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 Arcadis
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Date: 	February 10, 2017 
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On February 10, 2017, Karen Marsh had a telephone discussion with Joel Cohn of Arcadis to discuss comments on the proposed revisions to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly Owned Treatment Works (POTW). Mr. Cohn works as a consultant for Hopewell Regional Wastewater Treatment Facility (Hopewell) which is an existing Group 1 POTW. Mr. Cohn asked if an extension would be granted for the public comment period. EPA indicated that we had received extension requests and were evaluating them at the time. Mr. Cohn also stated that modeling emissions from sewers would be extremely difficult with little benefit given that controls are not generally available or cost-effective. He stated that limiting a new industrial user from discharging new HAP to the POTW could be a way that pretreatment limits would maintain emissions but cautioned the use of a requirement to make POTW evaluate and limit HAP from industrial users that are already permitted for discharges.

EPA requested that Mr. Cohn include his comments in a formal submission to the docket.

