P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

<$^0)II-C-3O 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 59 of 132 
EL2_ 

A 98 13 

"-C-30 

Date sent: Wed, 27 May 1998 15:34:27 -0400 

From: STEVE SHEDD <SHEDD.STEVE@epamail.epa.gov> 

Subject: Tentative NACD Conf. Call 

To: SHEDD.STEVE@epamail.epa.gov, bhaneke@rtp.pes.com, glaflam 

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Content-Disposition: inline 

Item Type: Appointment 

Start Date: 06/05/1998 08:30 am (Friday) 

Duration: 3 Hours, 30 Mins 

Place: sas 

Bill, 

June 1 through the am of June 4 does not work for us due to 

the workshop in Tx. So I would suggest that we do the 

conference call in the am on June 5th (starting as early a 9am). 

Are you arranging the phone tie-in? Below is a quick 

response to your questions and we can more fully discuss 

next week. Please pass along to originators of the questions. 

Steve 

Stephen Shedd 

U.S. EPA 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

voice: (919) 541-5397 

fax: (919) 541-0246 

E-mail: shedd.steve@epa.gov 

>>> BILLNACD <BILLNACD@aol.com> 05/26/98 11:55am >>> 

Steve, 

Below are several questions that we have received from 

members regarding the 

survey information. I anticipate we will receive several more 

within the next 

2 weeks. We would like to move forward with a conference 

call between 

interested NACD members who received the survey and EPA. 

The first week in 

June (next week) would be good. AM on the June 1st or June 

4th is good or 

anytime June 5th. Alos, the week of June 8th appears open on 

my calendar. 

Again, the purpose of the meeting is to address pre-submitted 

questions from 

member companies. I anticipate low member turnout at the 

Houston workshop. 

Bernd Haneke _._.___ Thu, 9 Jul 1998 10:50:15 
P.3 

Therefore, I propose conducting this conference call as an 

alternative. 

Questions received: 

--are fugitive emissions counted toward the HAP threshold? 

yes they are. All emissions must be accounted for 

from the entire plant site. 

--what level of documentation does EPA expect to show that 

facility emissions are below the threshold? I would expect 

that a written assessment of emissions would be 

required to be shown upon request. However, we are 

currently NOT asking for that documentation to be 

submitted. 

--does EPA plan to re-survey if too few facilities exceed the 

thresholds? We have no plans to re-survey at this time. 

However that option is always available if issues arise. 

--does EPA plan to lower the thresholds if it finds low facility 

applicability? We have no plans to lower the size facility 

threshold because of low returns. However we will 

assess at some point in time two associated issues 

that might cause a new need. (1) We will do a risk 

assessment of smaller sources to determine if there 

is a health threat and if so we would propose 

standards for the smaller sources (so called 

non-major sources) and (2) We will do an assessment 

to determine if there is a lower size aplicablity cutoff 

that could be used in the rule, to allow small sources 

out of the rule without the need for prior enforceable 

limits. 

--do all of our sites need to complete Section J of the survey? 

I do not understand the question. Subsection J of 

Section I, only contains the address of where to send 

the response. 

--we repackaged a total of 31,870 lbs. of butyl oxitol. With an 

estimated loss of less than 1%, please confirm we would be 

well below the HAP emissions threshold of 5 tons per year of 

any single HAP. We need to discuss and look into. Is 

the product a HAP or contain HAPs? I will have PES 

look into this. 

--there is a concern that EPA may be compiling a list of 

companies for future enforcement action. Is EPA able to 

confirm or deny this concern? There is no intent or has 

there been any discussion to use company/facility lists 

from this survey for any enforcement actions. The 

office I am in, does not do enforcement actions. 

Regards, 

Bill Allmond 

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Date: Tue, 26 May 1998 11:55:26 -0400 

From: BILLNACD <BILLNACD@aol.com> 

To: SHEDD.STEVE@EPAMAIL.EPA.GOV 

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Subject: List of MACT survey questions 

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Steve, 

Below are several questions that we have received from members 

regarding the survey information. I anticipate we will receive several 

more within the next 2 weeks. We would like to move forward with a 

conference call between interested NACD members who received the 

survey and EPA. The first week in June (next week) would be good. AM 

on the June 1st or June 4th is good or anytime June 5th. Alos, the 

week of June 8th appears open on my calendar. Again, the purpose of 

the meeting is to address pre-submitted questions from member 

companies. I anticipate low member turnout at the Houston workshop. 

Therefore, I propose conducting this conference call as an 

alternative. 

Questions received: 

--are fugitive emissions counted toward the HAP threshold? 

--what level of documentation does EPA expect to show that facility 

emissions are below the threshold? --does EPA plan to re-survey if too 

few facilities exceed the thresholds? --does EPA plan to lower the 

thresholds if it finds low facility applicability? --do all of our 

sites need to complete Section J of the survey? --we repackaged a 

total of 31,870 lbs. of butyl oxitol. With an estimated loss of less 

than 1%, please confirm we would be well below the HAP emissions 

threshold of 5 tons per year of any single HAP. --there is a concern 

that EPA may be compiling a list of companies for future enforcement 

action. Is EPA able to confirm or deny this concern? 

Regards, 

Bill Allmond 

BAEEEEE1.9CFD919A--

Bernd Haneke -- 3 -- Thu, 9 Jul 1998 10:50:16 

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