p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document, Number: 

) ll-F-6 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 257 of 264 
P.2 

(T-F-(o 

Keith Barnett To: Peter_D._Eglinton@omb.eop.gov 

11/09/2000 11:28 AM 

cc: Penny Lassiter/RTP/USEPA/US@EPA 

Subject: Re: Reply 

Dear Peter: 

My OSHA contact is Mr. Adam M. Finkel, E-mail is adam.finkel@osha.gov, Phone is 202-693-2256. 

Adam asked me if the CFA's concerns were justified. My response was that a properly designed 

permanent total enclosure (PTE) should not result in higher worker exposure levels. However, it 

might be possible for a facility to deliberately decide to reduce the workplace air flows to minimize 

control costs. This may increase worker exposure. However, as I explained earlier, our cost 

analysis assumed a PTE with sufficient airflow to protect the workers. 

Adam was mainly concerned that facilities would deliberately violate OSHA standards to comply 

with our rule. His suggestion was to change the 95 percent control level by requiring facilities to 

meet the existing source floors, which are based on pollution-prevention, and then control 95 

percent of the remaining emissions. This would be a more stringent option than the one we are 

proposing. 

Our final response was to add language to the preamble discussing this issue and requesting 

comment on more stringent alternatives. This language for new source floors begins on page 38, 

the middle paragraph and ends with the first full paragraph on page 39. The discussion on the 

above-the-floor option begins with the last paragraph that starts on page 48 and continues for about 

f^SA/*/-*- )**-> 05M& Zu^^ZX >» Utd^Z^d 

Keith W. Barnett , ^ ^ ^ ^ ^j^^j % 

U. S. Environmental Protection Agency ' ^ -

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Emission Standards Division ftMYfS 

MD-13

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Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Peter_D._Eglinton@omb.eop.gov 

Peter_D._Eglinton@om To: Keith Barnett/RTP/USEPA/US 

b.eop.gov 

11/09/2000 10:33 AM 

cc: 

Subject: Re: Reply 

Thanks! Very helpful. Could I get more information on OSHA's comments and 

EPA's responses? Also, who is your contact over there? 
P.3 

A-1 M-s-31 

\>\v N • 

Keith Barnett To: Peter_D._Eglinton@omb.eop.gov 

11/09/2000 11:28 AM 

cc: Penny Ussiter/RTP/USEPA/US@EPA 

Subject: Re: Reply 

Dear Peter: 

My OSHA contact is Mr. Adam M. Finkel, E-mail is adam.finkel@osha.gov. Phone is 202-693-2256. 

Adam asked me if the CFA's concerns were justified. My response was that a properly designed 

permanent total enclosure (PTE) should not result in higher worker exposure levels. However, it 

might be possible for a facility to deliberately decide to reduce the workplace air flows to minimize 

control costs. This may increase worker exposure. However, as I explained earlier, our cost 

analysis assumed a PTE with sufficient airflow to protect the workers. 

Adam was mainly concerned that facilities would deliberately violate OSHA standards to comply 

with our rule. His suggestion was to change the 95 percent control level by requiring facilities to 

meet the existing source floors, which are based on pollution-prevention, and then control 95 

percent of the remaining emissions. This would be a more stringent option than the one we are 

proposing. 

Our final response was to add language to the preamble discussing this issue and requesting 

comment on more stringent alternatives. This language for new source floors begins on page 38, 

the middle paragraph and ends with the first full paragraph on page 39. The discussion on the 

above-the-floor option begins with the last paragraph that starts on page 4 8 and continues for about 

2/3 of the way down page 49. ^ _ ^ ^ ^^ ^ ^ eZx ^ 

u"s ! EnvfronmLal Protection Agency ^" ^ VO/ V ^° ^ *"~ ~ Q-^* ^ * » 

Emission Standards Division fb nf\ fk 

MD^13 VNM X 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Peter_D._Eglinton@omb.eop.gov 

Peter_D._Eg|[nton@om To: Keith Barnett/RTP/USEPA/US 

b.eop.gov 

11/09/2000 10:33 AM 

cc: 

Subjea: Re: Reply 

Thanks! Very helpful. Could I get more information on OSHA's comments and 

EPA's responses? Also, who is your contact over there?