1 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 4:00 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: Bayer CropScience NACAA Comments (Bayer CropSci ence response)** 



### 6 of 6

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:56 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: Bayer CropScience NACAA Comments (Bayer CropSc ience response)



### Reference: WV emission data from 2005 NEI, chemical sector MACT Response 6 of 6

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of e missions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: David Fewell [mailto:David.Fewell@erm.com] Sent: Monday, March 04, 2013 2:10 PM To: Betterton, Robert J Cc: Lennie Scott (lennie.scott@bayer.com) Subject: Bayer CropScience NACAA Comments



### Bob,

Per your email request on February 7, 2013, Bayer C ropScience has reviewed the NACAA data you provided . The attached consolidated list represents the 2005 emis sions that are potentially associated with Bayer’s Institute Site operations. In general, these emissions accurately reflect Bayer’s hazardous air pollutant (HAP) emis sions provided in2 

### our 2005 air emissions inventory. However, please note that the emissions associated with emission po ints 01 and 02 are not Bayer CropScience emissions, but are believ ed to belong to Union Carbide/Dow’s Institute Plant operations. Emission for these two emission point were taken fr om the 2005 TRI database which would have included both Bayer’s and Dow’s TRI releases. In addition, as you had no ted in your email emissions listed as Bayer Corp ar e not from Bayer’s Institute operations and must be from another Bayer facility. Finally, not all emission points listed in the database are associated with PAI covered units as indicated in t he database and most of these unit have been shut d own. The table below shows each emission point, the associated uni t, and whether or not the emission point is subject to the PAI regulations. If another NESHAP regulation applies, they are noted in the table. If you have any questions, please contact

me at (304) 757-4777 x 102.

2005 AEI Emission Point Associated Emission Units Is Unit Subject
to PAI? Comments
01 NA No UCC/Dow emission point

02 NA No UCC/Dow emission point 006 243 Phosgene Unit Fugitives No Covered by HON ( Unit Shut Down) 008 242 MIC Unit Fugitives No Covered by HON (Unit Shut Down) 010 251 Oxidation Unit Fugitives No Covered by MON (Unit Shut Down) 011 253 Naphthol Refining Unit Fugitives No Covered by HON (Unit Shut Down) 013 260 Carbaryl Unit Fugitives No Covered by HON ( Unit Shut Down) 015 330 Oxime Unit Fugitives Yes PAI (Unit Shut Dow n) 016 331 Methomyl Unit Fugitives Yes PAI (Unit Shut Down) 017 332 Larvin Fugitives Yes PAI 018 450 Plant Laboratory No Laboratory not covered by PAI 019 400/460 Maintenance Tanks/Fugitives No Maintena nce not covered by PAI 020 010 WWTU Secondary No WWTU not covered by PAI 0AA 242/243 MIC/Phosgene Unit Flare No Covered by HON (Units Shut Down) 0FA 250 Hydrogenation Unit Tanks No Covered by HON (Unit Shut Down) 0GA 251 Oxidation Unit Tanks No Covered by MON (Un it Shut Down) 0HA 252 Crude Naphthol Unit All Emissions No Cover ed by MON (Unit Shut Down) 0IA 253 Naphthol Refining Unit All Emissions No Co vered by HON (Unit Shut Down) 0JA 253 Naphthol Refining Unit Tanks/Loading No Co vered by HON (Unit Shut Down) 0KA 254 Dowtherm Unit Tanks/Fugitive No Dowtherm Un it not covered by PAI (Unit Shut Down) 0LA 260 Carbaryl Unit Process No Covered by HON (Un it Shut Down) 0MA 260 Carbaryl Unit Process No Covered by HON (Un it Shut Down)

0MA1 260 Carbaryl Unit Process No Miss numbered emission point (OMA). Covered by HON (Unit Shut Down) 0NA 261 PANA Unit All Emissions No Covered by MON (Unit Shut Down) 0PA 310 Aldicarb Unit All Emissions Yes PAI (Unit S hut Down) 0RA 290 Rhodimet Unit Flare/PTO No Covered by HCN and MON (Unit Shut Down) 0SA 290 Rhodimet Unit All VOCs No Covered by HCN an d MON (Unit Shut Down)
0VA Miscellaneous Plantwide No Miscellaneous activi ties not covered by PAI 0WA 320 Carbofuran Unit All Emissions Yes PAI (Unit Shut Down) 0XA 320 Carbosulfan Unit All Emissions Yes PAI (Uni t Shut Down)

