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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 informatio n

Hi Mary and Michael,

Here’s the information from OEPA on the Carmeuse Li me plant near Zimmer based on my call with them last week. I was most interested in Carmeuse’s impact on the Zimm er peaks. The information below seems reasonable, given they don’t have modeling of the actual facility but do h ave modeling of a similar much larger facility. W hat 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 Lim e facility, believes that the impacts of the Carmeuse Lime faci lity located in Pendleton County, Kentucky, are con servatively and adequately represented by the background of 11 ppb (28.776 ug/m3) that was included in the Zimmer sourc e area.
Dispersion modeling of the Carmeuse Lime Maple Grov e facility, which is an approximately 4,500 TPY sou rce, indicated a maximum impact of 146 ug/m3, occurring 850 meters a way from the source. The Carmeuse Lime facility in Pendleton County, Kentucky that is in question emitted 614 to ns of SO2 in 2012, 524 tons in 2013, and 651 in 201 4. Therefore, this source is approximately 7 to 8 times smaller than t he source modeled in Ohio, based on actual emission s. A back of the envelope calculation would indicate that the maximu m impact of the Pendleton County facility would rou ghly be in the 18 to 21 ug/m3 range. The Pendleton County facilit y’s impacts would need to be roughly twice that amo unt, and at the2 point of Zimmer’s maximum impact, to model an exceed ance. Given the size of the facility and the 4.8 k ilometer distance between the Carmeuse Lime facility and the point of Zimmer’s maximum impact, such an occurrenc e is highly unlikely.

Further, Zimmer’s maximum impacts near the Carmeuse Lime facility are in the 128 to 136 ug/m3 range, in clusive of background. Thus, the facility’s maximum impact wo uld have to be approximately 60 ug/m3 for exceedanc es 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 Car meuse Lime facility. The tallest stack at the Carmeuse Facili ty is 36 meters high, and Ohio EPA’s experience ind icates 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 approximat ely 400 meters of the Carmeuse facility, well short of the point of Zimmer's maximum impact close to the facility. Agai n, 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 kno w if you need anything else.

Best,

Chris Beekman