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On November 29, WEF submitted comments on the EPA October 14 proposed rule for Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Sewage Sludge Incineration (SSI) Units. The rulemaking would subject SSIs units to the more stringent Section 129 requirements of the Clean Air Act that require maximum achievable control technology (MACT). These comments were developed by an expert Residuals and Biosolids Work Group composed of WEF members from a variety of disciplines and working in all aspects of wastewater and solids management.  EPA plans to issue final rulemaking for its June 4 proposed definition of solid waste and October 14 SSI MACT standards by January 16, 2011. WEF Comment Letter   

Summary of Comments

  • Proposed Rule does not Promote Resource Recovery from Wastewater Solids
  • Current Analysis Mercury Emissions are Overestimated
  • EPA’s Control Methods and Economic Analyses Are Erroneous
  • MACT Floor Determination is Erroneous
  • Emission Regulations and Testing is Burdensome
  • The Proposed Criteria for New Sewage Sludge Incinerators Do Not Meet the Intent of the MACT Standards as the Criteria Are Unachievable
  • Greater Clarity of Sector Operations is Needed
  • Proposed Regulations are Most Restrictive in the World and Would Effectively Eliminate Incineration as an Option for the Wastewater Sector