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From: Amy Hambrick, U.S. Environmental Protection Agency

To: Sewage Sludge Incinerator File and Docket

Re: July 8, 2009 Meeting Between the U.S. EPA and the National Associated of Clean Water 

Agencies (NACWA) regarding New Source Performance Standards (NSPS) and Emission 

Guidelines (EG) for Sewage Sludge Incinerators 

Date: August 17, 2009

On July 8, 2009, a teleconference meeting was held between the U.S. Environmental Protection 

Agency (EPA) and representatives from the National Associated of Clean Water Agencies 

(NACWA) to discuss the upcoming NSPS/EG for Sewage Sludge Incinerators. Various issues 

related to the Agency’s upcoming proposed rulemakings under the Resource Conservation and 

Recovery Act (RCRA) and the Clean Air Act (CAA) were discussed. EPA provided updates 

regarding the proposed rulemaking schedules for Identification of Non-Hazardous Materials That 

Are Solid Waste (under RCRA) and Sewage Sludge Incinerators (under CAA), as well as the 

Office of Resource Conservation and Recovery’s position on RCRA’s Domestic Sewage 

Exclusion. Also, EPA requested sewage sludge incinerator information from NACWA for 

purposes of updating an older database previously provided by NACWA. 

The meeting participants are listed below:

Name Organization 

Tracey Atagi EPA/ORCR 

Robert Dominak NACWA 

Susmita Dubey EPA/OGC 

Michael Galbraith EPA/ORCR 

Sasha Gerhard EPA/ORCR 

Amy Hambrick EPA/OAQPS 

Chris Hornbeck NACWA 

Ketan Patel EPA/OAQPS 

Martha Smith EPA/OAQPS 

Marc Thomas EPA/ORCR 
MEMORANDUM 

To: File 

From: Sasha Gerhard 

Subject: Meeting with National Association of Clean Water Agencies (NACWA) 

Date: 7/31/09 

On July 8, 2009, EPA (Michael Galbraith, Tracy Atagi, Marc Thomas, Sasha Gerhard, 

Martha Smith, Amy Hambrick, Ketan Patel, and Susmita Dubey) participated in a 

conference call with Chris Hornback of NACWA and Bob Dominak of Northeast Ohio 

Regional Sewer District, NACWA member, to discuss various issues related to the 

Agency’s upcoming proposed rulemakings under the Resource Conservation and 

Recovery Act (RCRA) and the Clean Air Act. (CAA). 

EPA provided updates regarding the proposed rulemaking schedules for Identification of 

Non-Hazardous Materials That Are Solid Waste (RCRA) and Sewage Sludge 

Incinerators (CAA), as well as the Office of Resource Conservation and Recovery’s 

position on RCRA’s Domestic Sewage Exclusion. Also, EPA requested sewage sludge 

incinerator information from NACWA for purposes of updating an older database 

previously provided by NACWA. 

SSI inventory information needed 

Amy Hambrick 

to: 

Chris Hornback, Robert Dominak 

07/08/2009 02:59 PM 

Cc: 

Michael Galbraith, Susmita Dubey, Ketan Patel, Robin Dunkins, Martha Smith 

Hello Chris and Bob: 

Thank you for taking the time to talk with us this morning. As mentioned during the phone call EPA is 

seeking to verify our SSI inventory and unit list. Since we are on a court ordered deadline we are working to 

move forward on our information gathering process as soon as possible. We hope to gain a better 

understanding of what is happening out in the field of SSI so that in the rule making process we can most 

reasonably and accurately create emission standards that reflect the industry. 

Again, I wanted to clarify that our current promulgation deadline for the SSI rule, which is needed to satisfy 

our obligations under section 112(c)(3), is October 15, 2009 . The court order documenting that deadline is 

attached. In order to work towards these dates, we need to begin our information collection process 

immediately. 

Preliminary information which needs to be confirmed and contributed to is the following below. If NACWA 

can get back to me within the next week or so (July 17, 2009) then EPA can move forward in our formal 

Information Collection Review process. I know that you will be at a conference till July 20 and short on time. 

Please let me know if this is doable and/or when the earliest time is that you could get me the information. 

1. SSI facility names 

2. SSI facility addresses 

3. SSI facility contact information 

4. SSI units and types per facility (if available) 

5. Y/N: Is entity is a small business (if available) - - small entities were initially identified as plants in cities 

with a population less than or equal to 50,000 but we are more interested in basing this on the population 

which the entity services. 

To assist you on this request, I have attached the inventory list which we currently have that you can use to 

compare to your inventory of members and if available any non-NACWA members that you know of. There 

are 3 tabs in the spread sheet. The first tab takes you to a list with basic information. The second tab has 

the same list with more detailed information. The third tab is the list that NACWA provided to EPA in 2007 

(outlining states and numbers of SSI units). 

As you mentioned during our phone call, NACWA has a considerable amount of information detailing types 

of SSI units, feed stock/rates, emission rates, pollutant emissions, control technologies that have lower vs. 

higher emissions, internal/external afterburners, and units that recover energy. This is the exact type of 

information that EPA is seeking. I understand that it is a large request to ask NACWA to put this information 

together in a manner that can be shared. If NACWA can provide us with this information as we are going 

through our process EPA will have a better understanding of industry technologies and concerns. I 

understand that this might take some time to put together. If NACWA is willing to share this information EPA 

would need to have it by August 31, 2009 or earlier if possible. Is that a reasonable time frame for you? 

Again, thank you for participating and contributing to our information collection process. I look forward to 

continuing this dialog with NACWA. Should you have any questions, feel free to call me at 919-541-0964. 

Regards, 

Amy Hambrick 

Natural Resources and Commerce Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964 

FAX: 303-312-6953