Comment submitted by E. Hogan

Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2008-0154 Address, http://www.regulations.gov Comment to; Revision of Source Category for Standards under Section 112 (k) of the Clean Air Act. From; EEH Environmental Consultant PO Box 516 Gauley Bridge, WV 25085 Phone 304-632-1885 E-Mail; genlo25085@hotmail.com The proposed rule for 40 CFR Part 63, (EPA-HQ-OAR-2008-FRL-8715-8) Ferroalloys Production Facilities, has a concern for the Bag Leak Detection System parameters. The requirement for a device to monitor stream flow at .00044grains per actual cubic foot appears not to be certifiable by numerous manufactures, and possibly only considers one type of device. Attempt to receive certified quotes was negative. The need to identify a bag leak might be served by lowering the requirement to .0029 grains per actual cubic foot thereby allowing alternative manufactures an ability to monitor the system flow. The ability to meet the requirement appears to fall to a type of device in the Triboelectric Monitoring field. The device requires an electrical charge being present on the fume and if the fume is neutral will not be able to meet the requirement. Other manufactures of alternative technology could meet the regulation if the monitoring requirement is lowered. The fume in question is Si02 and is considered to be inert by the Ferroalloy industry. The Ferroalloys industry in the United States no longer has research facilities to definitely address the concern and must rely on experience to comment. Conversations (10/6 and 10/09/08) with Mr. Conrad Chin, Peter Westlin, Steve Fruh and Beth Friedman indicated; they would insert a stipulation into the new regulation allowing alternative monitoring requirements to satisfy bag leak detection if the Triboelectric Monitoring device proves unable to be certified. This would allow industry to proceed with obtaining an Operating Permit with assurance of being able to comply with the regulation. Respectfully Eugene Hogan