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Arra, Sarah

From: Portanova, Mary

Sent: Tuesday, February 16, 2016 10:23 AM

To: Arra, Sarah

Subject: FW: Email for docket (2/2)

For Ohio designations docket. 

From: Robinson, Randall 

Sent: Tuesday, November 17, 2015 10:29 AM 

To: Portanova, Mary <portanova.mary@epa.gov>; Langman, Michael <langman.michael@epa.gov> 

Subject: FW: Carmeuse Lime/Zimmer source area SO2 information 

Hi Mary and Michael, 

Here’s the information from OEPA on the Carmeuse Lime plant near Zimmer based on my call with them last week. I 

was most interested in Carmeuse’s impact on the Zimmer peaks. The information below seems reasonable, given they 

don’t have modeling of the actual facility but do have modeling of a similar much larger facility. What do you think? 

Randy 

Randy Robinson 

Air and Radiation Division 

EPA Region 5 

312 353-6713 

From: christopher.beekman@epa.ohio.gov [mailto:christopher.beekman@epa.ohio.gov] 

Sent: Tuesday, November 17, 2015 10:25 AM 

To: Robinson, Randall <robinson.randall@epa.gov> 

Cc: Jennifer.VanVlerah@epa.ohio.gov

Subject: Carmeuse Lime/Zimmer source area SO2 information 

Hello Randy: 

Ohio EPA, based on professional judgement and prior modeling of a similar but much larger Carmeuse Lime facility, 

believes that the impacts of the Carmeuse Lime facility located in Pendleton County, Kentucky, are conservatively and 

adequately represented by the background of 11 ppb (28.776 ug/m3) that was included in the Zimmer source area. 

Dispersion modeling of the Carmeuse Lime Maple Grove facility, which is an approximately 4,500 TPY source, indicated a 

maximum impact of 146 ug/m3, occurring 850 meters away from the source. The Carmeuse Lime facility in Pendleton 

County, Kentucky that is in question emitted 614 tons of SO2 in 2012, 524 tons in 2013, and 651 in 2014. Therefore, this 

source is approximately 7 to 8 times smaller than the source modeled in Ohio, based on actual emissions. A back of the 

envelope calculation would indicate that the maximum impact of the Pendleton County facility would roughly be in the 

18 to 21 ug/m3 range. The Pendleton County facility’s impacts would need to be roughly twice that amount, and at the 
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point of Zimmer’s maximum impact, to model an exceedance. Given the size of the facility and the 4.8 kilometer 

distance between the Carmeuse Lime facility and the point of Zimmer’s maximum impact, such an occurrence is highly 

unlikely. 

Further, Zimmer’s maximum impacts near the Carmeuse Lime facility are in the 128 to 136 ug/m3 range, inclusive of 

background. Thus, the facility’s maximum impact would have to be approximately 60 ug/m3 for exceedances to be 

modeled in this portion of the domain. This maximum impact would have to occur at the point of Zimmer’s maximum 

impact close to the facility. The 136 ug/m3 impact from Zimmer occurs 1.5 kilometers away from the Carmeuse Lime 

facility. The tallest stack at the Carmeuse Facility is 36 meters high, and Ohio EPA’s experience indicates that the 

maximum SO2 1-hour impacts occur within a distance of approximately 10 times the highest stack height. Thus, the 

maximum impact would likely occur within approximately 400 meters of the Carmeuse facility, well short of the point of 

Zimmer's maximum impact close to the facility. Again, Ohio EPA believes this is an extremely unlikely occurrence. 

Sorry for the delay, we needed to get our review of the Sierra Club modeling out by today. Let me know if you need 

anything else. 

Best, 

Chris Beekman