SEWAGE SLUDGE INCINERATOR (SSI) CONFERENCE CALL

WITH 9 RECIPIENTS OF INFORMATION COLLECTION REQUEST (ICR) 

December 1, 2009 

11:00 am – 1:00 pm 

919-541-4332/ Room E145 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

MEETING ATTENDEES: 

U.S. EPA 

Office of Air Quality and Planning Standards

Amy Hambrick 

Ketan Patel 

Toni Jones 

Martha Smith 

Larry Elmore 

Robin Dunkins 

Ron Myers 

Office of General Council

Susmita Dubey 

Office of Water

Rick Stevens 

Maria Gomez-Taylor 

EASTERN RESEARCH GROUP

Roy Oommen 

Amber Allen 

ICR RECIPIENT REPRESENTATIVES

Wayne Township, NJ: 

Robert Androsiglio 

Steve Singer 

Upper Blackstone, MA: 

Tom Walsh 

Bob Cox 

Dorothy Austin 

Bill Wrightson 

Greensboro, NC: 

Martie Groome 

Wally Kling 

Metropolitan Council, MN: 

William Moore 

Dan Mueting 

Mary Gail Scott 

Kent Johnson 

Glenn Giefer 

The Metropolitan District, CT: 

Sally Nyren 

Craig Scott 

Central Contra Costa, CA: 

Randy Schmidt 

Columbia, SC: 

Tommy Faulk 

 

Ypsilanti, MI: 

Perry Thomas 

Kurian Joychan 

NACWA: 

Chris Hornback 

Bob Dominak (Northeast Ohio 

Regional Sewer District) 

Mark Feltner (Hampton Roads 

Sanitation District)

SUMMARY: 

This meeting served as an information session to address any questions from the SSI ICR recipients 

regarding the survey and testing requirements of the ICR. The outline for the call is included as 

Attachment 1. 
DISCUSSION: 

After brief introductions, Amy Hambrick summarized the background of the rule writing process for the 

sewage sludge incineration category and opened the floor to any questions. The following sections 

summarize questions and comments brought up during the call. 

Representative Data 

Industry representatives raised several concerns regarding the selection of the nine entities to which the 

ICR was sent. One representative asked how these specific entities were chosen out of all the SSI 

facilities in EPA’s inventory. EPA responded that the goal was to reduce the overall burden on the 

industry while maintaining a wide geographical representation as well as representing a variety of 

incinerator and control types. Ms. Hambrick also explained that the 9 entities comprise 20 incineration 

units, but that only those currently operating would be required to test (i.e. facilities having multiple units 

but only operating one at a time need only test the one unit). When asked how a small number of units 

could be used to determine the best performing twelve percent in order to set the standard, EPA explained 

that the units chosen were assumed to be the best performing in the industry, given the controls that are in 

place at these facilities. Additionally, given the court order deadline for the rule, it would be impossible 

and overly burdensome to the industry for EPA to require testing for a larger sample of facilities and units 

in such a short amount of time. Concern was expressed from industry that the science was being driven by 

the schedule rather than a statistically significant representation of the SSI category. 

Representatives also asked whether the nine entities would sufficiently show the differences between the 

fluidized bed and multiple hearth units. Ms. Hambrick responded that the nine selected entities have a mix 

of the two incinerator types. 

Ms. Hambrick described how the data received would be analyzed, explaining that EPA would review the 

collected data for quality and consistency and to determine outliers. She noted that facilities would be 

contacted to clarify any questions raised concerning the data received. She also explained that EPA is 

contacting its Regional offices and state partners to gather any further data available in-house and through 

permits. 

Schedule 

Ms. Hambrick summarized the overall schedule of the rulemaking process. 

One representative noted a discrepancy in the test submittal deadline; it was listed as February 16th in one 

place and February 17th in another. Ms. Hambrick clarified that the deadline would be February 17, 2010. 

Some representatives indicated that it would be nearly impossible for them to complete the required 

testing and submit results by this deadline. One representative stated that securing a bid from a testing 

contractor could hold up the process. The Ypsilanti representative explained that their board of 

commissioners would need to meet to approve testing costs before being able to move forward with 

requesting contractor bids, and that this would further delay the process. 

