From: Topham.Nathan@epamail.epa.gov

Sent: Friday, October 28, 2011 5:23 PM

To: Higgins, Cortney

Cc: French.Chuck@epamail.epa.gov; tierney.jan@epamail.epa.gov; Hanzel,

Veronica

Subject: RE: E.O. 12866 NESHAP Primary Lead Processing Final AQ

- 43

- Response to

OMB's 10/28 Questions

Hi Cortney,

The sector that included the primary lead smelting source category was "Non

- ferrous Metals

Processing".

In the case of primary lead, the only technology at the time was smelting based so the category name

was bas ed on that technology.

Despite that, the first sentence of the category description was pretty clear in describing the intention of

developing that category. The category was meant to include any facility processing lead ore into lead

metal.

Ta ke a look at the comment response on page B

- 26 in that background document that included the

source category description. It says that the information used to describe the processes and emission

points included in the source category will be supplemented during the development of regulations to

account for various types of operations. When we did the NESHAP in 1999, this technology did not

exist, so it would have been impossible to supplement the description of the category with this

information. This comment response is indicative that we developed the category list based on what

existed at the time rather than trying to describe any as yet undeveloped technologies but that we

would

add operations as information became available. Now that we're revi sing the rule again 12 years later,

such a technology does exist and it has become clear the category description was inadequate to

account for it.

I hope this adds some clarity as to why we feel it is necessary to account for this new process.

Nathan Topham

Environmental Engineer

US EPA/OAQPS/SPPD/MIG

Phone

- (919)541

- 0483

From:

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To:

Nathan Topham/RTP/USEPA/US@EPA

Date:

10/28/2011 05:01 PM

Subject:

RE: E.O. 12866 NESHAP Primary Lead Processing Final AQ

- 43

- Response to OMB's 10/28 QuestionsHi Nate,

Thanks for sending this information over.

The source category listing was for “Primary Lead Smelting,” not Primary Lead Processing. Smelting is a

heat based

process. Is n’t the new process that Doe Run is planning to install an aqueous based process? Have you

had

discussions about that point?

Regards,

Cortney

From: Topham.Nathan@epamail.epa.gov [mailto:Topham.Nathan@epamail.epa.gov]

Sent: Friday, October 28, 2011 4:36 PM

To: Higgins, Cortney

Cc: Talcott.Fred@epamail.epa.gov; French.Chuck@epamail.epa.gov; tierney.jan@epamail.epa.gov;

Secrest.Cary@epamail.epa.gov; Garlow.Charlie@epamail.epa.gov; Benner.Tim@epamail.epa.gov;

Stewart.M ichael@epamail.epa.gov; vahanzel@rti.org; mnl@rti.org

Subject: E.O. 12866 NESHAP Primary Lead Processing Final AQ

- 43

- Response to OMB's 10/28 Questions

Hi Cortney,

In response to some of your questions on our call today:

1. There were no co mments (supportive or adverse) on the original NESHAP related to the source

category applicability definition. The comments are all included in the preamble.

2. I've attached the initial source category listing document and the background document. Wh ere you'll

want to look is page A

- 8 for the description of primary lead. Please note the first sentence of the

paragraph is pretty clear in saying the category includes any facility processing lead ore to lead metal.

3. In response to your questi on about case

- by

- case MACT, as I understand it, the provision in 112(j) sets

up a program for states to develop permits where the EPA has failed to promulgate a standard on time.

I'm not an expert on the nuances but if you take a look at 112(j) it may provide some basic

understanding

of the provision.

Do you think we need to set up a time to have a call on Monday?

Nathan Topham

Environmental EngineerUS EPA/OAQPS/SPPD/MI G

Phone

- (919)541

- 0483