# CITY OF ALBUCUJERCUJE RECEIVED - 6PDL AIR PLANNING SEC. 11 SEP 

# 15 PH 4: 4'
September 12, 2011

Mr. GuyDonaldson Chief, AirPlanning Section (6PD-L) U.S. EnvironmentalProtection Agency, Region VI 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733
SUBJECT:
Dear Guy, Negative declaration ofthepresence ofSewage Sludge Incineration (SSI) Units in Bernalillo County,NewMexico

PO Box 1293

Albuquerque**NM871~**
www.cabq.gov 'Utider Section 111(d) of the Clean Air Act, EPA published regulations at 40 CPR Part 60, Subpart B which requires states to submit plans to control emissions of designated pollutants from designated facilities. In the event that a state does not have a particular designated facility located within its boundaries. EPA requires that a negative declaration be submitted in lieu of a control plan'. Therefore, this letter serves as a negative declaration of the presence of any 55I units for 

### which construction commenced on or before October 14, 2010, subject to 40 CPR 60, Subparts LLLL or MMMM, within Bernalillo County, New Mexico, upon lands under the jurisdiction of the Albuquerque-Bernalillo County AirQualityControlBoard(AirBoard). EPA promulgated

### Standords

### ofPerfomJance forNew SewageSludgeIncineration Units, and

### Emission Guidelinesand Compliance Timesfor Existing Sewage Sludge Incineration Units, on March 21, 2011 

### [FR Vol. 76, No. 54, pp. 15372-15454]. Under this rule, new sources are subject to 40 CPR 60 Subpart LLLL, and existing sources are subject to emissionguidelines under SubpartMMMM. An SSI unit combusts sewage sludge for the purpose of reducing the volume of the sewage sludge by removing combustible matter. SSI unit designs include fluidized bed and multiple hearth incinerators. An SSI unit also includes, butis not limited to, the sewage sludge feed system, auxiliary fuel feed system, grate system, flue gas system, waste heat recovery equipment, if any, and bottom ash system. The 55I unit includes all ash handling systems connected to the bottom ash handling system. The combustion unit bottom ash system ends at the truck loading station or similar equipment that transfers the ash to final disposal. The SSI unitdoes notinclude 

### airpollution control equipmentor the stack. 20.11.68 NMAC, 

### Intinerators and Crematon·es, Section 200 

### Applicable Requirements, Subsection B Construction/Operation, stipulates that: "The construction, use or operation of an incinerator, even if an 'affected facility' pursuant to 40 CFR 60, Subpart Ea as amended, on any property 

### is prohibited, except for certain crematories as allowed by this part". To date, no 'affected facilities' have been constructed or modified pursuant to Subpart Ea. In addition, 20.11.1.7.R NMAC defines a "crematory" in such a way that "sewage sludge" cannot be combusted at a crematory. Thus, the only wayan SSI unit could legally be constructed or operated within Bernalillo County, would be through the granting of a variance to 20.11.68 NMAC by theAirBoard.

Albuquerque -Making Hi.I'fory {706-2006NegativeDeclaration for55I Units
There has only been one variance granted for an incinerator; a natural gas fIred, C.B. 400, batch-loaded pathological waste incinerator constructed and operated at 5350 Second St. NW, in Albuquerque, New Mexico, by the Albuquerque Police Department. However, this incinerator is not used for combustion of sewage sludge. Therefore, there are no incinerators subjectto the SSI rule in Bernalillo County. Should youhave any questions regarding this matter, please do nothesitate to contactme.

# ~,=.'C7-= BillWestmoreland, P.E. Deputy Director Environmental Health Department City ofAlbuquerque One CivicPlaza, NW, Suite 3023 Albuquerque, NewMexico 87103 (505) 768-2706

cc: JeffRobinson, Chief;AirPermits Section, US. EPA, Region 6 Ken Boyce, EnvironmentalProtection Specialist, AirPlanningSection, US. EPA, Region 6 Alan Shat, SIP Coordinator, US. EPA, Region 6 Dr. MargaretMenache, Chair, Albuquerque

- Bernalillo CountyAir Quality ControlBoard MargaretNieto, Control Strategies Supervisor, AQD Richard Goodyear, Acting Chief, Air Quality Bureau, NMEnvironmentDepartment

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