Gardella, Anthon,l

From:

Sent:

To:

Cc:

Subject:

Attachments:

Luis R. Sierra Torres <LuisSierra@jca.pr.gov>

Monday, August 10, 2015 12:05 PM

Gardella, Anthony; Leimarys Delgado Medero

Mangels, Karl; Stamataky, Evans;Aponte, John

RE:PR EQB's State plan for sewage sludge incinerators

RCAPAmendment Reg 6630 CISWI Rule 405 Year 2003.pdf; RCAPAmendment Reg

6302 HMIWI Rule 405 Year 2001.pdf

Ted,

Bellow you will find the additional information requested.

Rule 102 Definitions

Several definitions were not included in the Sludge EG since they were incorporated in the Regulation for the Control of

Atmospheric Pollution (RCAP) as part of the HMIWI and CISWI EG. Enclosed you will find HMIWI and CISWI EGas

submitted to the Puerto Rico Department of State.

Source Inventory

- Can you clarify that there is only one 551facility in Puerto Rico at PRASAthat is subject to EQB's 551Rule 405d?

There is only 1 sludge incineration unit currently operating in Puerto Rico. The 551unit is located at Puerto Rico

Aqueduct and 5ewer Authority (PRA5A) in Puerto Nuevo and is subject to Rule 405(d) of the RCAP.

- Is it PFE-65-111-0 as identified in EQB's inventory of sources?

The facility was identified in the emission inventory as PRASAPuerto Nuevo with permit number PFE-65-1208-0633-1I1-

O. By mistake we do not include the complete operating permit number in page 3 of the inventory. The facility is

currently operation under a Title V permit application shield. The Title V permit application number is PFE-TV-4953-65-

0314-0142. The permit application was submitted on March 2014.

- How many 551units are there at the PRA5A facility?

There is only one unit installed and in operation at PRA5A Puerto Nuevo.

- Are there any 551units in Puerto Rico that are closed/shut down but not dismantled?

All shutdown units are dismantled.

- What type of incinerators are MHF#1 and MHF#2? MHF#2 is now closed since October 2000 - if it is/was an 551unit is

it now dismantled?

Units ID: MHF#1 and MHF#2 were multiple heart furnaces located at PRA5A Puerto Nuevo. Both units were dismantled.

legal Authority

We will send EPAcomment to our legal Affairs Office for their review and future reference.

If you have additional questions, feel free to contact us at your convenience.

Luis R. Sierra, PE, MBA

Chief, Inspection and Compliance Division

1
Air Quality Area

Puerto Rico Environmental Quality Board

Phone: (787) 767-8181 x.3237

From: Gardella, Anthony [mailto:Gardella.Anthony@epa.gov]

Sent: Friday, July 31,20153:21 PM

To: Leimarys Delgado Medero

Cc: Luis R. 5ierra Torres; Mangels, Karl; 5tamataky, Evans; Aponte, John

Subject: PR EOB's 5tate plan for sewage sludge incinerators

Leimarys,

We reviewed EOB's 5515tate plan and we are requesting additional clarifying information as follows:

Rule 102 Definitions

- EOB's 5tate plan includes amendments to Rule 102 that adds required definitions form EPA's emission guidelines (EG)

for 551units at 40 CFRpart 60, subpart MMMM. We note that there are several definitions in the EGthat are missing

from EOB's amendment to Rule 102 as submitted with EOB's 5515tate plan, including the following terms: auxiliary fuel,

bag leak detection system, calendar year, deviation, dioxins/furans, fabric filter, standard conditions, and wet

scrubber. Please send us via return email the entire Rule 102 that includes all the definition of terms in the EGfor 551.

Source Inventory

- Can you clarify that there is only one 551facility in Puerto Rico at PRA5A that is subject to EOB's 551Rule 405d? Is it

PFE-65-111-0 as identified in EOB's inventory of sources?

- How many 551units are there at the PRA5Afacility?

- Are there any 551units in Puerto Rico that are closed/shut down but not dismantled?

- What type of incinerators are MHF#l and MHF#2? MHF#2 is now closed since October 2000 - if it is/was an 551unit is

it now dismantled?

Emissions Inventory

- EOB's inventory of emissions for the PRA5A551is expressed in tons/year potential emissions. EOB indicates there is no

actual emissions for 2009 - is there any recent actual emissions that PRA5A could provide since 2009 or, if not, perhaps

an earlier year?

