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. Environmental 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 (SSI) and new source performance standards (NSPS) for new SSI. The 

regulations are designed to limit emissions of nine pollutants from these SSI. 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 (NOX), and sulfur dioxide 

(SO2). Regulations for the SSI 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, 2012. 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 covered 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 show 

which units have shut down since 2011 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 185

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, states, and SSI facilities and review of 

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

recognizes that 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 comment 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 documented in Appendix 

C-1 and 3, a total of 22 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 states to have shut down a number of years prior to the promulgation 

of the March 21, 2011;

- 5 units were identified by states 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 units1actually 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 operating, 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 confirmed by EPA Regions and states. These 

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

identified include the following: 

- Correcting 1 facility address

- The addition of 2 units not previously listed in the 2011 inventory2

- 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 the 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 were identified as shut down since 

March 21, 2011, were removed from this inventory. Subsequently, the two units, 

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

These units’ emissions were estimated based on the same methodology used to estimate baseline 

emissions of the 2011 EG3. 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 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-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 Post 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 NJPequannockLincolnFairfield 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 review 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 AM
To: 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 facility 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

Amy 
I’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 this 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 (SSI) 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 controls; 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 PM
To: 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 unit 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. Environmental 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, 

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)

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 Puerto 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 Status 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 soon 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, Margaret 

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 will 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 unless 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 25, 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: RE: 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: Sieffert, 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.

Should 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'

Subject: 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: Jackson, 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 

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.state.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: Sieffert, 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: Tuesday, 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 four 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.

Hamilton 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 operating 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

Wisconsin’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 Wisconsin, 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 inventories 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: Hambrick, 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 removed 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 states. 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 haven’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 might 
need another one. Perhaps you can call Deanne Fisher of MT since 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 process 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 coordinators” 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, Amy; 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.gov
Question for Region: I don’t know of any SSI in Arizona, Hawaii, Nevada, American Samoa, or Guam, 

do you?

According to AZDEQ, in the Arizona 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 to 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 considered 

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, Heather 

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 10
Office of Air, Waste and Toxics

1200 6th Ave, Suite 900, AWT-107

Seattle WA, 98101

(206) 553-6220

valdez.heather@epa.gov