**Thanks,**3 

### David R. Fewell **Principal Consultant ERM**  **204 Chase Drive Hurricane, West Virginia 25526**  **T: +1 (304) 757-4777 ext. 102 F: +1 (304) 757-4799**  **C: +1 (304) 549-5402**

**david.fewell@erm.com**

**www.erm.com**

**This message contains information which may be conf idential, proprietary, privileged, or otherwise pro**  **tected by law from disclosure or use by a third par ty. If you**  **have received this message in error, please contact us immediately and take the steps necessary to del**  **ete the message completely from your computer syste m.**  **Thank you.**

**Please visit ERM's web site: http://www.erm.com** 4 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 4:00 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: EPA Request for NACAA Assistance (DuPont Belle response)**  Attachments: **DuPont Belle Corrections NACAA Facility List - MACT 020413.xlsx** 



### 5 of 6

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:55 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: EPA Request for NACAA Assistance (DuPont Belle response)



### Reference: WV emission data from 2005 NEI, chemical sector MACT Response 5 of 6 (includes edited spreadsheet)

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of e missions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: LeAnne.Schottle@dupont.com [mailto:LeAnne.Schottle @dupont.com] Sent: Monday, February 11, 2013 10:52 AM To: Betterton, Robert J Subject: RE: EPA Request for NACAA Assistance



### Bob,

I marked changes on the attached spreadsheet and hi ghlighted those cells. Please let me know if there are any questions.5 

### From: Betterton, Robert J [ mailto:Robert.J.Betterton@wv.gov ] Sent: Thursday, February 07, 2013 12:33 PM To: JAMES.WHITE.B1@BAYER.COM ; MARYANN.HENDERSON.B@BAYER.COM ; BRIAN.SCHMIDT@BAYER.COM ; SCHOTTLE, LEANNE; YOUNG, MICHELLE LEA; HAILA.BUSKIRK@GE.COM ; IRIS.SONGERJ@DOW.COM ; szulm2@dow.com ; Scott.B.Whitwer@gruppomgus.com ; DEBRA.L.POWELL@GRUPPOMGUS.COM Cc: Benedict, John A; Azevedo, Alfred; Chakrabarty, Re nu M; Durham, William F Subject: EPA Request for NACAA Assistance

To All,

Several states have received information requests f rom EPA about certain source categories as part of its efforts to develop Risk and Technology Review (RTR) NESHAP rules. I’ve pasted EPA’s email below. I’ve attached only the spreadsheets that aff ect WV facilities affected by the chemical sector MACT. There were no WV facilities in the OSWR O spreadsheet so you can skip that section of Brian Shrager’s email.

Column AY contains the source of the data, which is mostly from your 2005 emissions inventory submitta ls that (after our internal QA procedures) we submitted to EPA’s National Emissions Inventory (NEI). When they expect a particular HAP and don’t see it in NEI data, EPA will back-fill from either the TRI or from their own Risk and Technolog y Review data. So first I’d check to make sure that the 2005 data you provided is correct (a common error is to misapply control efficiency) and then to reconcile your emissions inventory data wi th your TRI submittals. Finally, I suggest that you look at their Risk and Technology Review data b ack-fills to make sure they are appropriate for you r facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Mart insville, Marshall County, to Kanawha County. It also appears that there may have been so me double-counting of propylene oxide and ethylene oxide for Bayer Cro pScience. Possibly EPA brought forward some 2002 data from the TRI.

EPA has requested the information by March 8 but so that we have time to review the information, please send any corrections or comments to me by March 4. If you have immediate technical quest ions before your formal reply please call (304) 926-0499 to contact Alfred Azevedo (extension 1255 ) or Renu Chakrabarty (extension 1246 ). If Renu or Alfred are unavailable my extension i s 1241

.
To minimize the chances of this email being blocked by your fire wall or spam filter, I’ve zipped the files and changed the filename extensions to piz. To open them please change the extension back to zip and then unzip them.

It would be helpful if someone from each facility w ould acknowledge receipt of this email so I can be sure you got it.