EPA responded that entities to which this situation applies should email EPA as soon as possible with an 

outline of their specific situation and a proposal of how much additional time would be needed to submit 

test data to EPA. EPA will review these written emailed requests and submit a written response back to 

the entities. Ms. Hambrick emphasized that EPA would like to accommodate the needs of the entities but 

must also stay on track to meet its deadline. 
Costs 

Several industry representatives expressed concern about the financial limitations of facilities to test. Ms. 

Hambrick replied that entities should contact EPA explaining their specific concerns and that EPA would 

work with facilities on an individual basis in an attempt to resolve any outstanding issues. 

Testing 

Questions were raised as to why EPA was requiring testing for pollutants other than those covered by 

Section 129 of the Clean Air Act. Ron Myers responded that the initial intent was simply to collect as 

much data as possible without incurring additional cost. For example, if the Section 129 metals need to be 

tested, other metals such as phosphorus or selenium could be measured at the same time at no extra 

charge. However, one representative pointed out that previous metals tests, deemed by EPA as acceptable 

for this ICR, did not necessarily include these additional metals. Therefore, in this case, it would be an 

additional cost to test for these extra metals. Mr. Myers agreed and stated that if Section 129 test data 

within the past 5 years existed for a unit, the facility need not test the unit for additional, non-129 

pollutants. 

One representative asked specifically about which PAH compounds would need to be tested, and EPA 

indicated that detailed information could be found in the ERT test plan, included as Enclosure 7 in the 

Section 114 letters. 

Mr. Myers also clarified that PM testing using Method 5 would not be sufficient for the purposes of this 

ICR because Method 5 does not provide PM 2.5 results; condensible and PM2.5 are also required in 

addition to filterable PM for the purposes of the ICR. 

Concerns were raised about the capacity at which the units should be tested. Representatives indicated 

that for all other regulatory requirements, tests were usually conducted at maximum capacity. EPA, on the 

other hand, had requested these tests to be run at “typical” capacity. This would be inconsistent with any 

data submitted from previously conducted tests, and representatives wondered how this would affect the 

determination of standards. EPA agreed and felt it would be necessary to discuss this issue further. Ms. 

Hambrick indicated that EPA would provide further guidance on the capacity at which the units should be 

run during the testing, and that EPA would also clarify the pollutants to test for if some pollutants were 

previously tested for in the past five years. 

CONCLUSION: 

EPA wrapped up the call by summarizing the main topics raised and reviewing all follow-up tasks to be 

completed by EPA as well as the industry representatives. Action items included: 

• Ron Myers to send an email containing information about test plans for fluidized bed and 

multiple hearth units 

• Industry representatives to contact EPA to discuss testing cost and schedule issues specific to 

their facilities 

• EPA to provide further guidance on testing requirements 
Attachment 1 

Sewage Sludge Incineration 

EPA Conference Call with 9 ICR Recipients 

919-541-4332/ E145 

December 1, 2009 (11:00 am to 1:00 pm) 

11:00 am Introductions and Meeting Purpose 

11:10 am Rule Writing Process 

11:30 am Survey Parts II – IV, Test Methods, and Testing Component Questions 

12:30 pm Open Discussion 

12:50 pm Webinar Overview 

12:55 pm Meeting Adjourned 
SSI Conference Call Action Item Follow Ups 

Amy Hambrick 

to: 

Hambrick.Amy, 'Dove, Ashley', Cluverius, Jennifer S., Dorothy_Austin, 

bwrightson, tkwalsh, Robert.Martire, rschmidt, lmuzekari, TFAULK, 

lnagaraj, donald.howard, martie.groome, Glenn.Giefer, snyren, 

androsigliob, KJoychan, Robert Dominak, CHornback 

12/01/2009 06:15 PM 

Cc: 

Ketan Patel, Robin Dunkins, Ron Myers, Toni Jones, Susmita Dubey, Rick 

Stevens, Roy Oommen, Amber Allen 

Show Details 

HI SSI ICR Recipients: 

This email will address some of the action items that came up in today's 

meeting. You will note that we will be following up in a separate email 

with the remaining action items. As questions come up, please do not 

hesitate to contact EPA. 

I don't think that I have all the email addresses for everyone who was on 

the call, I just have the main entity contacts, please be sure to forward 

this on to other members of your teams who also participated in this 

call. If convenient, maybe NACWA could collect a participant call list 

(non EPA list) and email it to me as well? As I am going through my notes 

I believe that I am missing some participant names. 

