June
8,
2004
NOTE
SUBJECT:
Meeting
w/
CKRC
Re
112(
d)(
4)

FROM:
Bob
Holloway,
EPA
TO:
Docket
ID
No.
OAR­
2004­
0022
On
June
8,
2004,
Mike
Benoit
and
Dave
Novello,
Cement
Kiln
Recycling
Coalition
(
CKRC),
and
Curtis
Lesslie
and
A.
Heineri,
Trinity
Consultants,
met
with
Hugh
Davis,
Frank
Behan
and
Bob
Holloway,
EPA,
to
clarify
the
information
we
requested
in
the
NPRM
to
establish
national
risk­
based
emission
standards
for
cement
kilns
(
pp.
21305­
21306).

CKRC
expressed
concern
that
the
approach
we
apparently
were
suggesting
would
establish
a
national
mass
emission
rate
(
lb/
hr)
standard
for
all
cement
kilns
based
on
the
lowest
mass
emission
rate
for
any
kiln
facility.
This
would
be
problematic
because
all
other
kilns
could
emit
higher
emission
rates
w/
o
exceeding
a
Hazard
Index
of
1.0.

We
explained
our
concern
with
a
mass
concentration­
based
standard
(
ppmv):
gas
flowrates
could
increase
which
would
increase
the
mass
emission
rate
and
could
potentially
result
in
exceeding
the
HI
limit
of
1.0.

Given
that
CKRC
has
determined
that
HIs
would
not
exceed
0.7
for
any
facility
assuming
all
kilns
emitted
at
the
max
emission
concentration
 
130
ppmv
(
i.
e.,
risk­
based
emission
limit
would
be
capped
at
the
current
MACT
standard
of
130
ppmv
to
preclude
backsliding),
and
given
that
CKRC's
risk
modeling
assumed
that
all
kilns
operated
at
the
max
allowable
flowrates,
it
appears
that
it
is
highly
unlikely
that
any
facility
could
increase
gas
flowrates
under
the
MACT
rule
to
the
extent
that
an
HI
of
1.0
would
be
exceeded
at
the
max
concentration
of
130
ppmv.
CKRC
understands
our
concerns,
however,
and
will
present
information
that
will
document
that
an
HI
of
1.0
would
not
be
exceeded
by
any
facility
emitting
at
130
ppmv.

We
also
discussed
our
concern
about
acute
exposure.
As
explained
in
the
NPRM,
a
source
could
feed
chlorine
for
short
periods
of
time
at
rates
many
times
the
annual
average
limit
while
maintaining
compliance
with
the
annual
average
limit.
During
those
episodes
of
elevated
chlorine
federates,
however,
total
chlorine
emissions
would
be
substantially
higher
than
average
and
could
result
in
1­
hour
avg
ground
level
concentrations
that
exceed
a
HI
of
1.0
based
on
the
AEGL­
1
values
for
HCl
and
Cl2.

CKRC
indicated
that
a
12­
hour
averaging
period
for
the
chlorine
feedrate
limit
would
probably
be
acceptable,
in
lieu
of
an
annual
averaging
period,
because
that
would
be
status
quo.
This
should
reduce
the
concern
re
short
term
excursions
above
the
acute
HI
of
1.0.
We
remain
concerned
about
this
issue,
however,
and
CKRC
indicated
that
they
will
address
this
concern.