Thanks! Bob

Bob Betterton, Manager Emissions Inventory Unit WV DEP/DAQ/Planning Section
601 57 th Street, SE Charleston, WV 25304

Phone: 304-926-0499 x 1241

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

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 gathering.

CHEMICAL SECTOR

For several chemical sector MACT rules we have ident ified as "key" states that are included in this req uest. This e-mail includes requests for data review and information related to several RTR sourc e categories. The first group of source categories includes:

Polycarbonates Production (PC) Polymers and Resins III (P&RIII) Pesticide Active Ingredient (PAI)6

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 are ju st organized differently) to ensure that they are a ccurate and that all facilities in each source category from each listed state are included. The f iles include data records for each facility that co me from the 2005 National Emissions Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have additi onal information regarding these facilities. Note that these records only contain entries at eac h facility for the source categories of interest; w hole facility emissions are not included in these files, and we are not requesting review of our info rmation regarding processes in other source categor ies at these facilities . The "NACAA Facility List - State 020413.xlsx" file has separate tabs for eac h state, and the "NACAA Facility List - MACT 020413. xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", "P ET", "PS", and "SAN" are all part of the Polymers a nd 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 for OSWRO. Specifically:

1. We are requesting a list o f facilities subject to the OSWRO source category f rom all states in EPA Region 9 (AZ, CA, NV, HI). Fo r each facility, we are requesting:



### • Emissions inventory for the facility;



### • Details on the processes covered by OSWRO, includin g emissions estimates and other emissions informati on; 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 fa cility or facilities listed and provide the followi ng :



### • 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 the various attachments that are located in Texas and 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



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http://www.DuPont.com/corp/email_disclaimer.html8 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 3:59 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: Chemical Sector MACT Information (Bayer New Mar tinsville response)** 



### 4 of 6

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:55 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: Chemical Sector MACT Information (Bayer New Ma rtinsville response)



### Reference: WV emission data from 2005 NEI, chemical sector MACT Response 4 of 6

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of e missions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: Mary Henderson [mailto:maryann.henderson@bayer.com ] Sent: Thursday, February 28, 2013 10:05 AM To: Betterton, Robert J; James White Subject: RE: Chemical Sector MACT Information

**Bob –**

**Thanks for the opportunity to review the files.**

**The Bayer New Martinsville site is in the PEPO cate gory. It looks like you are right and the EPA mixed**  **us up with Crop Science at Institute. We have EO and PO emissions**  **and those listed as Bayer Corp. should be Bayer MAt erialScience –**  **New Martinsville. We are in Marshall County.**9 

### However, I cannot match the emissions up with any ye **ar. They are close to 2005, but not exact. Here is what I have for**  **2005 emissions**

**EO fug 0.649 tons EO vents 0.001** 

**PO fug 0.579 tons PO vents 0.001** 

**Hope this helps**



### Mary Ann Henderson
304-451-2431

Several states have received information requests f rom EPA about certain source categories as part of its efforts to develop Risk and Technology Review (RTR) NESHAP rules. I’ve pasted EPA’s email below. I’ve attached only the spreadsheets that aff ect WV facilities affected by the chemical sector MACT. There were no WV facilities in the OSWR O spreadsheet so you can skip that section of Brian Shrager’s email.

Column AY contains the source of the data, which is mostly from your 2005 emissions inventory submitta ls that (after our internal QA procedures) we submitted to EPA’s National Emissions Inventory (NEI). When they expect a particular HAP and don’t see it in NEI data, EPA will back-fill from either the TRI or from their own Risk and Technolog y Review data. So first I’d check to make sure that the 2005 data you provided is correct (a common error is to misapply control efficiency) and then to reconcile your emissions inventory data wi th your TRI submittals. Finally, I suggest that you look at their Risk and Technology Review data b ack-fills to make sure they are appropriate for you r facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Mart insville, Marshall County, to Kanawha County. It also appears that there may have been so me double-counting of propylene oxide and ethylene oxide for Bayer CropScience. Possib ly EPA brought forward some 2002 data from the TRI.