Best, 

Amy Hambrick 

Natural Resources and Commerce Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964 

1. Attachments to Enclosure 6, which are identified as "Enclosure 4 - 

Attachment A" and "Enclosure 4 - Attachment B." Can you simply confirm 

for us that these Enclosures do in fact go with Enclosure 6 as they are 

placed in the packet and that they are not out of order? 

Yes, Enclosure 6 has two parts: "enclosure 4 A" and "enclosure 4 B". 

Please note that enclosure "4" is a typo and should have been "6". But to 

clarify, "enclosure 4 A" and "enclosure 4 B" do belong to enclosure 6 of 

the ICR dated 10/23/09. 

2. Copy of SSI Court Order 

Please see attached "sec 112 signed final deadline order.pdf" Please note 

that this order addresses multiple rules. The SSI final signature deadline 

in December 16, 2010. 

3. EPA call attendees 
Please see the attached "EPA call participants SSI 12.1.09". 

4. Test Plan example 

Please refer to enclosure 7 in your packet, or see attached enclosure 7. 

Please note that we will be following up with sending a working electronic 

file of the Electronic Reporting Tool that you may use to develop your 

test plan. 

5. Testing extension 

EPA would like to gain a better understanding of how much time would be 

needed. If this situation applies to your entity, please email EPA as soon 

as possible with the following information: 

 -outline and document your specific situation 

 -propose an amount of time you think you would need 

EPA will review your written emailed request and submit a written response 

back to you. EPA would like to work with you to try to accommodate your 

needs, but we must also stay on track to meet our deadline. 
Re: Action Item: Follow-Up from December 1, 2009 SSI Call with 9-ICR 

Recipients 

Amy Hambrick 

to: 

Amy Hambrick 

12/18/2009 10:44 AM 

Cc: 

"'Dove, Ashley'", Amber Allen, androsigliob, bwrightson, CHornback, Robert 

Dominak, donald.howard, Dorothy_Austin, Glenn.Giefer, Hambrick.Amy, 

"Cluverius, Jennifer S.", Ketan Patel, KJoychan, lmuzekari, lnagaraj, 

Maria Gomez-Taylor, martie.groome, Rick Stevens, Robert.Martire, Robin 

Dunkins, Ron Myers, Roy Oommen, rschmidt, snyren, Susmita Dubey, TFAULK, 

tkwalsh, Toni Jones 

Show Details 

All, 

I received a call this morning, requesting more clarification on the below 

email that I sent yesterday. Please note the tables emailed to you 

yesterday were copied from the ICR letter dated 10/23/09. The pollutants 

that EPA is requesting testing for are outlined in the ICR letter and 

further detailed in Enclosure 2: Testing Component. Enclosure 7, the 

example test plan was included only to provide an example of what the test 

plan in the Electronic Reporting Tool (ERT) could look like. EPA is 

updating the ERT test plan to provide a working electronic template for 

you to model your test plans after. 

Again, please use the ICR letter and Enclosure 2 as direction to what 

pollutants EPA is asking you to test for. 

Please submit any existing test data (in the past 5 years) in the form of 

test reports (by email or CD), to EPA as soon as possible so that EPA can 

verify what additional pollutants must be tested for your specific entity. 

 EPA will also communicate if any test run times for the existing data are 

not acceptable. 

If your entity needs to test for any of the pollutants listed because of 

1) existing data is deemed not acceptable by EPA or 2) there is no 

existing data, then please follow testing instructions as outlined in the 

ICR. 

Re-attached is an updated survey (as of this morning). (Should be 

bug-free). 

Please call/ email with more questions. 

Warmest, 

Amy 
Amy Hambrick 

Natural Resources and Commerce Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964 

