From: Neuffer.Bill@epamail.epa.gov [mailto:Neuffer.Bill@epamail.epa.gov] 
Sent: Thursday, June 03, 2010 3:38 PM
To: Desai.Mausami@epamail.epa.gov; Jordan.Scott@epamail.epa.gov; Frank.Nathan@epamail.epa.gov; Sorrels.Larry@epamail.epa.gov
Cc: Ndoh.Christina@epamail.epa.gov; Icenhour, Melissa K.; Fairchild.Susan@epamail.epa.gov
Subject: Short Summary of Teleconference with TFI re: Subcategorization/Nitric Acid plants

TFI seems to want to subcategorize existing low and medium pressure units from the rest of nitric acid.
       TFI was not sure if any low and med lines have been subject to this NSPS thru mod/reconstruct
       We said it was very difficult if not impossible to have a subcategory based on hypothetical
       TFI will gather info on whether any low/ med line has been subject to this NSPS thru mod/reconstruct
       TFI said NSCR could not be changed if mod/reconst occur.  I said I was not sure that was true.
       TFI - new lines will be high or dual pressures
       TFI will submit written material on their proposal.
       I mentioned historical test data using Method 7 E without the proper procedures was of little value.
Tina, Melissa, Susan,
Feel free to add your comments.

Bill Neuffer
Metals and Minerals Group
Office of Air Quality Planning and Standards (D 243-02) US Environmental Protection Agency Research Triangle Park, NC 27711

Phone - 919-541-5435
Fax - 919 - 541-3207
E-mail - neuffer.bill@epa.gov
Office Location:  109 TW Alexander Drive RTP, NC (D 231C)

Overnight mail address:
US EPA
Mail Code D243-02
109 TW Alexander Drive
RTP, NC 27709