EPA has requested the information by March 8 but so that we have time to review the information, please send any corrections or comments to me by March 4. If you have immediate technical quest ions before your formal reply please call (304) 926-0499 to contact Alfred Azevedo (extension 1255 ) or Renu Chakrabarty (extension 1246 ). If Renu or Alfred are unavailable my extension i s 1241

.
To minimize the chances of this email being blocked by your fire wall or spam filter, I’ve zipped the files and changed the filename extensions to piz. To open them please change the extension back to zip and then unzip them.

It would be helpful if someone from each facility w ould acknowledge receipt of this email so I can be sure you got it.

Thanks! Bob

Bob Betterton, Manager Emissions Inventory Unit WV DEP/DAQ/Planning Section
601 57 th Street, SE Charleston, WV 25304

Phone: 304-926-0499 x 1241

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

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 gathering.

CHEMICAL SECTOR10

For several chemical sector MACT rules we have ident ified as "key" states that are included in this req uest. This e-mail includes requests for data review and information related to several RTR sourc e 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 are ju st organized differently) to ensure that they are a ccurate and that all facilities in each source category from each listed state are included. The f iles include data records for each facility that co me from the 2005 National Emissions Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have additi onal information regarding these facilities. Note that these records only contain entries at eac h facility for the source categories of interest; w hole facility emissions are not included in these files, and we are not requesting review of our info rmation regarding processes in other source categor ies at these facilities . The "NACAA Facility List - State 020413.xlsx" file has separate tabs for eac h state, and the "NACAA Facility List - MACT 020413. xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", "P ET", "PS", and "SAN" are all part of the Polymers a nd 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 for OSWRO. Specifically:

1. We are requesting a list o f facilities subject to the OSWRO source category f rom all states in EPA Region 9 (AZ, CA, NV, HI). Fo r each facility, we are requesting:



### • Emissions inventory for the facility;



### • Details on the processes covered by OSWRO, includin g emissions estimates and other emissions informati on; 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 fa cility or facilities listed and provide the followi ng :



### • 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 the various attachments that are located in Texas and 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

The information contained in this e-mail is for the exclusive use of the intended recipient(s) and may be confidential, proprietary, and/or legally privi leged. Inadvertent disclosure of this message does not con stitute a waiver of any privilege. If you receive this message in error, please do not directly or in directly use, print, copy, forward, or disclose any part of this message. Please also delete this e-mail and all co pies and notify the sender. Thank you.11

For alternate languages please go to http://bayerdisclaimer.bayerweb.com12 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 3:59 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: EPA Request for NACAA Assistance (M&G response)** Attachments: **NACAA EPA 2-2013 review.xlsx**



### 3 of 6

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:54 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: EPA Request for NACAA Assistance (M&G response )



### Reference: WV emission data from 2005 NEI, chemical sector MACT Response 3 of 6 (includes edited spreadsheet)

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of e missions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: Scott.B.Whitwer@gruppomgus.com [mailto:Scott.B.Whi twer@gruppomgus.com] Sent: Thursday, February 21, 2013 11:09 AM To: Betterton, Robert J Cc: David.Fewell@erm.com Subject: RE: EPA Request for NACAA Assistance



### Bob – I have taken a pass through this for M&G with the guidance of Dave. It took me a few minutes to figure out that the data in there for M&G is the 2002 data, not 2005. It looks our data is based on th e EPAs Risk and Technology Review Data, and they must have used the 2002 state agency data to obtain the emissions. Comparing what Debbie had13 

### in her files for 2002 vs. what is in the spreadshee t, it looks reasonable that what is in the spreadsh eet you provided is what was reported in 2002.

I couldn’t find in my predecessors files a few of t he entries – for example Cadmium and Nickel on emis sion point G10. But looking at what we have reported the past few y ears, the numbers in there look reasonable for that (though we are lower now). I stripped down the spreadsheet some s o that I could review it, and that is attached if t hat is any use to you. I do note that a lot of the emissions points in there no longer exist – I could about 43 of the 90 or so that are still
active...

Let me know if you need anything else on this.

Thanks!

