Fw: Re: Docket EPAHQOAR2007 0352-115

Michael Stewart to: crabtree.tricia 01/31/2010 11:38 AM

Michael J. Stewart, Ph.D.

Environmental Protection Specialist

Health and Environmental Impacts Division

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

(919) 541-7524

stewart.michael@epa.gov

-----Forwarded by Michael Stewart/RTP/USEPA/US on 01/31/2010 11:38AM -----

To: Edmund Crouch <crouch@CambridgeEnvironmental.com>

From: Michael Stewart/RTP/USEPA/US

Date: 01/29/2010 11:04AM

cc: Cindy Langworthy <clangworthy@hunton.com>, Laura Green 

<green@cambridgeenvironmental.com>

Subject: Re: Docket EPA–HQ–OAR–2007–0352-115

Dear Dr. Crouch:

Below are responses to your emails from 1/27/10 (5:04 PM; see original email 

below) and 1/28/10 (12:10 PM; copied and pasted below). Thank you again for 

your inquiries and please note that this, as well as all other emails received 

and sent during the Notice of Proposed Rulemaking for the SO2 NAAQS public 

comment period will be submitted to the SO2 docket.

1) Thank you for clarifying your request for data presented in the email 

dated 1/27/10 (5:04 pm) in your subsequent email dated 1/28/10 (12:10 PM)- 

this was very helpful. The amount of data requested is quite large and thus, 

we are working as quickly as possible to fullfill your request. Please be 

advised that since many of these files are very large, they may need to be 

sent via Federal Express. I will email you again on this issue as soon as I 

have additional information. 

2) The Risk and Exposure Assessment to Support the Review of the SO2 NAAQSFinal Report (REA) includes the methodology and results from the St. Louis and 

Greene County exposure analyses. Please see Chapter 8 of the REA. This 

chapter is titled "Exposure Analysis" and begins on page 184 and continues 

through page 313. Additional information on these exposure analyses can also 

be found in Appendix B of the REA. This Appendix is titled "Appendix B: 

Supplement to the SO2 Exposure Assessment" and begins on page B-1 and 

continues through page B-263. As noted in the Notice of Proposed Rulemaking, 

the REA can be found at 

http://www.epa.gov/ttn/naaqs/standards/so2/s_so2_cr_rea.html

3) The CASAC reviewed the overall methodology and results presented in the 

REA. The first draft REA was reviewed by CASAC at a public meeting on July 30 

-31, 2008. Transcripts of this meeting can be found at www.regulations.gov 
by searching for docket ID No: EPA-HQ-ORD-2006-0260-0023. In addition,

consensus CASAC comments on the first draft REA were expressed in a letter to 

the EPA Administrator. The reference for this letter is:

Henderson. (2008). Letter to EPA 

Administrator Stephen Johnson: Clean

Air Scientific Advisory Committee’s

(CASAC) Peer Review of EPA’s Risk and

Exposure Assessment to Support the

Review of the SO2 Primary National

Ambient Air Quality Standards (First

Draft, July 2008). EPA–CASAC–08–019.

August 22, 2008. Sulfur Dioxide Review

Docket. Docket ID No. EPA–HQ–OAR–

2007–0352–0034. Available at

www.regulations.gov .

The second draft REA was reviewed by CASAC at a public meeting on April 16-17, 

2009. Transcripts of this meeting can be found at www.regulations.gov by 

searching for docket ID No: EPA-HQ-ORD-2006-0260-0033. In addition, 

consensus CASAC comments on the second draft REA were expressed in a letter to 

the EPA Administrator. The reference for this letter is:

Samet JM. (2009). Letter to EPA

Administrator Lisa P. Jackson: Clean Air

Scientific Advisory Committee’s

(CASAC) Review of EPA’s Risk and

Exposure Assessment to Support the

Review of the SO2 Primary National

Ambient Air Quality Standards: Second

Draft. EPA–CASAC–09–007, May 18,

2009. Sulfur Dioxide Review Docket.

Docket ID No. EPA–HQ–OAR–2007–

0352–0035. Available at

www.regulations.gov .

The following is a copy of the email you sent on 1/28/10 (12:04 PM): 

Dear Michael

To follow up on my email of yesterday, let me be even more specific.

Where may I find the specific input files that were used for 

TRIM.Expo/APEX for the exposure modeling performed for the REA and 

described in Appendix B to the Final REA? I expected to find those all 

those in EPA–HQ–OAR–2007–0352-115, but none of them 

are present there.

The REA at Appendix B-4 states that version 4 of APEX (the stand-alone 

version) was used. The attachments to Appendix B describe the 

preparation of the files used for this version of APEX. It should be 

very straightforward to provide the exact files used as input to this 

model, so that anybody can replicate it as needed, or change various 

input parameters (such as the bin size for the output reporting).
Note: EPA-HQ-OAR-2007-0352-115 as present on www.regulations.gov is a

placeholder stating that one may obtain a CD-ROM from EPA. It does not 

even contain an index of that CD-ROM. That CD-ROM contains about 64 

MByte of data. I see no reason why all the contents cannot be placed in 

www.regulations.gov , or at least on an EPA web site for download. This 

would be cheaper and more convenient for all involved. At least an index 

of it should be present in www.regulations.gov . Presumably the required 

input files for TRIM.Expo/APEX may be larger, but some or all of them 

may already be available on the EPA TRIM site, while those specific to 

the SO2 REA could readily be placed on the EPA SO2 page.

