The following letter is being published at the request of the Stony Brook Regional Sewerage Authority, which services West Windsor, as well as Pennington Borough, Princeton, Hopewell Borough, Hopewell Township and South Brunswick Township.
Stony Brook Regional Sewerage Authority has entered into a Consent Decree with the United States Department of Environmental Protection and the New Jersey Department of Environmental Protection. The Consent Decree addresses notices of violation brought by the EPA and DEP alleging that SBRSA violated the Clean Air Act and associated laws and regulations with respect to SBRSA’s operation of two sewage sludge incinerators at its facility located on River Road in Princeton.
Without admitting liability and to avoid further litigation that would likely result in significantly higher costs, SBRSA has agreed to pay $335,750 in civil penalties shared equally by EPA and DEP. In addition, SBRSA has agreed to commit an additional $44,250 to DEP’s Environmental Mitigation Project Fund.
The majority of the violations alleged by EPA and DEP relate to SBRSA’s operation of an emergency bypass stack designed to protect the health and safety of employees, and SBRSA’s infrastructure, in the rare instances when commercial power or an equipment failure occurs. Although SBRSA’s sewage sludge incinerators are designed so that sludge (a byproduct of wastewater treatment) automatically stops feeding in the event of an emergency, it is impossible to stop burning instantaneously and emergency action must be taken.
Without the operation of the emergency bypass stack, the exhaust gases would fill areas where employees are present and would damage the incinerator air pollution control equipment. The emergency bypass stack is used approximately 0.04% of the time that the incinerators are in operation and only during events beyond the control of SBRSA.
SBRSA has implemented procedures to reduce the use of the emergency bypass stack. For example, SBRSA does not operate the incinerators in anticipation of severe weather or heavy rainfall, which have been associated with commercial power failures, and has installed an uninterruptible power supply or “UPS system” on critical components that provides emergency power when commercial power fails, in an effort to reduce emergency bypass events.
SBRSA endeavors to achieve compliance, or perform better than required by its permit at all times, and continuously works to protect the environment. To this end, several years ago, SBRSA installed a regenerative thermal oxidizer. The RTO recycles heat from the exhaust thus reducing the amount of fossil fuels required to maintain temperatures within the incineration system. The reduced use of fossil fuels and resulting reduction in adverse emissions are beneficial to the environment.
EPA and DEP also cited SBRSA for failing to file control plans specifically identifying steps taken to ensure that mercury, dioxins and furans are appropriately controlled. Apart from this misunderstanding over regulatory reporting, SBRSA’s daily sampling and monthly analysis of sludge fed to the incinerator, and verification through periodic stack emission testing, establish that mercury emissions have always been significantly less than the amount allowed under the Clean Air Act and SBRSA’s operating permit. Emissions of dioxins and furans have been negligible. In fact, emissions of all pollutants have always been less than the amount allowed under the Clean Air Act and SBRSA’s operating permit. Under the Consent Decree, SBRSA has agreed to incorporate mercury, furans, and dioxins, into future control plans.
SBRSA operates three wastewater treatment plants for parts of Princeton, West Windsor Township, South Brunswick Township, Pennington Borough, Hopewell Borough, Hopewell Township, and Plainsboro Township. At the River Road plant in Princeton, SBRSA incinerates its own sewage sludge and also incinerates sludge generated by other wastewater treatment facilities throughout the state of New Jersey. SBRSA has always been proactive.
SBRSA was among the first entities in the State to install afterburners and Continuous Emissions Monitoring Systems (CEMS), among the first in the State to permit and model the emergency bypass stack emissions, and the first New Jersey Sanitary Sewage Sludge Incinerator facility to obtain a Title V Operating Permit (TVOP). This desire to operate its Multiple Hearth Sewage Sludge Incinerator in an efficient and environmentally protective manner continues to this day. SBRSA remains committed to operating the incinerators in compliance with all applicable laws and regulations.
Questions regarding this matter should be addressed to Gale D. Downey, PhD at email@example.com.