### 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.govby searching for docket ID No : E PA

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. I n 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 a s present on w ww . r egulations.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 PMSubject: 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