MEMORANDUM

Date: April 7, 2015

Subject: Emissions and Unit Inventory for Federal Plan Requirements for Sewage Sludge

Incineration Units Constructed on or Before October 14, 2010

From: Amy Hambrick

OAQPS/SPPD ( E143

- 03 )

U.S. Envir onmental Protection Agency

Research Triangle Park, NC 27711

To: SSI Federal Plan Docket

I. Introduction

Under sections 111 and 129 of the Clean Air Act (CAA), the U.S. Environmental

Protection Agency (EPA) is required to develop emissions guidelines (EG) for existing sewage

sludge incinerators ( SS I) and new source performance standards (NSPS) for new SSI

. The

regulations are designed to limit emissions of nine poll utants from these SS I. The nine pollutants

are hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg),

particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NO X ), and sulfur dioxide

(SO 2 ). Regulations for the S SI category were promulgated on March 21, 2011

. The EG are

codified in 40 CFR part 60, subpart MMMM , and the NSPS are codified in 40 CFR part 60,

subpart LLLL

. Certain aspects of the SSI regulations were remanded by the U.S. Court of

Appeals for the D.C. Circuit (the Court) on August 20, 2013, for further explanation. The court did

not vacate the NSPS or EG and the requirements of the rules therefore remain in place.

Unlike the subpart LLLL NSPS, which apply directly to new sources, states must develop

a State Plan in order to compel existing sources to meet the subpart MMMM EG. Together,

subpart B and subpart MMMM of part 60 specify the State Plan content and the general rules for

adopting and submitting these State Plans. State Plans to implement the EG adopted on March

21, 2011, were due to EPA for review and approval on March 21 , 201 2

. The EG require EPA to

develop and implement a Federal Plan for each state that does not have an approved State Plan

. The Federal Plan to implement the March 21, 2011, EG will be codified in 40 CFR part 62,

subpart LLL

.

For approval, one of the requirements of a State Plan is a source inventory and an

emissions inventory. Likewise, the Federal Plan must contain a source and emissions inventory

for SSI not cover ed under a State Plan. The purpose of this memorandum is to present an

updated source and emissions inventory of the SSI industry for the proposed Federal Plan. The

source and emissions inventories are presented in Appendix A and B

. Appendix C

- 1 to 3 sh ow

which units have shut down since 201 1 and units that intend to shut down prior to 2016

.II. Federal Plan Inventory

Based on recently obtained inventory information, EPA has determined that there are 1 8 5

SSI currently operating located at 98 facilities in 25 states. The inventory of SSI was developed

and updated as a result of contacts with EPA Regions, s tates, and SSI facilities and review of

existing SSI inventories, title V permits, emissions test reports, and facility websites. The EPA

recognizes tha t this list may not be complete. Therefore, sources potentially subject to the

proposed SSI federal plan may include, but are not limited to, the SSI listed in Appendix A of this

memorandum in Docket No. Docket No. EPA

- HQ

- OAR

- 2012

- 0319

. Any SSI that meets the

applicability criteria in the proposed federal plan rule would be subject to the federal plan,

regardless of whether it is listed in the inventory. States or individuals are invited to identify

additional sources for inclusion to the list during the c omment period for this proposed federal

plan.

SSI Units Shut Down Since March 21, 2011

The March 21, 2011, NSPS and EG estimated 204 SSI units. As document ed in Appendix

C

- 1 and 3 , a total of 2 2 units have shut down since the promulgation of the SSI EG and NSPS on

March 21, 2011. It is helpful to examine the units that have shut down in order to fully understand

the SSI inventory changes :

- 7 units have been confirmed by their respective states to have shut down after March 21, 2011 ;

- 9 units were identified by s tates to have shut down a number of years prior to the promulgation

of the March 21, 2011 ;

- 5 units were identified by s tates that they do not believe exist

, contrary to EPA’s belief in the

March 21, 2011

, EG and NSPS record ;

- 1 unit’s shut down date is unknown.

For simplicity for the purpose of this inventory, we will consider all of these units “shut down”

since March 21, 2011

, even though only potentially 8 units 1 actually fit this description.

Units That Plan to Shutdown by March 21, 2016

As documented in Appendix C

- 2, 7 units located at 3 facilities in 3 states have submitted

correspondence to EPA or State environmental offices indicating that they are currently operating

but intend to shut down by March 21, 2016. Please note that 1 facility plans on replacing the 4

units it plans to shut down with 3 new more efficient units. For the purpose of this inventory, these

units are listed as currently oper ating

, as the facilities still have active operating permits with their

respective State agencies.