From: Amy Hambrick/RTP/USEPA/US 

To: Hambrick.Amy@epa.gov, "'Dove, Ashley'" <acdove@columbiasc.net>, 

"Cluverius, Jennifer S." <JCluverius@nexsenpruet.com>, 

Dorothy_Austin@golder.com, bwrightson@ubwpad.org, tkwalsh@ubwpad.org, 

Robert.Martire@alcosan.org, rschmidt@centralsan.dst.ca.us, 

lmuzekari@BPBarber.com, TFAULK@COLUMBIASC.NET, lnagaraj@columbiasc.net, 

donald.howard@greensboro-nc.gov, martie.groome@greensboro-nc.gov, 

Glenn.Giefer@metc.state.mn.us, snyren@themdc.com, 

androsigliob@waynetownship.com, KJoychan@ycua.org, Robert Dominak 

<DominakR@neorsd.org>, CHornback@NACWA.ORG

Cc: Ketan Patel/RTP/USEPA/US@EPA, Robin Dunkins/RTP/USEPA/US@EPA, Ron 

Myers/RTP/USEPA/US@EPA, Toni Jones/RTP/USEPA/US@EPA, Susmita 

Dubey/DC/USEPA/US@EPA, Rick Stevens/DC/USEPA/US@EPA, Roy Oommen 

<Roy.Oommen@erg.com>, Amber Allen <Amber.Allen@erg.com>, Maria 

Gomez-Taylor/DC/USEPA/US@EPA 

Date: 12/17/2009 04:20 PM 

Subject: Action Item: Follow-Up from December 1, 2009 SSI Call with 9-ICR 

Recipients 

Please be sure to forward this on to your team members as I only have 

email addresses for main site contacts. 

ICR COMPONENT II: TESTING REQUIREMENTS 

Action Item: Follow-Up from December 1, 2009 SSI Call with 9-ICR Recipients 

Testing Capacity 

EPA recommends that testing is done at maximum capacity. If you can not 

operate the unit at maximum load or operating, please document what load 

or operating conditions were used during the testing and please explain 

expected differences between test results for maximum capacity versus for 

the capacity at which you tested. 

Pollutants EPA requested testing for as outline in the October 23, 2009 

ICR 

Table 1 -- CAA Section 129 pollutants 

Cadmium (Cd) Opacity 

Carbon monoxide (CO) Oxides of nitrogen (NOx) 

Dioxin/ dibenzofurans (D/F) Particulate matter (PM) 

Hydrogen chloride (HCl) Particulate Matter less than 2.5 microns (PM2.5) 

Lead (Pb) Filterable Particulate Matter (FPM) 

Mercury (Hg) Condensable Particulate Matter (CPM) 

Sulfur dioxide (SO2) 

Table 2 -- Additional testing/analysis are required for the following 

pollutants: 

Metals: hydrogen fluoride (HF) 

antimony (Sb) polychlorinated biphenyls (PCBs) 

arsenic (As) polycyclic aromatic hydrocarbon (PAH) 

beryllium (Be) 

chromium (Cr) 
cobalt (Co) 

manganese (Mn) 

nickel (Ni) 

phosphorous (P) 

selenium (Se) 

For your information the following air pollutants of interest are also 

pollutants regulated by the Clean Water Act part 503: Arsenic (As), 

Beryllium (Be), Cadmium (Cd), Chromium (Cr), Lead (Pb), Mercury (Hg), 

Nickel (Ni), Total Hydro Carbon (THC) or Carbon monoxide (CO) - 

-operational standard 

Please also refer to: < 

http://www.epa.gov/ttn/atw/area/area_source_list_112202.pdf > for the list 

of CAA section 112 Urban Hazardous Air Pollutants for Area Source 

Categories. 

Please note that a number of pollutants in Table 2 over lap with air 

pollutants of interest as regulated under CWA part 503 and CAA section 112 

Urban HAP list. 

Testing Clarification: What pollutants must I conduct testing for and how 

long should the test runs be? 

The testing component of this ICR directs SSI unit owners to submit test 

results for all pollutants listed in Table 1 and Table 2 (above). This 

may be a combination of documentation from new testing which you conduct 

in response to this ICR or existing documentation if the testing was 

conducted within the past five years or you may submit the last 30 days of 

Continuous Emissions Monitoring Systems (CEMS) data including those days 

where manual testing was conducted. 

Please submit any existing test data (in the past 5 years) in the form of 

test reports (by email or CD), to EPA as soon as possible so that EPA can 

verify what additional pollutants must be tested for your specific entity. 

 EPA will also communicate if any test run times for the existing data are 

not acceptable. 

If your entity needs to test for any of the pollutants listed because of 

1) existing data is deemed not acceptable by EPA or 2) there is no 

existing data, then please follow testing instructions as outlined in the 

ICR. 

Should you have any additional questions, please contact me via email or 

by calling 919-541-0964. Attached is also a copy of the most updated 

survey, as I understand there were some problems with a previous version. 

The survey is due December 19, 2009. 

Regards, 

Amy Hambrick 

Natural Resources and Commerce Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964