Scott Whitwer QA / Environmental Manager, M&G Polymers USA, LLC State Rt. 2, Apple Grove WV 25502 Phone: 304-576-4589 Fax: 304-576-4625 Cel: 304-633-4077

From: Betterton, Robert J [ mailto:Robert.J.Betterton@wv.gov ] Sent: Thursday, February 07, 2013 12:33 PM To: JAMES.WHITE.B1@BAYER.COM ; MARYANN.HENDERSON.B@BAYER.COM ; BRIAN.SCHMIDT@BAYER.COM ; LEANNE.SCHOTTLE@USA.DUPONT.COM ; Michelle.L.Young@usa.dupont.com ; HAILA.BUSKIRK@GE.COM ; IRIS.SONGERJ@DOW.COM ; szulm2@dow.com ; Whitwer, Scott SB APG; Powell, Debbie DL APG Cc: Benedict, John A; Azevedo, Alfred; Chakrabarty, Re nu M; Durham, William F Subject: EPA Request for NACAA Assistance

To All,

Several states have received information requests f rom EPA about certain source categories as part of its efforts to develop Risk and Technology Review (RTR) NESHAP rules. I’ve pasted EPA’s email below. I’ve attached only the spreadsheets that aff ect WV facilities affected by the chemical sector MACT. There were no WV facilities in the OSWR O spreadsheet so you can skip that section of Brian Shrager’s email.

Column AY contains the source of the data, which is mostly from your 2005 emissions inventory submitta ls that (after our internal QA procedures) we submitted to EPA’s National Emissions Inventory (NEI). When they expect a particular HAP and don’t see it in NEI data, EPA will back-fill from either the TRI or from their own Risk and Technolog y Review data. So first I’d check to make sure that the 2005 data you provided is correct (a common error is to misapply control efficiency) and then to reconcile your emissions inventory data wi th your TRI submittals. Finally, I suggest that you look at their Risk and Technology Review data b ack-fills to make sure they are appropriate for you r facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Mart insville, Marshall County, to Kanawha County. It also appears that there may have been so me double- counting of propylene oxide and ethylene oxide for Bayer CropScience. Possibly EPA brought forward some 2002 data from the TRI.

EPA has requested the information by March 8 but so that we have time to review the information, please send any corrections or comments to me by March 4. If you have immediate technical quest ions before your formal reply please call (304) 926-0499 to contact Alfred Azevedo (extension 1255 ) or Renu Chakrabarty (extension 1246 ). If Renu or Alfred are unavailable my extension i s 1241

.
To minimize the chances of this email being blocked by your fire wall or spam filter, I’ve zipped the files and changed the filename extensions to piz. To open them please change the extension back to zip and then unzip them.

It would be helpful if someone from each facility w ould acknowledge receipt of this email so I can be sure you got it.

Thanks! Bob

Bob Betterton, Manager Emissions Inventory Unit WV DEP/DAQ/Planning Section
601 57 th Street, SE Charleston, WV 2530414

Phone: 304-926-0499 x 1241

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

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 gathering.

CHEMICAL SECTOR

For several chemical sector MACT rules we have ident ified as "key" states that are included in this req uest. This e-mail includes requests for data review and information related to several RTR sourc e 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 are ju st organized differently) to ensure that they are a ccurate and that all facilities in each source category from each listed state are included. The f iles include data records for each facility that co me from the 2005 National Emissions Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have additi onal information regarding these facilities. Note that these records only contain entries at eac h facility for the source categories of interest; w hole facility emissions are not included in these files, and we are not requesting review of our info rmation regarding processes in other so urce categories at these facilities. The "NACAA Fac ility List - State 020413.xlsx" file has separate tabs for eac h state, and the "NACAA Facility List - MACT 020413. xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", "P ET", "PS", and "SAN" are all part of the Polymers a nd 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 for OSWRO. Specifically:

1. We are requesting a list of facilities subject to the OSWRO source category from all state s in EPA Region 9 (AZ, CA, NV, HI). For each facili ty, we are requesting:



### • Emissions inventory for the facility;



### • Details on the processes covered by OSWRO, includin g emissions estimates and other emissions informati on; 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 fa cility or facilities listed and provide the followi ng :



### • 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 the various attachments that are located in Texas and 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 Group15

D205-02 Research Triangle Park, NC 27711 (919) 541-7689 Fax: (919) 541-5450 shrager.brian@epa.gov16 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 3:58 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: EPA Request for NACAA Assistance (SABIC respons e)** 



### 2 of 6

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:53 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: EPA Request for NACAA Assistance (SABIC respon se)