Facilities with other identified changes since March 21, 2011

1 The 8 units are comprised of the following “ 7 units have been confirmed by their respective states to

have shut down after March 21, 2011 ” and “ 1 unit’s shut down date is unknown. ”Other recent changes to facilities were confirm ed by EPA Regions and states . These

changes are described i n the Appendix A spreadsheet “Notes” column. Specifically, changes

identified include the following:

- Correcting 1 facility address

- The addition of 2 units not previ ously listed in the 2011 inventory 2

- Planned addition of 3 fluidized bed units to replace 4 multiple hearth units sometime in 2014

- Confirming units’ existence and last operational date

Appendix C

- 3 documents e

- mail correspondence from EPA Regions and states identifying

these changes.

III. Emissions Inventory

For the purpose of this federal plan proposal, EPA updated t he emissions inventory based

on available information about the SSI and typical emissions rates that were developed for

calculating nationwide air impacts of the 2011 EG. Units that wer e identified as shut down since

March 21, 2011, were removed from this inventory. S ubsequently

, the two units

, “NYWatertown” and “MNBuffalo,” that were not previously listed were added to this inventory

. These units’ emissions were estimated based on th e same methodology used to estimate baseline

emissions of the 2011 EG 3

. States or individuals are invited to identify additional sources for

inclusion in the emissions inventory during the comment period for this proposed federal plan.

Refer to Appendix B of this memorandum for the complete updated emissions inventory.

IV. Appendix

Appendix A : SSI Source Inventory Currently In Operation

Appendix B : SSI Emissions Inventory

Appendix C

- 1 : SSI Units Shut Down Since March 21, 2011

Appendix C

- 2 : Units That Intend to Shutdown By March 21, 2016

Appendix C

- 3 : Email Correspondence

2 See, “Revised Estimation of Baseline Emissions from Existing Sewage Sludge Incineration Units” at

Docket ID No. EPA

- HQ

- OAR

- 2009

- 0559

- 0154 and “ Final: Promulgation Inventory and Database” at

Docket ID No. EPA

- HQ

- OAR

- 2009

- 0559

- 0154

- 0049.

3 See, footnote 1 and “ Final: Post

- Proposal SSI Database Revisions and Data Gap Filling Methodology ”

at Docket ID No. EPA

- HQ

- OAR

- 2009

- 0559

- 0156 ”Appendix A: SSI Source Inventory Currently In OperationAppendix B: SSI Emissions InventoryAppendix C

- 1 : SSI Units Shut Down Since March 21, 2011

Appendix C

- 2 : Units That Intend to Shutdown b y March 21, 2016Appendix C

- 2 : Email Correspondence



### Contents

Region 1

................................ ................................ ................................ ................................ ................................ ........ 8

Massachusetts

................................ ................................ ................................ ................................ .......................... 8

Region 2

................................ ................................ ................................ ................................ ................................ ........ 8

New Jersey

................................ ................................ ................................ ................................ ................................ 8

New York

................................ ................................ ................................ ................................ ................................ ... 8

Puerto Rico

................................ ................................ ................................ ................................ ............................. 12

Virgin Islands

................................ ................................ ................................ ................................ ........................... 12

Region 3

................................ ................................ ................................ ................................ ................................ ...... 13

Pennsylvania

................................ ................................ ................................ ................................ ........................... 13

Region 4

................................ ................................ ................................ ................................ ................................ ...... 13

All Region 4 States

................................ ................................ ................................ ................................ .................. 13

Region 5

................................ ................................ ................................ ................................ ................................ ...... 14

All Region 5 States

................................ ................................ ................................ ................................ .................. 14

Illinois

................................ ................................ ................................ ................................ ................................ ...... 16

Indiana

................................ ................................ ................................ ................................ ................................ .... 16

Michigan

................................ ................................ ................................ ................................ ................................ . 16

Minnesota

................................ ................................ ................................ ................................ ............................... 17

Ohio

................................ ................................ ................................ ................................ ................................ ........ 18

Wisconsin

................................ ................................ ................................ ................................ ................................ 19

Region 6

................................ ................................ ................................ ................................ ................................ ...... 19

All Region 6 States

................................ ................................ ................................ ................................ .................. 19

Region 7

................................ ................................ ................................ ................................ ................................ ...... 20

Iowa

................................ ................................ ................................ ................................ ................................ ........ 20

Region 8

................................ ................................ ................................ ................................ ................................ ...... 20

All Region 8 States

................................ ................................ ................................ ................................ .................. 20

Region 9

................................ ................................ ................................ ................................ ................................ ...... 21

All Region 9 States

................................ ................................ ................................ ................................ .................. 21

Region 10

................................ ................................ ................................ ................................ ................................ .... 22

Alaska

................................ ................................ ................................ ................................ ................................ ...... 22

### Region 1

Massachusetts

From: Bird, Patrick

Sent: Monday, November 18, 2013 11:31 AM

To: Hambrick, Amy

Cc: McDonnell, Ida

Subject: RE: Action Request Region 1 SSI Status Update

Hi Amy,

See my comments in red below. We also have one unit which closed (see attached documentation). I

updated the inventory with strikeout.

