidenced by the participation in the St. Peters composting program). With both land-application and composting, there would be start-up costs and operations/maintenance costs to weigh against the currently reasonable cost of disposing the solids in the nearby IESI-BFC Ltd. (formerly Fred Weber) landfill (even considering tipping fees). Land application remains a viable option for the District to consider, but its applicability is based more on a full-time and permanent operation rather than as an emergency option. v. Lower Meramec The Lower Meramec WWTP is a trickling filter plant that was commissioned in 2007 with a permitted design flow of 15 mgd. A plant expansion is currently being considered that would likely convert it to a trickling filter/activated sludge process to better address anticipated future nutrient removal regulations. Ultimately, the District plans to decommission the Fenton and Grand Glaize treatment plants and convey wastewater flow from those two facilities to the Lower Meramec plant. Consequently, once these modifications have been completed, the plant is expected to have an average daily flow capacity of 56 mgd. The Fenton and Grand Glaize plants were evaluated as part of this study, but no recommendations were developed for long-term improvements given that they are ultimately scheduled to be de-commissioned. Consequently, current disposal practices for these two plants are expected to continue as is. The Lower Meramec plant currently does not provide solids stabilization at the plant. Dewatered solids are transported to the IESI-BFC Ltd. (formerly Fred Weber) landfill by truck. The plant is still relatively new, so most of the dewatering and truck load-out assets are in very good condition. Because there are no stabilization facilities, end-use options for the plant are generally limited to landfill disposal or transfer to one of the District’s other treatment facilities. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 16 QA/QC: L. Warren b. Limitations of Prospect Hill Disposal One of the secondary drivers for this study was the remaining life limitations of the Prospect Hill landfill, which has been the primary disposal site for incinerator ash from the Bissell Point and Lemay treatment plants. These issues were assessed and summarized as part of the Phase 1 report (reference TM 8 and TM 9). As noted, the landfill has historically averaged 72,500 cubic yards of material on an annual basis. Future ash production however is anticipated to increase to 96,500 cubic yards per year (and under certain “regional” scenarios not contemplated in Phase 1, this rate could be even higher since raw solids from the county plants would be incinerated rather than hauled to a landfill). At the current permitted landfill boundary limits (assuming a rate of 96,500 cubic yards per year) the landfill would have as little as 8 years of capacity remaining (thus requiring modified operations or landfill expansion by approximately 2017-2018). A vertical expansion is currently being considered by the District to add up to 814,000 cubic yards of volume to the landfill and extend the remaining life by approximately 8.4 years (at future ash production rates). Thus, with a vertical expansion, the Prospect Hill Landfill site has roughly 15-20 years of life remaining. There are some alternatives being considered that could extend the life of the landfill further. Most notable is a potential partnership opportunity with a local cement manufacturer who has expressed an interest in using the ash material as an amendment to their operations. Spokesmen for the company have conducted some preliminary assessments of the material and have indicated that they may be interested in taking all of the material that is produced from both the Lemay and Bissell Point plants. In reality, unless modifications could be made to address concerns for mercury, the feasibility of such a partnership is possibly limited to the remaining life of the MHI units as currently operated (i.e, without mercury limits). Other wastewater treatment facilities that have sewage sludge incinerators (SSI) units and had once had partnerships with cement manufacturers, indicated that once stringent mercury emission limits were imposed (and the mercury was removed within the ash instead of being emitted to the atmosphere), cement manufacturers faced their own regulatory issues with the mercury that effectively eliminated the use of the ash material as a suitable amendment, and thus partnership agreements were terminated. For the District however, even a temporary partnership BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 17 QA/QC: L. Warren with a cement manufacturer could potentially extend the life of the Prospect Hill landfill by another 3-5 years. Additionally, programs to remove mercury from the wastewater might also reduce it to levels such that its future removal or part of an advanced emission control system is not detrimental to cement manufacturer operations. In such a case, the life of Prospect Hill landfill as an alternate disposal live would be extended indefinitely. Preliminary discussions with cement manufacturers have indicated that this is not currently an issue that they are concerned with. c. Regulatory Issues Regulatory issues with respect to incineration facilities are anticipated to be the primary driver for the District’s future major capital expenditures related to the solids process and handling facilities. Since 1993, the Part 503 Regulations and Clean Air Act emission requirements for incinerators have primarily governed treatment and disposal options associated with biosolids. As summarized in TM 7 (Air Emission Requirements); the United States Environmental Protection Agency (USEPA) has developed regulatory rule changes under which air emission requirements for SSIs would be regulated under solid waste incinerator rules and criteria. Emissions from municipal wastewater SSIs are currently regulated under Section 112 of the Clean Air Act (CAA). If biosolids processed by SSIs are regulated as “solid waste,” incineration of biosolids would no longer fall under the “domestic sewage exclusion” provision and would be regulated under Section 129 of the Clean Air Act. USEPA has proceeded under this interpretation and has developed air emission requirements based on Maximum Achievable Control Technology (MACT) standards (which are based on the best performing 12% of SSIs currently operating in the U.S.). On October 14, 2010, USEPA released the draft MACT standards for SSIs. There were a number of emission limit standards developed that actually fell below the MACT ceiling (i.e., the limits as defined by the best performing 12% of SSIs). It was also noted that the MACT standards were developed from very limited data set and that emission limits were established based on each individual pollutant (or what is referred to as the best performing source for that pollutant). These standards were subject to a public hearing on October 29, 2010, and a comment period that ended on BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 18 QA/QC: L. Warren November 29, 2010. MSD and many other utilities provided comments on the proposed rule. MSD’s comments are attached to this memorandum (see Attachment 1). USEPA considered these comments and made some modifications. On March 21, 2011, EPA published is final SSI MACT standards and raised the limits on a number of pollutants (i.e., they became less restrictive), particularly for existing MHI SSI’s (see Attachment 2 for USEPA Final Rule Implementation) such that none of the emission limits were less than the MACT ceiling. Note that EPA maintained its interpretation that SSI’s should be regulated as a “solid waste.” As such, there are a number of public agencies (including NACWA) that are considering legal challenges to the rule as currently implemented. The rule became effective 60 days from the publication date (i.e., May 20, 2011). Although USEPA announced that it will “reconsider” certain aspects of other separate but related air emissions regulations (e.g., boiler and commercial/industrial solid waste incinerator, or CISWI, rules), the SSI rule is not part of the reconsideration. A summary of modifications made to the MACT standards from the initially proposed rule (October 14, 2010) to the final rule (March 21, 2011) is provided as follows: • Beyond the MACT Floor limit for Hg has been eliminated for existing MHI source category with the Hg limits for existing MHIs increased by a factor of 10. • The EPA has included a “new MHI” category. The new MHI category provides an option for existing MHIs that may undergo “modification” and be subject to ”new MHI” limits rather than existing source limits. • For new FBIs, the emission limit for Hg has not changed; Dioxin and Furan (CDD/CDF) limits have been relaxed; and all the others remain the same compared to the proposed rule. • For CDD/CDF, EPA is now giving the flexibility of choosing either the total mass basis (TMB) limits or the toxic equivalency (TEQ) based limits. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 19 QA/QC: L. Warren • Inclusion of an emission threshold test (< 75% of the limit), if met, will result in a a three- year testing frequency rather than annual performance testing for PM, Cd, Pb, Hg, SO2, HCl, NOx and CO. • Maintaining sludge feed rate and moisture criteria established during the performance test has been relaxed to more typical monitoring. • Compliance performance testing can be done at 85 percent of maximum permitted capacity of the SSI. • Contrary to the assumption in the proposed rule that alternative disposal methods (i.e., landfilling) would be required for a majority of the facilities, EPA now estimates that all facilities will choose to continue incineration. Should a facility choose an alternative method of disposal, EPA acknowledges that the decision is based on local variables. A summary of EPA’s proposed limits for MHIs and FBIs (for both new and existing) is provided in Table 11-1. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 20 QA/QC: L. Warren Table 11-1 - Final Emission Limits for SSI Units Final Emission Limits for SSI Units Pollutant Units Emission Limits for Existing MH SSI's Emission Limits for Existing FB SSI's Emission Limits for New MHI's Emission Limits for New FBI's Cd mg/dscm @7% O2 0.095 0.0016 0.0024 0.0011 CDD/CDF, TMB ng/dscm @ 7% O2 CDD/CDF, TEQ ng/dscm @ 7% O2 CO ppmvd @ 7% O2 3800 64 52 27 HCl ppmvd @ 7% O2 1.2 0.51 1.2 0.24 Hg mg/dscm @7% O2 0.28 0.037 0.15 0.001 NOX ppmvd @ 7% O2 220 150 210 30 Opacity % Pb mg/dscm @7% O2 0.3 0.0035 0.00062 PM mg/dscm @7% O2 80 18 60 9.6 SO2 ppmvd @ 7% O2 26 15 26 5.3 A number of project team discussions and workshops were conducted immediately following the USEPA’s announcement of potential SSI MACT standards, with consideration given to the long- term impact of the District’s operations and current overall master plan strategy. A summary of these discussions is provided as follows: • There are a number of inconsistencies in EPA’s proposed rules that will ultimately require clarification and interpretation to fully assess their impact on future investment decisions. • Currently, language appears to significantly limit the level of upgrades possible to MHIs before a threshold of 50% investment (defined as greater than 50% of the cost of the original unit updated to 2010 dollars) in a modification results in the re-classification of the MHI as a “New Unit” – which would trigger essentially non-achievable emission limits (for MHIs). Simultaneously, mercury limits for existing MHIs will necessitate the addition of Advanced Emission Control (AEC) equipment in order to comply with the proposed standards. Thus, BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 21 QA/QC: L. Warren utilities interested in keeping MHIs in operation would be required to invest in upgrades to equipment that may ultimately be rendered obsolete if those and/or other upgrades surpass the 50% threshold, and nearly non-achievable “New Unit” limits are imposed. Modification means a change to an SSI unit later than 6 months after March 21, 2011, and that meets one of two criteria: (1) The cumulative cost of the changes over the life of the SSI unit1 exceeds 50 percent of the original cost of building and installing the SSI unit (not including the cost of land) updated to current costs (current dollars). Land costs and costs for updated emission controls to meet the SSI MACT requirements are not included in the cumulative costs. (2) Any physical change in the SSI unit or change in the method of operating it that increases the amount of any air pollutant emitted for which Section 129 or Section 111 of the Clean Air Act has established standards. 1 The EPA uses a comprehensive definition of what constitutes a SSI unit – A SSI unit includes, but is not limited to, the incinerator vessel, the sewage sludge feed system, auxiliary fuel feed system, flue gas system, waste heat recovery equipment, if any, and ash system. The SSI unit includes all ash handling systems. The combustion unit ash system ends at the truck loading station or similar equipment that transfers the ash to final disposal. The SSI unit does not include air pollution control equipment or the stack. A summary of what constitutes a “modification” is provided below. Table 11-2 Modification Criteria for SSI Units Included in “modification” Not included in “modification” Feed system and grate system Air pollution control equipment Incinerator Maintenance Bottom ash and conveyance system Waste heat recovery equipment As noted, there currently exists a “penalty” for energy recovery that actually discourages its usage, as well as for the implementation new technology (FBIs). Furthermore, there is a lack of clarity as to how utilities are supposed to address these regulations given that the limits are reconsidered on a five year basis and are anticipated to get progressively stricter. Requirements for initial compliance with the regulations are summarized as follows: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 22 QA/QC: L. Warren • Existing SSIs must demonstrate compliance with the standards as expeditiously as practicable after approval of a State plan, but no later than 3 years from the date of approval of a State plan or by March 20, 2016, whichever is earlier. • Operators of SSIs must conduct initial and annual emissions performance tests or, as an alternative, install continuous emissions monitoring; bag leak detection systems for fabric filter (when used); and continuous monitoring of critical operating parameters and annual inspections for all air control equipment. • For new SSI units, operators must prepare and submit a pre-construction Site Analysis report that evaluates site-specific air pollution control alternatives that minimize potential risks to public health or the environment. The alternatives should be evaluated considering costs, energy impacts, non-air environmental impacts and other factors relating to alternative practicality. The report must be submitted to the EPA (and in some cases the state agency, instead of the EPA) prior to the start of facility construction. • All publicly operated treatment works and utilities operating existing and proposing new SSIs must obtain a new Title V air operating permit. • The new standards will require at least one operator or supervisor per facility to complete the operator training course, an annual review, or refresher course. POTWs and utilities that operate SSIs must maintain training information at each plant and update it annually. In general, there are a number of control mechanisms for addressing regulatory compliance, depending on the constituent. A summary of the various mechanisms for addressing selected MACT standard constituents is provided on the following page. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 23 QA/QC: L. Warren Table 11-3 Control Mechanisms for SSI Units Constituent Units Existing MHI New FBI Control Mechanism(s) Cd mg/dscm 0.095 0.0011 Particulate removal CDD/CDF, TEQ* ng/dscm 0.32 0.0044 Combustion, carbon CDD/CDF, TMB** ng/dscm 5 0.013 Combustion, carbon CO ppmvd 3,800 27 Combustion HCl ppmvd 1.2 0.24 Absorption or chemical conversion Hg mg/dscm 0.28 0.001 Adsorption NOx ppmvd 220 30 Combustion, chemical conversion Pb mg/dscm 0.3 0.00062 Particulate removal PM mg/dscm 80 9.6 Particulate removal SO2 ppmvd 26 5.3 Absorption or chemical conversion Existing SSIs must be assessed on a unit by unit basis to determine compliance under existing SSI limits. Baseline emissions from performance testing for SSIs should be used to determine compliance with the new rule. A review and analysis of the selected baseline emissions for SSIs reported by EPA suggests the following potential emission issues: Table 11-4 Potential Emissions Issues for SSI Units Cd CO HCl Hg NOx Pb CDD/CDF PM SO2 Existing MHI    New MHI      Existing FBI      New FBI       = potential emission limit issue based on EPA baseline emission data of selected SSIs and available control equipment BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 24 QA/QC: L. Warren An initial assessment of the “Existing Multiple Hearth” emission limits, based on the performance of a number of these units nationwide, indicates that most MHIs will likely comply with the limits initially. Compliance with CO should not be a problem. Older units, depending upon site-specific data, may need emission control upgrades or add-on emissions controls. Existing MHIs are anticipated to meet “existing” MHI standards. In some cases, Cd, Hg, NOx and SO2 emissions may be problematic, requiring additional controls. The District is currently conducting stack tests on its MHI units to assess its capacity to achieve “existing MHI” limits. A preliminary review of the District’s incinerator stack test data completed within the last 20 year period indicates that the MHIs may very well meet many of the currently proposed limits, with the potential to have occasional issues with NOx and SO2. Should the limits become tighter as they are periodically updated on a five year basis against the best performing 12% of SSIs, the feasibility of the MHIs maintaining regulatory compliance would need to be re-evaluated in conjunction with any emission limit modifications enacted. The District will need to closely track capital expenditures to determine if “modification” is triggered, which would reclassify an existing MHI to a new MHI. If functional upgrades are extensive, existing MHIs may have to shutdown rather than accept the “new” incinerator designation and limits. New MHI status is very restrictive, potentially requiring controls for CO, Hg, and CDD/CDF. New FBI, the most restrictive of all the categories, will require extensive emissions controls as part of the design package. This will dictate that AEC systems be employed on FBIs from the outset, rather than delaying until the more restrictive limits are imposed in the future. This scenario had already been contemplated during workshops completed in September 2010, and the consensus decision made then was to move AEC systems from an “alternative” to be implemented in the future into the overall FBI base case to be implemented with initial FBI construction. Although the limits for new facilities were more stringent for some pollutants that what had been anticipated, FBI systems with AEC equipment can achieve the proposed limits, although with less room for error than had previously been anticipated. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 25 QA/QC: L. Warren 2. Recommended Phasing and Implementation Schedule There are a number of drivers that will necessitate action by the District over the next 20 year period, some of which are reasonably well-known and for which long-term plans can be contemplated, and some of which remain in a state of uncertainty such that their overall long-term impacts may not be discernable for some time. As such, the District has undertaken this study to complete a thorough evaluation of its entire solids handling and processing systems in order to forge a general path forward; with the understanding that there will be a need to periodically re-assess and amend the plan as more information becomes known. The Plan developed herein is based on a thorough assessment of the District’s existing system, with consideration given to its condition and capacity for achieving future regulatory compliance. The District has considered social, economical, and environmental factors in developing this Plan, and has actively solicited public opinion and preferences. The District’s Solids Master Plan contains short-term, intermediate, and long-term elements that sequentially address the District’s anticipated needs at this time and yet is flexible enough to deviate going forward as project implementation drivers change. a. Triple Bottom Line (TBL) Summary The overall triple-bottom-line (TBL) assessment of all alternatives considered is provided in TM 10 (of this Phase 2 Master Plan Report). Each plant was assessed on an individual basis, and then from a more holistic system-wide approach. On a system-wide basis, a regional solids handling facility (with multiple options) was compared against a de-centralized option in which each plant maintained its existing operations. For the Bissell Point and Lemay plants, continued use of the MHIs was compared against replacing them with FBIs. The TBL analysis ultimately concluded that long-term operation of the MHIs was not the preferred or selected option for a variety of reasons; primarily due to concerns regarding their age and condition, and the general need for future upgrades in conjunction with profound regulatory uncertainty. Additionally, the cost of the FBI system BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 26 QA/QC: L. Warren (including AEC) drove the evaluation process towards the consideration of a regional facility – which it was determined in workshops would be located at the Bissell Point plant site. Ultimately, three overall total system alternatives were developed for a long-term strategy: 1) Construct a regional facility at Bissell Point, with all other plants (including Lemay) hauling solids to the facility (except Coldwater which would continue to pump solids to the Bissell Point collection system); 2) Construct a regional facility at Bissell Point, with Lemay and Coldwater pumping solids to the Bissell Point system and the remaining treatment plants hauling their solids to the regional facility; and 3) De-centralized options in which all existing plants are upgraded in accordance with their long-term needs. Under this alternative, the Bissell Point and Lemay plants would both ultimately replace their existing MHIs with new FBIs at each facility. The final TBL analysis results are shown in Figure 11-1. Following the publication of USEPA’s SSI MACT rules however, and given the lack of clarity in the rule’s implementation and potential legal challenges; other options for continuing to operate the MHI’s have emerged that should be considered until further stack testing has been completed which will define upgrades necessary (if any) that are required to meet the currently published emissions limits, and give the District more time to contemplate overall upgrades required to achieve regulatory compliance for a sustained 20 to 30 year period without having to rush into any upgrades based on emission limits that could very well change. