Comment submitted by Morton Satin, Director, Technical and Regulatory Affairs, Salt Institute (SI)

8/31/09 Environmental Protection Agency Air and Radiation Docket and Information Center, (2822T) 1200 Pennsylvania Ave., NW., Washington, DC 20460. Reference: Comments of the Salt Institute - Area Source NESHAP for Chemical Preparations Manufacturing - Docket ID No. EPA-HQ-OAR-2009-0028 – Proposed rule The Salt Institute, on behalf of the nation’s salt producers, would like to commend the EPA in taking steps to establish functional national emissions standards for control of hazardous air pollutants from the chemical preparations area source category that will serve both the interests of the public and the operational constraints of the industry. In general we support this proposed rule and offer a few thoughts for consideration. Although the Salt Institute has not yet had an opportunity to poll our industry members, we believe that the docket’s reference to 26 area facilities referred to on page 39016 (FR 74 #149) may be an underestimation. We will immediately send a note out to our members and, if our inquiry indicates a different number, we will inform you before 30 September. In answer to the questions posed on page 39019 of the docket, the Salt Institute submits the following comments: 1. In reference to the control of target Hazardous Air Pollutants (HAP) emissions points at identified existing sources, we are aware of one isolated very minor source where GACT (Generally Available Control Technology) management practice is employed rather than a PM control device. 2. In reference to particulate matter (PM) emission reductions, we have seen no scientific evidence in support of the value of an emission limit of 0.03 gr/dscf. 3. In reference to the economic feasibility of a greater than 95 percent PM, we believe that this may eliminate certain currently available control devices and functionally eliminate all options other than fabric filter baghouses.