	

Re: One more modeling question. and updates to Ohio's Lead	 Emissions

Jennifer Hunter 

to:

Andy Chang

04/05/2010 11:00 AM

Cc:

Douglas Aburano, Jay Bortzer, Michael Compher, Tom Rosendahl, John
Summerhays, 

Rhonda Wright

 

 



Andy, here is 1.  

 

We will need another week for #2 - our inventory person is out.  

 

First, our we only did a modeling/interp analysis on sources over 0.7
TPY of lead.  Deciding wether a source was at or above 0.7 TPY was based
on actual emissions, including both point and fugitive. Ohio EPA also
used actual emissions when performing the modeling/spatial
interpolation.  Ohio EPA evaluated actual reported emissions over a
range of years (2004-2006) from the National Emissions Inventory (NEI)
(which was submitted based upon emissions reported in Ohio's FER (fee
emissions report) and Toxics Release Inventory (TRI).  Ohio's FER
contains both stack and fugitive emissions.  Ohio ensured the maximum
emission rate modeled corresponded to the maximum TPY contained in the
NEI/FER and TRI between 2004 and 2006. In many cases, the modeled lead
emission rate was higher than the highest facility reported emissions in
that year, thus producing a conservative modeled concentrations.   We
went to each facility to obtain information regarding their lead sources
before we modeled. We requested information on both fugitive and stack
emissions.  Of all facilities modeled only one, Timkin, had fugitive
sources.  We did model those as fugitive.  Keep in mind, these weren't
fugitive in the sense you may be inquiring (e.g., a roadway) (building
fugitives instead). 

 

other fugitive emissions or re-entrainment of dust were not explicitly
modeled by Ohio EPA.  Modeling the re-entrainment of dust would be very
difficult using the air dispersion model AERMOD.  It is Ohio EPA’s
belief that unusual methods, such as soil samples surrounding the
facility, would be needed in order to determine the lead emission rate
for dust.  In addition, many other factors would need to be considered
before modeling fugitive emissions or re-entrainment of dust.  These
factors are currently unknown to Ohio EPA and were not provided by the
facility.  Additional guidance and research would be needed to be able
to accurately perform such an assessment.

 

Thanks, Jen