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 27 QA/QC: L. Warren Figure 11-1 Triple Bottom Line Results As shown, both of the options for a regional facility are virtually tied and are substantially ahead of a non-regional option. Ultimately, the District’s decision of whether to haul or pump solids from Lemay to the Bissell Point plant will depend on the overall feasibility of constructing a 12-mile force main through a heavily developed part of downtown St. Louis versus the potential social impacts (particularly odor) of having a load-out and hauling operation from Lemay to Bissell Point. Although a force main option has a number of technical and logistical challenges associated with it, it has favorable social and environmental impacts with it as compared against a major cake hauling operation from Lemay to Bissell Point. Unlike the Bissell Point plant, which is located in a predominantly industrial area, the Lemay plant sits in a very heavy residential and commercial area. Additionally, hauling cake solids from the Lemay plant to the Bissell Point plant will require tractor trailers to drive through the heart of downtown St. Louis (albeit on a major interstate) with a cargo BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 28 QA/QC: L. Warren that could very well elicit public complaints if done on an everyday basis on a massive scale. Significant odor control systems for a load-out facility will be required for this option, and extensive measures will be required to mitigate odors emanating from the tractor trailer to the greatest extent possible. A force main, on the other hand, could be constructed either to the Bissell Point plant or to a point in the Bissell Point watershed where the solids would be conveyed to the treatment plant. Consideration was given to extending the force main to the Barton Drop Shaft, from whence it would be conveyed to the Bissell Point plant via the Reach 4 tunnel portion of the collection system. However, it was determined that this would result in potential CSO issues during wet weather events, since the hydraulic grade line in the south leg of the Bissell Point Interceptor Tunnel can rise above the elevation of the interceptor on the New Mill Creek sewer at structure 21D4-649C. MSD's continuous simulation of the system for the year 2000 indicated a total of 63 "events" where this would occur; which would result in potential discharge of untreated solids to the Mississippi River outfall as part a CSO. Additionally, discharging solids from the Lemay plant to the Bissell Point collection system would also necessitate that the solids be processed through the Bissell Point headworks and primary treatment systems. Such an increase in the solids load to those facilities would likely dictate a plant expansion at Bissell Point for that purpose alone. Consequently, it was determined during workshops conducted as part of the development of this master plan, that any force main for the solids at Lemay would need to convey the solids to the Bissell Point plant independent of the collection system (and contrary to how solids are conveyed from the Coldwater plant). b. Implementation Concerns The Solids Handling Master Plan developed herein has considered needed improvements to the solids systems for the District as a response to its physical condition, as well as the system and regulatory requirements needed to ensure the continued viable operation of the program for the next 20 year planning period. MSD has considered economic, environmental and social impacts BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 29 QA/QC: L. Warren throughout the decision-making process. The overall recommended plan has been developed via a large and inclusive project team operating within a workshop format. Significant upgrade and modification recommendations have been developed through consensus to meet the District’s goals and objectives over the next 20 year period. However, these modifications will require a significant capital investment that will impact the District’s overall rate structure for its customers. Simultaneously, the District will also (over the next 20 years) be implementing a Long-term Control Plan (LTCP) for its combined sewer overflow (CSO) system, its sanitary sewer overflow (SSO) system, as well as a number of other regulatory issues that will need to be addressed. The CSO LTCP program alone is ultimately expected to cost nearly five billion dollars. Consequently, it is prudent to compare the cost of implementing an additional program for the solids handling facilities against whatever bare minimum cost alternative exists, irrespective of whether it was the selected alternative. Political pushback to potential rate increases should be considered a part of the plan; and as such will require an effective communication plan (referenced in a subsequent section of this memorandum). In general, there are at least three other alternatives to consider in lieu of the recommended plan, summarized as follows: • Use MHI’s Temporarily Assuming No AEC Equipment Required to Meet Emission Limits This concept will require stack testing to confirm that the existing MHIs can achieve compliance with the SSI MACT standards with no additional AEC required. This option would allow the District to continue operating the MHIs until further regulatory developments, clarifications, and legal challenges help to clarify the long-term regulatory picture, after which the District will be able to make an informed decision on its long-term solids handling strategies. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 30 QA/QC: L. Warren • Use MHI’s Temporarily With AEC Equipment Required to Meet Emission Limits This concept is based on an approach proposed by the District in a workshop on January 19, 2011, and assumes that the MHIs can be used for an extended period of time with additional AEC controls to meet emission limits. Under this concept, the existing MHIs would continue to operate indefinitely with advance air emission equipment constructed as necessary to meet SSI MACT pollutant limits under the assumption that these limits were reasonably achievable and not below the MACT floor. • Modify MHI’s for Long-Term Use In this case, financial considerations dictate the continued use of the MHIs for as long as possible, even if this requires significant investments to maintain the structural and functional integrity of the MHIs for a sustained 20 to 30 year design period, and would include advance emission control (AEC) systems as required to meet long-term regulatory objectives. This option also assumes that USEPAs “modification” rule will be clarified to conclude that such modifications could be made without triggering a revision in the emission limit standards such that the MHIs would be classified as “new.” This is unlikely given that the current definition for modification, as summarized in Table 11-2 – Modification Criteria for SSI Units, defines much of the structure as counting towards the threshold that would constitute such a re-classification. The standards for new MHIs are considered too stringent for existing MHIs to consistently meet. As such, this alternative has very little realistic probability, although it should certainly be considered. c. Short-Term Plan (0-5 Years) – Regional FBI Alternative This alternative essentially outlines the path that the District was headed down prior to the ambiguity that prevailed following USEPA’s publication of draft and final SSI MACT standards. Depending on the outcome of any legal challenges, the implementation of this plan may be warranted at any time within the next five year period. This plan is based on the assumption that the District has made no other facility improvements to the MHIs prior to implementation and that a primary driver BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 31 QA/QC: L. Warren for its implementation is regulatory compliance with emission limits or the functional performance of the MHIs. Beyond resolution of these regulatory driven issues, no major changes are anticipated in the solids handling operations for any of the District’s seven wastewater treatment facilities over the next five year period; other than current improvements being constructed at the Missouri River plant. A tentative schedule for implementing a major solids handling upgrade program with the construction of a regional FBI facility would take approximately seven years to complete and is outlined as follows: • RFQ/RFP Process 8 months • Preliminary Study 12 months • Negotiate Contract 2 months • Design 18 months • MDNR Permit/Review 6 months • Revise Plans and Bid 6 months • Construction 36 months 80 months total Again, the timeline for initiating the implementation schedule for a regional FBI facility will be dependent on the District’s overall assessment of its ability to achieve short-term and long-term compliance with the SSI MACT rules, with those issues weighed against the overall condition of the solids handling facilities, investments required, and the anticipated timeframe that the investments extend the functional life of the facilities. The summary below highlights anticipated strategies for the solids handling plan for the upcoming 3-year period. It assumes that the existing incinerators can achieve compliance with SSI MACT rules. • 2011–2012: Assess ultimate impact of the SSI MACT rule on overall strategy. Assess legal challenges of the rule from advocacy organizations such as NACWA. Assess through stack testing whether the existing MHIs can achieve regulatory compliance with the SSI MACT rules. Revise plan as necessary to account for modifications in limits and/or schedule of compliance. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 32 QA/QC: L. Warren • 2013: Depending on the status of compliance with the SSI MACT rule, begin planning and design of modifications at the Bissell Point and Lemay treatment plants, either for replacement with FBIs or for AEC for MHIs. Compliance with the SSI MACT regulations is required by March 2016. It is assumed that the District’s MHIs will be able to achieve compliance with the SSI MACT rule initially. Short-term operating strategies specific for each plant are summarized as follows: i. Bissell Point Assuming that a regional facility is ultimately constructed at the Bissell Point plant, overall design and construction of the facility could begin as early as 2013. The facility, as summarized in TM 6 – Regional Facility Solids Processing Alternatives Evaluation, would consist of FBI facilities supported by AEC and energy recovery. ii. Lemay Within this initial short-term timeframe, it would need to be determined whether solids from the Lemay plant will be conveyed to a regional facility by hauling or pumping. In either case, major design modifications to the plant for these options should begin in approximately 2013 to allow for implementation consistent with the start-up of a Regional Facility. iii. Coldwater During the next five year period, the overall need for redundancy of the existing sludge force main (conveying solids to the Bissell Point collection system) will be assessed against MSD operations staff’s concerns over its condition and integrity. It is anticipated that the District will proceed with a more thorough force main condition evaluation to assess its overall structural and functional integrity. Depending on the results of the condition assessment, the construction of a parallel force main could fall either into the short-term plan, or be moved into the intermediate plan. It is assumed that the parallel force main would be included in the short-term plan. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 33 QA/QC: L. Warren iv. Missouri River Major renovations in the short-term timeframe for Missouri River plant are going to depend on the District’s preference for either developing an alternative FOG (fats, oils, and grease) receiving station to the one at the Bissell Point plant, or replacing it altogether. The existing digesters are currently being renovated and a new digester is being constructed to increase the plant’s overall solids stabilization and energy recovery capacity. Consequently, no major modifications (beyond the previously mentioned District preference for FOG facilities) are anticipated in the short-term. v. Lower Meramec Long-term options for the Lower Meramec plant are contingent on ultimately de-commissioning the Fenton and Grand Glaize plants, and whether or not the District would ever desire to develop and implement a land-application program or an alternative program to the current disposal method of hauling to a landfill. From a planning perspective, it was assumed that Fenton would be de- commissioned in 2015, followed by Grand Glaize in 2025. In reality, a more realistic scenario is likely no sooner than ten years for the Fenton plant, and perhaps twenty years for the Grand Glaize plant. Consequently, no major upgrade modifications for the Lower Meramec plant are anticipated in the short-term. vi. Costs Overall anticipated costs in the short-term are summarized as follows for the recommended plan of constructing a regional facility at the Bissell Point plant location, and re-directing solids from the remaining plants to this location. These costs, as outlined above, are for the Bissell Point and Lemay plants only, as they are the only plant modifications for which immediate action is required. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 34 QA/QC: L. Warren Table 11-5 Present Worth Cost Table for Regional Alternative S-2 (0-5 Year Period) Alternative Regional System Modifications of Bissell and Lemay Alternative S-2 Capital Costs $269,470,000 Salvage Value ($9,034,000) Annual O&M Costs $17,452,000 Annual Revenue $0 Present Worth Costs Capital $269,470,000 Salvage Value ($3,405,000) O&M $217,490,000 Revenue $0 Total Present Worth Costs $483,555,000 Note: (There are not costs for Missouri River, and Lower Meramec included in 0-5 Year Plan). d. Short-Term Plan (0-5 Years) – Continued Use of MHIs There are a number of alternatives to a short-term plan utilizing the MHIs for an extended period of time that need to be considered and are in part dependent on the outcome of any legal challenges to USEPAs SSI MACT standards. Until those issues are resolved, and the District has had the time to adequately conduct extensive stack testing on their existing MHIs to assess their capacity to achieve immediate and long-term regulatory compliance, it is prudent to proceed on the basis of continuing to utilize the MHIs until there is long-term regulatory clarity. A cursory review of stack tests for emissions for Bissell Point and Lemay conducted over the previous 20 year period was inconclusive due to the lack of data, but did indicate that the MHIs may have occasional regulatory compliance issues with SOx and NOx emissions. It is not clear at this time however, if those issues would be problematic to the point that the District would need to undertake a significant upgrade to add BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 35 QA/QC: L. Warren advance emission controls (AEC) equipment to the existing systems in order to achieve consistent compliance, or if they were statistical anomalies that could be addressed without major upgrades. If stack test data indicates that the existing MHIs can achieve SSI MACT emission standards for the near-term, then the District can essentially delay any investments for the time being and continue to operate the MHIs. No upgrade investments would be required until the emission limits were modified and reduced to the point where the MHIs capacity for achieving regulatory compliance was compromised. This option, if available, would allow the District to assess the long-term regulatory picture and make an informed decision regarding its path forward. It is anticipated that the SSI MACT standards will be updated on either a five-year or a ten-year cycle, and that emission limits will ultimately become progressively more stringent. However, so long as the MHIs can achieve regulatory compliance, any upgrade plans that the District would undertake could proceed at a pace that the District is comfortable with and be based on the Districts self-defined priorities. On the other hand, if stack test data indicates that the MHIs can achieve regulatory compliance only through an upgrade to the advanced emission controls (AEC) equipment, the District will be confronted with a more difficult decision. As shown in Table 11-6, AEC equipment for both facilities is tentatively estimated at $54M. If a haul operation from Lemay to Bissell Point were undertaken and the incinerators at Bissell Point utilized for Lemay as well, then the investment in AEC equipment would be reduced somewhat. However, this would necessitate the operation of at least four of Bissell’s incinerators on an average-day basis and potentially all six of the incinerators on a peak solids basis, as well as a major haul operation from Lemay. Table 11-6 provides a summary of the investment required for AEC equipment to the MHI units, with no other upgrades or modifications completed to minimize the capital cost required to the greatest extent possible. The AEC equipment for MHIs is sized differently than for FBIs. Consequently, it would not be possible to re-utilize AEC equipment initially installed for the MHIs if later the District elected to construct FBIs. Upgrades for adding AEC systems to the MHIs would need to be weighed against delaying the costs for replacing the MHIs entirely by whatever BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 36 QA/QC: L. Warren timeframe that the AEC system buys. If an investment of $30-50M ensures that the MHIs can operate for another 10-20 year period without any regulatory problems, it very well could be worth the investment. On the other hand, if such an investment provides only 5 to 10 years of regulatory reliability, the District could very well elect to implement a comprehensive regionally based program of replacing the MHIs with FBIs. Table 11-6 Costs for AEC Equipment for MHI Units Alternative Bissell Pt. B-1 Lemay L-1 MHI+BFP MHI+BFP AEC $19,484,000 $30,535,000 Total Probable Construction Cost $19,484,000 $30,535,000 Engineering & Construction Services $2,201,000 $1,838,000 MHI Re-build (year 10) $0 $0 Capital Costs $21,685,000 $32,373,000 Total Capital Costs (Both Systems) = $54,058,000 Given the magnitude of the costs summarized for the recommended plan, it is also prudent to consider the cost for keeping the MHI units in operation for the planning period by upgrading them structurally and mechanically as needed to ensure their long-term successful operation. Capital costs for the MHI alternatives for the Bissell Point and Lemay facilities were assessed in TM-9 Opinions of Costs for Alternatives. The following table provides the overall recommended costs for upgrading the MHI units to a level that would ensure their successful operation for the duration of the 20-year planning period. Considering only capital costs because that may be the primary driver for deviating from the recommended plan, implementing a program that keeps the MHI units in operation for the planning period results in a capital cost expenditure of $176M, compared to the $269M identified for the recommended plan (i.e., regional facility located at Bissell Point; reference Table 11-5). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 37 QA/QC: L. Warren Table 11-7 Comparison of Costs for MHI Alternatives Alternative Bissell Pt. B-1 Lemay L-1 MHI+BFP MHI+BFP Sitework $0 $0 Steam Pipeline $0 $0 Structures $2,385,000 $225,000 Equipment $24,122,000 $10,478,000 Subtotal $26,507,000 $10,703,000 General Requirements $2,716,000 $1,098,000 Electrical Work $2,618,000 $1,070,000 Instrumentation and Control System $1,047,000 $428,000 Contingency $8,222,000 $3,325,000 Mid-Point of Construction $4,214,000 $1,704,000 Subtotal $45,324,000 $18,328,000 AEC $19,484,000 $30,535,000 Total Probable Construction Cost $64,808,000 $48,863,000 Engineering & Construction Services $11,331,000 $4,582,000 MHI Re-build (year 10) $24,145,000 $22,690,000 Capital Costs Capital Costs (Both Systems) = $176,419,000 $100,284,000 $76,135,000 Salvage Value ($782,000) ($3,093,000) Annual O&M Costs $9,179,000 $5,695,000 Annual Revenue $0 $0 Present Worth Costs 0 0 Capital $100,284,000 $76,135,000 Salvage ($295,000) ($1,166,000) O&M $114,393,000 $70,972,000 Revenue $0 $0 Total Present Worth Costs Total Present Worth Costs (Both Systems) = $350,323,000 $214,382,000 $145,941,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 38 QA/QC: L. Warren However, depending on the ultimate limitations for MHI investments due to the EPA SSI MACT rule, this would be an uncertain option with risks associated with it if it would result in the MHI units being re-classified as “new” and having to meet limits more stringent that they are capable of achieving. It should be noted that at the time these costs were developed, EPA had not published the SSI MACT rules, and so the constraint for upgrade/modification expenditures exceeding a 50% threshold of original incinerator costs (updated to current dollars) was not considered. As an illustrative example, District staff reviewed archived project files and determined that the Lemay solids facilities (with three incinerators) were commissioned in 1970 at a total construction cost of $6,016,000. Assuming 75% of these costs are applied to the incinerators results in an incinerator cost of $1.5M per incinerator (in 1970 dollars). Using Engineering News Record (ENR) construction cost indices of 3% per year for the past 40-year period results in a cost per incinerator of $4.9M (in today’s dollars), or $19.6M for all four incinerators at Lemay. Applying the same unit costs to the Bissell Point plant (for its six incinerators) results in an overall cost of $29.4M for all incinerators. In this case, incinerator modification/upgrade limitations that would likely result in the MHIs being re-classified as “new units” (and consequently subject to the significantly more stringent air emission requirements) are summarized as follows: • Bissell Point: $2.5M per incinerator (50% of original costs in today’s dollars), or approximately $15M total upgrade (6 incinerators) • Lemay: $2.5M per incinerator (50% of original costs in today’s dollars),or approximately $10M total upgrade (4 incinerators) These costs are summarized for illustrative purposes only. However, comparing these costs against those provided in Table 11-6, it is clear that the upgrades identified for a stable long-term operation using MHIs are likely greater than the ultimate threshold amount that would re-classify the MHIs as “new units” according to the SSI MACT rules. Consequently, the District would most likely not BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 39 QA/QC: L. Warren elect to invest anywhere near that amount in a technology that faces such long-term regulatory uncertainty. e. Intermediate Plan (6-10 Years) – Regional FBI Alternative Following the completion of a regional facility at the Bissell Point plant, with modifications completed at the Lemay plant to either haul or pump solids to the regional plant, it is anticipated that consideration will be given to any necessary upgrades to the remaining facilities. An intermediate strategy per plant is summarized as follows: i. Bissell Point Assuming that all upgrades have been completed to bring a regional facility on-line, no other major modifications or upgrades are anticipated for the Bissell Point plant for the next period. ii. Lemay As with Bissell Point above, if upgrades have been completed to bring a regional facility on-line, no other major modifications or upgrades are anticipated for the Lemay plant for the next period. iii. Coldwater Given the criticality of having redundancy to its solids handling system, if a parallel force main is not constructed as part of the short-term plan, it is anticipated that it would be constructed within this intermediate period. However, this is subject to review and re-assessment of MSD operations staff and depends on the overall condition of the existing force main. If it appears that the existing force main is compromised structurally and in need of frequent repairs or cleaning to keep it functional, the need for a parallel force main is significantly greater. For planning purposes it was assumed that the parallel force main will be constructed in the short-term plan. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 40 QA/QC: L. Warren iv. Missouri River It is anticipated that FOG facilities would be constructed at the Missouri River facility following the completion of the regional facility. The new FOG receiving station will either replace or supplement the existing FOG receiving station located at the Bissell Point plant. With the construction of a new regional facility that would be operational near the beginning of this phase, solids produced at the Missouri River plant would be hauled to the regional facility instead of the IESI-BFC Ltd. (formerly Fred Weber) landfill, even though the landfill is much closer. It is anticipated that the additional hauling costs would be more than offset by the savings in tipping fees. As part of this study, partnership opportunities with IESI-BFC Ltd. (formerly Fred Weber) were explored in which solids from the District’s plants could be disposed at the IESI-BFC Ltd. (formerly Fred Weber) landfill as a cover material or as an amendment to stimulate the potential production of biogas at the landfill. Those options could be re-visited to assess the viability of a tipping fee reduction for the Missouri River facility; otherwise, it is anticipated that solids from this plant will be hauled to the regional facility for processing. v. Lower Meramec It is not anticipated that any major renovations or upgrades will be completed at the Lower Meramec facility unless the timeline for de-commissioning the Fenton and Grand Glaize plants has been moved up significantly. End-use and disposal options, however, will change with the implementation of a regional facility at the Bissell Point plant. Currently, solids are hauled to the IESI-BFC Ltd. (formerly Fred Weber) landfill. Hauling costs to the regional facility are expected to be lower because of the reduced distance to go to the regional facility versus the IESI-BFC Ltd. (formerly Fred Weber) landfill (by approximately 5-6 miles), as well as the elimination of a tipping fee associated with disposal at a solid waste landfill. As discussed with the Missouri River plant above, future options for partnerships with the IESI-BFC Ltd. (formerly Fred Weber) landfill could be explored wherein the solids are used as cover or as an amendment for biogas production. The subsequent reduction in tipping fees could potentially make hauling to the IESI-BFC Ltd. (formerly BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 41 QA/QC: L. Warren Fred Weber) landfill more economically attractive. A disadvantage of the Lower Meramec facility is that Meramec solids are not stabilized and could not therefore qualify for Class B biosolids material cover. vi. Costs Overall anticipated costs in the intermediate-term are summarized Table 11-8 on the following page. It should be noted that these costs account for upgrades for the Coldwater and Missouri River facilities only. Costs for Bissell Point and Lemay were included in the short-term plan, and costs for the Lower Meramec plant are included in a long-term plan. Table 11-8 Present Worth Cost Table for Regional Alternative S-2 (6-10 Year Period) Alternative Regional Total System - Missouri River S-2 (Costs for Bissell Point, Lemay, Coldwater and Lower Meramec Not Included in 6-10 Year Plan) Capital Costs $203,000 Salvage Value $0 Annual O&M Costs $1,762,000 Annual Revenue $0 Present Worth Costs Capital $203,000 Salvage Value $0 O&M $21,958,000 Revenue $0 Total Present Worth Costs $22,161,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 42 QA/QC: L. Warren f. Long-Term Plan (11-20 Years) – Regional FBI Alternative Looking ten years out and assuming major upgrades and renovations have been completed, the primary challenges for the District from a solids handling perspective is anticipated to be the remaining life of the Prospect Hill landfill, and where the District stands with respect to constructing an extension to the Baumgartner Tunnel that would eliminate the Fenton and Grand Glaize plants. A summary of specific strategies for each plant is provided as follows: i. Bissell Point No major improvements are anticipated in the 11-20 year period for Bissell Point. A key constraint to Bissell Point operations though will be the viable operation of the Prospect Hill landfill, which currently has anywhere from 15-20 years of remaining life (as of 2010) assuming that a vertical expansion is undertaken and permitted. Consequently, at some point during this long-term 11-20 year phase, alternate sources of disposal and end-use should be identified and implemented. The default position is anticipated to be the IESI-BFC Ltd. (formerly Fred Weber) landfill, or the Milan landfill in Illinois. However, disposal to these sites will include additional transportation costs as well as tipping fees that will require reckoning. For the purposes of the planning it is assumed that the Prospect Hill landfill will remain viable through the 20-year planning period study; with the caveat that this alternative will be rapidly approaching the end of its useful life and thus new sources should be identified. If a viable alternative for cement manufacturer use of the material is found, this would potentially reduce disposal to the landfill and thus extend its life indefinitely. ii. Lemay No major solids handling upgrades are anticipated for the Lemay plant in the 11-20 year period. End use and disposal issues to the Prospect Hill landfill are summarized above under the Bissell Point plant. