From: "Christopher R. Bryant" <cbryant@lawbc.com> 

 To: Chuck French/RTP/USEPA/US@EPA 

 Cc: Homer Hine <HHine@rsrcorp.com>, Mike Buckantz <MBuckantz@rsrcorp.com>, Bob Finn <BFinn@rsrcorp.com>, John De 

 Paul <JDePaul@rsrcorp.com>, "Lynn L. Bergeson" <lbergeson@lawbc.com> 

 Date: 05/11/2011 09:38 AM 

 Subject: Questions on Flow Weighted Average Concept from Proposed Rule 

 

Chuck, 

A meeting tomorrow for us isn't going to work. We will get back to youon another time and date soon. 

In the meantime, we have some questions that we are struggling with as we analyze the proposal. 

Attached is a document which we believe represents the RSR City ofndustry (COI) smelter’s current status with respect to the flowweighted average ( 0.2 mg/dscm requirement ) . The document goes through the calculations as we think the rule is asking us to 

perform them, but it has raised the following questions. 

1. Can you confirm that the approach outlined in the appended document is the correct way to calculate the facility-wide flow 

weighted average? 

2. The proposal states that compliance with the standard must be demonstrated monthly. Is the monthly demonstration intended 

to capture changes based on test results that may have been performed during the past month? If not, what is the purpose of the 

monthly demonstration? 

3. Although the standard is expressed in milligrams per dry standard cubic meter (mg/dscm) the equation presented calls for flow 

to be expressed as dry standard cubic feet (dscf). Can you clarify this apparent inconsistency please? 

4. The use of dry standard cubic feet does not make a difference in the result of the calculation, but it does seem at odds with a 

standard expressed as 0.2 mg/dscm. Is the reference to dry standard cubic feet in the equation a n error? 

5. The proposed rule appears to require testing of each point source (stack) every year within a year of the previous test. Won't 

this cause tests for each point source to creep back in the calendar each year as sources move up testing to make sure they do not 

get a notice of violation for being late by a day ? 

6. Are we correct in our description above or is the real intent to test each stationary source once each calendar year ? 

We'd really appreciate a response to this questions as we continue to analyze the rule. 

Thanks, and please give me a call or shoot me an e mail if you have any questions. 

Chris 

Christopher R. Bryant 

BERGESON & CAMPBELL, P.C. 

1203 Nineteenth Street, NW 

Suite 300 

Washington, D.C. 20036-2401 

cbryant@lawbc.com 

(202) 557-3818 (phone) 

(202) 355-8281 (cell) 

(202) 557-3836 (fax) 

Please visit our Web Site at 

http://www.lawbc.com 

This e-mail may contain confidential or privileged information. If you are not the intended recipient, please advise by return e-mail 

and delete immediately without reading or forwarding to others. (See attached file: Flow Weighted Average Concept for Review_05-

10-2011.pdf) 
(a) (b) (c)

Lead Concentration Flow Rate Contribution

Source (mg/dscm) (dscf) Per Source Test Date

Busch Unit A 0.0006 40,656 24.39360 April, 2009

Busch Unit B 0.000704 39,486 27.79814 February, 2010

Busch Unit C 0.0017 27,237 46.30290 February, 2010

Busch Unit D 0.0013 18,031 23.44030 May, 2009

Busch Unit E 0.00049 36,000 17.64000 February, 2010

Busch Unit F 0.0011 36,055 39.66050 April, 2009

Busch Unit G 0.00285 33,464 95.37240 May, 2009

Busch Unit H 0.000414 35,460 14.68044 February, 2010

Busch Unit I 0.000661 32,227 21.30205 April, 2009

WESP Stack 0.00145 84,869 123.06005 November, 2010

Facility-Wide Totals 0.011269 383,485 433.65038

0.0011

Flow Weighted Average Demonstration - Privileged & Confidential

Summary of Lead Emission Rates - COI

Flow-Weighted Average = ∑ [(a) x (b)]

-------------

∑ (b)

Calculation Explanation: The calulation is performed according to the following procedure:

1. Obtain the most recent agency-approved stack test lead concentration (mg/dscm) and 

flow rate (dscf) from the most recent test for each point source at the secondary lead 

smelting facility. 

2. For each point source, multiply the lead concentration by the flow rate to determine the 

contribution per point source. 

3. Sum the contributions per point source for the entire facility.

4. Sum the flow rates for all point sources at the facility. 

5. Divide the sum of the contributions per point source by the sum of the flow rates for all 

point sources

6. The result is the Flow-Weighted Average for the facility.