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Parsons, Nick

From: Bezeau, Kurt <Kurt.Bezeau@toledo.oh.gov>

Sent: Tuesday, June 17, 2014 11:25 AM

To: Parsons, Nick

Cc: Granata, Karen

Subject: RE: Tembec (0448010370) Emissions Report - Embedded GIF

Attachments: EmissionsReport_179933_2008.pdf; EmissionsReport_185196_2009.pdf; EmissionsReport_

201282_2010.pdf; EmissionsReport_205155_2011.pdf; EmissionsReport_217616_2013.pdf

Mr. Parsons, 

Requested Tembec files attached. 

Kurt Bezeau 

Engineering Associate 

Division of Environmental Services 

348 S Erie St

Toledo, OH. 43604 

Phone: 419-936-3769 

Fax: 419-936-3959 

From: Parsons, Nick [mailto:Parsons.Nick@epa.gov] 

Sent: Tuesday, June 17, 2014 10:01 AM 

To: Bezeau, Kurt 

Subject: RE: Tembec (0448010370) Emissions Report - Embedded GIF 

Hi Kurt,

This report has been extremely helpful. Would it be possible to get the same emissions report for the Tembec 

facility for 2009, 2010, 2011, and 2012? Thanks.

- Nick

From: Bezeau, Kurt [mailto:Kurt.Bezeau@toledo.oh.gov] 

Sent: Wednesday, April 30, 2014 2:38 PM 

To: Parsons, Nick 

Subject: Tembec (0448010370) Emissions Report 

 

Nick,

Emissions report attached. I spoke with Cynthia Erchenbrecher a few minutes ago and she was confused about where to 

get the information from. Her and I are on the same page that OOO has applicability at Tembec as they are in fact using 

the urea formaldehyde. She also stated that she has the stack test data from 2006 which has flow rates and such that 

you might find useful if you need more information. The attached report is lengthy but contains HAP lbs/hr, flow rates, 

etc. Let me know if you need anything else. 

Kurt Bezeau

Engineering Associate

Division of Environmental Services

348 S Erie St
2

Toledo, OH. 43604

Phone: 419-936-3769

Fax: 419-936-3959

From: Erchenbrecher, Cynthia - Toledo [mailto:Cynthia.Erchenbrecher@tembec.com] 

Sent: Monday, April 28, 2014 9:34 AM 

To: Bezeau, Kurt 

Cc: Rowley, Larry - Toledo 

Subject: FW: Tembec Process Vent Information

 

Kurt,

I got this email from Nick Parsons about our OOO Applicability again. I thought that you had spoke with him about this 

to help clear this up already. But, can you speak to him again and help him understand our situation. Thanks.

Cynthia Erchenbrecher

Health, Safety & Environmental Manager

T 419-244-5856 ext. 45114 M 419-545-6105 F 419-244-9206

2112 Sylvan Avenue, Toledo OH 43606 tembec.com

From: Parsons, Nick [mailto:Parsons.Nick@epa.gov] 

Sent: Monday, April 28, 2014 9:22 AM 

To: Erchenbrecher, Cynthia - Toledo 

Subject: RE: Tembec Process Vent Information

 

Hi Cynthia,

I wanted to follow up w/ you to see if you had any updates for me on the OOO applicability status for your 

facility. Thanks.

- Nick

From: Parsons, Nick 

Sent: Tuesday, April 08, 2014 2:50 PM 

To: 'cynthia.erchenbreche@tembec.com' 

Subject: Tembec Process Vent Information 

 

Hi Cynthia,

As discussed on our call this morning, the EPA is interested in gathering information on the three (3) resin 

dryers located at Tembec BTLSR in Toledo, OH. These points are identified as P001, P002 and P003 in 

Tembec’s Title V permit issued on 10/21/2010. These emission points are exempted from any requirements in 

Tembec’s permit, as Subpart OOO (Amino/Phenolic Resins MACT) does not currently regulate continuous 

process vents from existing sources. You indicated on the phone that Tembec no longer manufactures Phenolic 

Resins, and therefore should not be listed as being subject to Subpart OOO. As such, you were going to reach 
3

out to the city of Toledo to determine whether references to Subpart OOO could be removed from Tembec’s 

permit.

The EPA’s interest in these emissions points is related to our recently proposed rulemaking on Subpart OOO, 

in which we proposed to establish a 85% emission reduction standard for continuous process vents (see 79 FR 

1703, January 9, 2014, http://www.gpo.gov/fdsys/pkg/FR-2014-01-09/pdf/2013-30132.pdf). While it appears that 

Tembec’s current operations may no longer meet the applicability requirements for Subpart OOO, just so that 

you are aware I am still including a description of the information that we would be looking for. In order to 

further evaluate the costs of this proposed change, for each of these emission points the EPA needs:

 

- Gas flowrate (ACFM)

- HAP flowrate (lb/hr) (speciated or total organic)

- Any current air pollution control device(s) being used to reduce these emissions

This information should be readily available from recent emissions inventories, and we are not requiring any 

additional stack testing be conducted. Additionally, we may also require the annual production rate for each 

process unit in order to establish an appropriate emission limit. As mentioned before, if Tembec is indeed no 

longer a producer of Amino/Phenolic Resins, then it is not necessary for you to submit any of this information, 

and the EPA will remove your facility from our affected facility list for Subpart OOO.

I look forward to hearing back from you after you’re able to discuss this issue w/ the city of Toledo. Please let 

me know if you have any questions. Thank you.

--

Nick Parsons

Environmental Engineer

U.S. Environmental Protection Agency

OAR/OAQPS/SPPD/RCG

Research Triangle Park, NC

919.541.5372

parsons.nick@epa.gov

"No man is more important than the team." -Bo Schembechler

 

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