This email request also added to the Docket.

Thanks again,

Michael

Michael J. Stewart, Ph.D.

Environmental Protection Specialist

Health and Environmental Impacts Division

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

(919) 541-7524

stewart.michael@epa.gov

 Edmund Crouch ---01/27/2010 05:04:46 PM---Dear Michael In that case, I repeat 

my question (that you did not answer):

From: 

Edmund Crouch <crouch@CambridgeEnvironmental.com> 

To: 

Michael Stewart/RTP/USEPA/US@EPA 

Cc: 

Cindy Langworthy <clangworthy@hunton.com>, Laura Green 

<green@cambridgeenvironmental.com> 

Date: 

01/27/2010 05:04 PM 
Subject: 

Re: Docket EPA–HQ–OAR–2007–0352-115 

Dear Michael

In that case, I repeat my question (that you did not answer):

" Given this, where may I find the data used to produce the values that were 

used in the relational database SO2_RiskAssessment_Stds_CS_99_J.sql?"

I assume that EPA is not relying on a non-replicable analysis.

I wish to know where I may find the data and methodology used to generate what 

went into that relational database, in order to replicate it and so that I may 

extract the relevant information (e.g. in bins narrower than 50 ppb). These 

data and that methodology are presumably what you refer to as the "exposure 

analysis" in your response; such an exposure analysis is not discussed 

anywhere in the REA (which is supposedly a "Risk and Exposure Assessment") or 

referenced documents. 

Also, please provide the reference to the independent review by CASAC that 

specifically recommended or approved 50 ppb wide bins.

Stewart.Michael@epamail.epa.gov wrote: 

Dear Dr. Crouch: 

Thank you for your email. The output data from the exposure analysis was 

generated in 50 ppb bins and was subsequently used as an input into the 

quantitative risk assessment. This method was independently reviewed by the 

Clean Air Scientific Advisory Committee (CASAC). The actual exposure 

concentrations, before being classified into 50 ppb bins, was not generated by 

EPA and is therefore unavailable. 

Thank you again, 

Michael 

Michael J. Stewart, Ph.D.

Environmental Protection Specialist

Health and Environmental Impacts Division

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

(919) 541-7524 

stewart.michael@epa.gov 

From: 

Edmund Crouch <crouch@CambridgeEnvironmental.com> 

To: 

Michael Stewart/RTP/USEPA/US@EPA 

Cc: 

Cindy Langworthy <clangworthy@hunton.com> , Laura Green 

<green@cambridgeenvironmental.com> 
Date: 

01/26/2010 04:53 PM 

Subject: 

Re: Docket EPA–HQ–OAR–2007–0352-115 

Dear Mr. Stewart,

EPA–HQ–OAR–2007–0352-115 contains the "User's Guide 

and TRIM Risk Model Files for SO2 Risk and Exposure

Assessment (REA) Report. October 2009". Within that User's Guide, it is 

stated that " To produce the results that appear in Appendix C of the Risk and 

Exposure Assessment report (U.S. EPA, 2009), Abt Associates populated the 

tables in the relational databases with the values necessary for TRIM.Risk 

HH-P to carry out the desired runs." The one and only relational database 

provided is that backed up in SO2_RiskAssessment_Stds_CS_99_J.sql. 

However, the entries in that relational database correspond to pre-processed 

data, presumably from TRIM.Expo or some other part of the TRIM modeling 

system. They are certainly not the raw data input files for that (or any 

other) system. They are substantially and irreparably incomplete in that 

(among other things) they do not specify the concentrations to which persons 

are exposed, but instead already have classified exposures into ranges with 

width 50 ppm (i.e. ranges 0-50, 50-100, etc.). I already demonstrated that 

such ranges are inadequate in EPA-HQ-OAR-2007-0352-31.1 (Appendix 1). 

Given this, where may I find the data used to produce the values that were 

used in the relational database SO2_RiskAssessment_Stds_CS_99_J.sql?

Alternatively, and much better from my point of view, where may I find 

information on the actual predicted concentrations, before classification into 

the 50 ppm-wide bins, to which people may be exposed under the various 

scenarios? For example, if TRIM.Expo was indeed used, where can I find the 

actual random samples obtained.

This query also entered in the docket. 

-- 

Edmund A.C. Crouch, Ph.D.

Senior Scientist 

Cambridge Environmental Inc 

58 Charles Street

Cambridge, MA 02141

Office: 617-225-0810

Fax: 617-225-0813 

http://www.CambridgeEnvironmental.com 

-- 

Edmund A.C. Crouch, Ph.D.
Senior Scientist

Cambridge Environmental Inc 

58 Charles Street

Cambridge, MA 02141

Office: 617-225-0810

Fax: 617-225-0813 

http://www.CambridgeEnvironmental.com