HomeMy WebLinkAboutStaff Report 1625City of Palo Alto (ID # 1625)
City Council Informational Report
Report Type: Informational Report Meeting Date: 5/16/2011
May 16, 2011 Page 1 of 2
(ID # 1625)
Council Priority: {ResProject:ClearLine}
Title: Update on EPA’s Rule for Sewage Sludge Incinerator
Subject: Update on Environmental Protection Agency’s Rule for Sewage Sludge
Incinerator Units
From:City Manager
Lead Department: Public Works
Executive Summary
On March 21, 2011, the United States Environmental Protection Agency (EPA) finalized
new regulations for sewage sludge incinerators. In November 2010, Palo Alto
submitted comments on EPA’s proposed sewage sludge incinerators rulemaking,
requesting that EPA focus on source control of mercury rather than further "end-of-
pipe" treatment in its air pollution control requirements because source control is more
cost effective (CMR 1297). In response, EPA's final regulations do not require Palo Alto
to install further mercury treatment devices, which would have cost millions of dollars.
Instead, Palo Alto will continue to implement and to improve its award-winning mercury
source control programs. Palo Alto will also continue to explore alternatives to
incineration as part of its ongoing Long Range Facilities Planning process. This is an
informational report and no action by Council is required.
Background
On October 14, 2010, EPA proposed new emissions guidelines for existing sewage
sludge incineration units. Due to a federal court decision in 2007, EPA was directed to
regulate sewage sludge incinerators as a solid waste under Section 129 of the Clean Air
Act. Section 129 of the Clean Air Act directs EPA to propose new emission limits that
are based on Maximum Achievable Control Technologies. The Palo Alto Regional Water
Quality Control Plant is one of 97 agencies nationwide that utilize sewage sludge
incinerators and are therefore affected by the new rule. Palo Alto and many other
agencies submitted comment letters on November 29, 2010. EPA acknowledged that
many of the comments submitted in response to the proposed emissions guidelines are
significant and valid, and EPA requested an extension from the federal Court. The
Court denied the request, instead ordering EPA to finalize the rule by February 21,
2011; the final rule was published in the Federal Register on March 21, 2011.
May 16, 2011 Page 2 of 2
(ID # 1625)
Discussion
The new EPA rule requires a formal incinerator training program; expanded emission
testing including cadmium, lead, mercury, carbon monoxide, hydrogen chloride, oxides
of nitrogen, particulate matter, sulfur dioxide, and dioxins and furans; a new Title V
permit; and additional recordkeeping. Due to Palo Alto’s relatively new air pollution
control equipment, Palo Alto is able to comfortably meet all of the emission limits
required by the new EPA rule, except for oxides of nitrogen. The oxides of nitrogen
limit will be met through process optimization. Palo Alto’s mercury emissions are
approximately 0.03 lbs per day; the emissions are low due to Palo Alto’s source control
efforts, specifically the dental amalgam program that reduced mercury emissions by
approximately 50 percent. While the final regulations will increase regulatory
requirements applicable to the incinerator, EPA's decision is favorable for Palo Alto
because Palo Alto will not have to spend millions of dollars on expensive stack gas
treatment systems for further mercury control. Rather, Palo Alto will continue to spend
its resources on far more cost effective source control measures. The new regulations
will become effective in four to five years, depending on the implementation schedule
established by the California Air Resources Board.
Prepared By:Karin North, Associate Engineer
Department Head:J. Michael Sartor, Interim Director
City Manager Approval: James Keene, City Manager