                               November 03, 2016
Memorandum

Subject:	Summary of Conference Call with National Lime Association Representatives and Industry Representatives

From:		Matt Hakos, RTI

To: 		Jim Eddinger, EPA/OAQPS

I.	Purpose

	The purpose of the call was to discuss industry comments regarding the draft Lime Manufacturing NESHAP information collection request (ICR). 

II.	Date and Time

	The call was held November 03, 2016 between 11:00 a.m. and 11:40 a.m.

III.	Attendees

	Jim Eddinger, EPA/OAQPS
      Jim Hirtz, EPA/OAQPS
	Matt Hakos, RTI
	William C. Herz, National Lime Association
	Hunter Prillaman, National Lime Association
	Jon De'ath, National Lime Association
	Bradford Frisby, National Lime Association
      Gary Bartkowski, Magnesita Refractories
      Kimberly Bauman, Mississippi Lime
      Steve Carieri, Lhoist
      Joe Freudenberg, Carmeuse
      David Swisher, Carmeuse
      Hal Lee, Graymont
      Joel Brannan, Pete Lien & Sons
      Scott Kisner, Greer Lime

IV.	Summary

 Introduction

      EPA, the National Lime Association (NLA), and industry representatives held a conference call to discuss the NLA's comments on the draft ICR.  NLA provided written comments on the draft ICR on October 7[th], 2016. 
      
 Summary of Discussion

      EPA stated that there were not many follow up questions regarding the comments provided by NLA on the draft ICR.  The main areas of discussion during the call are summarized below:
      
 Data collection of criteria air pollutants (CAP) and greenhouse gasses (GHG)  -  NLA wanted to know the reason that EPA was seeking this data.  EPA indicated that they are required to review NSPS standards, as well as NESHAP standards.  EPA indicated that there was no timeline to review the NSPS standard, but the information would be beneficial.  EPA indicated that they will likely collect this data.  
 Timing of the ICR  -  EPA indicated that the ICR will likely not go out before the end of the 2016 calendar year.  NLA confirmed an in-person meeting at EPA on December 13[th], 2016.  NLA indicated that the purpose of this meeting would be to provide a more detailed explanation of the existing data that they had and areas where they may need to collect new data for completion of the risk modeling inputs. 
 HAPs of concern  -  EPA indicated that the following HAPs would likely need to be modeled:
 HAP Metals (including mercury)
 Organic HAP
 Acid Gasses 
 Dioxin Furan
 Modeling process  -  NLA asked EPA for information regarding the modeling process.  EPA provided a brief summary of the process and the general approach for developing emission rates.
 Detection limits  -  NLA inquired about the procedure for handling non-detect values.  EPA provided a very brief overview of the process, overall indicating that EPA would need to evaluate the data once it was received. 
 EPA indicated that they would model plants that were temporarily shut down. 
 NLA expressed concern regarding the solid sampling approach in the draft ICR.  NLA indicated that they have sufficient data to support development of emission rates for HAP metals and hydrochloric acid (HCl). As such, the solid sampling approach is likely not needed.  NLA also indicated that the solid sampling approach is not preferred.  NLA indicated that they would rather perform stack testing. 
      