MAFitchburgEast

Thanks,

Pat

Patrick Bird

U.S. EPA

- Region 1

5 Pos t Office Square, OEP05

- 2

Boston, MA 02109

- 3912

Phone: 617

- 918

- 1287

Fax: 617

- 918

- 0287

Email: Bird.Patrick@epa.gov



### Region 2

New Jersey

Region confirmed that they received notification dated 1/6/2014 that NJPequan nockLincolnFairfield both units are

to shut down prior to March 21, 2016 however currently operating

. From: Gardella, Anthony

Sent: Monday, November 25, 2013 4:00 PM

To: Hambrick, Amy

Subject: RE: Action Request Region 2 SSI Status Update

- FOR NEW JERSEY

Hi Amy,

I just heard from NJ.

You can delete “Camden County Municipal Utilities Authority” from the Source Inventory Table since

the facility does not have a SSI unit.

Also, they said that NJ will probably do the federal plan but they will need to rev iew it first to confirm in

house capability and if there are sufficient resources.

Ted

212

- 637

- 3892



### New York

From: Gardella, Anthony

Sent: Friday, November 15, 2013 10:37 AMTo: Hambrick, Amy

Subject: FW: FW: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

- FOR New York

Amy

I sent out the request to all the R2 states. Here’s what I got back from NY. Is this sufficient or do you

need more info?

Thanks

Ted

Ted Gardella

EPA Region 2

212

- 637

- 3892

From: John Henkes [ mailto:jlhenkes@gw.dec.state.ny.us ]

Sent: Friday, November 15, 2013 9:46 AM

To: Gardella, Anthony

Cc: Michael Cronin

Subject: Re: FW: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

Hi Ted,

As we discussed, the following is offered to update EPA's information on operating SSI units in NYS.

No SSI units operating at the following:

NY Auburn shut down 9/09

NYFrankEVanLare (no SSI unit ever?)

NYNewRochelle shut down 1989

NYNoethWestQuadrant shut down ????

NYOrangeTown shut down 12/2005

NYOssining shut down 1989

NYPortChester shut down 6/2011

NYSchenectady (no SSI unit ever?)

Two facilities with operating SSI units not on your current list:

NYLittleFalls WPC 233 River Rd E., Little Falls NY, Herkimer Co. 1 Fluidized Bed Incinerator Intends to

surrender permit and close facility by March 2016

NYWaterTown WPCF 700 WMT Field Dr, Watertown NY, Jefferson Co. 1 Fluidized Bed Incinerator Intends to

surrender permit and close fa cility by March 2016

The rest of the table appears up to date:

John L Henkes, PE

NYSDEC, Environmental Engineer II

Bureau of Stationary Sources

(518)402

- 8403

(518)402

- 9035 fax

From: Hambrick, Amy

Sent: Wednesday, January 29, 2014 1:32 PM

To: Hambrick, Amy

Subject: FW: FW: FW: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

- FOR New

York

AmyI’m checking everything with NY

– not sure when I’ll get a response. I see in their SP that Little Falls has

a rate of 720 lb/hr

– not sure if t his is feed rate or unit capacity. No info if any APC devices.

Ted

Amy Hambrick

Fuels & Incineration Group

Office of Air Quality Planning & Standards

U.S. Environmental Protection Agency

+ 1 (919) 541

- 0964 (O)

+ 1 (919) 541

- 3470 (F)

From: John Henkes [ mailto:jlhenkes@gw.dec.state.ny.us ]

Sent: Wednesday, January 29, 2014 8:53 AM

To: Gardella, Anthony; Hambrick, Amy

Cc: Michael Cronin

Subject: Re: FW: FW: Action Request

- Sewage Sludge Incinerators (SS I) Status Update

- FOR New

York

Hi Ted, Amy

Attached are the Air Registrations for the Little Falls & Watertown SSI's.

Little Falls permit has expired. The Little falls SSI had a design capacity of 720 dry lbs/hour; it didn't

have air pollution con trols; and it is currently being dismantled.

