From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Monday, March 15, 2021 11:26 AM
To: 
David Ailor <dailor@accci.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
allowable rationale


Hi. I wanted to send an explanation of our rationale for the procedure used for calculating allowables, in case there was a question about this.

The risk assessment of allowables emissions is a check on the standard rather than the facility. It is a check of the standard using real and current industry operation, which the current industry facilities provide. 

If there is no standard, then allowables equals actuals, regardless of the operation level of the facility, i.e., regardless of capacity vs actual level of operation, and regardless of the "potential to emit." 

See the risk assessment in 2005 for subpart L as well as the integrated iron and steel RTR in 2020 (subpart FFFFF) for examples of this practice.

https://www.epa.gov/stationary-sources-air-pollution/national-emission-standards-hazardous-air-pollutants-neshap-9 




Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D243-02)
Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.

Pronouns - She/Her/Hers
Salutation - Dr./Ms.

From: David Ailor <dailor@accci.org> 
Sent: Friday, March 12, 2021 3:33 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: COMMENTS? -- coke model files have gone to EPA division QA

Hi, Donna Lee.  Thanks for being patient with us on this.

Rest assured that our top priority at the moment is responding to you on the questions/comments you sent us this week.  We're working our way through all of them as quickly as we can.

We plan to respond to you by next Wednesday (March 17) on most of them, including those that pertain to "PQBS category source file" issue nos. 1, 3, 4 and 5 and "Non-category source file" issue no. 3.  On the remaining questions/comments, which pertain to files we had not seen until this week (i.e., "PQBS category source file" issue no. 2 and "Non-category source file" issue nos. 1 and 2), we are still working our way through them and do not have a definitive date for you yet.

Please contact me if you have questions.  DCA

David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org