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 43 QA/QC: L. Warren iii. Coldwater No major solids handling upgrades are anticipated for the Coldwater plant in the 11-20 year period, assuming that a parallel sludge force main was constructed during the 0-10 year period. iv. Missouri River No major solids handling upgrades are anticipated for the Missouri River plant in the 11-20 year period, assuming that a FOG receiving station was constructed during the 0-10 year period. v. Lower Meramec Assuming that the Baumgartner Tunnel is extended during this period to eliminate the Fenton and Grand Glaize plants, upgrades to the Lower Meramec facility are anticipated to accommodate the additional solids loads to the plant. These upgrades also include anaerobic digestion facilities in conjunction with thickening and dewatering upgrades. vi. Costs Overall anticipated costs in the long-term are summarized in the following table: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 44 QA/QC: L. Warren Table 11-9 Present Worth Cost Table for Regional Alternative S-2 (11-20 Year Period) Alternative Regional Total System - Lower Meramec S-2 (Costs for Bissell Point, Lemay, Coldwater and Missouri River Not Included in 11-20 Year Plan) Capital Costs $3,215,000 Salvage Value ($367,000) Annual O&M Costs $895,000 Annual Revenue $0 Present Worth Costs Capital $3,215,000 Salvage Value ($138,000) O&M $11,154,000 Revenue $0 Total Present Worth Costs $14,231,000 g. Triggers for Change There are a number of issues that will need to be diligently considered before final decisions are made, as well as a number of assumptions that are being considered today that will ultimately undergo significant revision. Developing a feasible strategy requires consideration of these triggers, their impact on both long-term and short-term planning strategies, and a plan for mitigating and resolving them. The following table outlines a number of the issues that may impact the District’s Solids Master Plan, the impact of those issues, and a general strategy for addressing them. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 45 QA/QC: L. Warren Table 11-10 Consideration of Triggers that Modify Solids Master Plan Triggers for Change Issue Impact Mitigation Response MACT rules implemented as currently proposed; with MHI investment feasibility extremely limited. Investments in MHIs likely not economically justifiable given that MHIs will be replaced in 5-7 years. Implement both short and long- term strategy for replacing the MHIs at Bissell Point and Lemay with new FBIs at a regional facility. MACT Rules relaxed and/or the threshold of 50% investment in modifications / reconstruction has a much narrower interpretation that allows for MSD investment in MHIs without crossing the threshold. Investment in FBIs potentially delayed as modest investments in MHIs potentially extend their remaining viable life (i.e., capable of meeting regulatory air emission limits and also functional and structurally sound). Invest in MHI upgrades as needed to maintain their functional life. Prospect Hill landfill vertical expansion cannot be approved or permitted. Significant, as likely remaining life of the landfill is approximately 5-7 years, and alternative sources of disposal would need to be identified. Develop alternatives for re-use with cement companies. Landfill disposal or development of partnership agreements with IESI-BFC Ltd. (formerly Fred Weber) landfill. Consider partnership agreement with Milan landfill. Economic incentives for renewable energy credits increase significantly. Attractiveness and economic justification for energy recovery partnerships with third parties increases. Continued dialogue with Trigen on the construction of a steam line to Trigen's plant on Laclede's Landing with the sale of wholesale steam. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 46 QA/QC: L. Warren Table 11-10 Consideration of Triggers that Modify Solids Master Plan Triggers for Change Issue Impact Mitigation Response Continued dialogue with third party partners such as Ameren UE. If incentives are great enough, could consider heat drying at the Lower Meramec plant - if a partnership with Ameren UE is developed to use the dried biosolids as an alternative fuel source at one of its power plants. Possible third-party investments in energy from FOG facilities located at the Missouri River plant may also be attractive. Land application rules are modified with greater limitations on feasibility of a Class B land- application program. No immediate impact anticipated as MSD does not operate a land- application program; but long- term alternatives to landfill disposal would become more limited. MSD does not currently operate a land-application program; but this would reduce available options for disposal and make alternatives such as beneficial reuse with cement companies much more valuable. Markets emerge for ash material locally as part of land reclamation / Brownfield sites. Has the potential to extend life of the Prospect Hill landfill site. MSD would need to weigh cost of transporting material to site versus the cost of hauling to Prospect Hill landfill and compare that cost with the landfill costs that may be required when Prospect Hill is closed (i.e., assessing the value on an annual basis for extending the life of the Prospect Hill site). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 47 QA/QC: L. Warren h. Delivery Methods There are a number of construction methods that could be used for any of the projects identified in this Solids Master Plan, each with its own potential advantages in construction scheduling and/or cost savings to the project. Currently, the District is considering a change to its current charter that would provide the opportunity to undertake projects on a design-build (D/B) or construction- management-at-risk (CMR) basis. Until the charter has actually been changed and approved, the District is limited to the traditional design-bid-build alternative for project delivery. The following briefly summarizes some of the advantages and disadvantages for each. i. Traditional Design–Bid–Build The District is very familiar with the design-bid-build (D/B/B) method of project delivery. This process allows the District to fully engage in the design process with the selected design consultant to develop a project that meets the technical and operational requirements of the project. Because this process moves sequentially through each of the major phases (i.e., design, bid, and build), this delivery methods takes longer than other project delivery methods. However, it also provides the most assurance that equipment and material selection is consistent with District preferences, that the constructed facilities meet the overall goals and objectives of the project, and that District operational staff can readily operate the new systems with very little difficulty. ii. Design-Build The design-build (D/B) methodology can be implemented through either be a contractor-led or engineer-led program. In either case, a contractor and engineer form a single team as part of the design and construction process. This methodology typically includes a 20-30% preliminary design that is used as the basis for soliciting cost proposals for the project. This methodology offers scheduling advantages since a number of phases can be completed simultaneously. Also, since the general contractor is on board from the outset, specific elements of BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 48 QA/QC: L. Warren the design can be tailored selectively to the preferred construction skill-set of the general contractor; thus reducing the overall cost. A primary disadvantage of this methodology is that a cost for the project is established at a very early completion stage of the design (20-30%), and as such there many elements of the project that are yet to be defined. The District would have less control over the quality of the materials and equipment used for construction with this method, which places more emphasis on cost and schedule reduction. Consequently, although cost-savings are often realized at the outset, these costs are sometimes later offset by the additional operation, maintenance, and replacement costs that are incurred. iii. Construction Management at Risk The construction management at risk (CMR) process is a hybrid of the traditional processes described previously, and can be implemented in a number of ways. However, it typically involves the selection of an engineer to develop a preliminary design (typically to the 20-30% level), from which these documents are used to solicit proposals from CMR firms that provide a non-guaranteed price for the construction (based on the preliminary design) as well as a description for the means and methods that they intend to undertake to complete the project. Once a CMR firm has been selected, they work with the Owner and Engineer as partners to develop the plans to some subsequent completion level (typically 60%) from which the CMR firm will establish a target at-risk price. The CMR may or may not also act as a general contractor to self-perform some of the work. Once a target price has been established, the design engineer completes the contract documents to 100% completion. The target cost can be adjusted for additions and/or unforeseen conditions, but is not adjusted for cost variations between the anticipated and actual costs for the project. Thus, the CMR firm is at-risk financially. The owner can also elect to engage the CMR firm in “pain-gain” sharing in which the two entities split project cost savings (where a project is completed for under the target cost) or absorb cost over-runs (where a project is completed for greater than the target cost). BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 49 QA/QC: L. Warren Advantages of this method include reducing the overall project schedule similar to the D/B process, as well as potential cost savings associated with a contractor-specific design. This process also allows for greater Owner engagement in the design process at a much later stage than a D/B process, but not as much as a traditional D/B/B process, which can provide greater assurance that materials and equipment meet overall owner and operator objectives for quality and reliability. Disadvantages of this method primarily reside with the owner assuming some risk that unforeseen conditions and issues could arise prior to the completion of the project design that result in cost over-runs. This method typically requires the most time from the owner’s staff related to oversight of design details and the management of a guaranteed maximum price (GMP) budget. 3. Communication Plan As part of the technical assessment of MSD’s solids handling process, Vector Communications was retained to evaluate and consider public perception regarding biosolids and the solids handling processes being proposed. In the summer of 2009 and 2010, a total of five focus groups were conducted. In 2009, the primary focus was to ascertain the public’s general knowledge about biosolids and the solids handling process and to ascertain their social, economic and environmental values pertaining to the proposed improvements. In 2010, with more detailed knowledge about possible recommendations for MSD’s Bissell and Lemay plants, the focus groups discussed how the recommendations could impact them more specifically. From the focus groups, it was determined that: • The public has very little knowledge or understanding about the solids handling process. • Solids handling options most favored are those that keep rates affordable and protect the environment from additional harm. • Costs and environmental sustainability are the most critical factors for evaluating sewer infrastructure improvements. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 50 QA/QC: L. Warren • The public is unaware of most issues, such as regulatory compliance, aging infrastructure, that are facing MSD; and they want to know more about how MSD’s compliance and regulatory issues will impact future rate increases. • While most people don’t know what the term biosolids means, they view it in a positive light. • Sludge, an alternative term for biosolids, was viewed negatively by almost all focus group participants. • Most people view incineration ambivalently. From the responses of five focus groups, the term received positive, negative and indifferent reactions. As MSD moves forward with the recommended improvements, a communications plan for conveying key information to the public and soliciting public support should be considered to: 1) generate greater awareness about the issues that it is addressing environmentally; 2) demonstrate that it is an efficient steward of public funding; and 3) inform the public about its sewer improvement efforts and how those efforts can benefit the entire region. Specifically with biosolids and the solids handling process, the major target audiences are those residents and stakeholders who may be impacted because of their proximity to the Bissell and Lemay plants. Additionally, the general public should be informed about MSD’s vision to become an environmental leader in sewer improvements. a. Marketing Strategy During the Clean Rivers Healthy Communities Program, MSD’s Long-term Control Plan (LTCP) for reducing combined sewer overflows, the District adopted the tagline, “Protecting the Environment through Sewer Improvements.” Given that recommendations for solids handling are geared toward environmental protection and cost efficiencies, it is recommended that the solids handling upgrades be incorporated under that tagline. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 51 QA/QC: L. Warren b. Marketing Methods There are several types of marketing methods that MSD should use to increase public awareness, knowledge and understanding about the solids handling recommendations, as well as to demonstrate how this enhances MSD’s position as an environmental leader. To reach both the community at-large and the target audiences, MSD could consider a combination of direct and indirect connection mechanisms. Direct connections utilize person-to-person interfaces, such as meetings, presentations and events to engage audience members. Indirect connections employ communications channels like radio, print media, direct mail and email to achieve broad audience exposure. Most traditional communications campaigns rely heavily on indirect connections. However, this approach has limited effectiveness when the goal is to induce not only changes in audience awareness, but also changes in audience behavior. c. General Awareness Tactics MSD has created several videos about its operations and Vector believes that a video that details the current solids handling process and compares it to future improvements will help residents to understand MSD’s decision to invest in fluidized bed incinerators. This video should be no longer than 5 to 6 minutes and it should speak to the public’s values of cost efficiency and environmental stewardship. MSD should also develop an organizational fact sheet, which details (in laymen’s terms) its sewer investments over the past five to ten years and how those investments have positively impacted rate payers from an environmental standpoint. d. Organizational Briefings As seen during the LTCP process, it is assumed that most residents will not attend a MSD meeting unless there is a problem with basement back-ups, street flooding and/or rate increases. Therefore, MSD should consider outreach programs such as attending planned ward and organizational meetings. Typically, a five to ten minute presentation is all that is required, but this person-to-person BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Phasing and Implementation of Selected Alternatives December 10, 2010 MSD Contract No. 2009145 Updated June 16, 2011 B&V File 44.000 52 QA/QC: L. Warren contact positions MSD more firmly as a transparent and engaging neighbor. One recommended plan to consider at such a meeting would be to present a short video, along with distributing a brochure, following by a question and answer session. 53 QA/QC: L. Warren Attachment 1 MSD Comments on EPA SSI MACT Rule Metropolitan St. Louis Sewer District 2300 Market Street St. Louis, Missouri 63103 Phone: (314) 768-6200 Metropolitan St. Louis Sewer District Page 1 November 29, 2010 EPA Docket Center (EPA/DC) Environmental Protection Agency Mailcode 6102T 1200 Pennsylvania Ave., NW. Washington DC 20460 Attn: Docket ID No. EPA-HQ-OAR-2009-0559 Dear Madam or Sir: The Metropolitan St. Louis Sewer District (MSD) appreciates this opportunity to provide comments on the United States Environmental Protection Agency’s (EPA) proposed rule titled “40 CFR Part 60 Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Sewage Sludge Incineration Units; Proposed Rule” published on October 14, 2010. MSD serves a population of approximately 1.4 million and has approximately 519,000 single-family residential, multi-family residential and commercial/industrial accounts. MSD treats over 330 million gallons per day (mgd) of wastewater and operates seven wastewater treatment facilities. At our two largest facilities (Bissell Point and Lemay), we operate ten sewage sludge incinerators (SSI). This represents approximately 5% of the SSI’s that are impacted by this proposed rule. All of our incinerators are the multiple hearth furnace (MHF) type, and have been successfully operated for over 40 years in compliance with all EPA environmental rules and regulations. EPA’s proposed standards for this rule will have a profound impact on MSD’s operations and our ability to provide reliable and yet cost-effective service to our customers in the future. Although EPA’s proposed rule is well-intentioned, the EPA’s assessment of the overall impact of this rule from both a cost and benefit perspective is fundamentally flawed and in fact results in the opposite outcome from which it is intended to accomplish MSD is in a very unique position to be able to accurately assess the validity of the data used for our plants in developing this rule; having recently undertaken a broad planning effort to assess our solids handling and stabilization systems in order to develop a comprehensive plan for solids processing for the next 20 year period. EPA is accepting comments from the public on this rule until November 29, 2010; following a public hearing that was conducted on October 29, 2010 in Research Triangle, North Carolina. To emphasize the level of concern that MSD has with regards to this currently proposed rule, we sent our Director of Operations Jon Sprague to the hearing to testify on our behalf. EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 2 First of all, MSD still firmly contends that the regulation of SSI’s should fall under Section 112 of the Clean Air Act and not regulated as a solid waste incinerator under Section 129, which is the basis for this rule. With that said, we believe that this rule (as currently structured) will result in negative environmental, economic, and social consequences on those utilities that are affected. MSD hereby offers the following comments: 1. Mercury Emissions over-estimated Mercury emissions for MSD are significantly over-stated, and by natural extension, the level of anticipated reduction in Hg emissions from MSD is over-estimated. Based on stack emission testing completed by MSD over the last five years at our Bissell Point plant, Hg emissions are on the order of 55 lb/year. The ERG memorandum titled Estimation of Baseline Emissions from Existing Sewage Sludge Incineration Units dated June 2010 estimates MSD’s overall Hg emissions from all incineration units at 316 lb/year (per Attachment B of the ERG memo). Supporting data and calculations are included in Attachment 1 of this letter. 2. Total Emissions over-estimated Emission pollutant discharges are based on an assumed rate of production of 4,200 hours per year; which for MSD’s ten incinerators means that ERG has based its pollutant load contribution from MSD on 42,000 hours of operation per year. MSD’s current incinerator operations approach approximately 26,000 hours per year. Consequently, ERG’s estimates of pollutant contributions are over-estimated by approximately 62%. 3. Emissions compliance costs under-estimated The ERG memo indicates that emission controls for MSD are not needed, and further makes the assumption (reference section 3.1) that “most SSI’s are expected to have adequate space for an emission control system.” Both assumptions are erroneous. The Solids Handling Master Plan included an evaluation of continued operation of the existing MHI’s for 20+ years. The study identified $54M as the total cost to design, build facilities and place in service the advanced emission control equipment to meet proposed limits for “existing MHF’s.” Supporting data for these costs are provided in Attachment 2 of this letter. Two issues that significantly affect the cost are: • The ERG Memo assumes mercury removal can be achieved with the addition of an activated carbon injection system to the exhaust gas stream. In actuality, there is a limited temperature range required (300 to 400 degrees F) for effective mercury removal, which means that the normal incinerator exhaust gas exit temperature of 1300 °F must be cooled with a waste heat boiler and heat exchanger, or with a very tightly controlled quencher – prior to injection Then, activated carbon can be added within a carbon injection tower followed by a fabric filter. EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 3 • To construct the proposed emissions control systems would require the construction of new buildings and also major modifications to the operation of the existing MHI’s. MSD incinerators are located in buildings that do not have sufficient space for the new equipment. Nor is there sufficient space around the buildings for additions. 4. Section 60.4775 – Modification and Reconstruction Under Section 60.4775 of EPA’s regulation a SSI is a “new” unit if it commenced with a modification six months after the date of publication of the rule (October 14, 2010); and then further defines “modification” as a change to an SSI unit that meets one of two criteria: • The cumulative cost of the changes over the life of the unit exceeds 50 percent of the original cost of the building and installing the SSI unit (not including the cost of land) updated to current costs (current dollars). • Any physical change in the SSI unit or change in the method of operating it that increases the amount of any air pollutant emitted for which section 129 or section 111 of the Clean Air Act has established standards. We estimate the 50%-of-original-cost for MSD’s incinerators at about $2.5M per incinerator or about $25M for all ten incinerators. Reference Attachment 3 of this letter for a summary of how this cost was derived. The Solids Handling Master Plan stated that continued long-term operation of the existing MHI’s would require $122M in modifications for the incinerators alone (independent of advanced emission control equipment), To accommodate new advanced emission control equipment, an additional cost of $54M would be required. Attachment 2 of this letter provides a summary of these costs. Even if advanced emission controls are not counted towards the 50% threshold, our currently identified costs for needed improvements ($122M) exceeds the threshold amount ($25M) by nearly 500%; thus re-classifying them as “new SSI’s” and rendering them obsolete because they will not be able to meet the stricter “new incinerator” requirements. We therefore request that EPA clarify the definition of modification to mean greater than 50% of the cost of a new or replacement SSI fluidized bed unit, in today’s dollars. 