HomeMy Public PortalAboutExhibit MSD 73H - SMP PH 2 TM'sBLACK & 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 73H
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 Pres s 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
Sys tem
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 Sys tem
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 Sys tem s
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 Co ntrol
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 – As h Handling Sys tem
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 Sys tem
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 – As h Handling Sys tem
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 Sys tem
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) Was te 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 Sys tem – 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) Was te 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) Condens ate Handling Sys tem – 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 Sys tem – 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 As h Sys tem – 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 – Exis ting Belt Filter Pres s 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) Alternative L-1 - Exis ting Cake Conveyance and Storage Sys tem
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 - Exis ting Cake Storage Sys tem 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 Sys tem
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 - Exis ting Multiple Hearth Incinerator Sys tem s
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 – As h Handling Sys tem
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) Alternatives L-2 and L-3 - Sand Sys tem
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) Diges ter 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) Diges ter 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) Exhaus t Emiss ions
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 Diges ter
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. Diges ter 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. Diges ter Gas Treatment Sys tem
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. Compos ting
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 WWT P
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) Diges ter 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) Diges ter 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) Exhaus t Emis s ions
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 Sys tem – 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) As h Handling Sys tem – 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 Sys tem – 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) Was te 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 Sys tem - 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) Was te 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 Tu rbine 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) Condens ate Handling Sys tem - 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 Sys tem - 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 As h Sys tem - 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(NewEQ)
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)
EndUse 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 RegionalFacility
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
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
Coldw ater Low er
Meramec
Grand
Glaize
Fenton
De
s
i
g
n
s
o
l
i
d
s
(
d
t
p
d
)
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 04JNP2ero
w
e
o
n
D
S
K
5
C
L
S
3
C
1
P
R
O
D
w
i
t
h
P
R
O
P
O
S
A
L
S
2
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 Bis
s
e
l
l
Lem
ay
Coldw
a
t
e
r
Low
e
r
Mera
m
e
c
Mo Rive
r
Reg
i
o
n
a
l
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
Bis
s
e
l
l
Le
m
a
y
Co
l
d
w
a
t
e
r
Lo
w
e
r
Me
r
a
m
e
c
Mo
R
i
v
e
r
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
Bis
s
e
l
l
Le
m
a
y
Co
l
d
w
a
t
e
r
Lo
w
e
r
Me
r
a
m
e
c
Mo
R
i
v
e
r
Bis
s
e
l
l
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.
Bis
s
e
l
l
(B-2)
Lem
a
y
(1 - 3)
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
(M
-1)
Lo
w
e
r
Mera
m
e
c
(LM
-1)
Lem
a
y
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
Lo
w
e
r
Me
r
a
m
e
c
Re
g
i
o
n
a
l
(R-1)
Lem
a
y
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
Lo
w
e
r
Me
r
a
m
e
c
Re
g
i
o
n
a
l
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.
Bis
s
e
l
l
(B-2)
Lem
a
y
(1 - 3)
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
(M
-1)
Low
e
r
Me
r
a
m
e
c
(LM
-1)
Lem
a
y
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
Low
e
r
Me
r
a
m
e
c
Reg
i
o
n
a
l
(R-1)
Lem
a
y
Co
l
d
w
ate
r
(C-1)
MO
R
i
v
e
r
Low
e
r
Me
r
a
m
e
c
Reg
i
o
n
a
l
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
Cu
r
r
e
n
t
O
p
e
r
a
t
i
o
n
C-2
Ra
w
C
a
k
e
t
o
Lan
d
f
i
l
l
C-2-A
CF
G
D
e
w
a
t
e
r
i
n
g
C-2-B
RP
D
e
w
a
t
e
r
i
n
g
C-3
An
a
e
r
o
b
i
c
D
i
g
e
s
t
i
o
n
C-3-A
CF
G
D
e
w
a
t
e
r
i
n
g
C-3-B
RP
D
e
w
a
t
e
r
i
n
g
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
Cu
r
r
e
n
t
O
p
e
r
a
t
i
o
n
C-2
Ra
w
C
a
k
e
t
o
Lan
d
f
i
l
l
C-2-A
CF
G
D
e
w
a
t
e
r
i
n
g
C-2-B
RP
D
e
w
a
t
e
r
i
n
g
C-3
An
a
e
r
o
b
i
c
D
i
g
e
s
t
i
o
n
C-3-A
CF
G
D
e
w
a
t
e
r
i
n
g
C-3-B
RP
D
e
w
a
t
e
r
i
n
g
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 associa