One City’s Approach to Meeting Upcoming Incineration Regulations through Expedited Design


  • Laurissa Cubbage, PE, Todd Johnson, PE, Hunter Long, PE, Alan Stone, PE, Terry Houk, Carol McDowell, and Ken Newnam

To outline a unique collaborative design, procurement, and construction approach for solids handling and sewage sludge incineration upgrades. Upgrades to an existing incineration system were evaluated and ultimately selected over other disposal options to fully meet recently promulgated federal regulations and to provide the City with stable long-term biosolids disposal.

In water resource recovery facilities, handling and disposal of biosolids represents approximately 40% of the operational expenditures for a utility. Incineration is a biosolids disposal method which thermally oxidizes dewatered cake biosolids within a controlled environment and requires equipment and controls for reducing air pollutant emissions. By March 2016, municipalities are required to comply with new regulations for sewage sludge incinerators establishing air emission limits using the maximum achievable control technology (MACT) provisions of the Clean Air Act Section 129. One City compared the cost of upgrading its 3,000 dry-lbs/hr incinerator to meet the new regulations with landfilling and disposal privatization. The evaluation included estimated cost of treatment and assisted the City in deciding to continue disposal by incineration. In addition, the City’s solids handling facilities experienced recent equipment failure and were due for an upgrade.

Upon detailed review of replacing aging infrastructure and equipment required to meet the air emissions regulations, it was determined that long-lead equipment (some with a 54-week lead time) would need to be pre-procured by the City to allow arrival and installation by a contractor before the March 2016 deadline. Three procurement packages were bid which included incineration upgrades, high solids centrifuges and accessories, cake pumps and a dewatered cake storage hopper. The engineer with collaboration of the City and three equipment manufacturers produced unique design-bid-build construction documents which included completed manufacturers’ shop drawings. The design and construction phases proceeded on an expedited schedule in order for the installation to be complete and operational in time for compliance. The City, engineer, contractor and procurement manufacturers contributed to each phase of construction. The expedited schedule and project format created more risk than typical design-bid-build projects for the City, engineer, and contractor but is on track to be a successful installation that meets compliance by March 2016.

For more information, please contact the author at

Hear about new publications with our email newsletter

We will never share your details with anyone else.


Newsletter Newsletter

Horizons Fall 2017 (pdf)

Horizons showcases significant water, wastewater, reuse, and stormwater projects and innovations that help our clients to achieve their goals, and can help you achieve yours. Articles are written by top engineers and process group leaders, demonstrating and explaining the beneficial application of a variety of technologies and tools.

View previous issues »