From: Chelsea Gonzales <Chelsea.Gonzales@valleyair.org>

To: Rynda Kay/R9/USEPA/US@EPA

Cc: Jessi Fierro <Jessica.Fierro@valleyair.org>, Errol Villegas

<errol.villegas@valleyair.org>, Anna Myers <Anna.Myers@valleyair.org>

Date: Monday, May 07, 2012 04:55PM

Subject: RE: SJVAPCD R4682

Good Afternoon Rynda,

Before addressing the difference in the emissions from the spreadsheet versus the staff report, we

wanted to clarify that Dart is NOT an extrusion facility and was incorrectly included in the previous

spreadsheet. There should have only been three facilities identified (Pactiv – Bakersfield, Pactiv –

Fresno, and Pregis, see revised spreadsheet). There was a miscommunication between myself and the

permits engineer and Dart was inadvertently included. Dart is an expansion only facility and not subject

to the extrusion requirements in Rule 4682. Sorry for the confusion.

Regarding the emissions values in the spreadsheet; the values provided was based on the “actual

emissions” for each facility as reported to the District’s Emissions Inventory group. However, the

calculations used in the staff report are based on the facility’s Potential to Emit (which is a more

conservative approach).

Let me know if you have any additional questions or if you need further clarification. Thank you.

Chelsea Gonzales

Air Quality Specialist I

San Joaquin Valley Air Pollution Control District

Strategies and Incentives

1990 E. Gettysburg

Fresno, CA 93726

(559) 230-5803

https://epamailr812.epa.gov/mail/r9/rhudman.nsf/6d2399d00d65ecc...

1 of 4 5/29/2012 11:03 AM
From: Rynda Kay [mailto:Kay.Rynda@epamail.epa.gov]

Sent: Friday, April 27, 2012 2:51 PM

To: Chelsea Gonzales

Subject: RE: SJVAPCD R4682

Hi Chelsea,

Thanks so much for this information on extrusion facilities. I have one follow up question. The Rule 4682 Staff

Report says the DART in Lodi emissions are ~29tpy (pg. 16), but the spreadsheet you sent says 7.39 tpy. Is 7.39

tpy just the extrusion portion? If so, are all the values listed just for the extrusion operations of these facilities?

Thanks,

Rynda

_____________________

Rynda Hudman Kay, Ph.D.

Air Division, US EPA

75 Hawthorne St.

San Francisco, CA 94105

P: 415.947.4118 | F: 415.947.3579

From: Chelsea Gonzales <Chelsea.Gonzales@valleyair.org>

To: Rynda Kay/R9/USEPA/US@EPA

Date: 04/24/2012 05:17 PM

Subject: RE: SJVAPCD R4682

Good Afternoon Rynda,

Attached is the information you requested for the extrusion facilities specified in item #1 below. Let me know if

you need any additional information. Thank you.

Chelsea Gonzales

Air Quality Specialist I

San Joaquin Valley Air Pollution Control District

Strategies and Incentives

1990 E. Gettysburg

Fresno, CA 93726

https://epamailr812.epa.gov/mail/r9/rhudman.nsf/6d2399d00d65ecc...

2 of 4 5/29/2012 11:03 AM
(559) 230-5803

From: Rynda Kay [mailto:Kay.Rynda@epamail.epa.gov]

Sent: Friday, April 13, 2012 10:00 AM

To: Chelsea Gonzales

Subject: Re: SJVAPCD R4682

Hi Chelsea,

A few follow up questions that I need before we can act on the rule .Recall, one of the O'Conner criteria is " A

description of the affected processes and associated historical production and operating rates"

1. Extrusion Facilities Emission Inventory - We did not get values for this criteria. I need to include how large

these emissions are in my documentation of the rule.

Could you provide the following information about the extrusion facilities in SJV that are complying using the 2.4

pounds/100 pounds limit for the latest available year:

Facility Name, City, ROG (tons/year)

I got some information for 2008 from the CARB facility emissions website but this is outdated and of course I

couldn't tell which facilities apply to this category

2. Expansion Foam

From the staff report I gather 1 cup facility is complying using the 3.4 daily limit. Could you also give me the

information here as we;; . I think it is DART?, Bakersfield? and 29 tpy?

Facility Name, City, ROG (tons/year)

This facility was not listed in the Facility Emissions search in CARB for 2008. Did this manufacturer take over a

plant from someone else?

Thanks,

Rynda

_____________________

Rynda Hudman Kay, Ph.D.

Air Division, US EPA

75 Hawthorne St.

San Francisco, CA 94105

P: 415.947.4118 | F: 415.947.3579

From: Chelsea Gonzales <Chelsea.Gonzales@valleyair.org>

To: Rynda Kay/R9/USEPA/US@EPA

Date: 04/11/2012 07:37 AM

https://epamailr812.epa.gov/mail/r9/rhudman.nsf/6d2399d00d65ecc...

3 of 4 5/29/2012 11:03 AM
Subject: SJVAPCD R4682

Rynda,

Per our discussion on Monday, pages 3-5 of the staff report could help provide you with a better background on

the extrusion and expandable polystyrene (EPS) facilities. The discussion touches on the complexities of

calculating emissions daily for extruders (extended process times, multiple emissions sources, and the variable

conditions) and the difficulty of capturing emissions from the molding stage for EPS facilities.

To answer your question regarding why it is not feasible for extrusion facilities to abide by a daily limit, the

O’Connor discussion on pages 9-13 of the staff report goes into more detail regarding the inherent lack of

predictability in the extrusion process that makes it difficult to accurately estimate emissions on a daily basis.

Also, despite the maximum levels that extrusion facilities achieve on a daily basis, their current recordkeeping

system is not equipped to calculate these emissions levels daily; rather, emissions are back calculated monthly in

an approximately 10-hour process. The cost of installing new recordkeeping equipment needed to calculate daily

emissions would cost an average of $1.2 million dollars per facility. These details and other information regarding

the current recordkeeping system in place and equipment needed to make it feasible to calculate daily emissions

for extruders can be found from the last paragraph of page 12 to page 13 of the staff report.

Let me know if you have other questions. I hope the appendices helped your review of the staff report.

Best,

Chelsea Gonzales

Air Quality Specialist I

San Joaquin Valley Air Pollution Control District

Strategies and Incentives

1990 E. Gettysburg

Fresno, CA 93726

(559) 230-5803

[attachment "Extrusion Facilities Actual Emissions Summary.xlsx" deleted by Rynda Kay/R9

/USEPA/US]

Attachments:

Extrusion Facilities Emissions Summary Updated.xlsx

https://epamailr812.epa.gov/mail/r9/rhudman.nsf/6d2399d00d65ecc...

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