"Andy O'Hare" <aohare@cement.org> 
03/09/2006 01:56 PM
Please respond to
aohare@cement.org
	To
Keith Barnett/RTP/USEPA/US@EPA
cc

bcc

Subject
RE:	
		
		
		Keith, 

Thanks for your note.  Alan Kao with Environ did the modeling runs on HCl 
on
our behalf.  He also did the work on behalf of the National Lime
Association.  I plan to confer with Alan and devise and appropriate
response. 

Regards,
Andy 


Andrew T. O'Hare, CAE
Vice President
Portland Cement Association
1130 Connecticut Avenue, N.W., Suite 1250
Washington, D.C. 20036
Ph: (202) 408-9494
Fx: (202) 408-0877
e-mail: aohare@cement.org

-----Original Message-----
From: Barnett.Keith@epamail.epa.gov [mailto:Barnett.Keith@epamail.epa.gov] 
Sent: Thursday, March 09, 2006 1:27 PM
To: O'Hare, Andy
Cc: silverman.steven@epamail.epa.gov; Palma.Ted@epamail.epa.gov;
Fruh.Steve@epamail.epa.gov
Subject: 

Dear Andy:

We have taken a preliminary look at the HCl risk analysis provide with your
comments on the proposed amendments to the Portland Cement NESHAP.
Based in this review , we have the following points that need to be
addressed before we can continue our review:

1)    It is not clear if the facilities in either the PCA letter
(ENVIRON analysis) or the CKRC analysis are representative of those in the
entire source category.  Ideally, at a minimum we would like to have a more
detailed listing of the sources in category along with there most recent 
and
regulatory emissions data and stack information.  Further, it is not clear
if the CKRC sources burning hazardous waste will have similar
emissions/stack parameters to those burning more traditional fuels.

2)    Very little technical details are provided with either assessment.
For a complete review, modeling parameters such as receptor, meteorological
data, site specific parameters, and model configuration need to be provided
along with electronic copies of all modeling runs and supporting data.

3)    It is not clear if emission calculations are based on actual,
potential, permitted operating conditions

4)    Background ambient levels should be derived from more recent
ambient data such as that available on the EPA's AirDate website.
http://www.epa.gov/air/data/index.html

5)    Impacts should also be compared with all chronic and acute health
criteria as provided on EPA website including the CalEPA acute inhalation
reference exposure levels (REL) at :
http://www.epa.gov/ttn/atw/toxsource/summary.html

6)    PCA may also want to screen out certain facilities from the more
refined (ISCST3) modeling analysis by examining impacts from a conservative
model plant (a low stack, low exit velocity) and defining a minimum 
emission
rate that would be need to approach health criteria.

If anything here is unclear, I suggest we set up a phone call that includes
the personnel who actually did the analyses to discuss our questions.

Keith W. Barnett
US/EPA OAQPS, ESD/MICG C504-05
Research Triangle Park, NC  27711
919-541-5605
barnett.keith@epa.gov


