Potential Impacts ofMACT Standards on Biosolids Incinerators 

Municipal wastewater utilities have an obligation to serve their communities, 

protect human health and the envirorunent, meet regulatory requirements, and implement 

sustainable practices. Economic constraints make it difficult for Publicly Owned 

Treatment Works (POTWs) to balance these competing requirements. 

The potential impacts of MACT standards on utilities that incinerate their 

biosolids go beyond merely the capital costs of additional air pollution controls, and 

include: 

• Potential upgrades to meet low (MACT based) emission limits and cost 

impacts. 

Capital costs of additional air pollution controls, as well as O&M costs 

associated with operations, monitoring, and maintenance of these processes 

will increase. Moreover, these facility upgrades will require additional 

footprint at the plant; numerous facilities will require additional land and 

building space to accommodate these upgrades. Many plants are in close 

proximity to residences and are land-limited. Available area at the plant site 

has either been dedicated to additional liquid treatment capacity to meet 

increasingly stringent effluent requirements, additional flows due to growth, 

wet weather controls, or other treatment needs. 

• Shutdown of incinerators if cost prohibitive or technically infeasible to 

install add-on controls. 

If POTWs have to shutdown their incinerator operations, alternate methods of 

biosolids management must be employed. Utilities would be required to 

construct new facilities, and procure emergency or back-up type services 

during construction, most likely hauling to a landfill. The cost of emergency 

or back-up type contracts is significantly higher than longer-term contracts 

and may require significant haul distances resulting in more trucks on the road 

(increase in greenhouse gas emissions and other environmental impacts). 

[Note: the cost of landfill disposal and land application for NJ and NY 

WWTPs out of state was over 100% more what they pay now as a result of the 

Ocean Dumping Ban Act.] 

• Tradeoff for sustainable energy recovery. 

With limited funds available to municipal wastewater treatment utilities, 

facility upgrades that could provide longer-term, sustainable benefits, such as 

energy recovery facilities to produce much-needed renewable energy, would 

likely be deferred in order to meet increased emissions standards in addition to 

already complying with existing health-based and technology-based federal 

and state regulations. 
A substantial number of publicly owned treatment works (POTWs) that manage 

their biosolids through incineration simply do not have the space in their incineration 

facilities or adjoining areas to install additional equipment (e.g., advanced scrubbing 

systems, wet electrostatic precipitators, activated carbon polishing systems, etc.) that 

would be required to meet all of the anticipated MACT Standards. 

As a result, incineration would no longer be a viable option for these facilities and 

another method of biosolids management would need to be implemented. This action 

could results in substantial increases in capital expenditures, operating & maintenance 

costs, emissions of priority pollutants and/or emissions of Greenhouse Gases. 

NEORSD Residuals Management Study 

Faced with potential regulatory changes and potential increases in all of its 

wastewater residuals management costs, the Northeast Ohio Regional Sewer District 

(NEORSD) conducted a Residuals Management Study to: 

• Determine the NEORSD's residuals quantities and disposal costs 

• Investigate all potential residuals management options 

• Determine the most cost-effective, viable options 

• Develop a long term, District-wide Residuals Management Plan 

As part of this study, the NEORSD and its Consultants investigated the following 

potential biosolids management options for its wastewater treatment facilities: 

• Alkaline Stabilization 

• Composting 

• Heat Drying 

• Incineration 

• Land Application 

• Landfilling 

• Surface Disposal 

Based on a combination of detailed economic and non-economic analyses, the 

NEORSD's and its Consultants determined that the most viable, and cost-effective 

option for managing biosolids at its Southerly WWTC was to replace the four existing 

multiple hearth incinerators with three new fluidized bed incinerators. 
Biosolids Management Related Capital and O&M Costs 

The following is a summary of the capital costs and operating & maintenance 

(O&M) costs associated with the incineration, landfilling and land application of the 

biosolids generated at the Southerly WWTC. Costs are in 2014$ and based on a 25-year 

service life. 

Incineration Landfil

g Land Application 

($/wet ton) ($/wet ton) ($/wet ton) 

O&MCosts $31 $86 $80 

Total Costs 

(O&M + amortized $46 $93 $100 

capital costs) 

The following annual costs, in 2014$ were determined based on 190,000 wet tons 

of biosolids being generated annually at Southerly after the plant's existing sludge 

thermal conditioning system is removed from service in 2013: 

O&MCosts Total Costs 

Incineration $5,700,000 $8,740,000 

Landfilg $16,340,000 $17,670,000 

Land Application $15,200,000 $19,000,000 

Below is a summary of the additional total costs per year ($2014) to initiate a 

landfilling or land application program, instead of moving forward with the new fluidized 

bed incinerators: 

Additional Total Costs 

Incineration $0 

Landfilling $8.93 million/year 

Land Application $10.26 million/year 

While the cost reported herein are specifically for the Southerly WWTC, 

conversion from incineration to landfilling or land application for numerous other 

POTWs will also result in substantial cost increases. 
Emissions of Priority Pollutants 

The NEORSD and its Consultants also conducted detailed analyses to determine 

the emissions of priority pollutants associated with incineration, landfilling and land 

application of Southerly's biosolids. The following is a summary of their findings: 

Three Fluidized Trucks to Trucks to Land 

Pollutant Bed Incinerators Landfills* Application Sites * 

Carbon Monoxide 3 4 6 

Oxide of Nitrogen 44 44 65 

Sulfur Dioxide 6 4 6 

Particulate Matter 6 I 2 

Organic Compounds I 3 4 

Lead 0 0 0 

Totals 60 56 84 

* Does not mclude emissions of pnonty pollutants at the landfills or land applIcatIOn SItes 

While the emissions reported herein are specifically for the Southerly WWTC, 

conversion from incineration to landfilling or land application for numerous other 

POTWs will also result in an increase in priority pollutants. 

Greenhouse Gas Emissions 

In 2008, the NEORSD asked a Blue-Ribbon Panel of seven internationally 

renowned biosolids management experts to re-Iook at decision to more forward with 

fluidized bed incineration at Southerly, investigate newer biosolids management options 

and determine the Greenhouse Gas emissions associate with each option. 

The Blue-Ribbon Panel determined that the installation of new fluidized bed 

incinerators at the Southerly WWTC was the most viable, cost-effective and 

environmentally friendly option, and recommended that the NEORSD proceed with the 

proposed fluidized bed incineration project. 

The following is a summary of the Blue-Ribbon Panel's Greenhouse Gas 

emissions analyses: 

Biosolids Greenhouse Gas Emissions 

Process (Metric Tons CO2-equivelentlyear) 

Fluidized Bed Incineration with Energy 

Recovery and Electricity Production -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 Blue R ibbon Panel also noted that GHG emissions associated with a land 

application would be higher than incineration, but did not have time to conduct the 

analysis. 

While the emissions reported herein are specifically for the Southerly WWTC, 

conversion from incineration to land filling or land application for numerous other 

POTWs will also result in an increase in Greenhouse Gas emissions. 

Summary 

The elimination of incineration as a viable, cost-effective and environmentally 

friendly biosolids management option will result in substantial increases in capital 

expenditures, operating & maintenance costs, emissions of priority pollutants and/or 

emissions of Greenhouse Gases for a number of POTWs. 

R PD 

11-5-09