MEMORANDUM

To:		Docket EPA - HQ - OAR - 2016 - 0490

From: 	Karen Marsh, U.S. EPA, OAQPS, Sector Policies and Programs Division

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Subject:	Discussion of Proposed POTW NESHAP with American Bottoms Regional Wastewater Treatment Facility
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Date: 	December 2016  -  March 2017 
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Multiple telephone conversations were conducted with Kay Anderson of the American Bottoms Regional Wastewater Treatment Facility to discuss ABRTF's comments on the proposed revisions to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly Owned Treatment Works (POTW). ABRTF is considered a Group 2 POTW and is subject to the 1999 POTW NESHAP. Below is a summary of the topics discussed during each telephone conversation.

December 23, 2016:
Ms. Anderson stated that ABRTF is a major source of hazardous air pollutants (HAP) because of the potential methanol emissions from their facility. She indicated that ABRTF prohibits the use of the POTW by industrial facilities to comply with another NESHAP, therefore preventing them from becoming a Group 1 POTW. ABRTF does not utilize covers on any of the primary treatment units and by initial estimates would have difficulty complying with the proposed 0.08 HAP fraction emission limit for existing Group 2 POTW. Ms. Anderson further stated that since pretreatment reduces the influent loading at the POTW treatment plant, that pretreatment would not help a POTW comply with the HAP fraction emission limit. Given the difficulties with the HAP fraction limit, Ms. Anderson suggested that a separate standard could be appropriate for methanol. Finally, Ms. Anderson indicated that modeling or estimating emissions from collection systems would be a substantial requirement. EPA encouraged Ms. Anderson to include these topics in her formal submission of comments to the docket.

March 6, 2017:
Ms. Anderson again stated that methanol is the main pollutant from ABRTF and that it is received in large quantities from one specific industrial user. ABRTF had evaluated whether they could impose a limit on the industrial user but determined that would not be beneficial to either the POTW or the industrial user. 

During this discussion, Ms. Anderson asked whether any other POTW had identified themselves as subject to the rule and further stated that if any did, she would expect them to be Group 2 POTW. Ms. Anderson asked why additional standards were being proposed if there was no risk associated with the 1999 regulation. She stated that using a "safety factor" to set the HAP fraction was appreciated because it accounts for variability in flow and influent loadings. However, Ms. Anderson did suggest that a HAP fraction for the entire facility, and not just the primary treatment units, could be beneficial and allow ABRTF to comply with the regulation. She indicated that we provided data in the docket with HAP fraction calculations for both the primary units alone and the whole facility and she suggested that we reconsider the HAP fraction limit based on the data we have for the whole treatment plant.

As discussed in the December call, Ms. Anderson again raised the concern that pretreatment would not be a tool that a POTW could use to help with compliance with the HAP fraction. She further indicated that too much pretreatment would actually cause additional compliance issues because emissions resulting from a lower HAP load would actually raise the fraction emitted. Ms. Anderson suggested that the HAP fraction limit only be required when HAP loadings are above a specific threshold.

The proposed revisions indicated that all HAP listed in Table 1 of 40 CFR part 63, subpart DD would need to be evaluated when demonstrating compliance with the HAP fraction limit. Ms. Anderson stated that she had not been able to locate a lab that could actually test for the entire list of HAP in Table 1. 

Finally, Ms. Anderson indicated that the 12-month compliance date would not be sufficient for ABRTF to have systems in place to demonstrate compliance with any of the proposed revisions should they be finalized. EPA again requested that Ms. Anderson include all of this information in her formal comment submission to the docket.