The Watertown SSI has wet scrubber as emission control; no information as to its capacity.

Hope this helps...

John L Henkes, PE

NYSDEC, Environmental Engineer II

Bureau of Stationary Sources

(518)402

- 8403

(518)402

- 9035 fax

jlhenkes@gw.dec.state.ny.us >>> "Gardella, Anthony" < Gardella.Anthony@epa.gov > 1/28/2014 1:23 PM

>>>

John

Another question from Amy

– can you let me know. Amy is trying to complete the Federal plan. Thanks

Ted

From: Hambrick, Amy

Sent: Tuesday, January 28, 2014 1:12 PMTo: Gardella, Anthony

Subject: RE: FW: Action Request

- Sewage Sludge Incinerators (SSI ) Status Update

- FOR New York

Ted,

A second question: I am looking for a copy of these two facilities’ permits on NY’s webpage and cannot

find them. Could they be under different names or would they be synthetic minors? I was hoping to get a

sense of u nit capacity and feed rate. I don’t want to take a ton of your time but if you have a quick insight,

I’ll take it. If not don’t worry about it.

Thanks,

Amy

Amy Hambrick

Fuels & Incineration Group

Office of Air Quality Planning & Standards

U.S. Environm ental Protection Agency

+ 1 (919) 541

- 0964 (O)

+ 1 (919) 541

- 3470 (F)

From: Hambrick, Amy

Sent: Tuesday, January 28, 2014 1:01 PM

To: Gardella, Anthony

Subject: RE: FW: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

- FOR New York

Ted,

I have a follow up question for you:

RE:

Two facilities with operating SSI units not on your current list:

NYLittleFalls WPC 233 River Rd E., Little Falls NY, Herkimer Co. 1 Fluidized Bed

Incinerator Intends to surrender permit and close facility by March 2016

NYWaterTown WPCF 700 WMT Field Dr, Watertown NY, Jefferson Co. 1 Fluidized Bed

Incinerator Intends to surrender permit and close facility by March 2016

Q: Do these FB units have any air pollution control devices? If so what are they?

Thanks,

AmyAmy Hambrick

Fuels & Incineration Group

Office of Air Quality Planning & Standards

U.S. Envi ronmental Protection Agency

+ 1 (919) 541

- 0964 (O)

+ 1 (919) 541

- 3470 (F)



### Puerto Rico

From: Gardella, Anthony

Sent: Friday, November 15, 2013 11:28 AM

To: Hambrick, Amy

Subject: FW: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

- FOR Pu erto Rico

Amy.

Here’s what I got from PR EQB. Looks like only a change in the facility address.

Ted

From: Delgado Medero, Leimarys [ mailto:LeimarysDelgado@jca.gobierno.pr ]

Sent: Friday, November 15, 2013 7:47 AM

To: Gardella, Anthony

Cc: Sierra Torres, Luis R.; Claudio, Francisco; Aponte, John

Subject: RE: Action Request

- Sewage Sludge Incinerators (SSI) Status Update

Hi

PR unit is in operation. The Physical address for PRASA Puerto Nuevo is:

J. F. Kennedy Avenue

State Road PR

- 2, KM 2.0

San Juan, Puerto Rico

Cordially,

Leimarys Delgado Medero, P.E.

Chief, Permits & Engineering Division / Jefa, Div. Permisos e Ingeniería Air Quality Area/ Área de Calidad de Aire

Puerto Rico Environmental Quality Board / Junta de Calidad Ambiental

P.O. Box 11488

San Juan, P.R. 00910

(: 787

- 767

- 8181, Ext. 3278

6: 787

- 756

- 5906



### Virgin Islands

From: Gardella, Anthony

Sent: Monday, November 25, 2013 3:10 PM

To: Hambrick, Amy

Subject: RE: Action Request Region 2 SSI S tatus Update

- FOR THE VIRGIN ISLANDS

Hi Amy

The VI informed me that they are unaware of any SSI units in the territory.

Ted

### Region 3

Pennsylvania

From: Gordon, Michael

Sent: Wednesday, November 20, 2013 11:57 AM

To: Hambrick, Amy

Subject: RE: Action Request Region 3 SSI Status Update

Amy,

Here’s R3’s data for the SSI FP. Let me know if you have any questions!

Question for Region: I don’t know of any SSI in DC, Delaware, or West VA, do you? There

are no SSIs that EPA is aware of, or that the state/local reported for DC, DE, and WV. They all

submitted a negative dec.

