1 

### 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_18 5196_2009.pdf; EmissionsReport_ 201282_2010.pdf; EmissionsReport_205155_2011.pdf; E missionsReport_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 - Embedde d 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 Erc henbrecher a few minutes ago and she was confused a bout 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 lb s/hr, flow rates, etc. Let me know if you need anything else.

Kurt Bezeau Engineering Associate

Division of Environmental Services

348 S Erie St2 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 Ap plicability again. I thought that you had spoke wi th 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.co m

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 in terested 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 Resi ns MACT) does not currently regulate continuous process vents from existing sources. You indicated on the phone that Tembec no longer manufacture s Phenolic Resins, and therefore should not be listed as being subject to Subpart OOO. As such, you were going to r each3 out to the city of Toledo to determine whether refe rences to Subpart OOO could be removed from Tembec’ s permit.

The EPA’s interest in these emissions points is rel ated to our recently proposed rulemaking on Subpart OOO, in which we proposed to establish a 85% emission re duction 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 o rder 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 u sed to reduce these emissions

This information should be readily available from r ecent emissions inventories, and we are not requirin g 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 e mission limit. As mentioned before, if Tembec is ind eed no longer a producer of Amino/Phenolic Resins, then it is not necessary for you to submit any of this info rmation, and the EPA will remove your facility from our affe cted facility list for Subpart OOO.

I look forward to hearing back from you after you’r e 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 Schem bechler

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