2 Attachments 

Hi Stan,

Yes that is the case. 

I have attached the final ATCs for Belmont Memorial. They are just awaiting final compliance approval before 

being converted to permits.

Sandra

From: Tong.Stanley@epamail.epa.gov [mailto:Tong.Stanley@epamail.epa.gov] 

Sent: Monday, August 29, 2011 2:35 PM 

To: Sandra Lowe-Leseth 

Cc: Errol Villegas 

Subject: RE: 4 SJV sources - info needed (NDS Inc?)

RE: 4 SJV sources - info needed (NDS Inc?) 

Sandra Lowe-Leseth 

to: 

Stanley Tong 

08/29/2011 02:46 PM 

Cc: 

"Errol Villegas", "Jim Swaney" 

Hide Details 

From: "Sandra Lowe-Leseth" <Sandra.LoweLeseth@valleyair.org>

To: Stanley Tong/R9/USEPA/US@EPA 

Cc: "Errol Villegas" <errol.villegas@valleyair.org>, "Jim Swaney" 

<Jim.Swaney@valleyair.org>

image001.gif SJVAPCD C111 ATCs 08-29-11.pdf

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Sandra,

Thanks for the information. 

Based on our conversation, NDS has no VOC sources, and that the emissions inventory was showing/projecting 

emissions from an Authority to Construct (ATC) that has since expired. 

When you get a chance, can you email me the ATC for Belmont Memorial Park C-111. Thanks. 

Stanley Tong 

U.S. EPA Region IX 

Rules Office (AIR-4) 

75 Hawthorne St. 

San Francisco, CA 94105 

415-947-4122 -voice 

415-947-3579 -fax 

From: "Sandra Lowe-Leseth" <Sandra.LoweLeseth@valleyair.org> 

To: Stanley Tong/R9/USEPA/US@EPA 

Cc: "Errol Villegas" <errol.villegas@valleyair.org> 

Date: 08/29/2011 02:18 PM 

Subject: RE: 4 SJV sources - info needed (NDS Inc?) 

Hi Stan, 

 

Here is the answer on S-3337: 

 

Looking back at all the EI data for NDS it look like: 

1. The facility has been a statement facility for several years which means they review all information and sign 

for their emissions 

2. Historically the facility had put the emissions for the incinerator, now expired ATC unit ID 3 (in 2002-03?), 

under EI unit ID 1 process 3. 

3. Since EI unit 1 (Permit ID 1) has not been deleted and the facility has not indicated that emissions are in 

error. The emissions have been calculated each year for this process. 

We will correct this with ARB. 

 

Here is the answer for C-111: 

 

Belmont Memorial has very old permits (and therefore no emission limits listed), but has new ATC’s to explicitly limit their 

NOx emissions to 19,999 lb/yr (ATC’s issued 5/23/11). 

 

 

I’m still working on the R4301 question. 

 

Sandra

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From: Tong.Stanley@epamail.epa.gov [mailto:Tong.Stanley@epamail.epa.gov] 

Sent: Monday, August 29, 2011 12:43 PM

To: Sandra Lowe-Leseth

Cc: Errol Villegas

Subject: Fw: 4 SJV sources - info needed (NDS Inc?) 

 

Sandra, 

See George Heinin's reply in blue in the first email.

I was planning to include the permits in my technical support document to show these facilities have permit 

conditions <10 tpy. 

but I couldn't find that info in the permits you sent for 

S-3337 NDS (no listed VOC or NOx sources on the permit, so CARB's/SJV's inventory is wrong as Leland 

suggests?) 

or C-111 Belmont Memorial - didn't see the 5,000 lb NOx/year George mentions. 

I found the permit limits for the other 2 facilities. 

Also, any info on the rules that make up the 79.3 tpd (2008) for R4301 in SJV's RACT SIP? 

Stanley Tong 

U.S. EPA Region IX 

Rules Office (AIR-4) 

75 Hawthorne St. 

San Francisco, CA 94105 

415-947-4122 -voice 

415-947-3579 -fax 

----- Forwarded by Stanley Tong/R9/USEPA/US on 08/29/2011 12:26 PM ----- 

From: "George Heinen" <george.heinen@valleyair.org>

To: Stanley Tong/R9/USEPA/US@EPA

Cc: "Leland Villalvazo" <leland.villalvazo@valleyair.org>

Date: 02/09/2011 04:03 PM

Subject: RE: 4 SJV sources - info needed (NDS Inc?) 

 

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Stan

There may be something wrong with their emissions inventory report and perhaps Leland can have someone 

check into it. 

Plastic manufacturing facilities are covered under R4682 

Leland

There is no mention of a NOx source on the permit, but the 2009 inventory has it listed as coming from unit -1. 

Also, the PTO doesn't mention VOC emissions so I wonder if the permit is wrong or the EI sheet is not 

appropriate. 