## Reference: WV emission data from 2005 NEI, chemical sector MACT Response 2 of 6

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of emissions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: Haila Buskirk [mailto:haila.buskirk@sabic-ip.com] Sent: Thursday, February 14, 2013 4:58 PM To: Betterton, Robert J Cc: John Garner Subject: Re: EPA Request for NACAA Assistance



## Bob,17 

## I have reviewed the data in the spreadsheets and th ey match our records for SABIC Innovative Plastics Washington facility for the 2005 emissions inventor y and TRI. We have no comments or corrections to su bmit for this data. Thank you for the opportunity to rev iew the data. Regards, Haila On Fri, Feb 8, 2013 at 9:14 AM, Betterton, Robert J < Robert.J.Betterton@wv.gov > wrote:

From: Betterton, Robert J Sent: Thursday, February 07, 2013 12:33 PM To: ' JAMES.WHITE.B1@BAYER.COM '; ' MARYANN.HENDERSON.B@BAYER.COM '; ' BRIAN.SCHMIDT@BAYER.COM ';

' LEANNE.SCHOTTLE@USA.DUPONT.COM '; ' Michelle.L.Young@usa.dupont.com '; ' HAILA.BUSKIRK@GE.COM ';

' IRIS.SONGERJ@DOW.COM '; ' szulm2@dow.com '; ' Scott.B.Whitwer@gruppomgus.com ';

' DEBRA.L.POWELL@GRUPPOMGUS.COM ' Cc: Benedict, John A; Azevedo, Alfred; Chakrabarty, Re nu M; Durham, William F Subject: EPA Request for NACAA Assistance

To All,

Several states have received information requests f rom EPA about certain source categories as part of its efforts to develop Risk and Technology Review (RTR) NESHAP rules. I’ve pasted EPA’s email below. I’ve attached only the spreadsheets that aff ect WV facilities affected by the chemical sector MACT. There were no WV facilities in the OSW RO spreadsheet so you can skip that section of Bria n Shrager’s email.

Column AY contains the source of the data, which is mostly from your 2005 emissions inventory submitta ls that (after our internal QA procedures) we submitted to EPA’s National Emissions Inventory (NEI). When they expect a particular HAP and don’t see it in NEI data, EPA will back-fill from either the TRI or from their own Risk and Tech nology Review data. So first I’d check to make sure that the 2005 data you provided is correct (a common error is to misapply control efficiency) and then to reconcile your emissions inventory data wi th your TRI submittals. Finally, I suggest that you look at their Risk and Technology Review data b ack-fills to make sure they are appropriate for you r facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Mar tinsville, Marshall County, to Kanawha County. It also appears that there may have been so me double-counting of propylene oxide and ethylene oxide for Bayer CropScience. Possibly EPA brought forward some 2002 data from the TRI.

EPA has requested the information by March 8 but so that we have time to review the information, pleas e send any corrections or comments to me by March 4. If you have immediate technical questions before your formal reply please call (304) 926-0499 to contact Alfred Azevedo (extension 1255 ) or Renu Chakrabarty (extension 1246 ). If Renu or Alfred are unavailable my extension i s 1241

.

To minimize the chances of this email being blocked by your fire wall or spam filter, I’ve zipped the files and changed the filename exte nsions to piz. To open them please change the extension back to zi p and then unzip them.

It would be helpful if someone from each facility w ould acknowledge receipt of this email so I can be sure you got it.

Thanks!18

Bob

Bob Betterton, Manager

Emissions Inventory Unit

WV DEP/DAQ/Planning Section

601 57 th Street, SE

Charleston, WV 25304

Phone: 304-926-0499 x 1241

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

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 gathering.