- Can the emissions inventory from any stack tests be expressed in the same units (e.g., ppm dry volume at 7% 02, and

milligrams/dry standard cubic meter) for each pollutant as the emission limits required by the EGfor 551? If available,

compare PRA5A's actual emissions to the emission limits (ppm, mg/dscm, etc.) required by the EGfor 551at Tables 2 or

3, as applicable.

Legal Authority

- Our Office of Regional Counsel reviewed the legal authority portion of EOB's SSIState plan and have some minor

comments as summarized in the attached. Can you review the attached and let us know your comments. Region 2's

ORC asks that corrections to the legal authority as summarized in the attached should be made in the next State plan

submittal. It is not necessary to resubmit the legal authority for EOB's 551State plan.

If you need any clarification on the above comments, please let me know.

2
Ted Gardella

Environmental Engineer

Air Programs Branch, Air Planning Section

EPA Region 2

NY, NY

212-637-3892

3

Gardella. Anthonl.

From:

Sent:

To:

Subject:

Attachments:

5tamataky, Evans

Thursday, June 18, 2015 11:01 AM

Gardella, Anthony

comments to PREQB 55! rule

Commnets to PREQB 55! appliication.docx

Evans John Stamataky

Assistant Regional Counsel

U.S. Environmental Protection Agency

290 Broadway

New York, NY 10007

(212) 637-3201

Note: This transmission may contain confidential communications, attorney work product, enforcement

sensitive, attorney-client and/or other privileged materials. Do not release under FOIA without appropriate

review. If this message was sent to you in error, you must delete it and not print, copy re-transmit, disseminate,

or otherwise use the information.

1

In Section VII, Demonstration of Legal Authority, PREQBprovided citations to the Environmental Public

Policy Act Law No. 416 of September 22, 2004, as amended 12 LPRA§8001 et seq.

However, the citations provided do not exactly match those found in the copy that law provided by

PREQBin Section VII. Because 40 CFR§ 60.27 (b) requires that lithe provisions of law or regulations

which the State determines provide the authorities required by this section shall be specifically

identified," EPA requests that PREQB make the following changes to the citations.

I Authority to adopt emission standards and compliance schedules applicable to designated facilities

Change § 8002 c(b)(3)(E) to § 8002 c(B)(3)(e)

Change § 8002 c(b)(5) to § 8002c(B)(5)

Change § 8002 c(b)(13) to § 8002c(B)(13)

Change § 8002 c(b)(3)(D) to § 8002c(B)(3)(d)

Change § 8002 c(b)(13)(A)(xix) to §8002 c(B)(13)(a)(19)

II Authority to adopt enforce applicable laws, regulations, standards, and compliance schedules, and

seek injunctive relief

Change § 8002c(a)(7) to § 8002c(A)(7)

Change § 8002c(a)(9) to § 8002c(A)(9)

Change § 8002c(a)(ll) to § 8002c(A)(ll)

Change § 8002c(a)(12) to § 8002c(A)(12)

Change § 8002j{b) to § 8002j{B)

Change § 8002j{c) to § 8002j{c)

Change § 8002j{d) to § 8002j{D)

Change § 8002j{e) to § 8002j{E)

Change § 8002j{g) to § 8002j{G)

Change § 8002j{h) to § 8002j{H)

Change § 8002j{i) to § 8002j(1)
III Obtain necessary information to determine whether designated facilities are in compliance with

applicable laws, regulation, standards, and compliance schedules, including authority to require

recordkeeping and to make inspections and conduct test of designated facilities

Change § 8002c(b)(3)(C) to § 8002c(B)(3)(c)

Change § 8002c(b)(1)(g) to § 8002c(B)(1)(g)

Change § 8002c(a)(lO to § 8002c(A)(lO)

Change § 8002c(b)(13)(A)(xx) to § 8002c(B)(13)(a)(20)

Change § 8002c(b)(3)(D) to § 8002c(B)(3)(d)

IV Require owners or operators of designated facilities to install. maintain, and use emission monitoring

devices and to make periodic reports to the State on the nature and amounts of emissions from such

facilities; also, authority for the State to make such data available to the public as reported and as

correlated with applicable emission standards

Change § 8002c(b)(13)(i) to § 8002c(B)(13){1)

Change § 8002c(b)(1(G) to § 8002c(B)(1)(g)

Change § 8002c(b)(3)(C) to § 8002c(B)(3)(c)

V. Make emission data available to the public

Change § 8002c(b)(13)(A)(xxii) to § 8002c(B)(13)(A)(22)

Change § 8002c(b)(13)(A)(xxiii) to § 8002c(B)(13)(a)(23)