CITY OF ALBUCUJERCUJE

RECEIVED - 6PDL

AIR PLANNING SEC.

11 SEP 15 PH 4: 4'

September 12, 2011

Mr. Guy Donaldson

Chief, Air Planning Section (6PD-L)

U.S. Environmental Protection Agency, Region VI

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

SUBJECT:

Dear Guy,

Negative declaration of the presence of Sewage Sludge Incineration (SSI) Units

in Bernalillo County, New Mexico

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

Air Quality Control Board (Air Board).

EPA promulgated Standords of PerfomJancefor New Sewage Sludge Incineration Units, and Emission Guidelines and

Compliance Times for 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 emission guidelines under Subpart MMMM.

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, but is 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 unit does not include air pollution control equipment or 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 the Air Board.

Albuquerque - Making Hi.I'fory {706-2006
Negative Declaration for 55I 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 subject to the SSI rule in Bernalillo County.

Should you have any questions regarding this matter, please do not hesitate to contact me.

~,=.'C7-=

Bill Westmoreland, P.E.

Deputy Director

Environmental Health Department

City of Albuquerque

One Civic Plaza, NW, Suite 3023

Albuquerque, New Mexico 87103

(505) 768-2706

cc: Jeff Robinson, Chief;Air Permits Section, US. EPA, Region 6

Ken Boyce, Environmental Protection Specialist, Air Planning Section, US. EPA, Region 6

Alan Shat, SIP Coordinator, US. EPA, Region 6

Dr. Margaret Menache, Chair,

Albuquerque - Bernalillo County Air Quality Control Board

Margaret Nieto, Control Strategies Supervisor, AQD

Richard Goodyear, Acting Chief, Air Quality Bureau, NM Environment Department

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