CHEMICAL SECTOR

For several chemical sector MACT rules we have ident ified as "key" states that are included in this req uest. This e-mail includes requests for data review and information related to several RTR sourc e 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 are ju st organized differently) to ensure that they are a ccurate and that all facilities in each source category from each listed state are included. The f iles include data records for each facility that co me from the 2005 National Emissions Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have additi onal information regarding these facilities. Note that these records only contain entries at eac h facility for the source categories of interest; w hole facility emissions are not included in these files, and we are not requesting review of our info rmation regarding processes in other source categor ies at these facilities . The "NACAA Facility List - State 020413.xlsx" file has separate tabs for eac h state, and the "NACAA Facility List - MACT 020413. xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", "P ET", "PS", and "SAN" are all part of the Polymers a nd 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 for OSWRO. Specifically:19

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



### • Emissions inventory for the facility;



### • Details on the processes covered by OSWRO, includin g emissions estimates and other emissions informati on; 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 fa cility or facilities listed and provide the followi ng :



### • 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 the various attachments that are located in Texas and 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



## --

Haila Buskirk Environmental Engineer SABIC Innovative Plastics US LLC 9226 Dupont Road Washington, WV 26181 304-863-7694

"Good people do not need laws to tell them to act responsibly, while bad people will find a way a round the laws." - Plato20 

### This e-mail and any attachments are for authorized use by the intended recipient(s) only. They may contain proprietary material or confidential information an d/or be subject to legal privilege. They should not be c opied, disclosed to, or used by any other party. If you ha ve reason to believe that you are not one of the inten ded recipients of this e-mail, please notify the sender immediately by reply e-mail and immediately delete this e-mail and any of its attachments. Thank you.



## -- Haila Buskirk Environmental Engineer SABIC Innovative Plastics US LLC 9226 Dupont Road Washington, WV 26181 304-863-7694

This e-mail and any attachments are for authorized use by the intended recipient(s) only. They may contain proprietary material or confidential information an d/or be subject to legal privilege. They should not be c opied, disclosed to, or used by any other party. If you ha ve reason to believe that you are not one of the inten ded recipients of this e-mail, please notify the sender immediately by reply e-mail and immediately delete this e-mail and any of its attachments. Thank you.21 

## Parsons, Nick

From: **Shrager, Brian** Sent: **Tuesday, March 05, 2013 3:58 PM** To: **Parsons, Nick; Siefers, Andrea; Bouchard, Andrew** Cc: **Lassiter, Penny** Subject: **FW: Chemical Sector MACT Information (Bayer Materia lScience response)** 



### Response 1 of 6 from WV.

From: Porter, David J [mailto:David.J.Porter@wv.gov] Sent: Tuesday, March 05, 2013 3:52 PM To: Shrager, Brian Cc: Betterton, Robert J Subject: FW: Chemical Sector MACT Information (Bayer Materi alScience response)



### Reference: WV emission data from 2005 NEI, chemical sector MACT Response 1 of 6

Mr. Schrager,

I called you on 3/5/2013 to determine the best way to respond to your 2/4/2013 request for review of e missions data related to the chemical sector MACT rules. You suggested that I just send you the emails we re ceived from the facilities in question.

I am sending each response as a separate email.

Let me know if you need additional information.

David J. Porter, PE Engineer III WVDEP Division of Air Quality 601 57th Street Charleston, WV 25304

voice: 304-926-0499 x1699 fax: 304-926-0479 email: David.J.Porter@wv.gov

From: James White [mailto:james.white@bayer.com] Sent: Wednesday, February 13, 2013 4:28 PM To: Betterton, Robert J Cc: Mary Henderson Subject: RE: Chemical Sector MACT Information

**Bob,**

**I reviewed the data in the spreadsheets you sent me . The data for our facility is**  for the year 2002 and not 2005. **One spreadsheet column had – 20020101 over it.** 22 

### The total emissions are correct in the MACT (we are **in PEPO) and State list for State ID 0390102 which is the Bayer**  **MaterialsScience, South Charleston manufacturing fa cility. One comment about the spreadsheets. For each**  **of our HAP’s there are two line items for each HAP. Each l**  **ine item includes the process (vent) and fugitive f or an area of our**  **facility. That is how it was submitted in the AEI. The spreadsheet lists all line items as fugitives**  **and this is not correct.**

From: Betterton, Robert J Sent: Thursday, February 07, 2013 12:33 PM To: ' JAMES.WHITE.B1@BAYER.COM '; ' MARYANN.HENDERSON.B@BAYER.COM '; ' BRIAN.SCHMIDT@BAYER.COM ';

' LEANNE.SCHOTTLE@USA.DUPONT.COM '; ' Michelle.L.Young@usa.dupont.com '; ' HAILA.BUSKIRK@GE.COM ';

