Fw: 4 SJV sources - info needed (S- 3337 NDS Inc?) - thanks

Stanley Tong to: Leland.Villalvazo 03/16/2011 06:22 AM

From: Stanley Tong/R9/USEPA/US

To: Leland.Villalvazo@valleyair.org

Leland,

Received your voicemail - thanks for looking into it.

Stan

----- Forwarded by Stanley Tong/R9/USEPA/US on 03/16/2011 06:21 AM -----

From: Stanley Tong/R9/USEPA/US

To: Leland.Villalvazo@valleyair.org

Date: 03/15/2011 02:26 PM

Subject: Fw: 4 SJV sources - info needed (S- 3337 NDS Inc?) - followup

Leland,

Just following up on my earlier email if you have any information on NDS' emissions. 

This is to support our review of the District's RACT SIP submittal. 

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 03/15/2011 02:16 PM -----

From: Stanley Tong/R9/USEPA/US

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

Date: 03/01/2011 10:02 AM

Subject: Fw: RE: 4 SJV sources - info needed (S- 3337 NDS Inc?)

Leland,

Can you help on whether "NDS" is a major source for VOC, or if there is an error in CARB's emission 

inventory or the SJ Permit?

CARB's 2008 inventory shows NDS had 15 tpy. CARB's 2009 inventory shows almost 20 tpy. See 

George Heinen's reply to me below.

If NDS is >10 tpy, what type of source is NDS and which district rules cover their operations?

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 03/01/2011 09:32AM -----

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

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

Date: 02/09/2011 04:03PM

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

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

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 -----

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

Stanley,

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

by the 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.

FACID NAME VO

C

NO

x

111

BELMONT MEMORIAL 

0.4 7.5
PARK

2820

VANDERLANS & SONS, 

INC.

9.2 0.1

3337 NDS INC 19.9 6.5

4284 INSTANT STORAGE 0.1 0.0

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 -----

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>

Date: 02/09/2011 01:26 PM

Subject: FW: 4 SJV sources - info needed

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.

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