5. Part IV.E. Rationale for Performance Testing and Monitoring Requirements Under the second paragraph on page 63281 (following Table 11), the proposed rule states that EPA “would require repeat performance tests and updates to the monitoring plan if any of the following process changes occur… (3) an increase in the allowable wastewater received from an industrial source to the wastewater treatment facility.” MSD monitors approximately 1,500 industries, and over 200 have individual discharge permits. Industries routinely modify their processes with negligible impact on treatment plant operations or regulatory compliance. Furthermore, we currently administer an industrial pre- treatment program in which pollutant loads are monitored on a routine basis and therefore EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 4 has the capacity to assess whether substantial changes to a particular industry’s wastewater contribution warrants additional performance tests and monitoring plan updates. Incinerators are more influenced by pollutant loads rather than flows We feel MSD’s pretreatment and monitoring program requirements provide an adequate safeguard against potential compliance issues. We therefore request that Item 3 of this provision be deleted. 6. Section 60.4870 – Operating Limits Under the new rule, MSD will be required to meet a large number of performance criteria which we feel is unrealistic considering our operations. We wish to highlight two of these requirements: a. Section 60.4870(j) provides that “maximum sludge feed rate, calculated at 110 percent of average...” b. Section 60.4870(k) provides that “Sludge moisture content… must be no less than 10 percent less than and no more than 10 percent greater than average…” At MSD’s Bissell Plant, sludge cake varies in solids content from the low 20’s to over 50% depending on the variability of the volatile solids content. The weather plays a dramatic role in plant influent flow, with extended dry-weather flows under 100 mgd to wet-weather flows over 200 mgd. The proposed tolerances on sludge volumes and material characteristics are not viable in real-world plant operations. MSD agrees that a consistent feed is necessary to maintaining stable operations. However, solids loads to the incinerators are contingent upon variables that MSD has no control over; such as wet weather issues. Emission limits can be maintained under all conditions; even when significant changes to the feed rate have occurred. Therefore, MSD requests that these stipulations be removed from the rule language. 7. Landfilling sludge – multiple issues: Disposal Costs and Quantities The ERG memo titled “Cost and Emission Reduction of the MACT Floor Level of Control” dated June 2010 significantly under-estimates the alternative cost for disposing solids in a landfill; even while simultaneously over-estimating the level of solids production at the facilities compared directly to actual solids production. These solids production and cost estimates differences are summarized in the calculations at the end of this document. As shown, ERG estimates MSD’s solids production at 84,480 dry tons per year, while our actual production is approximately 53,655 dry tons per year (5-year average); an over-estimate of 58%. Simultaneously, ERG under-estimates the actual cost for landfill disposal at $3.7M (for both plants) when the actual landfill disposal cost would approach $9.3M. Consequently, landfill hauling costs are under-estimated by a factor of 2.5. Note that MSD EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 5 estimated landfill costs are based on actual hauling and disposal rates and have not been inflated to account for potential future cost increases associated with having to procure multiple sources of disposal. While it’s understandable that ERG did not account for MSD’s actual solids production rate and based their estimate upon our incinerator capacity; the basis for their error in under-estimating landfill disposal costs appears to be a fundamental misunderstanding of the physical properties of the material itself; specifically, that cake material is hauled to a landfill at a solids concentration of approximately 25% (with the remaining 75% consisting of water). As a result, the actual wet weight of the sludge for disposal is approximately four times the estimate in ERG’s memo, which leads to their under-estimation of overall landfill disposal costs. Calculations and corresponding data on this issue are included in Attachment 4. Construction of Sludge Load-out Facilities The memo significantly under-estimates the capital cost associated with constructing load-out and odor control facilities for a landfill disposal operation. Realistically implementing a landfill disposal option would entail the construction of truck-loading facilities, and odor control systems that would have to treat odors emanating from raw sludge cake; which are generally the most challenging odors (requiring the most extensive treatment) in the entire wastewater treatment process. Sustainability and Social Impact of Increased Sludge Hauling to Landfill The ERG memo fails to consider the negative social impact of a hauling and landfill alternative to incineration. MSD currently sends approximately 15% of its solids to a landfill and occasionally receives complaints regarding odors emanating from tractor trailers hauling the material. . Additionally the landfill owner and operations staffs have expressed resistance at accepting even this amount of sludge due to odor issues and other concerns. With landfill, the number of trucks would be six times greater. This would multiply the social concerns, and it is not even realistic to contemplate that the landfill is going to be amenable to accepting six times our current volume. MSD will be forced to find multiple sources of disposal sites, some of which are located well outside our metropolitan area, requiring longer drives. Greenhouse Gases – Landfills Perform Poorly The memo fails to consider the negative environmental consequences for hauling solids to a landfill as opposed to stabilizing the solids through the incineration process and then disposing of the ash material. The Solids Handling Master Plan evaluated greenhouse gas (GHG) for the various alternatives considered using Intergovernmental Panel on Climate Control (IPCC) and Local Governmental Operations Protocol (LGOP) guidelines. As shown in the table below, greenhouse gas production for a landfill option will be 4 times greater than for MHF incineration, and 9 times greater than for FB incineration. This is in large part due to the fact that greenhouse gas emissions from hauling are significantly greater due to the volume increase, as well as the fact that methane release from cake solids applied to a landfill has 21 EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 6 times the greenhouse gas forming potential of carbon dioxide. Consequently, as noted from the following table, greenhouse gas emissions are significantly greater for the landfill option. Greenhouse Gas (GHG) Emissions for Incineration/Landfill Options For MSD’s Two Large Treatment Facilities (emissions per plant) Alternative GHG Emissions (tonne/yr) Multiple hearth incineration 7,300 Fluidized bed incineration 3,000 Landfill 27,000 In closing, MSD requests that the EPA not rush these types of rules. It is essential to take more time to understand the implications of setting mercury limits below the MACT limits, utilities alternates, the true costs for utilities and the time allowed for compliance. These standards are significant and will change the disposal methods used by many utilities. The expedited approach EPA is using to develop these standards are detrimental to creating a well reasoned regulation. The agency needs to thoroughly consider the impact of these changes on utilities, communities and the environment. Failing to do so will result in higher costs and unintended social and environmental impacts. Respectfully submitted, Jeff Theerman, P.E. Executive Director CC: Ms. Amy Hambrick Natural Resource and Commerce Group Sector Policies and Programs Division (E143-03) Environmental Protection Agency Research Triangle Park, North Carolina 27711 EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 7 Attachment 1 Bissell Point WWTP Sludge Feed Rate Mercury Gas Flow HG Proposed Incinerator Stack Test Date dt/hr g/24 hrs dscfh mg/dscm MACT 2 Feb-07 3.43 49.3 1113914 0.0651 0.02 3 Nov-06 3.2 25.3 1138517 0.0327 0.02 4 Nov-06 3.2 18.5 945030 0.0288 0.02 5 Feb-07 2.43 45.6 1178914 0.0569 0.02 6 May-04 3.53 N/D 1261448 N/D 0.02 Average 3.065 34.675 N/D - non detectable Mercury data is an average of the 3 test runs dscfh - dry standard cubic feet per hour, average of 3 test runs stack test data is adjusted to 7% O2 Calculations: Actual Hg Emitted by MSD (based on stack testing) Hg Production: g/dt 0.471384 MSD Sludge Production (Bissell and Lemay) dy/year: 53000 Hg Production: lb/year 55 ERG Estimate of Hg Emitted by MSD Hg Production Per Incinerator (ton/year) 0.0158 No. of Incinerators 10 Hg Production - All Incinerators (lb/year) 316 EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 8 Attachment 2 Total MHI Upgrade Cost Estimate Alternative Bissell Pt. B-1 Lemay L-1 MHI+BFP MHI+BFP Sitework $0 $0 Steam Pipeline $0 $0 Structures $2,385,000 $225,000 Equipment $24,122,000 $10,478,000 Subtotal $26,507,000 $10,703,000 General Requirements $2,716,000 $1,098,000 Electrical Work $2,618,000 $1,070,000 Instrumentation and Control System $1,047,000 $428,000 Contingency $8,222,000 $3,325,000 Mid-Point of Construction $4,214,000 $1,704,000 Subtotal $45,324,000 $18,328,000 Advanced Emission Controls (AEC) $19,484,000 $30,535,000 Total Probable Construction Cost $64,808,000 $48,863,000 Engineering & Construction Services $11,331,000 $4,582,000 MHI Re-build (year 10) $24,145,000 $22,690,000 Total Project Cost $100,284,000 $76,135,000 Total Project Costs for both Plants $176,419,000 Total Project Cost Associated with AEC for both Plants (including Engineering) $54,058,000 Total Project Costs for both Plants for MHI Upgrades Only (Ignoring AEC) $122,361,000 EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 9 Attachment 3 Economic Assessment of Original MHI Cost in 2010 Dollars Item Summary / Total Location Lemay Project Construction of 3 - 100 dtpd MHI Units Total Project Cost at time of construction $6,016,623 Date Commissioned 5/7/1970 Years of Operation 40 Interest Rate 3% Percentage of Project Cost Associated with MHI Units (Estimated): 75% Total Project Cost in 2010 Dollars: $19,626,452 Total Cost Per Incinerator (adjusted for MHI cost only) $4,906,613 50% of the Total Cost Per Incinerator in Today's Dollars (Rounded to nearest hundred thousand) $2,500,000 EPA Docket Center (EPA/DC) Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2009-0559 November 29, 2010 Metropolitan St. Louis Sewer District Page 10 Attachment 4 ERG Solids Production Estimate (from Table 5 of memo) Production: 2.02 dtph per incinerator Operation Rate: 4200 hours per incinerator No. of Incinerators 10 Annual Solids Production Rate Estimated: 84840 dry tons per year Actual Solids Production Rate: 53655 dry tons per year Notes: Actual Solids Production Rates are from MSD’s internal data. dtph – dry tons per hour ERG Estimate of Landfill Cost (from Table 2b of memo) Lemay WWTP Solids Production 47 Dtpd Wet Cake % 28% TS Density 1,500 lb/cy Wet Tons Produced 168 Wtpd Distance to Landfill 20 Miles Haul Cost $14 Cy Tipping Fee $30 per wet ton Annual Cost $2,981,702 ERG Estimate $1,509,448 Bissell Point WWTP Solids Production 100 Dtpd Wet Cake % 28% TS Density 1,500 lb/cy Wet Tons Produced 357 Wtpd Distance to Landfill 20 Miles Haul Cost $14 Cy Tipping Fee $30 per wet ton Annual Cost $6,344,048 ERG Estimate $2,264,172 Total Annual Cost $9,325,750 Total ERG Estimate $3,773,620 Notes: dtpd – dry tons per day wtpd – wet tons per day ; cy – cubic yards 54 QA/QC: L. Warren Attachment 2 USEPA Final SSI MACT Rule Implementation MSD Solids Management Plan Phase 2 Kickoff – Meeting Minutes Date: Monday, January 11, 2010 Time: Noon – 2:00 pm Location: MSD Offices 2300 Market Street St. Louis, MO Attendees: Steve Roberts, MSD Becca Coyle, MSD Bret Berthold, MSD Todd Heller, MSD Ken Gambaro, MSD Mike Townley, MSD Neil Frankenberg, MSD Bill Ehrhard, MSD Jon Sprague*, MSD Mike Stewart, MSD Matt Bond, B&V Bently Green, B&V *Part time Meeting Minutes: • Notes: The agenda and sign-in sheet are attached to these minutes. • Ash Testing Preliminary Results: Terracon’s preliminary report on ash testing was reviewed. Preliminary findings indicate that the material is unsuitable for use as a concrete admixture due to plasticity and strength issues. TCLP tests indicate that there are no hazardous compounds in the samples, and so the material could be suitable as a soil amendment, or possibly for other uses. Terracon has follow-up tests that are to be conducted under their existing contract (such as permeability) and will follow up with a final report detailing suitability for potential uses within the next couple of weeks. Terracon’s preliminary summary raised the possibility of conducting further tests to evaluate the potential of using the material as a concrete admixture (by mixing with other materials), but this concept is not warranted given the unsuitability of the materials physical properties for this particular use. Remaining tests will focus on uses appropriate for the material. • Phase 1 Overview: Matt Bond gave an overview of the Phase 1 study, noting that the remaining work for Phase 1 included completing Technical Memo No. 1, once MSD has provided the O&M Costs for the previous three years (by plant and by solids unit process). Plant managers thought they could get the O&M cost reviewed by the end of January. This will delay B&V if not resolved by the middle of February. o TM 5 – will be revised per Jon Sprague’s direction on modifications to the POF and COF criteria and ratings. • Communications: will resume bi-weekly calls on Tuesdays at 8:00 am; put them on calendars as a placeholder. If there are weeks with nothing significant to discuss or review, we will notify everyone by the Friday before if there is a need to cancel a call. " Amendment status: Steve Roberts noted that the contract amendment scope of work dated January 6, 2010 was currently being reviewed by upper management. Steve will advise if any changes need to be made prior to the District approving. No major modifications are anticipated. " Coldwater Force Main Assessment: Steve noted that with the current scope of work, approximately $45,000 remains on the allocated budget for this project. Steve also noted that the Coldwater Force Main Physical Assessment, which is listed as optional at this time and is not anticipated to be included in the approved amendment, could very well be added to the contract at a later date. One option to be considered would be using MSD maintenance crews to self-perform a portion of the work in order to reduce cost. " Phase 2 Overview: Bently Green provided an overview of the Phase 2 scope of work and anticipated project schedule. o Incinerator Seismic Assessments Steve to provide previous reports completed on seismic condition of incinerator stacks. Options that retain the incinerator stacks will have these repair costs added. o Grease Handling Option It was noted that all private haulers deliver to Bissell Point currently. With regards to considering a receiving station at one of the county facilities, there would be no impediment from a logistical standpoint if it made sense. There was nothing inherent in the existing program that made Bissell Point the only logical location for a grease handling station. In fact, some of the private haulers would probably prefer a county location. � Premium on grease only disposal It was noted that one problem currently dealt with is the disposal of grease mixed in with other material (such as car wash waste, etc.). One option MSD may want to consider in the future would be to specify grease-only disposal to better control and treat it in the wastewater treatment process. � Quantities. Early in the analysis, B&V will confirm the grease quantities for the basis of analysis as summarized in the appendix to Phase 1 Tech Memo 2. o Coldwater Force Main assume that a parallel force main will need to be constructed, or solids dewatering added, to give necessary reliability for solids disposal. o Submittals for documents submitted to the District for review, the number and allocation is as follows: � Bissell Point 2 � Lemay 2 � Ken Gambaro 1 (sent to Coldwater) � Todd Heller 1 (sent to Grand Glaize) � Market Street Main Office 4 (all sent to Steve Roberts) � John Lodderhose and Buffy Santel copied on submittals related to regulatory issues or environmental compliance. o Schedule – will be modified once the Notice to Proceed is issued to reflect actual start date. Primary dates for submittals and completion will be incorporated into the contract schedule. o Invoicing – keep the invoicing numbering system the same as for Phase 1. o Cost Estimating Accuracy – Bill asked about the level of accuracy for the Phase 2 report cost estimates. B&V will follow up with a memo summarizing report cost estimating accuracy and key assumptions. o Implementation Plan – will need to be flexible in incorporating regulatory driven issues, such that major upgrades account for reasonable level of potential change to the regulatory structure of system operation (i.e., incinerator upgrades should account for significantly more stringent criteria in the future, or be designed such that upgrades can readily be incorporated). o Odor Issues – build in a carbon odor control treatment for dewatering analyses with dewatering of raw sludge, such as the Grand Glaize facility. o MSD Team Leader - Bill noted that Pam Huntoon was scheduled to be involved with the District’s implementation of its new software management system for the next several months. Mike Stewart will serve in her place either until the point that Pam is available, or perhaps longer. Attachments: • Meeting agenda. • Sign-in sheet. Distribution (electronically): • All attendees. • Tom Ratzki, B&V • Alan Christanell, B&V • Trish Scanlan, B&V • Jim Rowan, B&V MSD Solids Management Plan – Phase 2 Agenda for Kickoff Meeting ¾ Brief summary of Phase 1 • Updates from Ph. 1 to complete in Ph. 2 – info needed from Carole ¾ Summarize overall goals and objectives for Phase 2 ¾ Finalize contract for Phase 2 • Review version dated January 8, 2010: Agreed upon in principle / assess if any modifications need to be made to finalize. • Establish NTP as January 18, 2010 ¾ Review project administration • Project communications ¾ MSD – Steve Roberts is point-of-contact ¾ B&V – Matt Bond and Bently Green will serve as primary points of contact ¾ Resume bi-weekly teleconferences (discuss date/time) ¾ Cygnet site access and files posted • Invoicing procedure, etc. ¾ Project Workplan (to be submitted following NTP) Scope of Work Project Team • B&V Key People: ♦ Matt Bond / Bently Green / Tom Ratzki / Alan Christanell ♦ Trish Scanlan / Jim Rowan / Gary Shimp ¾ QA/QC Procedures • Teaming Partners ♦ EDSI ♦ ABNA ♦ Vector Project schedule – review Project Deliverables • Phase 2 SMP ♦ Electronic and hardcopy versions • Technical Memo on Ash Handling • Focus Group Studies Background information needed from MSD • Operations data from Carole Quality Management Plan Additional items ♦ Ash analysis – discuss Terracon preliminary assessment • Grease handling alternatives ¾ Other Issues Force Main Physical Assessment 1 BLACK & VEATCH MEETING MEMORANDUM Metropolitan St. Louis Sewer District B&V Project 165186 Comprehensive Solids Handling Master Plan – Phase 2 B&V File Phase 2 – 42.4 MSD Project 2009145 June 10, 2010 TO: Meeting Participants FROM: Alan Christanell RE: Project Workshop No. 1 – Treatment Plant alternatives Date: Wednesday, June 2, 2010 at 10:00 a.m. Location: MSD offices at 2350 Market St. ATTENDING: MSD Black & Veatch Brett Berthold Matt Bond (part time – conference call) Rebecca Coyle Alan Christanell Bill Ehrhard (part time) Bently Green Neil Frankenberg Gustavo Queiroz (conference call) Ken Gambaro Tom Ratzki Todd Heller Jim Rowan Pam Huntoon Hari Santha John Lodderhose Trish Scanlan (conference call) Steve Roberts Buffy Santel Jon Sprague (part time) Jeff Theerman (part time) Mike Townley SUMMARY COMMENTS Action Items 1. MSD will deliver their review comments on the treatment plant technical memorandums to Steve Roberts by June 16 2. Steve Roberts will deliver the MSD review comments on the treatment plant technical memorandums to B&V by June 18. 3. Decision items as part of providing review comments from MSD are discussed in the summary sections below for each treatment plant. 2 General Discussion 1. Conclusions from the Focus Group sessions completed to date are 1) residents are not worried about construction causing interruptions in their neighborhood, 2) continue incinerating since it is not causing any problems now, 3) the energy recovery of fluidized bed incinerators (FBIs) is a positive for the technology, 4) concerned that FBIs may cause loss of jobs, and 5) there are no concerns with trucking other plant’s sludge to the Bissell WWTP. 2. Items to be prepared for based on the Focus Group sessions completed to date are 1) What is the projected life of FBIs and have they worked elsewhere? 2) Will just enough energy be created for the WWTP or can it be sold? 3) Will MSD protect the jobs of multiple hearth incinerator (MHI) workers if FBIs are used? 4) Don’t complicate the message with new “politically correct” terms. 5) Focus on past success and show MSD is improving. 3. EPA is expected to issue a new rule by December 2010 that classifies POTW sludge to be incinerated as a solid waste. This would result in much stricter emission standard for wastewater treatment plant incinerators. 4. Incinerator emissions are typically based on performance tests, but can include some type of continuous monitoring as well during normal operation. 5. Generally, it is accepted that FBIs will have an easier time meeting the expected new emission standards than MHIs. In MHI, advanced emissions control is achieved by adding more components to the air handling system, but with FBIs emissions are controlled by optimizing the operational parameters (temperature etc.) 6. A FBI will have generally twice the capacity as a MHI in approximately the same footprint. 7. The capital cost for a FBI is more than that for a MHI, but the 20 year life cycle costs are approximately equal. 8. FBIs operate at 4 to 5 psi pressure (some operate in the push-pull mode at zero pressure); whereas MHIs operate at zero pressure. Consequently, it may be difficult to reuse the existing MHI shells for FBIs. 9. Typically, it takes about 2 to 3 months for repairing the refractory lining in a FBI. Have to do periodic inspections and keep up on the repairs. Bissell Point WWTP Technical Memorandum 1. Sludge quantities for this plant are based on a model run by B&V using activated sludge rather than the existing trickling filters. This is due to the expected requirements enacting nutrient removal at the plant. 2. As part of their review comments, MSD will state levels of redundancy required for reuse of existing MHIs and new FBIs. B&V analysis shows 3 MHIs or 2 FBIs required for maximum month conditions. MSD may want redundant units. 3 3. As part of the redundancy issue, MSD will consider storage on-site of dewatered sludge or a sludge loading/hauling facility. In the present configuration, there is no storage upstream from the incinerators, except the primaries. Storing solids in the primaries is not recommended. 4. If new FBI units are installed, MSD will consider a wet ash or dry ash system. 5. MSD asked how a FBI would react to changes in feed volatile solids concentration. Feed consistency is critical for optimum operation of a FBI. Variations in feed VS concentration are to be minimized as much as possible by mixing/flow equalization. 6. Need provision to weigh solids to the incinerator 7. Besides Trigen, other potential steam buyers include Proctor & Gamble and Covidien (Mallinkrodt). B&V will contact them. 8. Trigen steam demand may only be during the winter months – to be confirmed. Per MSD, Trigen was contemplating putting in a cooling loop, but not sure if the system is in place. 9. For a once-through system (condensate not returned), the water conditioning costs will be much higher than a system with condensate recycle because the conditioning chemicals are lost with the condensate. 10. Need a trained/certified boiler operator for high pressure steam. 11. The approximate size of a single FBI layout is 200’ x 65’. 12. Locating the new Solids Processing Building (with FBIs) near the Sligo building as shown in the technical memorandum is too far from the existing facilities. The preferred location is in the open area just west of the ash lagoons adjacent to the existing Administration Building. Two sludge tanks in this area are no longer used and can be removed. Note: Follow-up discussions with MSD also suggested merit in locating the new solids facilities to the east of the existing solids building. 