' IRIS.SONGERJ@DOW.COM '; ' szulm2@dow.com '; ' Scott.B.Whitwer@gruppomgus.com ';

' DEBRA.L.POWELL@GRUPPOMGUS.COM ' Cc: Benedict, John A; Azevedo, Alfred; Chakrabarty, Re nu M; Durham, William F Subject: EPA Request for NACAA Assistance

To All,

Several states have received information requests f rom EPA about certain source categories as part of its efforts to develop Risk and Technology Review (RTR) NESHAP rules. I’ve pasted EPA’s email below. I’ve attached only the spreadsheets that aff ect WV facilities affected by the chemical sector MACT. There were no WV facilities in the OSWR O spreadsheet so you can skip that section of Brian Shrager’s email.

Column AY contains the source of the data, which is mostly from your 2005 emissions inventory submitta ls that (after our internal QA procedures) we submitted to EPA’s National Emissions Inventory (NEI). When they expect a particular HAP and don’t see it in NEI data, EPA will back-fill from either the TRI or from their own Risk and Technolog y Review data. So first I’d check to make sure that the 2005 data you provided is correct (a common error is to misapply control efficiency) and then to reconcile your emissions inventory data wi th your TRI submittals. Finally, I suggest that you look at their Risk and Technology Review data b ack-fills to make sure they are appropriate for you r facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Mart insville, Marshall County, to Kanawha County. It also appears that there may have been so me double- counting of propylene oxide and ethylene oxide for Bayer CropScience. Possibly EPA brought forward some 2002 data from the TRI.

EPA has requested the information by March 8 but so that we have time to review the information, please send any corrections or comments to me by March 4. If you have immediate technical quest ions before your formal reply please call (304) 926-0499 to contact Alfred Azevedo (extension 1255 ) or Renu Chakrabarty (extension 1246 ). If Renu or Alfred are unavailable my extension i s 1241

.
To minimize the chances of this email being blocked by your fire wall or spam filter, I’ve zipped the files and changed the filename extensions to piz. To open them please change the extension back to zip and then unzip them.

It would be helpful if someone from each facility w ould acknowledge receipt of this email so I can be sure you got it.

Thanks! Bob

Bob Betterton, Manager Emissions Inventory Unit WV DEP/DAQ/Planning Section
601 57 th Street, SE Charleston, WV 25304

Phone: 304-926-0499 x 1241

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

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 gathering.

CHEMICAL SECTOR23

For several chemical sector MACT rules we have ident ified as "key" states that are included in this req uest. This e-mail includes requests for data review and information related to several RTR sourc e 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 are ju st organized differently) to ensure that they are a ccurate and that all facilities in each source category from each listed state are included. The f iles include data records for each facility that co me from the 2005 National Emissions Inventory (NEI) and have already been reviewed by EPA to the best of our ability, but the states may have additi onal information regarding these facilities. Note that these records only contain entries at eac h facility for the source categories of interest; w hole facility emissions are not included in these files, and we are not requesting review of our info rmation regarding processes in other so urce categories at these facilities. The "NACAA Fac ility List - State 020413.xlsx" file has separate tabs for eac h state, and the "NACAA Facility List - MACT 020413. xlsx" file has separate tabs for each source category (please note that the tabs "ABS", "MBS", "P ET", "PS", and "SAN" are all part of the Polymers a nd 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 for OSWRO. Specifically:

1. We are requesting a list of facilities subject to the OSWRO source category from all state s in EPA Region 9 (AZ, CA, NV, HI). For each facili ty, we are requesting:



### • Emissions inventory for the facility;



### • Details on the processes covered by OSWRO, includin g emissions estimates and other emissions informati on; 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 fa cility or facilities listed and provide the followi ng :



### • 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 the various attachments that are located in Texas and 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

The information contained in this e-mail is for the exclusive use of the intended recipient(s) and may be confidential, proprietary, and/or legally privi leged. Inadvertent disclosure of this message does not con stitute a waiver of any privilege. If you receive this message in error, please do not directly or in directly use, print, copy, forward, or disclose any part of this message. Please also delete this e-mail and all co pies and notify the sender. Thank you.24

For alternate languages please go to http://bayerdisclaimer.bayerweb.com