PAKiskiValley Kiski Valley WPCA Kiski Valley

WPCA Shutdown

- Mike

Mike Gordon

Environmental Engineer

EPA Region III

Office of Permits & Air Toxics 3AP10

1650 Arch Street

Philadelphia, PA 19103

(215)

- 814

- 2039

Gordon.Mike@epa.gov



### Region 4

All Region 4 States

From: Kukier, Stan

Sent: Thursday, December 05, 2013 3:10 PM

To: Hambrick, Amy

Subject: RE: Action Request Region 4 SSI Status Update

Hi Amy,

Wanted to try and get this back to you without too much delay. I have been out of the office quite a bit

the past few weeks with some use or lose leave and other regular leave. I know the shutdown has thrown

a bunch of stuff off schedule as well. Of course, I appreciate all of your help very much. This

information should be up to date as of 12/05/13. Hope this information is helpful. I know that lots of

folks will be out so on on annual leave over the holidays. I will be out of the office on A/L until the

second week in January. Hope all is well. Wanted to wish you the best for the holidays as well.

Thanks,

Stan

(404)562

- 9046

### Region 5

All Region 5 States

From: Sieffert, M argaret

Sent: Monday, November 25, 2013 4:19 PM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Here is what our air enforcement staff provided regarding your request. I have sent it out to the states for

verification/clarification. I wil l forward those responses separately once I receive them.

Thanks, Margaret

From: Schaufelberger, Daniel

Sent: Wednesday, November 20, 2013 10:57 AM

To: Sieffert, Margaret

Subject: RE: OAQPS SSI Status Update Request

Margaret

– See my responses below in red.

Question for Region: I don’t know of any SSI in Illinois, do you?

No, there are no SSI’s in the state of Illinois.

FacilityID NumberOfUnits Unit ID Unit

Type FacilityOrUnitNotes

INBelmontNorth 8 1, 2, 3, 4 MH There are currently 8

operating MH

SSI’s. Unit ID’s 1

- 8.

MIAnnArbor 1 1 MH My records indicate

that this unit was

removed. Need to

verify this.

MIBattleCreek 2 1 and 2 MH This is correct.

MIDetroitComplex1 6 1, 2, 3, 4,

5, 6 MH This is correct.

MIDetroitComplex2 8 1, 2, 3, 4,

5, 6, 7, 8 MH Unit ID’s are 7

- 14

MIFlint 4 1, 2, 3, 4 MH This is correct.

MIPontiacAuburn 1 1 MH This is correct.

MIWarren 1 1 MH This is correct.

MIYpsilanti 1 EU

- FBSSI FB This is correct.

MNSeneca 2 Incinerator

1 and 2 MH This is correct.MNStPaulMetro 3 FBR 1,

FBR 2,

FBR 3 FB Replaced 6 MH with 3

FB.

This is correct.

OHCanton 2 1 and 2 MH This is correct.

OHColumbusSoutherly 4 3 and 4 MH My records indicate

that there are 4 MH’s

with ID’s 1

– 4.

OHEuclid 2 1 and 2 MH This is correct.

OHJacksonPike 2 1 and 2 MH This is correct.

OHLittleMiami 1 1 FB FB replaced a MH.

Other MH was

abandoned or no longer

permitted. This is

correct.

OHMillCreek *6 1, 2, 3 FB *3 new FBs will

replace the 6 existing

MHs in 2010. My

records indicate 6 MH

w/ ID’s 1

– 6.

OHNEORSDEasterly 1 1 FB This is correct.

OHNEORSDSoutherly 4 1, 2, 3, 4 MH My records indicate

that the 4 MH’s were

replaced with 3 FB’s.

OHNEORSDWesterly 2 2 MH I think 1 shut down?

My records show 2

FB’s (Units 1 & 2).

OHWilloughbyEastlake 1 1 MH This is correct.

OHYoungstown 2 1 and 2 MH This is correct.

WIGreenBayMetro 2 1 and 2 MH This is correct.

Daniel Schaufelberger

U.S. Environmental Protection Agency, Region 5

77 West Jackson Blvd. (AE

- 17J)

Chicago, IL 60604

- 3590

Phone: (312) 886

- 6814

### Illinois

From: Sieffert, Margaret

Sent: Wednesday, November 27, 2013 10:40 AM

To: Hambrick, Amy

Subject: RE: OAQPS SSI Status Update Request

I haven’t heard back from Illinois and am not sure if I will at this point so un less you hear back from me

before your deadline assume there are no SSI facilities in Illinois. Otherwise I believe you have

everything else for R5.