13. If the new Solids Processing Building can be located adjacent to the existing Administration Building, new centrifuges can be located where the out-of-service gravity belt thickeners are now located. Lemay WWTP Technical Memorandum 1. As part of their review comments, MSD will state levels of redundancy required for reuse of existing MHIs and new FBIs. B&V analysis shows 2 MHIs or 1 FBI required for maximum month conditions. MSD may want redundant units. 2. MSD stated they would prefer 2-70 ton/day FBI units rather than 1-100 ton/day FBI unit. 3. As part of the redundancy issue, MSD will consider storage on-site of dewatered sludge or a sludge loading/hauling facility. 4. If new FBI units are installed, MSD will consider a wet ash or dry ash system. 4 5. A potential steam buyer is Rockwood Pigment. B&V will contact them. 6. The new Solids Processing Building (with FBIs) should be located as close as possible to the existing Incinerator and Filter Building. 7. Need provision to weigh solids feed to the incinerator 8. Need a trained/certified boiler operator for high pressure steam. 9. For the regional option, will also consider transporting solids to the Bissell site by rail car and by developing a pumping / force main alternative that would extend to a dropshaft location in the Bissell collection system (somewhere south of AB facilities). Coldwater WWTP Technical Memorandum 1. The solids quantities numbers may be too low. B&V will review. Note: One primary difference is that projections are based on future loadings, and during Phase 1 it was decided that the Coldwater system is built-out while the Mo River system has room for growth. 2. For this memorandum, a 50/50 split was assumed for WAS/RAS. MSD will provide better information for the split between WAS and RAS. 3. Alternative No. 1 will include a parallel force main for pumping sludge to the Bissell collection system as well as new pumps. 4. Alternatives that do not include pumping sludge via a force main to the Bissell collection system will not require existing digester tanks to be used for emergency sludge storage (as currently arranged). The digester tanks will be converted back to anaerobic digesters. Missouri River WWTP Technical Memorandum 1. The existing engine generators are approximately 20 years old and in good condition - do not need to be replaced. 2. MSD will provide data to B&V on their gas sampling. 3. The proposed FOG receiving station will be located near the Solids Handling Building and access will be via the truck road for that building. Lower Meramec WWTP Technical Memorandum 1. This memorandum is based upon the Fenton WWTP going off-line in 2015 and the Grand Glaize WWTP going off-line in 2025 with their flows being diverted to the Lower Meramec WWTP in those years. 5 2. Locations on site for proposed rotary drum thickeners and anaerobic digesters will have to be coordinated with plans being developed by HDR for disinfection and future plans for an activated sludge process. Regional Solids Processing Facility 1. Locating the new Regional Facility (with FBIs) near the Sligo building as shown in the technical memorandum is too far from the existing facilities. Also, Prairie Ave. at the north end of the Bissell Point WWTP property would not be a good road for access to the Regional Facility since it receives a lot of grain elevator traffic. The preferred location is in the open area just west of the ash lagoons adjacent to the existing Administration Building. Two sludge tanks in this area are no longer used and can be removed. 2. The new location will allow the building layout to be adjusted and possibly reduced in size. 1St. Louis MSD St. Louis MSD Comprehensive Solids Handling Comprehensive Solids Handling Master PlanMaster PlanAssessment of Selected AlternativesAssessment of Selected AlternativesPhase 2 – Workshop No. 1June 2, 2010Objectives for todayTake Phase 1 alternatives to the next level –assess feasibility / obstacles / preferences / logistics5 plants were considered in the assessmentDiscuss MHF’s vs. FBI’sRefine alternatives / confirm path for next phase (cost and implementation)Assess Public Focus Group Results for Ph. 2AgendaIntroduction – 10 minutesBrief Discussion of Selected Alternative Analysis – 5 minutesPublic Focus Group Workshop Results – 30 minutesIncineration Discussion – 40 minutesEPA Rule Interpretation Current StatusIncineration Site Visit – Minneapolis / St. PaulCurrent incineration components / issues.Working Lunch – break 10 minutesAlternatives Evaluations Detailed Discussion – 120 minutesLemayBissellMo RiverMo RiverColdwaterLower MeramecRegionalPreliminary Discussion of Phased Implementation Plan (setting stage for Workshop 2 in August). – 15 minutesWrap-up Items – 5 minutesOverviewLot’s of information to cover – broad issues as well as detailed technical informationNot enough time to cover it all - schedule pushed up a week more bl i h dproblematic than assumedIn the interest of time; will move on as needed to ensure major items are coveredAny items tabled we will come back to later, or in upcoming bi-weekly callsThese are “draft interim” TM’s – covering the technical feasibility of the selected alternatives.Cost data not incorporated at this time / will be in AugustAssess incineration issuesAssess alternatives on the county plants.Want review comments from you, during today’s discussion or later. 2Alternatives Evaluated – Bissell PointBissell Point WWTP - Solids Processing AlternativesEquipmentAlternative 1Re-use MHIsAlternative 2New FBIsCake Receiving and Handling E NDewatering Belt Filter PressesE---Dewatering Centrifuges---NDewatered Cake Equalization BinsENIncinerator Cake Feed PumpsENMultiple Hearth IncineratorsE---Fluidized Bed Incinerators---NAir Pollution Control (Wet Scrubber)ENAdvanced Air Pollution Control (Fine Particulate and Mercury Removal)---NDry Ash Handling ENLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Alternatives Evaluated - LemayLemay - Solids Processing Alternatives EquipmentAlternative 1Alternative 2 Alternative 3 Re-Use BFPs and MHIsRe-Use BFPs and New FBIsNew CFs and FBIsMHIsNew FBIsDewatering Belt Filter PressesE E ---Dewatering Centrifuges--- --- NDewatered Cake Equalization BinsEENSludge Cake Storage/Loadout--- NNIncinerator Cake Feed Pumps --- NNMultiple Hearth Incinerators E--- ---Fluidized Bed Incinerators --- NNAir Pollution Control (Wet Scrubber)ENNAdvanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling)NNNLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Alternatives Evaluated – Missouri RiverMissouri River - Solids Processing AlternativesEquipment Alternative 1Current PracticeAlternative 2Co-Digestion of FOGSolids Thickening gRotary Drum ThickenersEECo-DigestionFOG Receiving Facilities---NSolids StabilizationAnaerobic DigestionEESolids DewateringCentrifugesEECake Storage and LoadoutCake PumpsEECake Storage Silos/LoadoutEEEnergy RecoveryDigester Gas CleaningEEEngine-GeneratorsNNEngineGeneratorsNNOther Combined Heat & Power (CHP) Options--- OLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.O = Options being evaluated.Alternatives Evaluated - ColdwaterColdwater - Solids Processing Alternatives EquipmentAlt. 1 Alt. 2 Alt. 3Continue Ex. Solids MgmtLandfill of RawDewateredAnaerobic DigestionMgmt.Dewatered SolidsSolids Thickening EEEGravity Thickener (PS)EE ---Gravity Thickener (WAS)--- --- NRotary Drum Thickeners--- N NSolids StabilizationAnaerobic Digestion--- --- ESolids DewateringCentrifuges--- N NBFP’s--- N NRotary Press---NNCake Storage and Loadout--- N NPump to Bissell PointE --- ---Legend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated. 3Alternatives Evaluated – Lower MeramecLower Meramec - Solids Processing AlternativesEquipmentAlt. 1Ex. w/ DigestionAlt. 2RDT’s w/ DigestionSolids ThickeningGiThik (PS)EEGravity Thickener (PS)EEGravity Thickener (WAS) E--Rotary Drum Thickeners (WAS)--NSolids StabilizationAnaerobic DigestionNNSolids DewateringBFPsEECake Storage and LoadoutConveyors/Cake PumpsEECake Storage Silos/Loadout EEEnergy RecoveryDigester Gas CleaningNNCogeneration NNLegend:E = Existing system will be evaluated and modifications/upgrades recommendedN = Implementation of a new system will be evaluatedPublic Focus Group – Looking for Issues and ConcernsWhat do they know about biosolids processing?Does what happens inside the WWTP fence concern them?Targeted people who live and work around Lemay and Bissell.Checking if public has any pushback on continuing incineration.Is the public willing to pay more for FBI benefits?Is there something MSD might do that would be a show stopper?Focus Group DemographicsLemayTen residents, living within one to threemiles of the Lemay WWTPGender: 50% – female; and 50% –male;Ethnicity: 30% – African American; and 70% – European American; Age: 10% – 31 to 40 years of age; 20% – 41 to 50 years of age; and 70% – 50+ years of age;Household Composition: 30% – with children between the ages of one and sixteen years of age;Traveling Past WWTP:90% past the plant daily or weekly; andBiosolids Knowledge: 30% – indicated familiarity with the term biosolids.Focus Group DemographicsBissellTen residents, living within one to five miles of the Bissell WWTPGender: 60% –female; and 40% –male;Ethnicity: 100% – African American; Age: 10% – 20 to 30 years of age 20% – 31 to 40 years of age; 40% – 41 to 50 years of age; and 30% – 50+ years of age;Household Composition: 50% – with children between the ages of one and sixteen years of age;ages of one and sixteen years of age;Traveling Past WWTP:70% past the plant weekly; andBiosolids Knowledge: 20% – indicated familiarity with the term biosolids. 4Sessions InformationDefinition of termsOi fttiljtOverview of potential projects at WWTPListen to understand issues and concernsDiscuss impacts ofDiscuss impacts of construction operationsPerceived health/way of life roleTerminology we use……Is it too technical?BiosolidsSludgeIncinerationEnergy RecoveryThermal OxidationUnexpected Responses & ReactionsOver 50% don’t understand terms“Biosolids” is not much better than sludgeIncineration is often perceived as a positiveThermal oxidation is a train wreckMost don’t know what it means.“Warms things like long johns do” - good“Will cause global warming” - badPublic Perceptions about AlternativesMultiple Hearth Furnace Fluidized Bed IncinerationAdvantagesRetains jobs and maintains costs over the short-termMeets the Clean Air Act and is safe for the environment todayMore efficient with fewer moving parts and lower long-term maintenance costsEco-friendly and sustainableProvides employee cross-training opportunities.Better for the public good.DisadvantagesCostly in the long-term, both economically and possible May lead to employee displacement and/or layoffenvironmentallyCould lead to more pathogens being dispersedOnce implemented, future regulations can cause new technology to become obsolete in fewer years 5Focus Group – Key Word Perspectives345181012Lemay Focus Group – Key Word Perspectives 72659850246Biosolids Sludge Incineration Thermal OxidationEnergy RecoveryIndifferentNegative Positive11012Bissell Focus Group – Key Word Perspectives31104919264102468Biosolids Sludge Incineration Thermal OxidationEnergy RecoveryIndifferentNegative PositiveThings we learnedResidents not worried about construction disruptionContin e incineratingContinue incinerating –doesn’t hurt us now, so it should only get betterThey like energy recovery of FBIAfraid FBI will eliminate jobsNo concern if other WWTP sludge is trucked to Bissell.What we need to be prepared forWhat is the life-cycle of FBI – has it worked elsewhere?Will we sell energy or just make enough for the WWTP’s?Will MSD protect jobs of MHF workers?Don’t complicate message with new“politicallyDon t complicate message with new politically correct” terms.Focus on past success and show we are simply improving.Incineration 6Incineration DiscussionIncineration Issues have significant impact on overall study (85% of total MSD solids handling tl )currently)Current EPA rule interpretation / revision could have significant impact on future operationsPotential emission limits much titstricterAssessment based on current use of MHI’s (with modifications) versus replacement with FBI’s.Solids Production SummaryEPA Rule InterpretationImplications to POTW IncinerationUSEPA developing maximum achievable control technology (MACT) standards that will be applicable to all SSIs.Proposed in June/July. Finalized in Dec 2010.May have different MACTs for MHF and FBIsRequired regardless of size of emitterCovered in May 21, 2010 meeting / telecon with MSDSection 129 OSWI Emission LimitsContaminant Limit Units (all corrected to 7% O2)MHIFBICadmium 18 µg/dscm Carbon 40ppmdv CO emissions erratic Able to meetmonoxideppDioxins/Furans 33 Ng TCDDeq/dscmAble to meet Able to meetHCl 1 ppmdv May require chemical addition to scrubber waterMay require chemical addition to scrubber waterLead 226 µg/dscm Able to meet Able to meetMercury 74 µg/dscm May require additional scrubber. May require additional scrubber.Opacity 10 % ?? Able to meetNO (NO +103dDiffi lt t tAbl t tB&V-NOx (NO + NO2)103ppmdvDifficult to meet. ~ 4.5 lb/dt Able to meet. PM 0.013 ppmdv Able to meet Able to meetSO23.1 ppmdvMay require chemical addition to scrubber waterMay require chemical addition to scrubber waterPotential Section 129 Emission LimitsContaminant SWILimit MHILimitAFBILimitUnits (all corrected to 7% O2)Cadmium18 40 40 µg/dscm Carbon monoxide 40 500 40 ppmdv Dioxins/Furans 33Ng CDDeq/dscmHCl1ppmdvLead226µg/dscmMercury74 50 to 80 50 to 80 µg/dscmOpacity10 20 20 %B&V-24NOx (NO + NO2) 103 200B100 ppmdvPM0.013 ppmdvSO23.1PpmdvA. Based on test results of similar MHI operation.B. ~ 8 lb/dt 7Potential Future Emission ControlsB&V-Incineration Comparison –General ParametersIncineration Comparison – Project ScheduleMHI has assumed longer construction time because existing MHI’s must be kept in service during construction.Incineration Comparison Summary Costs 8Incineration ComparisonProject Cost AnalysisyMHI option assumes replaced with FBI system in 10 yearsFBI System Preferences Review (Preliminary)Based on Minneapolis – St. Paul visitCincinnati visit scheduled for AugustWill roll results into final Master Plan ReportFBI System with Comprehensive Emission Systems (Minn./St. Paul FBI Schematic)MCES Plant: 220 mgd, 110 dtpd incinerator capacity, 3 unitsFBI System Top View1 of 3 units, rated 110 dtpd eachCk Ij ti blCake Injection below 9PrimaryHeat ExchangerProvides “hot windbox” for FBI fuel use reduction (autogenous)Similar to Exhaust gasheating of CS air for Bissell incineratorsWaste Heat BoilerWaste Heat BoilerRecovers heat from exhaust gas to produce 500 psig steam for power generation and building heatingSecondary Heat ExchangerUsed to recover heat from exhaust gas to reheat exhaust gas after wet scrubbersPlume suppressionFabric FilterAsh Transporter BelowBag house used to collect particulates and carbon with Hg in exhaust gas for reduction in Hg emissionsMost ash comes out here and is collected as dry ash. Pneumatically conveyed to storage silos. Non hazardous ashp 10Ash Handling SystemPneumatic system required air injection within pipeline every 25-50 feet; to maintain flow.Operators indicated system performed well.Wet ScrubberCombination tray and fixed venturi scrubber.Takes out remaining ash, and acid gasesSame function as wet scrubbers at Bissell and LemayWet Electrostatic Precipitator – additional particulate scrubbingTurbine Generator•Uses stream from waste heat boiler•Uses stream from waste heat boiler. •Generates power in warmer months when no building heat required. •Rated for 4 MW, runs ~ 2.5 MWGeneral NotesReplaced MHF Units 8 years ago with FBI system. Drivers were -Consent decree from EPA75 odor complaints in 2004 / 0 in 2009Yellow plumePreviously provided ash to concrete companies / FBI system removes more Hg / concrete companies can’t have this; so had to stopEnergy savings $3.5-$4M per year; do not sell power back to grid.Have 3 incinerators / essentially run 2 ½. Two can’t keep up all the time; have to run third about half time.Erosion due to abrasiveness has been biggest problem. Have cut tubes twice. Particularly a problem with the boilerParticularly a problem with the boiler.Acid gas corrosion also has been problem. Can’t have enough SS.Serious corrosion issues in the Primary Heat Exchangers and Carbon Tower.Re-coated Secondary Heat Exchanger tubes / holes in it created NOV issue when clean and dirty gas co-mingled. 11Initial Conclusions– MSD Preferences11121 – if dry ash3 – if wet ash31 – Necessary component2 – Not crucial but desired component3 – Considered a luxury component11 – if Hg emission3 – if no HgSelected Alternative Tech Memo ReviewBissell PointLemayRegionalColdwaterMissouri RiverLower MeramecBISSELL POINT WWTPB&V-Solids QuantitiesParameterUnits Max. Month Ann. AverageP i S lidPrimary SolidsTotal Solidsdtpd75 62Volatile Solids% of TS59% 59%Waste Activated SolidsTotal Solidsdtpd48 24.5B&V-Volatile Solids% of TS55% 55%Combined SolidsTotal Solidsdtpd123 86.5Volatile Solids% of TS57.9% 57.4% 12Bissell Point – Existing Solids Process SchematicBissell Point – Alternative 1 Reuse Ex. MHI’sBissell Point WWTP - Solids Processing AlternativesEquipmentAlternative 1Re-use MHIsAlternative 2New FBIsCake Recei ing and HandlingENCake Receiving and Handling ENDewatering Belt Filter PressesE---Dewatering Centrifuges---NDewatered Cake Equalization BinsENIncinerator Cake Feed PumpsENMultiple Hearth IncineratorsE---Fluidized Bed Incinerators---NAir Pollution Control (Wet Scrubber)ENAdvanced Air Pollution Control (Fine Particulate and Mercury Removal)---NDAhHdliENDry Ash Handling ENLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Bissell Point – Alternative 1Bissell Point – Alternative 2 New FBI’sBissell Point WWTP - Solids Processing AlternativesEquipmentAlternative 1Re-use MHIsAlternative 2New FBIsCake Receiving and Handling ENDewatering Belt Filter PressesE---Dewatering Centrifuges---NDewatered Cake Equalization BinsENIncinerator Cake Feed PumpsENMultiple Hearth IncineratorsE---Fluidized Bed Incinerators---NAir Pollution Control (Wet Scrubber)ENAdvanced Air Pollution Control (Fine Particulate Nand Mercury Removal)---NDry Ash Handling ENLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated. 13Bissell Point – Alternative 2Bissell – FBI’s with Steam GenerationBissell – FBI’s with Power GenerationBissell – Advanced Control With Hg Emission 14Proposed BuildingLEMAY WWTPB&V-Solids QuantitiesParameterUnits Max. Month Ann. AverageP i S lidPrimary SolidsTotal Solidsdtpd 30 21Volatile Solids% of TS-- --Waste Activated SolidsTotal Solidsdtpd 64 30.1B&V-Volatile Solids% of TS-- --Combined SolidsTotal Solidsdtpd94 51.1Volatile Solids% of TS45.5% 49.6%Lemay – Existing Solids Facilities 15Lemay – Alt. 1 Reuse Existing BFP’s and MHI’sLemay - Solids Processing Alternatives EquipmentAlternative 1Alternative 2 Alternative 3 Re-Use BFPs and MHIsRe-Use BFPs and New FBIsNew CFs and FBIsMHIsNew FBIsDewatering Belt Filter PressesE E ---Dewatering Centrifuges --- --- NDewatered Cake Equalization BinsEENSludge Cake Storage/Loadout--- NNIncinerator Cake Feed Pumps--- NNMultiple Hearth IncineratorsE --- ---Fluidized Bed Incinerators --- NNAir Pollution Control (Wet Scrubber)ENNAdvanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling)NNNLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Lemay – Alternative 1Lemay – MHI’s with Power GenerationLemay – Alt. 2 Reuse Existing BFP’s w/ new FBI’sLemay - Solids Processing Alternatives EquipmentAlternative 1Alternative 2 Alternative 3 Re-Use BFPs and MHIsRe-Use BFPs and New FBIsNew CFs and FBIsMHIsNew FBIsDewatering Belt Filter PressesE E ---Dewatering Centrifuges --- --- NDewatered Cake Equalization BinsEENSludge Cake Storage/Loadout--- NNIncinerator Cake Feed Pumps--- NNMultiple Hearth IncineratorsE --- ---Fluidized Bed Incinerators --- NNAi P ll ti C t l (W tENNAir Pollution Control (Wet Scrubber)ENNAdvanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling)NNNLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated. 16Lemay – Alternative 2 Ex. BFP’s w/ new FBI’sLemay – Alt. 3 Centrifuges w/ new FBI’sLemay - Solids Processing Alternatives EquipmentAlternative 1Alternative 2 Alternative 3 Re-Use BFPs and Re-Use BFPs and New CFs and FBIsMHIs New FBIsDewatering Belt Filter PressesE E ---Dewatering Centrifuges --- --- NDewatered Cake Equalization BinsEENSludge Cake Storage/Loadout--- N NIncinerator Cake Feed Pumps--- N NMultiple Hearth IncineratorsE --- ---Fluidized Bed Incinerators---NNFluidized Bed IncineratorsNNAir Pollution Control (Wet Scrubber)ENNAdvanced Air Pollution Control (Fine Particulate and Mercury Removal with Dry Ash Handling)NNNLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Lemay – Alt. 3 New FBI & New CentrifugesLemay – FBI with Power Generation 17Lemay – Air Pollution Control with Hg ScrubbingLemay – Proposed Site PlanREGIONAL SOLIDS PROCESSING FACILITYB&V-Solids QuantitiesParameterUnits Max. Month Ann. AverageBi ll P i t & C ld tdt d12387Bissell Point & Coldwaterdtpd 12387Lemaydtpd 94 52Missouri Riverdtpd 58 47.7Lower Meramecdtpd 53.2 39.2Combined SolidsB&V-Total Solidsdtpd328.2 225Volatile Solids% of TS60.9% 63.7% 18Regional – Process Flow DiagramRegional – Solids ReceivingRegional – Fluidized Bed IncineratorRegional – FBI’s w/ Optional Steam Generation 19Regional – Advanced Pollution with Hg ScrubbingRegional – Site Plan LayoutCOLDWATER WWTPB&V-Solids QuantitiesParameterUnits Max. Month Ann. AverageP i S lidPrimary SolidsTotal Solidsdtpd 9.3 7.1Volatile Solids% of TS84% 81%Waste Activated SolidsTotal Solidsdtpd 9.3 7.1B&V-Volatile Solids% of TS78% 75%Combined SolidsTotal Solidsdtpd18.5 14.1Volatile Solids% of TS81% 78% 20Coldwater – Alt. 1 Continue Ex. Solids Mgmt.Coldwater - Solids Processing Alternatives EquipmentAlt. 1 Alt. 2 Alt. 3Continue Ex. Solids Landfill of RawAnaerobic DigestionMgmt. Dewatered SolidsgSolids Thickening EEEGravity Thickener (PS)EE ---Gravity Thickener (WAS)--- --- NRotary Drum Thickeners--- N NSolids StabilizationAnaerobic Digestion--- --- ESolids DewateringCentrifuges--- N NBFP’s---NNNNRotary Press--- N NCake Storage and Loadout--- N NPump to Bissell PointE --- ---Legend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Coldwater – Existing Solids ProcessColdwater – Alt. 2 Landfill of Raw Dewatered SolidsColdwater - Solids Processing Alternatives EquipmentAlt. 1 Alt. 2 Alt. 3Continue Ex SolidsLandfill of RawAnaerobic DigestionEquipmentEx. Solids Mgmt.RawDewatered SolidsDigestionSolids Thickening EEEGravity Thickener (PS)EE---Gravity Thickener (WAS)------NRotary Drum Thickeners---NNSolids StabilizationAnaerobic Digestion------ESolids DewateringCentrifuges---NNBFP’sNNBFP s---NNRotary Press---NNCake Storage and Loadout---NNPump to Bissell PointE------Legend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Coldwater – Alternative 2 21Coldwater – Alt. 3 Anaerobic DigestionColdwater - Solids Processing Alternatives EquipmentAlt. 1 Alt. 2 Alt. 3Continue Ex. Solids Landfill of RawAnaerobic DigestionMgmt. Dewatered SolidsgSolids Thickening EEEGravity Thickener (PS)EE---Gravity Thickener (WAS)--- ---NRotary Drum Thickeners--- NNSolids StabilizationAnaerobic Digestion--- ---ESolids DewateringCentrifuges--- NNBFP’s---NNNNRotary Press--- NNCake Storage and Loadout--- NNPump to Bissell PointE--- ---Legend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.Coldwater – Alternative 3Coldwater – Site LayoutMISSOURI RIVER WWTPB&V- 22Solids QuantitiesParameterUnits Max. Month Ann. AverageP i S lidPrimary SolidsTotal Solidsdtpd 37.1 29.1Volatile Solids% of TS80% 80%Waste Activated SolidsTotal Solidsdtpd 19.9 17.8B&V-Volatile Solids% of TS80% 80%Combined SolidsTotal Solidsdtpd57 46.9Volatile Solids% of TS80% 80%Missouri River – Alt. 1 Current PracticeMissouri River - Solids Processing AlternativesEquipment Alternative 1Current PracticeAlternative 2Co-Digestion of FOGSolids ThickeningSolids Thickening Rotary Drum ThickenersEECo-DigestionFOG Receiving Facilities---NSolids StabilizationAnaerobic DigestionEESolids DewateringCentrifugesEECake Storage and LoadoutCake PumpsEECake Storage Silos/LoadoutEEEnergy RecoveryDigester Gas CleaningEEDigester Gas CleaningEEEngine-GeneratorsNNOther Combined Heat & Power (CHP) Options---OLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.O = Options being evaluated.Missouri River – Existing Solids FacilitiesMissouri River – Alt. 2 Co-Digestion with FOGMissouri River - Solids Processing AlternativesEquipment Alternative 1Current PracticeAlternative 2Co-Digestion of gFOGSolids Thickening Rotary Drum ThickenersEECo-DigestionFOG Receiving Facilities---NSolids StabilizationAnaerobic DigestionEESolids DewateringCentrifugesEECake Storage and LoadoutCake PumpsEECake Storage Silos/LoadoutEEEnergy RecoveryDigester Gas CleaningEEEngine-GeneratorsNNOther Combined Heat & Power (CHP) Options---OLegend:E = Existing system will be evaluated and modifications/upgrades recommended.N = The implementation of a new system will be evaluated.O = Options being evaluated. 23Co-Digestion of FOGLOWER MERAMEC WWTPB&V-Solids QuantitiesFlow ConditionTotal Solids (ppd)Volatile Solids (ppd)Flow (gpd)2030 D i C diti2030 Design ConditionsMaximum Month106,400 79,700 1,913,700Annual Average 39,100 28,700 703,2002015 ConditionsMaximum Month 43,700 32,600 786,000B&V-2025 ConditionsMaximum Month92,900 69,700 1,687,000Lower Meramec – Alt. 1 Anaerobic DigestionLower Meramec - Solids Processing AlternativesEquipmentAlt. 1Ex. w/ DigestionAlt. 