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Parsons, Nick

From: Shrager, Brian

Sent: Monday, February 25, 2013 2:01 PM

To: Parsons, Nick; Siefers, Andrea; Bouchard, Andrew

Cc: Lassiter, Penny; Kissell, Mary; Conner, Lisa

Subject: South Carolina Response to EPA Request for NACAA Assistance in Information Gathering 

and Review

Attachments: South Carolina - Chemical Sector Facilities.xlsx; South Carolina - Updated 2005 Emissions 

Inventory Data.xls

Nick, Andrea, and Andrew, 

Please take a look at this response to our data review request from SC and then we can talk. Haven’t heard much from 

other States except that NC and WV are working on it. Planning to follow up with NACAA this week. 

Mary Tom – no info on OSWRO yet. 

Thanks! 

Brian 

From: Kaiser, Heinz [mailto:kaiserh@dhec.sc.gov] 

Sent: Thursday, February 21, 2013 3:51 PM 

To: Porter, Henry; Shrager, Brian 

Cc: Barnes, Lynn 

Subject: Re: EPA Request for NACAA Assistance in Information Gathering and Review 

Brian,

South Carolina believes that the 2008 NEI data better reflects HAP emissions from the chemical sector specially if EPA is going 

to use this data to develop Risk and Technology Review (RTR) NESHAP rules. We would like to understand why EPA is using 

2005 NEI data. 

Attached to this email are two spreadsheets with updated 2005 emissions inventory data from the chemical sector in South 

Carolina and information on other chemical facilities not listed in your 2005 NEI data. Please note that some facilities in your list 

are not subject to the chemical MACTs or the permit will be closed out. Please contact me if you have any questions. 

Heinz 

---------- Forwarded message ---------- 

From: Mary Sullivan Douglas <mdouglas@4cleanair.org> 

Date: Mon, Feb 4, 2013 at 3:57 PM 

Subject: EPA Request for NACAA Assistance in Information Gathering and Review 

To: "hellwigv@michigan.gov" <hellwigv@michigan.gov>, "sheila.holman@ncdenr.gov" 

<sheila.holman@ncdenr.gov>, "djshaw@gw.dec.state.ny.us" <djshaw@gw.dec.state.ny.us>, 

"scla461@ecy.wa.gov" <scla461@ecy.wa.gov>, "reecemc@dhec.sc.gov" <reecemc@dhec.sc.gov>, 

"John.A.Benedict@wv.gov" <John.A.Benedict@wv.gov>, "bates@adeq.state.ar.us" <bates@adeq.state.ar.us>, 

"jgoldste@arb.ca.gov" <jgoldste@arb.ca.gov>, "melges@ndep.nv.gov" <melges@ndep.nv.gov>, 

"ecm@azdeq.gov" <ecm@azdeq.gov>, "nolan.hirai@doh.hawaii.gov" <nolan.hirai@doh.hawaii.gov> 

TO: Selected NACAA Members
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EPA has asked our assistance in information gathering and review from several states about certain 

source categories as part of their efforts to develop Risk and Technology Review (RTR) NESHAP rules. 

Below is an email with specifics about the type of information EPA is seeking. If possible, EPA staff would like 

this information by March 8, 2013. We know everyone is very busy but we encourage you to supply the 

requested information as it will assist EPA in developing the best possible RTRs for these categories.

NACAA members from whom we are seeking information about the chemical sector MACT are from 

Michigan, North Carolina, South Carolina, and West Virginia (see below for details about this effort).

NACAA members from whom we are seeking information about the Off-site Waste Recovery 

Operations are from Arkansas, New York, Washington, Arizona, California, Nevada and Hawaii (see below for 

details about this effort).

Please provide your responses and/or direct any questions to Brian Shrager of EPA at 

Shrager.brian@epa.gov or (919) 541-7689.

Thank you very much.

****************************

Mary Sullivan Douglas

National Association of Clean Air Agencies

444 North Capitol Street, NW, Suite 307

Washington, DC 20001

(202) 624-7864

mdouglas@4cleanair.org

www.4cleanair.org

From: Shrager.Brian@epamail.epa.gov [mailto:Shrager.Brian@epamail.epa.gov] 

Sent: Monday, February 04, 2013 3:01 PM 

To: Mary Sullivan Douglas 

Subject: EPA Request for NACAA Assistance
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Mary, 

Per our discussions over the last couple of weeks, I am writing to request NACAA's assistance with contacting 

several states for data review and information gathering. 

CHEMICAL SECTOR

For several chemical sector MACT rules we have identified as "key" states that are included in this request. 

This e-mail includes requests for data review and information related to several RTR source categories. The 

first group of source categories includes: 

Polycarbonates Production (PC) 

Polymers and Resins III (P&RIII) 

Pesticide Active Ingredient (PAI) 

Polyether Polyols Production (PEPO) 

Polymers and Resins IV (P&RIV) 

We are requesting that the States review the records in the attached files ("NACAA Facility List - State 

020413.xlsx" and "NACAA Facility List - MACT 020413.xlsx" contain identical records, they are just organized 

differently) to ensure that they are accurate and that all facilities in each source category from each listed 

state are included. The files include data records for each facility that come from the 2005 National Emissions 

Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have 

additional information regarding these facilities. Note that these records only contain entries at each facility for 

the source categories of interest; whole facility emissions are not included in these files, and we are not 

requesting review of our information regarding processes in other source categories at these facilities. The 

"NACAA Facility List - State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - 

MACT 020413.xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", 

"PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 

020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 

Operations (OSWRO, subpart DD) source category. The type of assistance requested is quite different for 

OSWRO. Specifically:

1. We are requesting a list of facilities subject to the OSWRO source category from all states in EPA 

Region 9 (AZ, CA, NV, HI). For each facility, we are requesting:

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions 

information; and 

• Operating Permit.

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request 

OSWRO-Facilities with Unquantified OSWRO Emissions.xlsx" that each state review the facility or facilities 

listed and provide the following:
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• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions estimates and other emissions information. 

(See attached file: NACAA Request OSWRO-Facilities with Unquantified OSWRO Emissions.xlsx)

Please let me know if you have any questions regarding this request. I will be submitting a separate request 

through EPA Region 6 for the facilities listed in the various attachments that are located in Texas and 

Louisiana. 

We are requesting that any information be submitted by March 8, 2013. Thanks for your help! 

Brian Shrager 

Environmental Engineer 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Programs Division/Policy and Strategies Group 

D205-02 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450

shrager.brian@epa.gov

-- 

Myra C Reece, Chief

Bureau of Air Quality

SC Department of Health and 

Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

(803) 898-4102 (office) 

(803) 667-1113 (cell) 

-- 

Heinz Kaiser 

Air Toxics Section Manager/ Bureau of Air Quality 

2600 Bull Street, Columbia, SC 29201-1708 

Phone: (803) 898-4089 - Fax: (803) 898-4117 

Email: kaiserh@dhec.sc.gov
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