Thanks and have a happy thanksgiving,

Margaret



### Indiana

From: Sieffert, Margaret

Sent: Monday, November 2 5, 2013 4:21 PM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Indiana’s response.

From: Bem, Susan [ mailto:SBEM@idem.IN.gov ]

Sent: Friday, November 22, 2013 8:11 AM

To: Sieffert, Margaret

Subject: R E: OAQPS SSI Status Update Request

For Belmont there are 8 units. Four of them have not operated since 1994. Units 1

- 4 are currently in

use. So there are 8 units but you might want to note that 4 of them are not in current operation.



### Michigan

From: Sief

fert, Margaret

Sent: Monday, November 25, 2013 4:19 PM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Michigan’s response.

From: Khan, Asad (DEQ) [ mailto:KHANA@michigan.gov ]

Sent: Monday, November 25, 2013 3:10 PM

To: Sieffert, Margaret

Cc: Maupin, Mary (DEQ)

Subject: OAQPS SSI Status Update Request

Margaret,

Our emissions inventory records indicate that all the SSI units that your spreadsheet shows operational is

correct.

However, the unit numbers for the Detroit complex 1 and 2 are under one stationary source ID # B

2103; the unit numbers are 1 to 14 for the two complexes (1 and 2) in your records, and that’s why the

unit numbers in complex 1 are from 1 to 6 and in complex 2 are 7 to 14.

Shou ld you have any questions please contact me.

Asad Khan

517

- 284

- 6751

### Minnesota

From: Sieffert, Margaret

Sent: Monday, November 25, 2013 4:33 PM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Minnesota’s response.

From: Jackson, Anne M (MPCA) [ mailto:Anne.Jackson@state.mn.us ]

Sent: Monday, November 25, 2013 3:31 PM

To: Sieffert, Margaret

Subject: RE: OAQPS SSI Status Update Request

See additional incinerator in list. It is neither a FB or MH unit.

From: Sieffert, Margaret

Sent: Thursday, November 21, 2013 1:26 PM

To: 'Anne.Jackson@state.mn.us'; 'dana.thompson@epa.state.oh.us'; 'David Bloomberg';

'IrvineR@michigan.gov'; 'Mary Maupin'; 'ralph.patterson@wisconsin.gov'; 'sbem@idem.in.gov'

Sub ject: FW: OAQPS SSI Status Update Request

Question for Region: I don’t know of any SSI in Illinois, do you? No, there are no SSI’s in the state of

Illinois.

MNBuffalo

- NEW ADDITION

From: Sieffert, Margaret

Sent: Tuesday, January 28, 2014 1:23 PM

To: Jac kson, Anne M (MPCA); Hambrick, Amy

Subject: RE: OAQPS SSI Status Update Request

Thank you Anne for the quick response.

From: Jackson, Anne M (MPCA) [ mailto:Anne.Jackson@state.mn.us ]

Sent: Tuesday, January 28, 2014 12:22 PM

To: Hambrick, Amy; Sieffert, Margaret

Subject: RE: OAQPS SSI Status Update Request

Yes, those are the permits.

From: Hambrick, Amy [ mailto:Hambrick.Amy@epa.gov ]

Sent: Tuesday, January 28, 2014 12:20 PM

To: Sieffert, Margaret

Cc: Jackson, Anne M (MPCA)

Subject: RE: OAQPS SSI Status Update Request

HI Margaret,

I have a follow up question for you RE:MNBuffalo City of Buffalo

WWTP City of Buffalo 1 25th St SE Buffalo MN 55313 1 EU 001 Belt dryer

and

incinerator NEW ADDITION

Can you confirm this is their permit:

http://www.pca.state.mn.us/index.php/view

- document.html?gid=11124

- 2009

http://www.pca.state.mn.us/index.php/view

- document.html?gid=11125

- 2007

http://www.pca.stat e.mn.us/index.php/view

- document.html?gid=11126

- 2006

Thank you,

Amy

Amy Hambrick

Fuels & Incineration Group

Office of Air Quality Planning & Standards

U.S. Environmental Protection Agency

+ 1 (919) 541

- 0964 (O)

+ 1 (919) 541

- 3470 (F)



### Ohio

From: Sieff

ert, Margaret

Sent: Wednesday, November 27, 2013 7:41 AM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Ohio’s response.

From: Thompson, Dana [ mailto:dana.thompson@epa.ohio.gov ]

Sent: Tues day, November 26, 2013 1:44 PM

To: Sieffert, Margaret

Subject: RE: OAQPS SSI Status Update Request

Margaret:

Sorry, I forgot about this. I checked our STARS2 permitting database and found the following:

City of Euclid: They did have four units, but all fou r have been permanently shut down, most recently in

2000.

