2017 marks the final implementation stage for energy recovery facilities that will now be regulated under the CISWI NSPS regulatory structure, and CISWI incineration facilities that are upgrading controls to meet the February 7, 2018 existing facility compliance date. NSPS incineration rules under CAA Section 129 have been rolled out over the last 15+ years for a number of categories, including:
- Municipal Waste Combustors (MWC)
- Commercial and Industrial Solid Waste Incinerators (CISWI)
- Hospital, Medical, and Infectious Waste Incinerators (HMIWI)
- Sewage Sludge Incinerators (SSI)
- Other Solid Waste Incinerators (OSWI)
The CISWI compliance framework, upgraded by the 2011 and 2013 rule revisions, represents a similar structure to the MACT combustion rule framework, in addition to some more typical incineration-type requirements. The general regulatory framework includes:
- Emissions standards and corresponding operating limits for continuous compliance (separate tables for each CISWI subcategory)
- Initial and ongoing performance testing to verify stack emissions, and performance evaluation requirements for continuous monitoring instrumentation (CEMs and CMS)
- Plans and operating procedures
- Recordkeeping and reporting
- Operator training and certification requirements
- Waste Management Plan
- Preconstruction Siting Analysis (new facilities only)
With the CISWI rule 2011/2013 changes, the rules now extend applicability to units that were previously regulated by MACT standards. This can include units previously characterized as boilers under Boiler MACT or EGU MATS, or industrial furnaces such as cement or lime plants regulated under the PC MACT or Lime MACT standards that utilize alternative (non-traditional) fuel that is solid (non-hazardous) waste. Also, prior to a new incinerator installation, facilities must determine NSPS regulatory applicability based on the type of waste handled, addressing non-hazardous solid waste, municipal trash versus sewage sludge, medical waste, and more.
EPA published the proposed federal implementation plan (FIP) rule on January 11, 2017 under which CISWI facilities will be regulated until and unless their state submits and EPA approves a state implementation plan (SIP) rule. The EPA rule reiterates the final requirements in 40 CFR 62 Subpart III (starting at 62.14500) that implement the CISWI 40 CFR 260 DDDD guidelines, while new CISWI facilities fall under the 40 CFR 260 CCCC regulation. The time has arrived for final preparation for the February 7, 2018 compliance date. Final actions include control device and instrumentation installation, submittal of the Waste Management Plan by November 7, 2017, and implementation planning for the host of other requirements—from submittal of the Site-Specific Monitoring Plan to site-specific Operator documentation and training, to performance testing and establishing the surrounding recordkeeping and reporting system.
Trinity is working with a number of facilities through their implementation details and is available to assist others with CISWI implementation tasks and/or NHSM documentation for energy recovery units to avoid CISWI applicability. For further information, please contact John Schnarre at (636) 256-5655.