From: Telander, Jeff [mailto:Telander.Jeff@epa.gov] 

Sent: Tuesday, December 09, 2014 10:27 AM

To: Susan Miller <SMiller@bia.org>

Cc: Nizich, Sharon <Nizich.Sharon@epa.gov>; Barnett, Keith <Barnett.Keith@epa.gov>

Subject: RE: Further information from EPA

The Brick_Facility_max_risk_and_HI spreadsheet is the output from running the input of 250 tpy 

HCl. This file does not include a concentration field. A model run for unit emissions (1 TPY), was 

done only to estimate the level of the HBEL, and once we estimated that at 250 TPY, the model 

run with 250 TPY was the confirmation of and support for the HBEL. The maximum modeled 

concentrations for each facility can be determined by multiplying the HI values in the 

Brick_Facility_max_risk_and_HI file by the HCl Reference Concentration (0.02 mg/m3).

Jeff

From: Susan Miller [mailto:SMiller@bia.org]

Sent: Tuesday, December 09, 2014 6:03 AM

To: Telander, Jeff; Irene Kuo

Subject: FW: Further information from EPA

Please see below

Susan J Miller

(919) 380-2191

When you talk, you are only repeating what you already know; but when you listen, you may learn 

something new. - Dalai Lama

From: Irene Kuo [mailto:ikuo@rtpenv-nc.com]

Sent: Monday, December 08, 2014 3:08 PM

To: Susan Miller

Subject: RE: Further information from EPA

Susan, Can you confirm with Jeff whether the Brick_Facility_max_risk_and_HI spreadsheet is the 

output from running the input of 250 tpy HCl or the unit 1 tpy emissions? Based on the other files 

provided, and the values in the HI spreadsheet, it appears to the be the result of running the 250 

tpy input. If this is the case, we will need the output max risk and HI file from running the unit 

emissions to evaluate EPA’s HBEL determination. The individual facility files would provide the 

modeled impact values. We can back-calculate the concentrations from the HI values, but it would 

be preferable to begin with raw data where we can.
From: Susan Miller [mailto:SMiller@bia.org]

Sent: Monday, December 08, 2014 10:11 AM

To: Telander, Jeff

Cc: Irene Kuo

Subject: RE: Further information from EPA

We will check again! Thanks, Jeff! Irene may contact you directly if she is having trouble finding 

the information.

Keith mentioned that the rule may be published this week... that would put a Public Hearing right at 

Chirstmas... is that really going to happen, if requested?

sus

Susan J Miller

(919) 380-2191

When you talk, you are only repeating what you already know; but when you listen, you may learn 

something new. - Dalai Lama

From: Telander, Jeff [mailto:Telander.Jeff@epa.gov]

Sent: Monday, December 08, 2014 9:38 AM

To: Susan Miller

Cc: Nizich, Sharon; Barnett, Keith

Subject: RE: Further information from EPA

Susan,

It is my understanding that the information in the files that Irene identified is included in the files 

that I’ve previously provided to you.

Maximum_indiv_risks.xls – this file contains the max risk and HI (only HI matters here) for the 

facility for the census block receptor where the max occurs. This same info is given in the 

“Facility_max_risk_and_HI” file we already provided, which contains these data for all facilities

Maximum_offsite_impacts.xls – similar to the Maximum_indiv_risks.xls file, this file contains the 

max risk and HI for the facility for any receptor (census block or otherwise) where the max occurs. 

The model automatically creates a set of polar receptors for every facility run, but these receptors 

were not scrutinized to ensure they are actually offsite, and it is very likely that the modeled max 

“offsite” polar receptor is actually onsite. Since our focus in determining the HBEL was long-term 

human health, we only focused on the census block receptors for the chronic runs.

Risk_breakdown.xls – This file provides the risk breakdown at the max receptor (both census block 

and polar), i.e., how much of the risk comes from which pollutant and which sources. This file also 

doesn’t really provide any new information because for each run we did there was only a single 

pollutant, and the emissions were equally spread out over however many kilns each facility had. 
I hope this is helpful.

Jeff

From: Susan Miller [mailto:SMiller@bia.org]

Sent: Thursday, December 04, 2014 4:46 PM

To: Telander, Jeff

Subject: FW: Further information from EPA

Can you help me with the files Irene mentions below? Thanks

sus

Susan J Miller

(919) 380-2191

When you talk, you are only repeating what you already know; but when you listen, you may learn 

something new. - Dalai Lama

From: Irene Kuo [mailto:ikuo@rtpenv-nc.com]

Sent: Thursday, December 04, 2014 12:24 PM

To: Susan Miller

Subject: Further information from EPA

Susan,

In order to fully evaluate the proposed HBEL, I need the output files, or a summary of those files, 

that contain the modeled chronic impacts from each facility. There are a number of output files for 

each facility. The key files we would need for each facility are entitled:

· Maximum_indiv_risks.xls

· Maximum_offsite_impacts.xls

· Risk_breakdown.xls

Please let me know if you need any further information or clarification.

Irene

Irene Kuo

RTP Environmental Associates

304-A West Millbrook Road

Raleigh, NC 27609

ikuo@rtpenv.com

919-845-1422 ext. 24