 

From: Tong.Stanley@epamail.epa.gov [mailto:Tong.Stanley@epamail.epa.gov] 

Sent: Wednesday, February 09, 2011 3:29 PM

To: George Heinen

Subject: Fw: 4 SJV sources - info needed (NDS Inc?) 

George, 

What rules cover NDS' VOC emissions? OR

is there a SJ emissions inventory person I can contact to look into NDS' emissions?

See CARB's email below.

Stan

Stanley Tong 

U.S. EPA Region IX 

Rules Office (AIR-4) 

75 Hawthorne St. 

San Francisco, CA 94105 

415-947-4122 -voice 

415-947-3579 -fax

----- Forwarded by Stanley Tong/R9/USEPA/US on 02/09/2011 03:19 PM ----- 

 

 

Stanley, 

Our most current inventory available online is for the year 2008, and it reflects emissions reported to us by the 

From: "Ruiz, Gabe@ARB" <gruiz@arb.ca.gov> 

To: Stanley Tong/R9/USEPA/US@EPA 

Cc: "Lerch, Vivian@ARB" <vlerch@arb.ca.gov> 

Date: 02/09/2011 03:09 PM 

Subject: 

RE: 4 SJV sources - info needed

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district around Jan 2010. Their report for the 2009 year (which we received last month), is more or less consistent 

with their comments, except that NDS Inc. (ID 3337) shows VOC emissions of 20 tpy. 

Here’s a summary of the 2009 emissions reported by the district for these facilities. 

 

Let me know if you have any other questions. 

--Gabe 

 

 

From: Tong.Stanley@epamail.epa.gov [mailto:Tong.Stanley@epamail.epa.gov] 

Sent: Wednesday, February 09, 2011 2:04 PM

To: Ruiz, Gabe@ARB

Subject: Fw: 4 SJV sources - info needed 

Gabe,

Any thoughts on why San Joaquin's data shows these facilities are <10 tpy and CARB's inventory shows >10tpy?

More up to date data? I'm comparing apples to oranges? The blue text is SJ's reply to my question. Thanks

Stan

Stanley Tong 

U.S. EPA Region IX 

Rules Office (AIR-4) 

75 Hawthorne St. 

San Francisco, CA 94105 

415-947-4122 -voice 

415-947-3579 -fax

----- Forwarded by Stanley Tong/R9/USEPA/US on 02/09/2011 02:01 PM ----- 

FACID NAME VOC NOx

111 BELMONT MEMORIAL PARK 0.4 7.5

2820 VANDERLANS & SONS, INC. 9.2 0.1

3337 NDS INC 19.9 6.5

4284 INSTANT STORAGE 0.1 0.0

From: "George Heinen" <george.heinen@valleyair.org> 

To: Stanley Tong/R9/USEPA/US@EPA 

Cc: "Leland Villalvazo" <leland.villalvazo@valleyair.org>, "Errol Villegas" <errol.villegas@valleyair.org> 

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Stan,

I checked the permits for these facilities and they are all below the 10 ton/year threshold (see notes below).

Not sure why they were listed higher in the CARB inventory. 

 

 

From: Tong.Stanley@epamail.epa.gov [mailto:Tong.Stanley@epamail.epa.gov] 

Sent: Wednesday, February 09, 2011 11:25 AM

To: George Heinen

Subject: 4 SJV sources - info needed

George, 

CARB's 2008 emissions inventory database shows the following sources >10 tpy, but don't 

appear in SJ's RACT SIP table of major sources. 

What are the VOC / NOx sources at these facilities and is there a District rule covering them? 

Thanks. 

S- 3337 NDS Inc, Lindsay, CA 15 tpy VOC SIC 3089 - plastic 

products 

- No VOC emissions and less than 1,000 lb/yr of PM10. Apparently no plasticizers are used in their products.

S- 4284 Instant Storage, Bakersfield, CA 14 tpy VOC SIC 3479 - coating and 

engraving 

- Has a coating operations with limits of 11,200 lb VOC/year 

N- 2820 Vanderlans & Sons, Lodi, CA 13 tpy VOC SIC 3069 - fabricated 

rubber products 

- Combined VOC emissions from this facility are limited to 19,999 pounds in any one calendar year.

Date: 02/09/2011 01:26 PM 

Subject: 

FW: 4 SJV sources - info needed

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C-111 Belmont Memorial Park, Fresno, CA 13.7 tpy NOx SIC 7261 - funeral / 

crematory 

- Has two 5,000 lb NOx/year incinerators and one 1,000 lb VOC/year GDF.

Stan

Stanley Tong 

U.S. EPA Region IX 

Rules Office (AIR-4) 

75 Hawthorne St. 

San Francisco, CA 94105 

415-947-4122 -voice 

415-947-3579 -fax

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