1 

### 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 As sistance in Information Gathering**  **and Review** Attachments: **South Carolina - Chemical Sector Facilities.xlsx; S outh Carolina - Updated 2005 Emissions**  **Inventory Data.xls**

Nick, Andrea, and Andrew,

Please take a look at this response to our data rev iew request from SC and then we can talk. Haven’t h eard much from other States except that NC and WV are working on i t. 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 Informatio n Gathering and Review

**Brian,**

**South Carolina believes that the 2008 NEI data bett er reflects HAP emissions from the chemical sector**  **specially if EPA is going to use this data to develop Risk and Technology Rev**  **iew (RTR) NESHAP rules. We would like to understand why EPA is using**  **2005 NEI data.**

**Attached to this email are two spreadsheets with up dated 2005 emissions inventory data from the chemic**  **al sector in South Carolina and information on other chemical faciliti**  **es not listed in your 2005 NEI data. Please note t hat 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 Inform ation 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**2

**EPA has asked our assistance in information gatheri ng and review from several states about certain**  **source categories as part of their efforts to devel op 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 y ou to supply the**  **requested information as it will assist EPA in deve loping 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, C**  **alifornia, Nevada and Hawaii (see below for details about this effort).** 

**Please provide your responses and/or direct any que stions 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**3 **Mary,**

**Per our discussions over the last couple of weeks, I am writing to request NACAA's assistance with con**  **tacting several states for data review and information gath**  **ering.**

CHEMICAL SECTOR

**For several chemical sector MACT rules we have iden tified as "key" states that are included in this re**  **quest. This e-mail includes requests for data review and i**  **nformation 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 record s in the attached files ("NACAA Facility List - Sta**  **te 020413.xlsx" and "NACAA Facility List -**  **MACT 020413.xlsx" contain identical records, they a re just organized**  **differently) to ensure that they are accurate and t hat all facilities in each source category from eac**  **h 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 E PA to the best of our ability, but the states may h**  **ave additional information regarding these facilities.**  **Not e that these records only contain entries at each f**  **acility for the source categories of interest; whole facility e**  **missions are not included in these files, and we ar e not**  **requesting review of our information regarding proc esses in other source categories at these facilitie**  **s. The "NACAA Facility List - State 020413.xlsx" file has**  **separate tabs for each state, and the "NACAA Facili ty List -**  **MACT 020413.xlsx" file has separate tabs for each s ource category (please note that the tabs "ABS", "M**  **BS", "PET", "PS", and "SAN" are all part of the Polymers**  **and Resins IV MACT category).**

(See attached file: NACAA Facility List - State 020 413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

**The other source category that we are requesting NA CAA's assistance with is the Off-site Waste Recover**  **y Operations (OSWRO, subpart DD) source category. The**  **type of assistance requested is quite different fo r**  **OSWRO. Specifically:**

**1. We are requesting a list of facilities subject to t**  **he OSWRO source category from all states in EPA Region 9 (AZ, CA, NV, HI). For each facility, we ar**  **e requesting:**

• **Emissions inventory for the facility;**

• **Details on the processes covered by OSWRO, includin g 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 Requ**  **est OSWRO-Facilities with Unquantified OSWRO Emissions.**  **xlsx" that each state review the facility or facili ties**  **listed and provide the following :** 4

• **Is the facility subject to OSWRO?**

• **Details on the processes covered, including any emi ssions 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 regard ing this request. I will be submitting a separate r**  **equest through EPA Region 6 for the facilities listed in t**  **he various attachments that are located in Texas an d**  **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 Standar ds**  **Sector Policies and Programs Division/Policy and St rategies 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.gov5