From: Theresa Beddoe [mailto:tbeddoe@knowlton-co.com] 
Sent: Tuesday, February 20, 2018 10:15 AM
To: Smith, Korbin <smith.korbin@epa.gov>
Cc: Erick Austin <eaustin@knowlton-co.com>
Subject: RE: Emissions Calculations

Oh yes, forgive me.  I muddied those waters a bit.  I would still estimate that our effort is 8 hours/ event and 6 events for SSM events reported in the semi-annual monitoring compliance report.

Theresa Beddoe
HSES Specialist
Knowlton Technologies, LLC 
(315) 755-2656 Direct
(315) 783-9976 Cell
Together - Turning Challenges into Value



From: Smith, Korbin [mailto:smith.korbin@epa.gov] 
Sent: Tuesday, February 20, 2018 10:09 AM
To: Theresa Beddoe <tbeddoe@knowlton-co.com>
Subject: RE: Emissions Calculations

Theresa,

Thanks for the response. The 8 hours per occurrence and 2 occurrences currently is reference to the SSM report which is a separate report that is filed when an SSM event happens that is in exceedance of the standard and the SSM plan is not followed. If I'm understanding you correctly, what you are estimating at 8 hours and 6 events is the total amount of SSM reporting that is included in the semi-annual compliance report, is this correct? I know these line items can get a little confusing. 

Korbin Smith BS, MPH
Physical Scientist
U.S. EPA OAR/OAQPS
Sector Policies and Programs Division
109 TW Alexander Drive
Mail Code D243-04
Research Triangle Park, North Carolina 27711
(919) 541-2416





From: Theresa Beddoe [mailto:tbeddoe@knowlton-co.com] 
Sent: Tuesday, February 20, 2018 10:02 AM
To: Smith, Korbin <smith.korbin@epa.gov>
Cc: Erick Austin <eaustin@knowlton-co.com>
Subject: RE: Emissions Calculations

Hi, Korbin!  Yes, I have been mulling this question over.  I think that your 8 hours per event is probably good, when you consider everyone that has input on these things.  It just takes time to figure these things out and to report them, and I have no idea how to calculate the time spent on the each event except by best-guess estimate.  However, your estimate of the number of events per semi-annual report, which I believe was two, is light.  At least for our boiler/incinerator, it is more like six events per report.  I don't know what portion of that is due to having two operational modes that you are frequently shifting between.  Perhaps if another incinerator always ran in incinerator mode (or boiler ran in boiler mode) the number of events would be fewer.  For us, it is more like 6 events per report, which I calculate as the average over the previous 2 years.  I hope that this helps, and I apologize for the delay in responding.  --Theresa

Theresa Beddoe
HSES Specialist
Knowlton Technologies, LLC 
(315) 755-2656 Direct
(315) 783-9976 Cell
Together - Turning Challenges into Value



From: Smith, Korbin [mailto:smith.korbin@epa.gov] 
Sent: Tuesday, February 20, 2018 7:59 AM
To: Theresa Beddoe <tbeddoe@knowlton-co.com>
Subject: RE: Emissions Calculations

Theresa,

I hope you had a great weekend. I wanted to check to see if you were able to find anything regarding estimating burden with reporting SSM in the semi-annual compliance report.

Regards,

Korbin Smith BS, MPH
Physical Scientist
U.S. EPA OAR/OAQPS
Sector Policies and Programs Division
109 TW Alexander Drive
Mail Code D243-04
Research Triangle Park, North Carolina 27711
(919) 541-2416