NEORSD Southerly: The three fluidized bed units that will replace the four MH’s will become

operational in 2014. A draft title 5 permit is being issued today.

NEORSD Westerly: It has two operating multiple hearth units with wet scrubbers. I don’t why the lists I

generated in April and May show only one. There are two synthetic minor permits, both of which expire

next month. The two units are not intended to be operated simultaneously.

Hami lton County Mill Creek: They have about seven units that have been out of service for some time,

and at present they’re operating three 4 dry ton/hour fluidized bed units (N008, N009, and N010). They’re

contesting some language that’s been put into their o perating permit pertaining to the Sec. 503 water

standard, and I’d have to do some research to find exactly how their permitting situation stands.Columbus Southerly: A couple of active multiple hearth units, N003 and N004, are covered by a title 5

permit , and three units were shut down around 1990.

Let me know if I need to do more digging into any of these.

Dana



### Wisconsin

From: Sieffert, Margaret

Sent: Monday, November 25, 2013 4:21 PM

To: Hambrick, Amy

Subject: FW: OAQPS SSI Status Update Request

Wiscon sin’s response.

From: Patterson, Ralph C

- DNR [ mailto:Ralph.Patterson@wisconsin.gov ]

Sent: Monday, November 25, 2013 3:18 PM

To: Sieffert, Margaret

Subject: RE: OAQPS SSI Status Update Request

For Wisc onsin, Green Bay Met is correct.

Ralph Patterson

Emission Inventory Team Leader

Compliance, Enforcement & Emission Inventory Section

Bureau of Air Management

Wisconsin Department of Natural Resources

WDNR

- AM/7

101 S. Webster St.

Madison, WI 53707

(() phone: (608) 267

- 7546

(() fax: (608) 267

- 0560

(+) e

- mail: Ralph.Patterson@wisconsin.gov



### Region 6

All Region 6 States

From: Boyce, Kenneth

Sent: Thursday, December 05, 2013 2:15 PM

To: Hambrick, Amy

Subject: RE: Action Request Region 6 SSI Status Update

Dear Amy,

In regards to inventories, that’s where I’m at a lost. I have no real true involvement with Inventories of

111/129 Units or Permit Applications. I’m only privy to inventori es when a State Plan is submitted.

If you have any questions, please contact me.

Ken Boyce, Environmental Protection Specialist

PH: (214) 665

- 7259

FAX: (214) 665

- 7263

### Region 7

Iowa

From: Hanlon, Lisa

Sent: Friday, November 22, 2013 9:04 AM

To: Hambri ck, Amy

Subject: FW: State Managers: Request for in on SSI Status Update

From: Algoe

- Eakin, Amy

Sent: Thursday, November 21, 2013 1:08 PM

To: Hanlon, Lisa

Subject: RE: State Managers: Request for in on SSI Status Update

Iowa has not submitted a state 111( d) plan yet for existing SSI units. However, this (along with adoption

of SSI NSPS) is included in IDNR’s draft rulemaking proposal currently out for informal public

input. As far as the inventory below, please remove the City of Dubuque. They have remov ed their SSI

units. City of Cedar Rapids will be the only existing facility subject to the SSI 111(d) plan.

The draft rulemaking proposal to adopt NSPS, NESHAP, and Emission Guidelines (including SSI) is

available on our website at

http://www.iowadnr.gov/InsideDNR/RegulatoryAir/StakeholderInvolvement.aspx (click on “Rulemaking

for NESHAP and NSPS Adoption: Draft Proposal”).

Kansas

From: Hanlon, Lisa

Sent: Friday, November 22, 2013 9:03 AM

To: Hambrick, Amy

Subject: FW: State Managers: Request for in on SSI Status Update

From: Kemp, Lachala

Sent: Thursday, November 21, 2013 1:02 PM

To: Bhesania, Amy; Algoe

- Eakin, Amy; Crable, Gregory

Cc: Tapp, Joshua; Brown, Steven ; Hanlon, Lisa

Subject: RE: State Managers: Request for in on SSI Status Update

No change to the info provided below. KS has yet to submit.



