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 Comments Submitted by Gulf Coast Waste Disposal Authority
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Date: 	April 18, 2017 
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On April 18, 2017, Karen Marsh had a telephone discussion with Shaun Austin of Gulf Coast Waste Disposal Authority (GCWDA) to discuss GCWDA's comments on the proposed revisions to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly Owned Treatment Works (POTW). GCWDA owns and operates 3 POTW that are subject to the 1999 NESHAP. These include the Bayport Facility (Group 1), 40-Acre Facility (Group 2), and Washburn Tunnel (Group 2). Below is a summary of the topics discussed during each telephone conversation.

GCWDA submitted information on all 3 POTW during the October 2015 information collection effort that indicated all 3 POTW were major sources and subject to the 1999 NESHAP. In reviewing these submissions and preparing the review of the rule, EPA inadvertently did not include 40-Acre or Washburn Tunnel in the analysis. In the public comment submission from GCWDA (DCN EPA-HQ-OAR-2016-0490-0052), GCWDA alerted EPA to this error. 

EPA followed up via telephone to discuss HAP emissions from 40-Acre and Washburn Tunnel. Mr. Austin stated that both POTW are subject as existing Group 2 POTW because emission modeling (using Water9 and ToxChem+) indicated the potential HAP emissions would exceed the major source threshold of 10 tons per year (tpy) for any single HAP or 25 tpy for any combination of HAP. Mr. Austin further indicated that while these are the potential emissions, neither POTW has exceeded these thresholds in actual operating conditions. When asked which HAP are the primary pollutants, Mr. Austin stated that methanol is the largest emission for both facilities. Additionally, Mr. Austin stated that GCWDA had submitted emissions estimates to the state of Texas for the 2016 calendar year in March 2017 and indicated this information would be publicly available to EPA. 