2RDT’s w/ DigestionSolids ThickeningGravity Thickener (PS)EEGravity Thickener (PS)EEGravity Thickener (WAS) E--Rotary Drum Thickeners (WAS)--NSolids StabilizationAnaerobic DigestionNNSolids DewateringBFPsEECake Storage and LoadoutConveyors/Cake PumpsEECake Storage Silos/Loadout EEEnergy RecoveryDigester Gas CleaningNNCogeneration NNLegend:E = Existing system will be evaluated and modifications/upgrades recommendedN = Implementation of a new system will be evaluated 24Lower Meramec – Ex. Solids Processing FacilitiesLower Meramec – Co-Thickening & DigestingRaw WastewaterFrom Baumgartner PSPrimary Clarifiers(2 Total)FlareSecondary Clarifiers(2 Total)ReceivingWellDigestedSludge PumpsDigesterFeedPumps(5 Total)Sludge Gravity Thickeners(4 Total)Recycle to Primary TreatmentBelt Filter Press Dewatering(2 Total)Sludge TruckLoading Hoppers(2total)GritPrimary Sludge and Grit Pumps(3 Total)MGrit/Sludge Separators(3 Total)Thickened Sludge Pumps (3 Total)BFP Feed Pumps (2 Total)ReceivingWellDigestedSludge Pumps(5 total)DigesterFeedPumps(5 Total)Anaerobic Digesters(4 total)Blend TankDigesterGas CleaningCogenerationSecondary Sludge Pumps(3 Total)MSD LOWER MERAMEC WWTPALTERNATIVE 1CO-THICKENING AND DIGESTION165186.103-1g ADI 05/05/10(2 total)TruckLoading HopperTruck to Compost or LandfillTruck to LandfillLower Meramec – Alt. 2 Anaerobic Digestion w/ RTD’sLower Meramec - Solids Processing AlternativesEquipmentAlt. 1Ex. w/ DigestionAlt. 2RDT’s w/ DigestionSolids ThickeningGravity Thickener (PS)EEGravity Thickener (PS)EEGravity Thickener (WAS) E--Rotary Drum Thickeners (WAS)--NSolids StabilizationAnaerobic DigestionNNSolids DewateringBFPsEECake Storage and LoadoutConveyors/Cake PumpsEECake Storage Silos/Loadout EEEnergy RecoveryDigester Gas CleaningNNCogeneration NNLegend:E = Existing system will be evaluated and modifications/upgrades recommendedN = Implementation of a new system will be evaluatedLower Meramec – Separate Thickening/DigestionRaw WastewaterFrom Baumgartner PSPrimary Clarifiers(2 Total)FlareReceivingWellDigestedSludge PumpsDigesterFeedPumps(5 Total)Sludge Gravity Thickeners(2 Total)Recycle to Primary TreatmentBelt Filter Press Dewatering(2 Total)Sludge TruckLoading Hoppers(2total)GritPrimary Sludge and Grit Pumps(3 Total)MGrit/Sludge Separators(3 Total)Thickened Sludge Pumps (3 Total)BFP Feed Pumps (2 Total)ReceivingWellDigestedSludge Pumps(5 total)DigesterFeedPumps(5 Total)Anaerobic Digesters(4 total)Blend TankDigesterGas CleaningCogenerationMSD LOWER MERAMEC WWTPALTERNATIVE 2SEPARATE THICKENING AND DIGESTION165186.103-1h ADI 05/05/10(2 total)TruckLoading HopperTruck to Compost or LandfillTruck to LandfillTWASRotaryDrum ThickenerTWASPumpsWASRotaryDrum Thickener(4 total)TWASPumps(4 Total)RDT Feed Pumps(4 total) 25QuestionsResults and Conclusions / Next StepsConfirmation of current pathReview today’s discussion / any modifications?Develop cost estimating and phased implementation planComments requested by Friday June 10Comments requested by Friday, June 10.Next meeting set for mid to late August – following Cincinnati visit.Other wrap-up items?MSD Operation Cost Data SummaryParameterUnitCostPowerkWh$0.070Natural GasmmBtu$3.53Labor (Operations/Maintenance) hour$40Polymerlb$2.50Equipment MaintenancePercent of equipment2%Equipment MaintenancePercent of equipment cost2 %Hauling to Composting Site wet ton$3.00Disposal at Composting Site wet ton$15.25 MSD Comprehensive Solids Handling Master Plan Phase 2 Workshop No. 2 – MSD Offices on Market Street Friday, September 10, 2010, 10 a.m. to 2:00 p.m. Date of Issuance: September 20, 2010 Objectives: 1. Review updates to TM’s 1 through 6 for each of the treatment facilities 2. Review TM 7 for GHG Emissions 3. Review TM 8 for Air Emission Requirements 4. Review TM 9 for Overall Cost Data 5. Review TM 10 for Alternative Evaluation and Selection and get consensus on path forward 6. Assess Public Focus Group portion and discuss path forward for additional studies. Attendees: 1. Jon Sprague, MSD 2. Rich Unverferth, MSD 3. Ken Gambaro, MSD 4. Todd Heller, MSD 5. Becca Coyle, MSD 6. Steve Roberts, MSD 7. Mike Townley, MSD 8. Bill Ehrhard, MSD 9. Bret Berthold, MSD 10. Brad Nevois, MSD 11. Pam Huntoon, MSD 12. John Lodderhose, MSD 13. Neil Frankenburg, MSD 14. Buffy Santel, MSD 15. Jon Berganthal, Jacobs 16. Jessica Perkins, Vector Communications 17. Jim Rowan, B&V 18. Yinan Qi, B&V 19. Trish Scanlon, B&V 20. Tom Ratzki, B&V 21. Bently Green, B&V 22. Matt Bond, B&V Agenda: • Alternative Evaluation Re-cap / Cost Evaluation Summary (TM 9) - 75 minutes o Bissell o Lemay o Coldwater o Mo River o Lower Meramec o Regional vs. De-centralized • Discussion of Additional Public Participation Considerations – 15 Working Lunch – break 15 minutes • TM 10 – Selected Alternatives Analysis – 60 minutes o TM 7 – Discussion of Air Emission Requirements / Regulatory Update o TM 8 – Discussion of GHG Impacts on Various Alternatives • Discussion of Phased Implementation Plan – 15 minutes • minutes • Wrap-up Items – 5 minutes Sign-In Sheet: Attached. Workshop Power Point: Attached. Meeting Minutes: • TM 9 o Table 9/15 – Jon Sprague flagged maintenance costs for MHI’s as higher than FBI’s. B&V to re-assess this and respond. o Review cost structure and consider “alternative maintenance” cost assessment parameter. o Consider major rehab of MHI’s at Year 5 o Green energy credits – add in at $0.02/Kw-hr o Coldwater – maintenance cost for pump station of $18k seems low (Ken G) – re-assess this cost. o Mo River – add structural costs for building expansion for engine generators  Confirm whether odor control system upgrade should be considered  Add costs for additional carbon exchange for odor control o Lower Meramec  Need to add BFP’s to the overall cost / don’t add to capital costs (included in another report) but include it in the O&M and note it in the report.  Add the alternative for continuing to haul to landfill  Note: Blend tank on TM 5 never was built. o Table 9-20 – check hauling and disposal costs; confirm if tipping fees are included in going to Bissell Point. Jon S. noted costs should be lower. B&V will re-assess. o Odor control of $3.3M for regional – provide backup of how costs were derived. o Electric costs – will go up significantly. Consider cost increase for this that exceeds rate of inflation 4% per year. o Lemay – make sure that the O&M costs for dewatering have been taken out for the Lemay Pump Option and incineration. o Modify costs for the Lemay pump option to include the force main all the way to Bissell Point (see below). • TM 10 TBL o Make modifications as noted in the workshop – assess whether major conclusion change from those discussed in workshop. o Note: Per follow-up conference call on 9-13-2010; it was noted that the Categorical Criteria for the triple bottom line analysis had been changed to 15% social, 25% environmental, and 60% economical; per final resolution in Phase 1 (reference page 64 of TM 7 in the Phase 1 Final Report). • TM 11 Phased Implementation Plan o B&V currently in process of completing. o Will assume drivers are going to necessitate upgrade to MHI’s from regulatory perspective within 5 years. • Regional Facility o Lemay Alternative Disposal Options  Railcar hauling was discussed and was eliminated based on the preliminary findings, which indicated that it was not a cost effective option for short distances.  Force main to Bissell Point – this option was discussed at length and it was concluded that the option of pumping to the Barton Drop Shaft was would not be evaluated further due to potential problems with the solids being discharged to the CSO system during wet weather events; as well as problems associated with these solids being discharged to the Bissell Point headworks and primary clarifier systems. It was ultimately decided that two routes for conveying solids by pumping from Lemay to Bissell Point were warranted: 1) routing the line through downtown on the Missouri side of the Mississippi River, and 2) conveying from Lemay to Bissell by crossing the Mississippi River at Lemay and constructing the line on the Illinois side of the Mississippi River and then re-crossing the Mississippi River to connect to the Bissell Point treatment plant. Deadline for Comments: One week from date of minutes. 1 St. Louis MSD St. Louis MSD Comprehensive Solids Handling Master PlanComprehensive Solids Handling Master Plan Alternatives Evaluation and ReviewAlternatives Evaluation and Review September 10, 2010 Agenda Alternative Evaluation Re-cap / Cost Evaluation Summary (TM 9) - 75 minutes 1.Bissell 2.Lemay2.Lemay 3.Coldwater 4.Mo River 5.Lower Meramec 6.Regional vs. De-centralized Discussion of Additional Public Participation Considerations – 15 Working Lunch – break 15 minutes TM 10 – Selected Alternatives Analysis – 60 minutes TM 7 –Discussion of Air Emission Requirements / Regulatory Update TM 8 – Discussion of GHG Impacts on Various Alternatives Discussion of Phased Implementation Plan – 15 minutes minutes Wrap-up Items – 5 minutes September 10, 2010B&V - 2 2 TM 1 – Bissell Point September 10, 2010B&V - 3 Bissell Point September 10, 2010B&V - 4 3 Bissell Point – Existing System September 10, 2010B&V - 5 Bissell Point – Alt B-1 (MHF with BFP dewatering) September 10, 2010B&V - 6 4 Bissell Point – Alt B-2 (FBI with centrifuges) September 10, 2010B&V - 7 Bissell Point – Alt B-2A (FBI with steam recovery) September 10, 2010B&V - 8 5 Trigen Steam Line September 10, 2010B&V - 9 Bissell Point – Alt B-2B (FBI with power generation) September 10, 2010B&V - 10 6 Bissell Point – Alt B-2C (Advanced emission ctrl) September 10, 2010B&V - 11 Construction Factors Used (for all plants) September 10, 2010B&V - 12 7 Unit Costs and Revenues Used (for all plants) Table 9-3 Unit Costs and Revenues Used Units Bissell Point and Regional Facility Lemay Coldwater, Missouri River, & Lower MeramecUnit Costs Power $/kWh 0.052 0.055 0.052p)Labor (includes benefits) Supervisor $/hr 35 35 35 Operator $/hr 30 30 30 Maintenance $/hr 32 32 32 Stationary Engineer $/hr 35 35 - Fuel Natural gas $/mmBtu 10 10 -Fuel oil $/gal 2 2 -Chemicals Polymer $/active lb 0.84 0.84 0.84Odor control $/lb September 10, 2010B&V - 13 $/lbDisposal Costs Hauling $/cy 13.35 13.35 13.35 Landfill tipping fee $/wt 25.6 25.6 25.6 Hauling to Regional Facility from plant $/cy na 13.35 13.35Ash lagoon cleanout $/cy 2 2 2Revenue Sources Steam production $/1000 lbs -5 -5 -5 Power production $/kWh -0.052 -0.055 -0.052 Capital Costs for Bissell Point ($1,000’s) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG B-2-C FBI+AEC Sitework $0 $200 $0 $0 $0 Steam Pipeline $0 $0 $2,074 $0 $0 Structures $2,385 $14,167 $0 $2,060 $4,817 Equipment $24,122 $59,107 $6,318 $14,514 $9,074 Subtotal $26,507 $73,274 $8,622 $16,574 $13,891 Total Probable Construction Cost $45,324 $120,071 $10,713 $23,202 $20,674 September 10, 2010B&V - 14 Engineering & Construction Services $11,331 $30,018 $2,678 $5,801 $5,169 Total Project Cost $56,655 $150,089 $13,392 $29,003 $25,843 8 O&M Costs for Bissell Point Table 9-14 Annual Costs and Revenues for Bissell Point WWTP Alternatives($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG B-2-B FBI+AEC OtiCtOperation Costs Power $830 $1,090 $27 $60 $201 Labor $2,184 $1,953 $186 $373 $198 Fuel Maintenance $1,256 $857 $195 $1,204 $0 $119 $0 $196 $0 $161 Odor control $0 $50 $0 $0 $0 Chemicals $1,234 $1,746 $25 $25 $98 Total operating costs $6,361 $6,238 $357 $653 $658 September 10, 2010B&V - 15 Hauling And Disposal $1,494 $1,494 $0 $0 ($412) Total Annual Costs $7,855 $7,732 $357 $653 $246 Revenues Steam ($0) ($0) ($588) ($0) ($0) Power generation ($0) ($0) ($0) ($349) ($0) Total Annual Revenues ($0) ($0) ($588) ($349) ($0) Present Worth Costs for Bissell Point Table 9-21 Summary of Cost Opinions for Bissell Plant Alternatives 1 ($1000) Alternative B-1 MHI+BFP B-2 FBI+CFG B-2-A FBI + ST B-2-B FBI + STG B-2-C FBI+AEC Capital Costs $56,655 $150,089 $13,392 $29,003 $25,843 Salvage Value ($518) ($3,400) ($1,106) ($494) ($1,156) Annual O&M Costs $7,855 $7,731 $357 $653 $246 Annual Revenue ($0) ($0) ($588) ($349) ($0) Present Worth Costs September 10, 2010B&V - 16 Capital $56,655 $150,089 $13,392 $29,003 $25,843 Salvage ($195) ($1,281) ($417) ($186) ($436) O&M $97,896 $96,358 $4,449 $8,138 $3,068 Revenue ($0)($0) ($7,328) ($4,355) ($0) Total Present Worth Costs $154,356 $245,166 $10,096 $32,600 $28,475 1. See Technical Memorandum No. 1 for description of alternatives. 9 Bissell Point GHG Emissions 15,000 20,000 25,000 e/year 0 5,000 10,000 , B1 B2 B2A B2B B2CTonne CO2eScope 1 Scope 2 Scope 3 September 10, 2010B&V - 17 TM 2 - Lemay September 10, 2010B&V - 18 10 TM 2 - Lemay September 10, 2010B&V - 19 Lemay – Existing System September 10, 2010B&V - 20 11 Lemay – Alt 1 (MHI with BFP dewatering) September 10, 2010B&V - 21 Lemay – Alt 1-A (MHI with power generation) September 10, 2010B&V - 22 12 Lemay – Alt 2 (FBI with BFP dewatering) September 10, 2010B&V - 23 Lemay – Alt 3 (FBI with centrifuge dewatering) September 10, 2010B&V - 24 13 Lemay- Alt 2-A and 3-A (FBI with power generation) September 10, 2010B&V - 25 Lemay- Alt 1-B, 2-B, and 3-B (Advanced Emission Controls) September 10, 2010B&V - 26 14 Lemay GHG Emissions 14,000 16,000 2,000 4,000 6,000 8,000 10,000 12,000 Tonne CO2e/year September 10, 2010B&V - 27 0 , L1 L2 L3 L1A L1B L2A L2B Scope 1 Scope 2 Scope 3 Capital Costs for Lemay ($1,000’s) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-1-B MHI +AEC L-2&3-FBI +STG L-2&3-FBI +AEC Sitework $0 $200 $200 $0 $0 $0 $0 Structures $225 $6,799 $10,927 $2,060 $5,155 $2,060 $4,144 Equipment $10,478 $39,527 $48,101 $12,987 $11,258 $10,062 $8,567 Subtotal $10,703 $46,526 $59,228 $15,047 $16,413 $12,122 $12,708 Total Probable Construction Cost $18,328 $76,878 $96,969 $23,228 $24,428 $19,379 $18,914 September 10, 2010B&V - 28 Cost Engineering & Construction Services $4,582 $19,220 $24,242 $5,807 $6,107 $4,845 $4,728 Total Project Cost $22,911 $96,098 $121,211 $29,036 $30,535 $24,223 $23,642 15 O&M Costs for Lemay Table 9- 15 Annual Costs and Revenues for WWTP Alternatives ($1000) Alternative L-1 MHI +BFP L-2 FBI +BFP L-3 FBI +CFG L-1-A MHI +STG L-1-B MHI +AEC L-2&3-A FBI +STG L-2&3-B FBI +AEC Operation Costs Power $278 $502 $738 $58 $189 $58 $189 Labor $1,491 $1,425 $1,425 $339 $198 $339 $198 Fuel Maintenance $497 $607 $205 $885 $56 $1,047 $0 $226 $0 $177 $0 $143 $0 $133 Odor Control $0 $0 $50 $0 $0 $0 $0 Chemicals $295 $294 $588 $25 $56 $25 $56 Total operating costs $3,167 $3,311 $3,904 $648 $620 $565 $576 $$$$($ )$($ ) September 10, 2010B&V - 29 Hauling And Disposal $1,009 $1,009 $1,009 $0 ($281)$0 ($281) Total Annual Costs $4,176 $4,320 $4,913 $648 $339 $565 $294 Revenues Steam ($0) ($0) ($0)($0) ($0) ($0) ($0) Power generation ($0) ($0)($0) ($180) ($0) ($182) ($0) Total Annual Revenues ($0)($0) ($0)($180) ($0) ($182) ($0) Present Worth Costs for Lemay Table 9-22 Summary of Cost Opinions for Lemay Plant Alternatives 1 ($1000) L-1 MHI L-2 FBI L-3 FBI L-1-A MHI L-1-B MHI L-2&3-A FBI L-2&3-B FBI Alternative +BFP +BFP +CFG +STG +AEC +STG +AEC Capital Costs $22,911 $96,098 $121,211 $29,036 $30,535 $24,223 $23,642 Salvage Value $0 ($1,632) ($2,622) ($494) ($1,237) ($494) ($994) Annual O&M Costs $4,176 $4,320 $4,913 $648 $339 $565 $295 Annual Revenue ($0) ($0) ($0) ($180) ($0) ($182) ($0) Present Worth Costs Capital $22,911 $96,098 $121,211 $29,036 $30,535 $24,223 $23,642 September 10, 2010B&V - 30 Salvage ($0) ($615) ($988) ($186) ($466) ($186) ($375) O&M $52,045 $53,833 $61,229 $8,076 $4,223 $7,041 $3,674 Revenue ($0) ($0) ($0) ($2,245) ($0) ($2,268) ($0) Total Present Worth Costs $74,956 $149,315 $181,452 $34,681 $34,292 $28,810 $26,941 16 TM 3 - Coldwater September 10, 2010B&V - 31 Coldwater September 10, 2010B&V - 32 17 Coldwater – C-1 (Existing System) September 10, 2010B&V - 33 Coldwater – Alt 2 (Dewatering and Landfill) September 10, 2010B&V - 34 18 Coldwater - Alt 3 (Digestion, Dewatering, Landfill, Cogen) September 10, 2010B&V - 35 Capital Costs – Coldwater ($1,000’s) Alternative Operatione to Landfillateringteringc DigestionateringteringC-1Current OC-2Raw CakeC-2-ACFG DewC-2-BRP DewatC-3AnaerobicC-3-ACFG DewC-3-BRP DewatSitework $3,361 $483 $483 $483 $572 $572 $572 Structures 0 $1,671 $1,671 $1,671 $3,243 $3,243 $3,243 Equipment $844 $6,331 $5,817 $5,525 $11,762 $11,587 $11,438 Subtotal $4,205 $8,485 $7,971 $7,679 $15,576 $15,401 $15,252 September 10, 2010B&V - 36 Total Probable Construction Cost $5,494 $13,787 $12,966 $12,499 $25,309 $25,030 $24,791 Engineering & Construction Services $1,374 $3,447 $3,242 $3,125 $6,327 $6,257 $6,198 Total Project Cost $6,868 $17,233 $16,207 $15,623 $31,636 $31,287 $30,989 19 O&M Costs for Coldwater Table 9-16 Annual Costs and Revenues for Coldwater WWTP Alternatives($1000) Alternative C-1 Current Operation C-2 Raw Cake to Landfill C-2-A CFG Dewatering C-2-B RP Dewatering C-3 Anaerobic Digestion C-3-A CFG Dewatering C-3-B RP Dewatering Operation Costs Power $62 $83 $97 $83 $223 $219 $222 Labor $37 $145 $145 $145 $431 $431 $431 Fuel $0 $0 $0 $0 $0 $0 $0 Maintenance $18 $226 $122 $119 $520 $413 $394 Chemicals $0 $81 $162 $162 $140 $239 $239 Digester Cleaning $0 $0 $0 $0 $26 $26 $26 Total Operation Costs $117 $535 $526 $509 $1 340 $1 328 $1 312 September 10, 2010B&V - 37 Total Operation Costs $117 $535 $526 $509 $1,340 $1,328 $1,312 Hauling And Disposal $0 $898 $795 $795 $741 $630 $630 Total Annual Costs $117 $1,433 $1,321 $1,304 $2,081 $1,958 $1,942 Revenues Steam $0 $0 $0 $0 $0 $0 $0 Power generation $0 $0 $0 $0 ($175) ($175) ($175) Total Annual Revenues $0 $0 $0 $0 ($175) ($175) ($175) Present Worth Costs for Coldwater Table 9-23 Summary of Cost Opinions for Coldwater Plant Alternatives 1 ($1000) C-1 Current C-2 Raw Cake C-2-A CFG C-2-B RP C-3 Anaerobic C-3-A CFG C-3-B RPAlternativeCurrent Operation to Landfill CFG Dewatering RP Dewatering Anaerobic Digestion Dewatering RP Dewatering Capital Costs $6,868 $17,233 $16,207 $15,623 $31,636 $31,287 $30,989 Salvage ($601) ($401) ($401) ($401) ($584) ($584) ($584) Annual O&M Costs $117 $1,433 $1,321 $1,304 $2,081 $1,958 $1,942 Annual Revenue $0 $0 $0 $0 ($175) ($175) ($175) Present Worth Costs September 10, 2010B&V - 38 Costs Capital $6,868 $17,233 $16,207 $15,623 $31,636 $31,287 $30,989 Salvage ($227) ($151) ($151)($151) ($220) ($220) ($220) O&M $1,458 $17,858 $16,462 $16,250 $25,938 $24,405 $24,206 Revenue $0 $0 $0 $0 ($2,177) ($2,177) ($2,177) Total Present Worth Costs $8,100 $34,940 $32,520 $31,720 $55,177 $53,300 $52,797 20 Coldwater GHG Emissions 8 000 10,000 2,000 4,000 6,000 8,000 Tonne CO2e/year September 10, 2010B&V - 39 0 C1 C2 ‐BFP C2A ‐ Cent C2B ‐RP C3 ‐BFP C3A ‐ Cent C3 ‐RP Scope 1 Scope 2 Scope 3 TM 4 – Missouri River September 10, 2010B&V - 40 21 Missouri River September 10, 2010B&V - 41 Missouri River – Alt 1 (Existing System with cogen) September 10, 2010B&V - 42 22 Missouri River – Alt 2 (Existing system with FOG, cogen) September 10, 2010B&V - 43 Missouri River GHG Emissions 4,000 1 642 -1,875 ‐2,000 0 2,000 M1 M2 Tonne CO2e/year -1,642 September 10, 2010B&V - 44 ‐6,000 ‐4,000 Scope 1 Scope 2 Scope 3 23 Capital Costs for Missouri River ($1,000’s) Alternative M-1 M-2AlternativeCurrent Operation Co-digestion with FOG Sitework $0 $60 Structures $0 $61 Equipment $1,021 $1,376 Subtotal $1,021 $1,497 Total Probable Construction Cost $1,658 $2,432 September 10, 2010B&V - 45 Engineering & Construction Services $415 $608 Total Project Cost $2,073 $3,040 O&M Costs for Missouri River Table 9-17 Annual Costs and Revenues for Missouri River WWTP Alternatives($1000) Alternative M-1 Current Operation M-2 Co-digestion with FOG Operation Costs Power $7 $12 Labor $0 $66 Fuel $0 $0 Maintenance $238 $284 Chemicals $0 $0 Total operating costs $258 $317 September 10, 2010B&V - 46 Hauling And Disposal $2,143 $2,143 Total Annual Costs $2,388 $2,505 Revenues Steam $0 $0 Power generation ($594)($695) Total Annual Revenues ($594)($695) 24 Present Worth Costs for Missouri River Table 9-24Summary of Cost Opinions for Missouri River Plant Alternatives 1 ($1000) Alternative M-1 CtOti M-2 Co-digestion with Current Operation g FOG Capital Costs $2,073 $3,040 Salvage $0 $29 Annual O&M Costs $2,388 $2,505 Annual Revenue ($594)($695) Present Worth Costs Capital $2 073 $3 040 September 10, 2010B&V - 47 Capital $2,073 $3,040 Salvage ($0) ($11) O&M $29,760 $31,218 Revenue ($7,403)($8,661) Total Present Worth Costs $24,430 $25,590 1. See Technical Memorandum No. 4for description of alternatives. TM 5 – Lower Meramec September 10, 2010B&V - 48 25 Lower Meramec September 10, 2010B&V - 49 Lower Meramec – Alt 1 (Co-thickening, digestion, cogen September 10, 2010B&V - 50 26 Lower Meramec – Alt 2 (Separate thickening, digestion, cogen) September 10, 2010B&V - 51 Capital Costs for Lower Meramec ($1,000’s) LM-1 LM-2 Alternative Co-thickening and Digestion Separate Thickening and Digestion Sitework $288 $288 Structures $12,945 $13,195 Equipment $6,766 $9,405 Subtotal $20,008 $22,887 September 10, 2010B&V - 52 Subtotal Total Probable Construction Cost $32,509 $35,776 Engineering & Construction Services $8,127 $8,944 Total Project Cost $40,637 $44,720 27 O&M Costs for Lower Meramec Table 9-18 Annual Costs and Revenues for Plant Alternatives($1000) Alternative LM-1 Co-thickening and Di ti LM-2 Separate Thickening and DigestionDigestionand Digestion Operation Costs Power $198 $167 Labor $117 $215 Fuel $0 $0 Maintenance $320 $408 Chemicals $0 $56 Digester Cleaning $85 $82 September 10, 2010B&V - 53 Total operating costs $721 $928 Hauling And Disposal $1,129 $1,129 Total Annual Costs $1,850 $2,057 Revenues Steam $0 $0 Power generation ($213)($213) Total Annual Revenues ($213)($213) Present Worth Costs for Lower Meramec Table 9-25 Summary of Cost Opinions for Lower Meramec Plant Alternatives 1 ($1000) LM-1 Co-thickening and LM-2 Separate Thickening Alternative Co thickening and Digestion Separate Thickening and Digestion Capital Costs $40,553 $44,720 Salvage Value ($5,275)($4,944) Annual O&M Costs $1,850 $2,057 Annual Revenue ($213)($213) Present Worth Costs $40 553 $44 720 September 10, 2010B&V - 54 Capital $40,553 $44,720 Salvage ($1,988) ($1,863) O&M $23,055 $25,635 Revenue ($2,654)($2,654) Total Present Worth Costs $58,966 $65,838 28 Lower Meramec GHG Emissions 1,500 796 616 500 0 500 1,000 LM1 LM2Tonne CO2e/year 796 September 10, 2010B&V - 55 ‐1,000 ‐500 Scope 1 Scope 2 Scope 3 TM 6 – Regional Facility at Bissell Point September 10, 2010B&V - 56 29 De-Centralized System Coldwater Thi k i Lower Meramec Thickening Lemay Thickening Bissell Point Thi k i MSD Decentralized Treatment System (S‐1) Solids Handling Process Flow Chart MO River Thi k i Thickening Gravity Thickening(NewEQ) Force Main to Regional Facility (New PS& FM) Thickening Gravity Thickening (New EQ & Tank) Dewatering1 BFP Thickening Gravity Thickening GBT Dewatering Centrifuge (New) Thickening Gravity ThickeningGBT Dewatering Centrifuge (New) Incineration FBI (New) Thickening RDT Thickening(New EQ) Anaerobic Digestion Dewatering Centrifuge CHP (New EQ) Incineration FBI (New) Anaerobic Digestion (New) CHP (New) September 10, 2010B&V - 57 Cake Storage and Loadout to Disposal1 (New Extra Capacity) Ash Dewatering (Ash Lagoon, upgrade to slurry system) Ash Loadout Cake Storage and Loadout to Disposal EndUse EndUse Ash Dewatering (Ash Lagoon, upgrade to slurry system) EndUse EndUse Ash Loadout Note 1Additional equipment needed but not included in the cost evaluation. Regional System (S-2) Lemay Haul Coldwater Thickening MO River Thickening Lower Meramec Thickening Lemay Thickening Bissell Point Thickening MSD Regional System (S‐2) Solids Treatment Process Flow Chart ‐Hauling Cake from Lemay g Gravity Thickening Force Main to Regional Facility (New PS & FM) g RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to RegionalFacility g Gravity Thickening (New EQ & Tanks) Dewatering1 BFP (New Add.EQ) Cake Storage and Loadout to RegionalFacility1 Thickening Gravity Thickening GBT Dewatering Centrifuge (New) Cake Storage and Loadout to RegionalFacility Thickening Gravity Thickening GBT Dewatering Centrifuge (New) September 10, 2010B&V - 58 DewateredSludge Receiving (New)Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout Note1Additional equipment needed but not included in the cost evaluation. 30 Regional System (S-3) Lemay Pump Coldwater Thickening MO River Thickening Lower Meramec Thickening Lemay Thickening Bissell Point Thickening MSD Regional System (S‐3) Solids Treatment Process Flow Chart ‐Pumping Sludge from Lemay Thickening Gravity Force Main to Regional Facility(New PS & FM) Thickening RDT Thickening Dewatering Centrifuge Cake Storage and Loadout to Ri lF ilit Thickening Gravity Thickening (New EQ & Tanks) Dewatering1 BFP (New Add.EQ) Cake Storage and Loadout to Regional l 1 Thickening Gravity Thickening GBT Thickening Gravity Thickening GBT Dewatering Centrifuge (New) Force Main to Regional Facility (New PS & FM) September 10, 2010B&V - 59 RegionalFacility Facility1 DewateredSludge Receiving (New)Incineration FBI (New) Regional Facility Ash Dewatering (New) Ash Loaddout Note1Additional equipment needed but not included in the cost evaluation. Regional Facility September 10, 2010B&V - 60 31 Lemay Force Main Option September 10, 2010B&V - 61 Capital Costs for Regional Facility Alternative R-1 FBI+CFG R-1-A FBI+ST R-1-B FBI+STG R-1-C FBI+AEC Sitework $315 $0 $0 $0 Structures $23,177 $0 $3,296 $6,304 Steam Pipeline $0 $2,304 $0 $0 Equipment $76,514 $10,868 $17,329 $14,053 Subtotal $100,006 $13,172 $20,625 $20,357 Total Probable Construction Cost $165,247 $16,482 $32,972 $30,298 September 10, 2010B&V - 62 Engineering & Construction Services $41,312 $4,121 $8,243 $7,575 Total Project Cost $206,599 $20,603 $41,215 $37,873 32 O&M Costs for Regional Facility Table 9-19 Annual Costs and Revenues for Regional Plant Alternatives ($1000) Alternative R-1 FBI+CFG R-1-A FBI + ST R-1-B FBI + STG R-1-C FBI+AECAlternativeFBI+CFG FBI + ST FBI + STG FBI+AEC Operation Costs Power $1,588 $66 $154 $346 Labor $1,953 $186 $373 $198 Fuel Maintenance $384 $1,740 $0 $220 $0 $307 $0 $239 Odor Control $3,300 $0 $0 $0 Chemicals $1,024 $30 $30 $249 Total operating costs $9 989 $502 $864 ($1 032) September 10, 2010B&V - 63 Total operating costs $9,989 $502 $864 ($1,032) Hauling And Disposal $3,659 $0 $0 ($997) Total Annual Costs $13,648 $502 $864 $35 Revenues Steam ($0) ($1,898)($0) ($0) Power generation ($0) ($0) ($1,136) ($0) Total Annual Revenues ($0) ($1,898) ($1,136) ($0) Present Worth Costs for Regional Table 9-26 Summary of Cost Opinions for Regional Facility Alternatives 1 ($1000) Alternative R-1 FBI+CFG R-1-A FBI+ST R-1-B FBI+STG R-1-C FBI+AECFBI CFG FBI ST FBI STG FBI AEC Capital Costs $206,559 $20,603 $41,215 $37,873 Salvage Value ($5,563)($1,106) ($791) ($1,513) Annual O&M Costs $13,648 $502 $864 $35 Annual Revenue ($0)($1,898) ($1,136)($0) Present Worth Costs Capital $206,559 $20,603 $41,215 $37,873 September 10, 2010B&V - 64 Salvage Value ($2,096)($417) ($298) ($570) O&M $170,087 $6,256 $10,767 $433 Revenue ($0)($23,658) ($14,153)($0) Total Present Worth Costs $374,550 $2,784 $37,531 $37,736 1. See Technical Memorandum No. 6 for description of alternatives. 