### Region 8

All Region 8 States

From: Morrison, Kendra

Sent: Thursday, November 14, 2013 1:57 PM

To: Okubo, Noreen

Cc : Hambrick, Amy

Subject: RE: Action Request Region 8 SSI Status Update

Hi Noreen,

I am happy to help you address this request if you need it

– just let me know. We don’t have any SSIs in

our Region so we have expected negative declarations from all the st ates. To my knowledge before my

detail began, we had received negative declarations for CO, ND, SD, and WY. Abby Fulton is working

on processing these for FR publication, so she has them in a file in her office with the dates received. If

MT and UT hav en’t already done so, you might check in with them and remind them to send in their

declaration (provided they still have no sources). I sent reminders before I went on detail, but they mightneed another one. Perhaps you can call Deanne Fisher of MT sin ce we spoke to her by conference call in

the recent past about MT’s HMIWI plan. Mark Berger is the rules coordinator and contact for Utah, and

his contact information is on the last pages of the summary of Section 129 that I prepared.

I hope all is going well! It was great to see you this morning!

Kendra

From: Okubo, Noreen

Sent: Thursday, November 14, 2013 3:45 PM

To: Hambrick, Amy

Cc: Morrison, Kendra; Fulton, Abby; Rothery, Deirdre

Subject: RE: Action Request Region 8 SSI Status Update

Hi Amy

Kendra is correct. I’ll find the negative declarations letters from CO, ND, SD and WY. Then remind UT

and MT that 40 CFR Part 60 Subpart MMMM Emissions Guidelines for compliance times for existing

sewage sludge incineration units (60.5030 Is there an approval p rocess for negative declaration letters) is

due. The information in the Comments Column in the attached spreadsheet dated Jan 31/2013 applies to

HMIWI’s in Region 8 not SSI’s, so Abby and I will correct.

Ciao

Noreen Okubo

303

- 312

- 6646

From: Okubo, Noreen

Sent: Wednesday, November 20, 2013 12:08 PM

To: Hambrick, Amy

Cc: Rothery, Deirdre; Fulton, Abby; Morrison, Kendra; Parker

- Christensen, Victoria

Subject: RE: Action Request Region 8 SSI Status Update

Hi Amy

Yes, I spoke to both MT and UT “air rules coord inators” yesterday, both states plan to submit Negative

Declarations probably by the end of the year at the latest.

Noreen Okubo

303

- 312

- 6646



### Region 9

All Region 9 States

From: Borgia, Adrianne

Sent: Wednesday, December 04, 2013 2:50 PM

To: Hambrick, Am y; Kelly, Shaheerah

Subject: RE: Action Request Region 9 SSI Status Update

Amy,

This is my input (marked with “AB”). I contacted both the treatment plants to confirm the incineration

units.

Adrianne Borgia

EPA

- Air Rules Office (Air

- 4)

75 Hawthorne St.

San Francisco, CA 94105

tele: (415) 972

- 3576

borgia.adrianne@epa.govQuestion for Region: I don’t know of any SSI in Arizona, Hawaii, Nevada, American Samoa, or Guam,

do you?

According to AZDEQ, in the Arizon a Pollutant Discharge Elimination System (AZPDES)Program 2003

report, incineration of bio

- solids is prohibited in AZ

Per NV DEP, sewage sludge is buried, not incinerated

Apparently HI uses Carbonization and Flash Carbonization techniques or conveys waste t o mainland

American Samoa

– unknown

(AB)

FacilityID NumberOfUnits Unit ID Unit

Type FacilityOrUnitNotes

CACentralContraCosta 2 MHF 1

MHF 2 MH 12

- 4

- 13 confirmed

there are still 2 identical

units but one is being

service per permit and

will be back in

operation in January.

(AB)

CAPaloAlto 2 1 and 2 MH 12

- 4

- 13 confirmed

there are still 2 identical

units but only one is run

at a time and they are

rotated annually(AB)



### Region 10

Alaska

From Region 10’s attached file:

11

- 18

- 13 from source

- The Juneau

- Douglas WWTP Incinerator has a Title V Operating Permit No.

213TVP01 that expired in 2005. The permit was not renewed.

The incinerator has not operated since it’s heat exchanger failed in 9/2010. One method being consid ered

is to purchace a new unit.

It would have the pollution control design

- wet tray scrubber system with the venturi and impingement

tray design, along with an upgraded CEM pollution control equipment to meet EPA’s new emission

limits.

From: Valdez, Heat her

Sent: Friday, November 22, 2013 6:31 PM

To: Hambrick, Amy

Cc: Gordon, Michael

Subject: RE: Action Request Region 10 SSI Status Update

Hi Amy, here is my update. Have a good weekend!

Heather Valdez

Chemical Engineer

EPA Region 10Office of Air, Waste a nd Toxics

1200 6th Ave, Suite 900, AWT

- 107

Seattle WA, 98101

(206) 553

- 6220

valdez.heather@epa.gov