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November 25, 1980 Request for Guidance on PSD Applicability for Refuse-to-Energy Facilities 2.14
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2.14
Mr. Daniel J. Dent Dear Mr. Dent: This is in response to your letter of October 7, 1980, in which your requested guidance on PSD applicability for refuse-to-energy facilities. Specifically, you requested information on how the daily firing rate of such a facility should be determined. To determine if the facility in question is capable of charging 250 tons of refuse per day (and thus falling into the 100 ton major source category for PSD applicability) the firing rate should be based on the solids content of the municipal waste and the dry weight of the papermill sludge. These parameters are used in order to maintain consistency with applicability and source testing under the new source performance standards for incinerators and sewage treatment plants (See 40 CFR 60, Subparts E and O). If you have any questions regarding this determination, Please contact Janet Littlejohn of my staff at 755-2564.
Edward Rice, Director Dear Mr. Rice:
Subject: Bechtel Job 14487 We are presently engaged in a feasibility study for a refuse-to-energy facility to be located in the State of Connecticut with capabilities of steam and/or electricity production. The facility will utilize modular incinerators to co-fire both municipal solid waste (MSW) and papermill sludge. The papermill sludge will have a solids content of approximately 35 percent, and the moisture content of the MSW will be in the range of 20 to 25 percent. PSD regulations at present do not define sludge for purposes of co-disposal, and we are therefore not sure whether the wet or dry weight of the sludge should be used in arriving at the total firing rate at the facility. That is, in the 250 tons/day cut off limit that determines whether an incinerator is a major source, should the dry weight of the co-fired sludge be used in reckoning that component of the mixed waste. Please call me if there are any questions concerning this request. We would appreciate your written response as soon as possible to enable us to proceed with the sizing of this facility.
DJD:FR:jd
cc: W. R. Elliott |