                              September 13, 2016
Memorandum

Subject:	Summary of Conference Call with National Lime Association Representatives

From:		Matt Hakos, RTI

To: 		Jim Eddinger, EPA/OAQPS

I.	Purpose

	The purpose of the call was to continue discussions with industry regarding the Lime Manufacturing NESHAP and RTR, specifically related to the forth coming information collection request. 

II.	Date and Time

	The call was held September 13, 2016 between 11:00 a.m. and 12:30 p.m.

III.	Attendees

	Jim Eddinger, EPA/OAQPS
	Steve Fruh, EPA/OAQPS
      Christian Fellner, EPA/OAQPS
	Matt Hakos, RTI
	William C. Herz, National Lime Association
	Hunter Prillaman, National Lime Association
	Jon De'ath, National Lime Association

IV.	Summary

 Introduction
      
      EPA and the National Lime Association (NLA) held a conference call to discuss the forthcoming information collection request (ICR).  EPA provided a draft copy of the ICR for review by industry.  The NLA circulated the ICR to its members and compiled a list of questions that were addressed during the call. NLA notified EPA of its intent to submit formal comments on the ICR by October 7[th].  The NLA is also planning to hire a consultant to compile a solids material testing protocol, which it intends to provide to EPA by mid-November.
   
 Topic 1

      The NLA asked EPA what its intent was in inquiring information from area sources. EPA explained that based on the current rule (Subpart AAAAA), there was reason to believe that area sources would have testing data for HCl and organic HAP.  EPA also indicated that they were interested in any controls that may have been applied to synthetic minor sources.  The NLA indicated that they are unaware of any area sources who were using controls or permit limits to attain area source status.  NLA indicate that the area source facilities emissions were low due to the facilities being physically small. 
      The NLA indicated that there would be less area source HCl test data available than expected, because only certain facilities required testing to demonstrate area source status.  Many facilities were able to petition the permitting authorities and demonstrate area source status through potential to emit calculations.  Only facilities that were close to the major source thresholds for HAP were actually tested.  Furthermore, 63.7142(c) gives the permitting authority discretion to allow one kiln test to be applied to "essentially identical kilns".  
      NLA also indicated that they are unaware of any organic HAP testing that was conducted in support of area source status determinations. NLA indicated that the availability of HCl and organic HAP test data will be less than expected and that the burden of the ICR was not warranted for these facilities. 
      
 Topic 2.

      The NLA indicated that they were unclear about the equipment that EPA was seeking information for, based on the current language in the Draft ICR.  EPA clarified that they were only seeking information for currently regulated equipment, specifically kilns, their coolers, and processed stone handling operation systems. 
      
 Topic 3.

      The NLA expressed concern regarding the draft ICRs request for "most current test" data.  NLA indicated that the most current test data would likely be insufficient to accurately portray emissions.  The NLA suggested providing the last 2 - 3 tests available, focusing from 2011 to 2016. The NLA explained that the test data they will provide will be primarily PM test data.  The NLA indicated that there is likely very little speciated metal or organic HAP test data available. 
      
 Topic 4.

      The NLA inquired about the request for HAP metal and halogen testing of solid material feedstocks, solid combustion feedstocks, and end use products. EPA indicated that this data would be used to perform a mass balance in order to estimate effluent stack emissions.  The NLA agreed that this approach was reasonable, but stated that sampling of the lime kiln dust should also be required.  NLA indicated that the current sampling length of three days was insufficient and that sampling should occur over a longer period.  
      The NLA stated that the test methods identified in the current testing protocol were inadequate. The NLA also stated that the sampling protocols were impractical for certain facilities. The NLA indicated that they intend to hire a consulting firm to draft a better sampling protocol.  NLA indicated that they would try to get this protocol to EPA by mid-November.  NLA also suggested using one lab to process all samples from all facilities.

 Topic 5.

      The NLA inquired about the current rule and the status of HCl as unregulated. During the original development of the rule, it was determined that HCl emissions were an acceptable from risk standpoint, therefore a standard for HCl was not set.  EPA indicated that current processes require a numerical standard and outlined general options for how that standard may be set. 

 Topic 6.

      The NLA inquired whether or not the modeling supporting the forthcoming RTR could be performed by a consulting firm hired by the NLA.  NLA indicated that in the original rulemaking, modeling was performed in this manner.  The modeling file was submitted to EPA for verification. NLA indicated that they would be open to hiring a consultant again.  EPA agreed to talk with members of the modeling group to determine what current practices and procedures are in place.
