The EPA has proposed new rules directed at emissions from sewage sludge incinerator (SSI) units. SSI units are typically found at wastewater treatment facilities and, according to the EPA, are the sixth-largest source of mercury air emissions in the US. The proposal not only limits mercury emissions, but also sets standard and emission guidelines for eight other pollutants, including lead, cadmium, hydrogen chloride, particulate matter, carbon monoxide, dioxins and furans, nitrogen oxide, and sulfur dioxide. However, mercury is of particular interest because the proposed emission standard is more stringent than the mandates that were set under the Clean Air Act.

Learn more about Mercury emissions from sewage incinerators…

Recently, the EPA announced it intends to propose a rule to reduce mercury waste from dental offices. Mercury is a concern to human health because it is considered a persistent bioaccumulative toxic element.

According to the EPA, dental amalgams, or fillings containing mercury, account for 3.7 tons of mercury discharged into US waterways each year.

Read more about Reducing Mercury from Dental Offices

In a Federal Register notice published June 23, the EPA proposed changes to its permitting program under the Clean Water Act (CWA) to ensure the use of sufficiently sensitive analytical methods for monitoring chemical pollutants in discharge water.

Specifically, the new rule affects the CWA’s National Pollutant Discharge Elimination System (NPDES). Its purpose is to specify that applicants and permittees must use analytical methods that are capable of detecting and measuring pollutants at, or below, current water quality criteria.

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Under the Resource Conservation and Recovery Act (RCRA), the EPA has proposed a rule that would regulate coal combustion residuals (CCR) for the first time.

CCRs, commonly known as coal ash, are residues captured from the combustion of coal at power plants and are typically disposed of at large surface impoundments in liquid (wet or slurried) form and at landfills in solid (dry) form. CCRs are currently considered exempt wastes under an RCRA amendment.

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By Ed Wallace, Project Chemist, Kelso, WA

EPA Method 29 measures hazardous air pollutant (HAP) emissions from stationary sources for mercury and other metals. The Clean Air Act (CAA) requires all major sources to meet HAP emission standards reflecting the application of maximum achievable control technology (MACT). These sources include industrial, commercial, and institutional boilers and process heaters. The other metals to be tested are antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, manganese, nickel, phosphorus, selenium, thallium and zinc.

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On September 13, 2004, the EPA promulgated Maximum Achievable Control Technology (MACT) emissions standards for industrial boilers. Emission limits were established for total selected metals (TSM), mercury (Hg), and hydrochloric acid (HCl). The heat content and moisture content of the fuel is also discussed in the rule. The regulations include site-specific fuel analysis plans to demonstrate compliance. The regulations specify approved procedures for sample collection, sample processing, sample preparation, and chemical analysis. The approved methods are shown in Table 6 of the boiler MACT rule. The regulations also allow the use of equivalent methods and alternative methods. In order to meet site-specific emission limits, equivalent and alternative methods are often used in the fuel analysis plan. When alternative test methods are used a written request seeking approval of its use must be submitted to the EPA. The compliance date for these industrial boilers is September 13, 2007. Compliance can be demonstrated by fuel testing or with stack testing in combination with fuel testing.

This article is divided into two parts: recommended solid fuel testing techniques and recommended stack testing techniques for compliance with boiler MACT regulations.

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Mercury is responsible for over three-quarters of all contaminant-related advisories for threats to human health. During the 1990’s, the number of mercury related fish consumption advisories more than doubled, despite significant decreases in the total mercury emissions over the last 20 years. The increase in advisories is probably the result of more testing rather than more contamination.

While the contamination is showing up in lakes and fish, most mercury does not come from effluent, rather is derived from atmospheric deposition. Atmospheric transport and subsequent bioaccumulation of mercury can affect aquatic ecosystems far from mercury sources. According to EPA estimates, emissions from coal-fired utilities account for 13 to 26 percent of the total (natural plus anthropogenic) airborne emissions of mercury in the United States. Thus, the EPA has begun to regulate emissions from power plant boilers and process heaters.

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