33 Regional GHG Emissions 40,000 45,000 5 000 10,000 15,000 20,000 25,000 30,000 35,000 Tonne CO2e/year September 10, 2010B&V - 65 ‐5,000 0 5,000 R1 R1A R1B R1C R2 ‐Pump Scope 1 Scope 2 Scope 3 Capital Costs Regional vs. Decentralized Alternative Decentralized (No Regional) S-1 Regional Total System S-2 (Lemay Haul) Regional Total System S-3 (Lemay Pump) Sitework $4,049 $4,164 $22,974 Structures $42,135 $28,069 $28,068 Steam Pipeline $0 $0 $0 Equipment $115,840 $86,780 $89,603 Subtotal $162,024 $119,013 $140,645 General Requirements $14,870 $11,568 $13,701 Electrical Work $10,195 $8,095 $8,117 Instrumentation and Control System $4,368 $3,469 $3,478 September 10, 2010B&V - 66 Contingency $45,447 $34,644 $34,771 $23,859 $18,125 $20,574 Total Probable Construction Cost $260,763 $194,914 $221,286 Engineering & Construction Services $64,160 $48,739 $55,322 Total Project Cost $324,923 $243,653 $276,608 34 O&M Cost Regional vs. Decentralized Table 9-20 Annual Costs and Revenues for the Regional Systems ($1000) Al i Decentralized (No Regional) S 1 Regional Total System S 2(L H l) Regional Total System S 3(L P )Alternative S-1 S-2 (Lemay Haul)S-3 (Lemay Pump) Operation Costs Power $2,108 $2,039 $2,053 Labor $3,532 $2,330 $2,606 Fuel $251 $384 $384 Maintenance $1,950 $1,872 $1,986 Odor Control $100 $3,300 $3,300 Digester Cleaning $86 $0 $0 Chemicals $3,158 $2,436 $2,436 September 10, 2010B&V - 67 $,$,$, Total operating costs $11,185 $12,361 $12,765 Hauling And Disposal $5,775 $7,478 $6,504 Total Annual Costs $16,960 $19,839 $19,269 Revenues Steam ($0)($0)($0) Power generation ($807)($0)($0) Total Annual Revenues ($807)($0)($0) Present Worth Cost Regional vs. Decentralized Alternative Decentralized (No Regional) S-1 Regional Total System S-2 Regional Total System S-3 $$$Capital Costs $324,923 $243,653 $276,608 Salvage Value ($12,208)($7,832)($11,781) Annual O&M Costs $16,960 $19,839 19,269 Annual Revenue ($807)($0)($0) Present Worth Costs Capital $324,923 $243,653 $276,608 September 10, 2010B&V - 68 Capital $324,923 $243,653 $276,608 Salvage Value ($4,601) ($2,952) ($4,440) O&M $211,359 $247,238 $240,134 Revenue ($10,057)($0)($0) Total Present Worth Costs $521,624 $487,939 $512,302 35 System GHG Emissions 45,000 50,000 5 000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 Tonne CO2e/year September 10, 2010B&V - 69 0 5,000 S1 No Regional S2 S3 Pump Scope 1 Scope 2 Scope 3 Triple Bottom Line Evaluation September 10, 2010B&V - 70 36 Triple Bottom Line – Criteria Definitions An “economic” component that reflects the cash flow accounting stance of the utility (i e internal costs andaccounting stance of the utility (i.e., internal costs and revenues) A “social” component that reflects the social impacts of the utility action (e.g., minimizing nuisance impact to the local community such as truck traffic, odor, and noise from plant operations.) An “environmental” component that addresses environmental impacts of the utility actions and decision, such as reducing Green House Gas (GHG) emissions by reducing fossil fuel use and electricity purchases September 10, 2010B&V - 71 TBL Criteria September 10, 2010B&V - 72 37 Recommendations and Next Steps September 10, 2010B&V - 73 Next Steps September 10, 2010B&V - 74 38 Air Emission Requirements September 10, 2010B&V - 75 TM 7 – Air Emission Requirements September 10, 2010B&V - 76 1 BLACK & VEATCH MEETING MEMORANDUM Metropolitan St. Louis Sewer District B&V Project 165186 Comprehensive Solids Handling Master Plan – Phase 2 B&V File Phase 2 – 42.4 MSD Project 2009145 January 19, 2011 TO: Meeting Participants FROM: Bently C. Green, P.E. RE: Project Workshop No. 3 – TMs 9 and 10 Review Date: Wednesday, January 19, 2011 at 1:00 p.m. Location: MSD offices at 2350 Market St. ATTENDING: MSD Black & Veatch Brett Berthold Matt Bond (part time – conference call) Rebecca Coyle Bently Green Mike Townley Jim Rowan Neil Frankenberg Tom Ratzki Ken Gambaro Trish Scanlan (conference call) Todd Heller Gustavo Queiroz (conference call) Pam Huntoon Hari Santha (conference call) Buffy Santel Steve Roberts Buffy Santel Jon Sprague NOTES: This workshop was conducted in an informal environment to discuss the recommendations contained in TMs 9, 10, and 11. Reference is made to those TMs. No presentation or Powerpoint of results was provided. SUMMARY COMMENTS Action Items 1. Develop new Alternatives S-4, S-5, and S-6 to TM 9 (Alternatives Evaluation) with cost estimates as a comparison to S-1, S-2, and S-3. These alternatives are to be based on the assumption of a relaxed air emission standard for mercury. 2. Add an Executive Summary to TM-11 (Implementation Plan). 2 General Discussion 1. Provide an Executive Summary for TM 11, and for the entire plan study. a. Overall on the Phase 1 and Phase 2 b. Recommendations / costs and Trigger Points for TM 11 2. MSD conducted internal meetings regarding TM 11, and have concerns about the costs. a. Develop additional alternatives (Jon Sprague) – i. Assess the three primary alternatives under the assumption that the Hg limits are raised, b. Implementation Schedule i. Gives a duration – not tied to any particular year 3. General questions and topics of discussion: a. If Hg is relaxed, what else would be an issue? i. NOX ii. Opacity b. Is a reserve AEC unit for MHI’s needed? c. If Lemay does not have full redundancy, then cake load out facilities are needed in case of emergencies. d. Preferred solution for continued use of MHIs i. 3 MHIs operating at Lemay ii. 4 MHIs operating at Bissell iii. Regionalize Bissell – would go to 5 MHIs e. Appendix for TM 9 i. Need a concise listing of what all is included in the alternatives f. Odor control – “should be considered” – full odor control at the cake hauling facility g. Hg removal with activated carbon i. St. Paul takes out as dry ash ii. When they had MHI’s took it to cement kiln / didn’t want it once it had Hg and C in it iii. With dry ash – impacts cement kiln operation iv. Wet ash off the scrubber – most comes off the bottom dry (90%) v. Put a fabric filter in for a FBI – 1. Media type C filter after WS – take Hg out – which comes out in scrubber water / most comes out in carbon 2. MHI’s – put in pneumatic system in 3. Hessler in KC – dry ash handling system 4. Uzi Unicem system in Festus 4. Public Participation – although there is scope remaining on this task, the consensus was to wrap this up based on the work that has been completed to date. 3 Agenda: 1) TM 11 – Phasing and Implementation Plan a) MSD Comments and Review b) Reconciliation and Development of Final Plan c) Impact on MSD’s CIP 2) TM 10 – Selected Alternatives (TBL Analysis) a) Final Reconciliation 3) Regulatory Issues / Update a) MSD and others comments to SSI MACT Rule b) EPA Path Forward c) Implications to MSD 4) SMP Path Forward a) Future updates based on regulatory changes b) Future updates based on market conditions c) Anticipated path toward project development d) Final comments / wrap-up / adjourn 1 BLACK & VEATCH MEETING MEMORANDUM Metropolitan St. Louis Sewer District B&V Project 165186 Comprehensive Solids Handling Master Plan – Phase 2 B&V File Phase 2 – 42.4 MSD Project 2009145 September 22, 2011 TO: Meeting Participants FROM: Bently Green RE: Project Workshop No. 4 Date: Thursday, August 11, 2011 at 1:30 pm Location: MSD offices at 2350 Market St. ATTENDING: MSD Black & Veatch Brett Berthold Matt Bond (conference call) Rebecca Coyle Trish Scanlan (conference call) Bill Ehrhard Hari Santha (conference call) Jon Sprague Gustavo Queiroz (conference call) Ken Gambaro Jim Rowan (conference call) Mike Townley Tom Ratzki Pam Huntoon Bently Green John Lodderhose Steve Roberts Buffy Santel Neil Frankenberg Brad Nevois SUMMARY COMMENTS Action Items 1. Black & Veatch to review and either confirm or revise the O&M costs for S-1 through S-6 alternatives. NOTES: 1. Reference Power point presentation attached. 2. Project Recap a. January – August 2010: B&V produces TM’s 1-8, hold Workshop No. 1 in May 2010. 2 b. Workshop No. 2 held on September 20, 2011 to review TM’s 1-10 c. MSD directed B&V to d. Include AEC on all FBI costs for TM 9 e. September 29, 2010 – EPA releases copy “draft” MACT SSI Rules – very stringent. f. October 14, 2010 – EPA officially publishes “draft” MACT SSI Rule. g. November 2010 – MSD submits official comments to EPA, and Jon Sprague testifies at EPA public hearing. h. December 10, 2010 – B&V submits draft TM-11 for MSD’s review. i. Workshop No. 3 held on January 19, 2011 i. MSD directed B&V to 1. Develop 3 additional cost estimates S-4, S-5, and S-6 to TM-9 2. Add Executive Summary to TM-11 j. February 17, 2011 – NACWA Conference Call discusses legal challenge to rule k. February 21, 2011 – EPA denied stay for 6 month consideration of rule, releases updated draft of rule to be published in 30 days. l. March 21, 2011 – EPA published final SSI MACT Rule m. May 17, 2011 – B&V submits Final TM-9 to MSD n. May 20, 2011 – SSI MACT Rule becomes final o. June 14, 2011 – B&V submits Final TM-11 p. August 11, 2011 – Workshop No. 4 (Wrap-up) 3. Jon Sprague questioned the costs for O&M for Alternatives S-4, S-5, and S-6, compared to the overall O&M costs for alternatives S-1, S-2, and S-3. 4. There was a lot of discussion over how the rules would be implemented by the state, and how the 50% modification expenses would be accounted for. We replied that it was still to be determined, but that a likely scenario would consist of MDNR requiring MSD to submit incinerator expenses as part of an annual report that they would submit for each plant. 5. There was considerable discussion on what constitutes a modification for an existing MHI, which would exceed EPA’s 50% Modification criteria that would classify the MHI’s as “new” versus “existing” and would result in more stringent emission limits for the MHI’s. a. Are BFP improvements / upgrades considered a “modification”? Black & Veatch does not believe that a modification to belt filter presses would constitute a modification to the incinerators and count against the 50% modification rule. b. Would an ash handling system revision count as a “modification” that is downstream of the Schwing pumps? Ash handling system revisions would likely count as a modification. c. Is the replacement of the Schwing pumps considered a modification? If the pumps are replaced with the same size pumps, Black & Veatch believes that this would likely fall under “maintenance” and not count as a modification. If the pumps are replaced with higher capacity pumps 3 and/or is substantially different from what was there, this may be considered a “modification” and count against the 50% modification rule. 6. Stack Testing Currently being conducted a. Bissell – Preliminary results indicate that SO2 could be a problem b. Lemay – new results not complete. Previous testing from the 1990’s indicate that Cd and NOx could be an issue. 7. Discussed the need for MSD to have the ability to engage a consultant to provide real-time evaluation of regulatory and partnership opportunities going forward, since there are a number of variables in play and this will be a dynamic process. 8. General consensus on conclusion recommendations: a. MSD needs to evaluate the results of the stack tests to determine if there are compliance issues that will have to be addressed immediately. b. It is agreed that the “new” MHI limits cannot realistically be achieved if expenditures on the existing MHI’s exceed the 50% Modification criteria, and would result in MSD electing to replace the MHI’s with FBI’s. c. Significant investment in the MHI’s does not appear warranted based on current EPA definition of modification. d. Pending results of the stack tests, MSD’s general direction for the MHI’s is to continue to operate them until it is time for a major re-build, and in the meantime, start planning for a regional FBI system. REVISIONS: 1. Table 9-28 of TM-9 Opinion of Costs for Alternatives is revised as follows: Alternative Decentralized (No Regional) Regional Total System Regional Total System S-1 S-2 S-3 Capital Costs $366,785,000 $274,488,000 $316,143,000 Salvage Value ($10,626,000) ($9,034,000) ($15,875,000) Annual O&M Costs $20,362,000 $20,109,000 $17,182,000 Annual Revenue ($2,032,000) $0 $0 Present Worth Costs Capital $366,785,000 $274,488,000 $316,143,000 Salvage Value ($4,005,000) ($3,405,000) ($5,983,000) O&M $253,756,000 $250,603,000 $214,126,000 Revenue ($25,323,000) $0 $0 Total Present Worth Costs $591,213,000 $521,686,000 $524,286,000 4 2. Table 9-29 of TM-9 Opinion of Costs for Alternatives is revised as follows: Alternative Decentralized (No Regional) Regional Total System Regional Total System S-4 S-5 S-6 Capital Costs $251,057,750 $166,674,000 $242,959,000 Salvage Value ($3,289,000) ($701,000) ($2,187,000) Annual O&M Costs $26,278,000 $25,247,000 $20,911,000 Annual Revenue ($2,032,000) $0 $0 Present Worth Costs Capital $251,058,000 $166,674,000 $242,959,000 Salvage Value ($1,240,000) ($264,000) ($824,000) O&M $327,482,000 $314,633,000 $260,597,000 Revenue ($25,323,000) $0 $0 Total Present Worth Costs $551,977,000 $481,043,000 $502,732,000 3. Figure 11-1 of TM-11 Phasing and Implementation of Selected Alternatives is revised as follows: 5 Attachment 1 Powerpoint Presentation for Meeting 1 St. Louis MSD St. Louis MSD Comprehensive Solids Handling Master PlanComprehensive Solids Handling Master Plan Workshop No. 4Workshop No. 4 Wrap-up and Review August 11, 2011 Agenda Project Re-cap NACWA Update TM 9 & 10 – Update per Jan. 19, 2011 Workshop Impact of SSI MACT Rule TM 11 –Implementation Planp Wrap-up Items September 10, 2010B&V - 2 2 Project Re-cap January – August 2010: B&V produces TM’s 1-8, hold Workshop No. 1 in May 2010. Workshop No. 2 held on September 20, 2011 to review TM’s 1-10 MSD directed B&V to Include AEC on all FBI costs for TM 9 September 29, 2010 –EPA releases copy “draft”MACT SSI Rules –very stringent.September 29, 2010 EPA releases copy draft MACT SSI Rules very stringent. October 14, 2010 – EPA officially publishes “draft” MACT SSI Rule. November 2010 – MSD submits official comments to EPA, and Jon Sprague testifies at EPA public hearing. December 10, 2010 – B&V submits draft TM-11 for MSD’s review. Workshop No. 3 held on January 19, 2011 MSD directed B&V to Develop 3 additional cost estimates S-4, S-5, and S-6 to TM-9 Add Executive Summary to TM-11 February 17, 2011 – NACWA Conference Call discusses legal challenge to rule February 21, 2011 –EPA denied stay for 6 month consideration of rule, releases updated draft of rule to be published in 30 days. March 21, 2011 – EPA published final SSI MACT Rule May 17, 2011 – B&V submits Final TM-9 to MSD May 20, 2011 – SSI MACT Rule becomes final June 14, 2011 – B&V submits Final TM-11 August 11, 2011 – Workshop No. 4 (Wrap-up) August 11, 2011B&V - 3 NACWA Update Matt and/or Jeff August 11, 2011B&V - 4 3 Final TBL Results Prior to SSI MACT Rule September 10, 2010B&V - 5 Equipment Modifications for Regional System September 10, 2010B&V - 6 4 Equipment Modifications for Regional System with relaxed Mercury limits August 10, 2011B&V - 7 TM 9 – Updated Cost Table for Regional Options August 11, 2011B&V - 8 5 TM 9 –Regional Options with Lower Hg Limits August 11, 2011B&V - 9 SSI MACT Final Emission Limits August 11, 2011B&V - 10 6 Compliance Deadlines Existing SSIs E i i G id li (EG’ ) t di tl f blEmissions Guidelines (EG’s) are not directly enforceable. Only enforceable through a State Implementation Plan (SIP) approved by EPA. SIP’s must be submitted to EPA for approval by March 21, 2012 Existing SSI’s must be in compliance with EG’sExisting SSI s must be in compliance with EG s No later than 3-years after approval of SIP or 5-years after promulgation of the Rule (March 21, 2016). August 11, 2011B&V - 11 Title V Applications All POTW’s that have SSI’s will have to either: Obt i Titl V i i i itObtain a new Title V air emission permit or Modify their existing Title V permit Existing SSI’s – Apply for new or modified permit 12 months after effective date of SIP 12 months after effective date of FIP, or, No later than March 21, 2014 August 11, 2011B&V - 12 7 Definition of Modification August 11, 2011B&V - 13 Control Mechanisms for SSI Units August 11, 2011B&V - 14 8 SSI MACT Challenges for Incinerators August 11, 2011B&V - 15 MHI’s – Conclusions and Other Considerations Existing MHIs are anticipated to meet “existing” MHI standards. In some cases, Cd, Hg and SO2 emissions may be problematic requiring additional controls. New MHI status is very restrictive, potentially requiring controls for CO, Hg, and CDD/CDF. Existing FBIs may require Hg and CDD/CDF controls. Additional SO2and PM control may be required for some units. New FBI, the most restrictive of all the categories, will require extensive emissions controls as part of the design package. We’ve built this in. Many facilities may not have adequate available space near their SSI to install emission control technologies into existing facilities. Without available space, some facilities may have to dismantle equipment to make room for emission control devices, which can disrupt operations. August 11, 2011B&V - 16 9 MHI’s – What to do? An initial assessment of the “Existing Multiple Hearth” emission limits show that most MHIs will likely comply. Older units may not fair so well and, depending upon site-specific data, will likely need emission control upgrades or add-on emissions controlsupgrades or add-on emissions controls. Owners of existing MHIs should closely track capital expenditures to determine if “modification” is triggered, which would reclassify an existing MHI to a new MHI. If functional upgrades are extensive, existing MHIs may have to shutdown rather than accept the “new” incinerator designation and limits. As with any new regulation, the cost-benefit of investing in improvements to comply must be balanced with the condition of the existing equipment, pros/cons of upgrading to new technology, and uncertainty of future regulatory risks associated with incineration and other biosolids management practices. August 11, 2011B&V - 17 MSD Stack Test Results – Bissell Point Pending – but old data below. Inc 6 Stack Parameter New Limit Old Limit Test Results SO ld bCd 0.095 mg/dscm 0.026 mg/dscm CO 3800 ppmv 1563 ppm HCl 1.2 ppmv 50 ppm 0.36 ppm Hg 0.28 mg/dscm 3200 g/day 0.044 mg/dscm NOX 220 ppmv 6.1 lb/dry T incinerated 106.5 ppm Pb 0.30 mg/dscm 0.0338 mg/dscm PCDD,PCDF0.32 ng/dscm n/a PM 80 mg/dscm 1.3 lb/dry T incinerated 31 mg/dscm SO2 26 ppmv 500 ppm 26.69 ppm SOx could be a problem. September 10, 2010B&V - 18 Bissell Point WWTP Sludge Feed Rate Mercury Gas Flow HG Proposed Incinerator Stack Test Date dt/hr g/24 hrs dscfh mg/dscm MACT 2Feb‐07 3.43 49.3 1113914 0.0651 0.28 3Nov‐06 3.2 25.3 1138517 0.0327 0.28 4Nov‐06 3.2 18.5 945030 0.0288 0.28 5Feb‐07 2.43 45.6 1178914 0.0569 0.28 The original MACT standard for Hg was 0.02. The new standard should not be a problem to meet. 10 MSD Stack Test Results – Lemay Pending – but old data below. Incinerator No. Test Date 1 7/26/1990 2 6/15/1993 10/11/1989 4 New Emision Polluntant Units Limit Cd mg/dscm @ 7% O2 0.095 0.067 0.096 CO ppmvd @ 7% O2 3,800 1,928 HCl ppmvd @ 7% O2 1.2 Hg mg/dscm @ 7% O2 0.28 0.146 NOx ppmvd @ 7% O2 220 296.7 Pb mg/dscm @ 7% O2 0.30 0.165 0.16 PCDD/PCDF,TEQ ng/dscm @ 7% O2 0.32 PCDD/PCDF,TMB ng/dscm @ 7% O2 5 PM mg/dscm @ 7% O 80 24 02 12 47 43 31 September 10, 2010B&V - 19 PM mg/dscm @ 7% O2 80 24.02 12.47 43.31 SO2 ppmvd @ 7% O2 26 10.4 mg/dscm = gr./dscf X .0648grams/grains X 1000 milligrams/gram X 35.31 cu ft/cu meter mg/dscm = ug/dscf X .001 mg/ug X 35.31 cu ft/cu meter Cadj = Cmeas (20.9-7)/(20.9-%O2) MSD Path Forward Stack tests indicate full compliance immediately I dit ti t$0f lt liImmediate cost impact: $0 for regulatory compliance Future cost impact: TBD Stack tests indicate AEC facilities required to achieve compliance Immediate cost impact for compliance only: $30-60M Future cost impact – depends on feasibility of running MHI’s indefinitely $120M cost estimate for long term MHI upgrades identified, but would have to compare trigger costs for modification rule. September 10, 2010B&V - 20 11 Cost for Regional Alternative with FBI’s September 10, 2010B&V - 21 Costs for AEC for MHI’s September 10, 2010B&V - 22 12 MHI Testing On-going by Black & Veatch Seems promising with respect to regulatory compliance Currently testing MHI’s with SO2 issues Able to treat SO2 with standard venturi / impingement tray modified with packed bed and ring jets gj Hg has not been a problem yet with MHI’s tested CO has not presented a problem August 11, 2011B&V - 23 So where are we at? It runs but needs work. You can do general maintenance, oil, filters, tires, etc. You can replace muffler for emissions. Can’t do any major overhaul or it counts as a “new” car, with new emission limits that cannot be met. Options Available Run it until it breaks down and needs major repairs and then buy a August 11, 2011B&V - 24 Run it until it breaks down and needs major repairs and then buy a new one. Wait to get a clearer regulatory picture, measure your emissions, and decide what kind of time that a modest investment will get you. Or lastly, you can buy a new one now. 13 Going forward……………. Assess regulatory issues in real time Assess partnership opportunities on case by case basis Opportunities to dispose ash Opportunities for energy recovery (steam / electricity) Opportunities to convert raw product to renewable energy through partnership with electric utility Assess long-term disposal issuesg Vertical expansion to Prospect Hill Phosphorus mining Disposal to landfill or other potential partner August 11, 2011B&V - 25 Questions August 11, 2011B&V - 26 Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –1– Comprehensive Solids Handling Master Plan Public Perception Focus Group Summary, Phase II May/June 2010 Background The Metropolitan St. Louis Sewer District (MSD) contracted Black & Veatch to prepare a district-‐ wide Comprehensive Solids Handling Master Plan. This plan, which is an outgrowth of MSD’s initial evaluation of WWTP scrubber upgrades, is designed to inform the District as it evaluates and plans for future investments in solids handling and disposal. In August 2009, Black & Veatch contracted Vector Communications to conduct a focus group to: Determine the public’s knowledge of biosolids or water reuse management strategies; Gauge the public’s concerns and issues regarding biosolids management practices; and Understand the public’s values regarding biosolids management. After listening to a 20-‐minute overview about biosolids and solids processing, use and disposal technologies, focus group participants asked questions and then, offered their perceptions during a facilitated discussion. As revealed during the focus group, residents knew very little about the treatment, disposal and recycling of biosolids. However, once informed about the processes, residents were concerned about: ¥ Odors and emissions associated with processing; ¥ Increased truck traffic for hauling end-‐products; ¥ Facility locations in urban and low-‐income residential areas; and ¥ MSD’s accountability to the public regarding odors and emissions. Overall, participants found environmentally friendly and cost effective options, such as land application and composting, as more acceptable than incineration and landfills. Phase II Focus In May 2010, after recommending specific solids handling alternatives to MSD, Black & Veatch wanted to solicit additional public input regarding the alternatives. With Phase II focus group participants, the objectives were: Learn and understand the public’s concerns and issues related to specific plant related solids handling process recommendations; Discover possible public sentiments that could derail the implementation of Black & Veatch’s recommendations to MSD; and Develop community outreach, education and engagement strategies for developing a transparent and informative relationship between MSD and the WWTP’s contiguous neighborhoods. Three focus groups, two with participants living close to WWTPs and one with at-‐large residents, were held in late May and early June and the demographics for each are detailed below. Focus Group Demographics Lemay Ten residents, living within one to three miles of the Lemay WWTP, participated in the focus group. Of those participating, the following demographic representation prevailed: Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –2– ¥ Gender: 50% – female; and 50% –male; ¥ Ethnicity: 30% – African American; and 70% – European American; ¥ Age: 10% – 31 to 40 years of age; 20% – 41 to 50 years of age; and 70% – 50+ years of age; ¥ Household Composition: 30% – with children between the ages of one and sixteen years of age; ¥ Pet Ownership: 60% – dog owners; ¥ Traveling Past WWTP: 90% past the plant daily or weekly; and ¥ Biosolids Knowledge: 30% – indicated familiarity with the term biosolids. Bissell Ten residents, living within one to five miles of the Bissell WWTP, participated in the focus group. Of those participating, the following demographic representation prevailed: ¥ Gender: 60% – female; and 40% –male; ¥ Ethnicity: 100% – African American; ¥ Age: 10% – 20 to 30 years of age; 20% – 31 to 40 years of age; 40% – 41 to 50 years of age; and 30% – 50+ years of age; ¥ Household Composition: 50% – with children between the ages of one and sixteen years of age; ¥ Pet Ownership: 60% – dog owners; ¥ Traveling Past WWTP: 70% past the plant weekly; and ¥ Biosolids Knowledge: 20% – indicated familiarity with the term biosolids. At-Large Eight residents, with 55% from the City of St. Louis and the remainder from St. Louis County, participated in the focus group. Two of the nine attendees participated previously in the focus last summer. The participants represented the following demographics: ¥ Gender: 50% – female; and 50% –male; ¥ Ethnicity: 62% – African American; and 38% – European American; ¥ Age: 67% – 41 to 50 years of age; and 33% – 50+ years of age; ¥ Household Composition: 67% – with children between the ages of one and sixteen years of age; ¥ Pet Ownership: 78% – dog owners; ¥ Traveling Past WWTP: None of the participants lived close proximity to a WWTP; and ¥ Biosolids Knowledge: 63% – indicated familiarity with the term biosolids. Methodology The two-‐hour focus group process began with a brief introduction from Jessica Perkins of Vector Communications. Perkins explained that the focus group was designed to gather feedback about future upgrades that could take place at either the Lemay or Bissell plants. Stating that MSD is concerned about being a “good neighbor”, Perkins wanted to ensure that the discussion would answer the following questions: ¥ How will recommended solids processing upgrades impact you and/or family? ¥ How interested are you in the solids handling process, especially when it occurs in close proximity to your residence? ¥ What additional information would you need as MSD upgrades its facilities? ¥ What mechanisms are best for communicating this information? After the introduction and prior to Black & Veatch’s 20-‐minute presentation about possible upgrade recommendations, Perkins asked the participants to provide their perceptions about five terms – biosolids, sludge, thermal oxidation, incineration and energy recovery – related to solids handling. Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –3– The Black & Veatch presentation included the topics below and after the presentation Perkins initiated a discussion about the participants’ perceptions regarding the multiple hearth and fluidized bed incineration processes. ¥ Introduction to solids processing; ¥ MSD’s solids processing and treatment methodology; and ¥ Black & Veatch’s solids handling recommendations processes for Lemay and Bissell. Focus Group Results Part I – Participants’ Perception of Key Terms By stating “positive, negative or indifferent”, participants were asked their first reaction to each of the five terms; additionally, participants were asked for their rationale for that reaction. For all groups, “sludge” and “energy recovery” demonstrated the most unilateral preferences. Sludge was viewed negatively by 90% of the participants; and energy recovery was viewed positively by 89% of the participants. All other terms elicited mixed responses. Biosolids – Biosolids, although a new term for most, was viewed positively by 50% of the participants and viewed negatively or indifferently by the remaining participants. For those who viewed the term negatively, the perception was based on unfamiliarity with the term. Sludge – Across all focus groups, sludge was a term that educed negative connotations. For most, the term conjured images of unfiltered waste, mess, slime and sewer back-‐up residue and odors. Participants viewed sludge as a residual product that was “left over after the good stuff was extracted”. One individual related sludge to a television commercial where sludge was described as the “black stuff” that blocks an engine when the oil isn’t changed. 60% 25% 28% 30% 10% 25% 22% 70% 30% 50% 50% 0% 20% 40% 60% 80% 100% 120% Lemay Bissell At-Large Average "Biosolids" Perception Positive Negative Indifferent Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –4– Thermal Oxidation – Receiving mixed perceptions across the three focus groups, thermal oxidation received either a negative or indifferent response from seven out of ten participants. For those viewing it positively, they equated thermal with warmth and comfort, as with “thermal underwear”. Oxidation was equated with “breaking down” or releasing heat for decomposition. Forty percent of the respondents were indifferent because they were unfamiliar with the term. 80% 90% 100% 90% 20% 10% 10% 0% 20% 40% 60% 80% 100% 120% Lemay Bissell At-Large Average "Sludge" Perception Positive Negative 40% 50% 30% 50% 20% 50% 40% 50% 40% 30% 0% 20% 40% 60% 80% 100% 120% Lemay Bissell At-Large Average "Thermal Oxidation" Perception Positive Negative Indifferent Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –5– Incineration – Collectively, almost 70% of the participants viewed the term positively. This varied greatly from the results of the Phase I focus group, where the participants viewed incineration negatively. Phase II focus group participants stated that incineration reminded them of: ¥ Recycling; ¥ Disposing of something; ¥ Turning a solid into ash; or ¥ Breaking down materials. Although the term received favorable results, especially from the Bissell participants, the results may not demonstrate the individuals’ true perception. It was obvious to the facilitator that groupthink was demonstrated by the Bissell focus group participants. In other words, it seemed as though several participants were swayed or biased by the comments of other focus group members. Fifty percent of the at-‐large focus group participants viewed the term indifferently because they were concerned about the pollutants associated with incineration. Since the responses were mixed across the groups and possibly biased for the Bissell focus group, it is best to use the Lemay or average focus group responses as the barometer. Energy recovery (chart on next page) was viewed favorably because “recovery” sounded positive, i.e., to restore life, save energy, improve or make better. For the 11% that viewed the term indifferently, they wondered if energy waste had occurred and required recovery or they were too unfamiliar with the term to rate it favorably. 50% 17% 40% 13% 18% 60% 100% 38% 66% 0% 20% 40% 60% 80% 100% 120% Lemay Bissell At-Large Average "Incineration" Perception Positive Negative Indifferent Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –6– Part II – Public Perceptions about Incineration Alternatives The table below portrays the participants’ perceptions about each alternative. Although, fluidized bed incineration may require rate increases, overall participants felt that MSD should pursue this alternative over multiple hearth furnace incineration. Multiple Hearth Furnace Fluidized Bed Incineration Advantages ¥ Retains jobs and maintains costs over the short-‐term ¥ Meets the Clean Air Act and is safe for the environment today ¥ Less expensive in the short-‐ term ¥ Maintains status quo ¥ More efficient with fewer moving parts and lower long-‐term maintenance costs ¥ Eco-‐friendly and sustainable ¥ Provides employee cross-‐training opportunities ¥ Better for the public good ¥ Rate increases may be less frequent because MSD isn’t attempting to maintain an obsolete system Disadvantages ¥ Costly in the long-‐term, both economically and possible environmentally ¥ Could lead to more pathogens being dispersed ¥ May lead to employee displacement and/or layoff ¥ Once implemented, future regulations can cause new technology to become obsolete in fewer years 10% 10% 13% 11% 90% 90% 88% 89% 0% 20% 40% 60% 80% 100% 120% Lemay Bissell At-Large Average "Energy Recovery" Perception Positive Negative Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –7– Additional Comments ¥ FBI was favored over MHF in all three groups; but a 50-‐year cost analysis would be necessary for a more definitive answer. ¥ Implementing FBI sooner than later was viewed as the best decision because construction costs will be higher in the future and environmental regulations may become more stringent. Therefore, it would probably be more cost-‐efficient to the community. ¥ No major issues, other than excessive rate increases, environmental damage or irresponsibility, would cause the participants to boycott or protest either project. ¥ Construction disruption was of little concern to those living close to Lemay and Bissell WWTPs. ¥ Truck traffic from other five plants is of little concern, as well. Part III – Communicating with the Public To keep the public informed about any changes to solids processing at the Lemay or Bissell plants, MSD should consider addressing the following questions: ¥ What other cities are using FBI and how successful has it been? ¥ What is the expected life cycle of the FBI technology? ¥ Is the change to FBI more cost effective today or should MSD wait for a few more years before implementation? ¥ Would MSD keep MHF operating with FBI? ¥ Over a 50-‐year horizon, which technology is most cost efficient? What is the break-‐even point for each technology? ¥ Are there other technologies available that are being tested today? Could these technologies be more cost efficient and environmentally sustainable than FBI? ¥ In the future, how easy will it be to order and install parts for the MHF incinerator? ¥ How many employees are needed for FBI as compared to MFH? How does MSD prepare its employees for technology changes? ¥ Will FBI impact casino patronage at Lemay? ¥ How will MHF impact the public, especially children, if we continue using it? ¥ Are there any environmental concerns associated with the FBI construction? ¥ With respect to construction, would FBI or MHF provide more jobs over the short-‐term? ¥ Is it possible to have FBI at Bissell, but maintain MHF at Lemay, to lessen the cost? ¥ How expandable or flexible is FB? What is the capacity Recommended Communications Channnels ¥ Website updates ¥ Newsletter ¥ Bill inserts or e-‐bill inserts ¥ Weekly or monthly column in major newspapers ¥ Public affairs talk shows Part IV – Public’s Priorities: Affordable Rates, Environmental Protection and/or Neighborhood Impacts During the first phase, Black & Veatch wanted to know the public’s preferences with respect to the triple bottom line model of evaluating projects based on economic, environmental and social impacts. On a scale of one to five, with five being most important, Phase I focus group attendees weighted environmental considerations as most important with a 4.33, followed by economic and social considerations, both with a rating of 3.33. Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –8– Collectively, Phase II focus group participants, rated economic considerations highest with a rating of 4.57, followed by environmental and social considerations, which were rated 4.29 and 4.12, respectively. By focus group, Bissell and the At-‐large groups rated considerations in the following order – economic, environmental and social; and the Lemay group rated all three impact areas the same. The tables below indicate the ratings by focus group for each of the triple bottom line statement. Economic Statement –Maintain capital, operating and maintenance expenses to keep sewer rates as affordable as possible. Frequency Distribution Focus Group 1 – Least Imp 2 3 4 5 – Most Imp Rating Bissell 1 1 7 4.56 Lemay 1 2 7 4.40 At-‐Large 2 6 4.75 Total 1 1 0 5 20 4.57 Environmental Statement – Minimize the effects of green house gas emissions to protect the environment. Frequency Distribution Focus Group 1 – Least Imp 2 3 4 5 – Most Imp Rating Bissell 2 3 4 4.22 Lemay 2 2 6 4.40 At-‐Large 2 2 4 4.25 Total 0 0 6 7 14 4.29 Social Statement – Use technologies, which minimize neighborhood impacts, such as odors, truck traffic and plant aesthetics. Frequency Distribution Focus Group 1 – Least Imp 2 3 4 5 – Most Imp Rating Bissell 3 1 5 4.22 Lemay 2 2 6 4.40 At-‐Large 2 1 2 3 3.75 Total 0 2 6 5 14 4.12 Solids Handling Master Plan Phase II Focus Group Summary – May/June 2010 –9– Implications for the Solids Handling Master Plan Black & Veatch, along with MSD, should consider the following as the master plan is developed: ¥ When preparing public communications, energy recovery is a favorable term and should be used whenever possible. MSD should visually (using diagrams) describe the terms biosolids, incineration and thermal oxidation, because at least 50% of the population isn’t aware of these terms. Finally, sludge should never be used to describe biosolids. ¥ Regarding incineration technologies, the public is most concerned with economic and environmental impacts. Therefore, any communications materials supporting or describing upgrades to the Bissell or Lemay plants should focus on the financial and ecological benefits. Residents are concerned minimally about social impacts, such as construction disruption and truck traffic. ¥ Finally, because of economic and environmental concerns, residents found the FBI technology more appealing because while it could lead to increased rates, in the long term, the technology was presented as being cost effective and ecologically efficient. 1 Metropolitan St. Louis Sewer District Building Awareness about Biosolids Processing Situational Analysis Approximately 18 months ago, the Metropolitan St. Louis Sewer District (MSD) hired Black & Veatch to prepare a district-wide Comprehensive Solids Handling Master Plan. The master plan was an outgrowth of MSD’s initial assessment of its WWTP scrubber upgrades, where it was determined that: • Scubber upgrades would be costly and may be unnecessary, if the District upgraded to a cleaner process of incineration; and • Future WWTP upgrades should consider the future direction of solids handling and stricter U.S. EPA regulations regarding incinerator emissions. As part of its technical assessment of MSD’s solids handling process, Black & Veatch decided to also consider public perception regarding biosolids and the solids handling process. In the summer of 2009 and 2010, a total of five focus groups were conducted. In 2009, the focus was to ascertain the public’s general knowledge about biosolids and the solids handling process and to ascertain their social, economic and environmental values pertaining to sewer improvements. In 2010, with more detailed knowledge about possible recommendations for MSD’s Bissell and Lemay WWTPs, the focus groups discussed how the recommendations could impact them more specifically. From the focus groups, it was determined that: • The public has very little knowledge or understanding about the solids handling process; • Solids handling options most favored are those that keep rates affordable and protect the environment from additional harm. • Costs and environmental sustainability are the most critical factors for evaluating sewer infrastructure improvements. • The public is unaware of most issues, such as regulatory compliance, aging infrastructure, facing MSD; and they want to know more about how MSD’s compliance and regulatory issues will impact future rate increases. • While most people don’t know what the term biosolids means, they view it in a positive light. • Sludge, an alternative term for biosolids, was viewed negatively by almost all focus group participants. • Most people view incineration ambivalently. From the responses of five focus groups, the term received positive, negative and indifferent reactions. 2 Initiative Goals and Target Audiences If MSD is going to become an environmental leader in sewer improvements, it must embark upon communications campaign to: 1) generate greater awareness about the issues that it is addressing environmentally; 2) demonstrate that it is an efficient steward of public funding; and 3) inform the public about its sewer improvement efforts and how those efforts can benefit the entire region. Specifically with biosolids and the solids handling process, the major target audiences are those residents and stakeholders who may be impacted because of their proximity to the Bissell and Lemay WWTPs. Additionally, the general public needs to be informed about MSD’s vision to become an environmental leader in sewer improvements. Marketing Strategy During the Clean Rivers Healthy Communities Program, MSD’s Long-Term Control Plan (LTCP) for reducing combined sewer overflows, the District adopted the tagline, “Protecting the Environment Through Sewer Improvements”. Since Black & Veatch’s recommendations for solids handling are geared toward environmental protection and cost efficiencies, Vector recommends incorporating the solids handling upgrades under that tagline. Marketing Tactics There are several types of marketing tactics that MSD should use to meet the goals of increased awareness, knowledge and understanding about the solids handling recommendations and MSD desire to become an environmental leader. To reach both the community at-large and the target audiences, MSD must employ a combination of direct and indirect connection mechanisms. Direct connections utilize person-to-person interfaces like meetings, presentations and events to engage audience members. Indirect connections employ communications channels like radio, print media, direct mail and email to achieve broad audience exposure. Most traditional communications campaigns rely heavily on indirect connections. However, this approach has limited effectiveness when the goal is to induce not only changes in audience awareness, but also changes in audience behavior. While audience awareness is critical, behavior change is important even with solids handling. MSD customers must understand how disposed liquids and solids impact the region’s water supply. 3 General Awareness Tactics Awareness Video MSD has created several videos about its operations and Vector believes that a video which details the current solids handling process and compares it to future improvements will help residents to understand MSD’s decision to invest in fluidized bed incinerators. This video should be no longer than 5 to 6 minutes and it should speak to the public’s values of cost efficiency and environmental stewardship. MSD Fact Sheet or Brochure MSD should develop an organizational fact sheet, which details (in laymen’s terms) its sewer investments over the past five to ten years and how those investments have positively impacted rate payers from an environmental standpoint. Audience Specific Awareness Tactics Prescription and OTC Drug Giveback Program MSD should partner with one of the drugstore chains, such as Walgreen’s or CVS (and the municipality’s department of health) to begin a giveback program because this will help residents to understand how the dumping of medicinal drugs can have a negative impact on our water supply. At the giveback days, which should be held initially in the Lemay and Bissell WWTPs service areas, MSD should also distribute its Stormwater Phase II brochures about other measures that the public can take to reduce the amount solids entering the sewer system. Additionally, at these events MSD can begin to inform the residents about its upgrades at the WWTPs. Organizational Briefings As experienced during the LTCP, most residents will not attend a MSD meeting unless there is a problem with basement back-ups, street flooding and/or rate increases. Therefore, MSD needs to continue its outreach by attending planned ward and organizational meetings. Typically, a five to ten minute presentation is all that is required, but this person-to-person contact makes MSD appear as a transparent neighbor. Vector’s suggestion is to show the video, distribute the brochure and answer questions. Also, if the briefing is conducted prior to a drug giveback day, the briefing could be used to market the program. 1 St. Louis MSD St. Louis MSD Comprehensive Solids Handling Comprehensive Solids Handling Master PlanMaster PlanMaster PlanMaster Plan Cincinnati FBI System Site VisitCincinnati FBI System Site Visit August 9, 2010 Cincinnati Visit Looked at two plants – Little Miami and Mill Creek Little Miami In operation since 2000 Single 72 dtpd FBI facility replacing MHI’s within existing building Mill CreekMill Creek In operation since 2010 Three 96 dtpd FBI facility replacing MHI’s in a new building. 2 Little Miami WWTP •One FBI Unit •72 dtpd capacity •Installed within i ti b ildiexisting building formerly used for MHI’s. •Staff did not recommend utilizing existing buildings from either construction or operationoperation standpoint. Little Miami – BFP Dewatering 3 Little Miami – Cake Feed Pumps Little Miami – Sludge Feed Points into FBI 4 Little Miami – Scrubbers Venturi Scrubber Impingement tray scrubber Scrubber Little Miami – FBI Primary Heat Exchanger & Duct 5 Little Miami – Control Room Cincinnati FBI Schematic – Mill Creek 3 FBI Units at 96 dtpd capacity 6 Mill Creek 7 Mill Creek Mill Creek 8 Mill Creek Mill Creek 9 Mill Creek Mill Creek 10 Mill Creek Mill Creek 11 Mill Creek Mill Creek 12 Mill Creek Mill Creek 13 General Notes Replaced MHF Units 8 years ago with FBI system Drivers were a consent decree from EPA 75 odor complaints in 2004 / 0 in 2009 Yellow plume Previously provided ash to concrete companies / FBI system removes more Hg / concrete companies can’t have this; so had to stop Energy savings $3.5-$4M per year; do not sell power back to grid. Have 3 incinerators / essentially run 2 ½. Two can’t keep up all the time; have to run third about half time. Erosion due to abrasiveness has been biggest problem. Have cut tubes twice. Particularly a problem with the boilerParticularly a problem with the boiler. Acid gas corrosion also has been problem. Can’t have enough SS. Serious corrosion issues in the Primary Heat Exchangers and Carbon Tower. Re-coated Secondary Heat Exchanger tubes / holes in it created NOV issue when clean and dirty gas co-mingled. Initial Conclusions - Preferences 1 1 1 2 1 – if dry ash 3 – if wet ash 3 1 – Necessary component 2 – Not crucial but desired component 3 – Considered a luxury component 1 1 – if Hg emission 3 – if no Hg 14 The End 1 St. Louis MSD St. Louis MSD Comprehensive Solids Handling Comprehensive Solids Handling Master PlanMaster Plan MCES (St. Paul, MN) FBI System Site MCES (St. Paul, MN) FBI System Site VisitVisit April 8, 2010 MSD / B&V Staff on Site Visit: Neil Frankenberg, MSD Becca Coyle, MSD Mike Townley, MSD Steve Roberts, MSD Scott Fronek, Minneapolis, B&V Bently Green, St. Louis, B&V Jim Rowan, Kansas City, B&V 2 Minn./St. Paul FBI Schematic MCES Plant: 220 mgd, 110 dtpd incinerator capacity, 3 units Dewatering - Centrifuges 3 Dewatering - Centrifuge TS – 28% avg. (27-30%) Range VS – 82% avg. (75-85% Range Cake Conveyance – Schwing Pumps Operators noted these had been relatively trouble free 4 FBI System Top View 1 of 3 units, rated 110 dtpd each Cake Injection below Primary Heat Exchanger Provides “hot windbox” for FBI fuel use reduction (autogenous) Similar to heating of CS air for Bissell incinerators Exhaust gas 5 Waste Heat Boiler Recovers heat from exhaust gas to produce 500 psig steam for power generation and building heating Secondary Heat Exchanger Used to recover heat from exhaust gas to reheat exhaust gas after wet scrubbers Plume suppression 6 Fabric Filter Bag house used to collect particulates and carbon with Hg in exhaust gas for reduction in Hg emissions Most ash comes out here and is collected as dry ash. Pneumatically conveyed to storage silos. Non hazardous ash Ash Transporter Below Ash Handling System Pneumatic system required air injection within pipeline every 25-50 feet; to maintain flow. Operators indicated system performed well. 7 Wet Scrubber Combination tray and fixed venturi scrubber. Takes out remaining ash, and acid gases Same function as wet scrubbers at Bissell and Lemay Wet Electrostatic Precipitator – additional particulate scrubbing Turbine Generator 8 Turbine Generator •Uses stream from waste heat boiler. •Generates power in warmer months when no building heat required. •Rated for 4 MW, runs ~ 2.5 MW Water Conditioning required for steam system 9 Ash Conditioning and Loading General Notes Replaced MHF Units 8 years ago with FBI system. Drivers were - Consent decree from EPA 75 odor complaints in 2004 / 0 in 2009 Yellow plume Previously provided ash to concrete companies / FBI system removes more Hg / concrete companies can’t have this; so had to stop Energy savings $3.5-$4M per year; do not sell power back to grid. Have 3 incinerators / essentially run 2 ½. Two can’t keep up all the time; have to run third about half time. Erosion due to abrasiveness has been biggest problem. Have cut tubes twice. Particularly a problem with the boiler. Acid gas corrosion also has been problem. Can’t have enough SS. Serious corrosion issues in the Primary Heat Exchangers and Carbon Tower. Re-coated Secondary Heat Exchanger tubes / holes in it created NOV issue when clean and dirty gas co-mingled. 10 Initial Conclusions – MSD Preferences 1 – Necessary component 2 – Not crucial but desired component 3 – Considered a luxury component 1 1 1 1 2 1 – if Hg emission 3 – if no Hg 1 – if dry ash 3 – if wet ash 3 MCES CONTACT FOR VISIT: David Quast, P.E. Principal Engineer 651 602 8297 david.quast@metc.state.mn.us