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 CropScience 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 CropScience 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 emissions data 

related to the chemical sector MACT rules. 

You suggested that I just send you the emails we received 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 CropScience has reviewed the NACAA data you provided. The 

attached consolidated list represents the 2005 emissions that are potentially associated with Bayer’s Institute Site 

operations. In general, these emissions accurately reflect Bayer’s hazardous air pollutant (HAP) emissions provided in 
2

our 2005 air emissions inventory. However, please note that the emissions associated with emission points 01 and 02 

are not Bayer CropScience emissions, but are believed to belong to Union Carbide/Dow’s Institute Plant operations. 

Emission for these two emission point were taken from the 2005 TRI database which would have included both Bayer’s 

and Dow’s TRI releases. In addition, as you had noted in your email emissions listed as Bayer Corp are 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 the database and most of these unit have been shut down. The table 

below shows each emission point, the associated unit, 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 Down) 

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 Maintenance 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 (Unit Shut Down) 

0HA 252 Crude Naphthol Unit All Emissions No Covered by MON (Unit Shut Down) 

0IA 253 Naphthol Refining Unit All Emissions No Covered by HON (Unit Shut Down) 

0JA 253 Naphthol Refining Unit Tanks/Loading No Covered by HON (Unit Shut Down) 

0KA 254 Dowtherm Unit Tanks/Fugitive No Dowtherm Unit not covered by PAI (Unit Shut Down) 

0LA 260 Carbaryl Unit Process No Covered by HON (Unit Shut Down) 

0MA 260 Carbaryl Unit Process No Covered by HON (Unit Shut Down) 

0MA1 260 Carbaryl Unit Process No 

Miss numbered emission point (OMA). Covered by HON (U

Down) 

0NA 261 PANA Unit All Emissions No Covered by MON (Unit Shut Down) 

0PA 310 Aldicarb Unit All Emissions Yes PAI (Unit Shut 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 and MON (Unit Shut Down) 

0VA Miscellaneous Plantwide No Miscellaneous activities not covered by PAI 

0WA 320 Carbofuran Unit All Emissions Yes PAI (Unit Shut Down) 

0XA 320 Carbosulfan Unit All Emissions Yes PAI (Unit 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 confidential, proprietary, privileged, or otherwise protected by law from disclosure or use by a third party. If you 

have received this message in error, please contact us immediately and take the steps necessary to delete the message completely from your computer system. 

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 emissions data 

related to the chemical sector MACT rules. 

You suggested that I just send you the emails we received 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 highlighted 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, Renu M; Durham, William F 

Subject: EPA Request for NACAA Assistance 

To All, 

Several states have received information requests from 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 affect WV facilities affected by the chemical 

sector MACT. There were no WV facilities in the OSWRO 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 submittals 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 Technology 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 with your TRI submittals. Finally, I suggest that 

you look at their Risk and Technology Review data back-fills to make sure they are appropriate for your facility. 

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Martinsville, Marshall County, to Kanawha 

County. It also appears that there may have been some 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 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 is 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 would 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 57th 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 contacting several states for data review and 

information gathering. 

CHEMICAL SECTOR

For several chemical sector MACT rules we have identified as "key" states that are included in this request. This e-mail includes requests for data 

review and information related to several RTR source 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 records in the attached files ("NACAA Facility List - State 020413.xlsx" and "NACAA Facility List - MACT 

020413.xlsx" contain identical records, they are just organized differently) to ensure that they are accurate and that all facilities in each source 

category from each listed state are included. The files include data records for each facility that come 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 additional information regarding these facilities. 

Note that these records only contain entries at each facility for the source categories of interest; whole facility emissions are not included in these 

files, and we are not requesting review of our information regarding processes in other source categories at these facilities. The "NACAA Facility List 

- State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - MACT 020413.xlsx" file has separate tabs for each source 

category (please note that the tabs "ABS", "MBS", "PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 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 states in EPA Region 9 (AZ, CA, NV, HI). For each facility, we 

are requesting: 

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions information; and 

• Operating Permit. 

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request OSWRO-Facilities with Unquantified 

OSWRO Emissions.xlsx" that each state review the facility or facilities listed and provide the following:

• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions 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 regarding this request. I will be submitting a separate request 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 Standards 

Sector Policies and Programs Division/Policy and Strategies Group 

D205-02 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450 

shrager.brian@epa.gov

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8

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 Martinsville 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 Martinsville 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 emissions data 

related to the chemical sector MACT rules. 

You suggested that I just send you the emails we received 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 category. 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 MAterialScience – 

New Martinsville. We are in Marshall County. 
9

However, I cannot match the emissions up with any year. 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 from 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 affect WV facilities affected by the chemical 

sector MACT. There were no WV facilities in the OSWRO 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 submittals 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 Technology 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 with your TRI submittals. Finally, I suggest that 

you look at their Risk and Technology Review data back-fills to make sure they are appropriate for your facility. 

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Martinsville, Marshall County, to Kanawha 

County. It also appears that there may have been some 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 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 is 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 would 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 57th 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 contacting several states for data review and 

information gathering. 

CHEMICAL SECTOR
10

For several chemical sector MACT rules we have identified as "key" states that are included in this request. This e-mail includes requests for data 

review and information related to several RTR source 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 records in the attached files ("NACAA Facility List - State 020413.xlsx" and "NACAA Facility List - MACT 

020413.xlsx" contain identical records, they are just organized differently) to ensure that they are accurate and that all facilities in each source 

category from each listed state are included. The files include data records for each facility that come 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 additional information regarding these facilities. 

Note that these records only contain entries at each facility for the source categories of interest; whole facility emissions are not included in these 

files, and we are not requesting review of our information regarding processes in other source categories at these facilities. The "NACAA Facility List 

- State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - MACT 020413.xlsx" file has separate tabs for each source 

category (please note that the tabs "ABS", "MBS", "PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 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 states in EPA Region 9 (AZ, CA, NV, HI). For each facility, we 

are requesting: 

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions information; and 

• Operating Permit. 

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request OSWRO-Facilities with Unquantified 

OSWRO Emissions.xlsx" that each state review the facility or facilities listed and provide the following:

• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions 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 regarding this request. I will be submitting a separate request 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 Standards 

Sector Policies and Programs Division/Policy and Strategies 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 privileged. 

Inadvertent disclosure of this message does not constitute a waiver of any privilege. If you receive this message in error, please do not directly or indirectly use, 

print, copy, forward, or disclose any part of this message. Please also delete this e-mail and all copies and notify the sender. Thank you. 
11

For alternate languages please go to http://bayerdisclaimer.bayerweb.com
12

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 emissions data 

related to the chemical sector MACT rules. 

You suggested that I just send you the emails we received 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.Whitwer@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 the EPAs Risk and Technology 

Review Data, and they must have used the 2002 state agency data to obtain the emissions. Comparing what Debbie had 
13

in her files for 2002 vs. what is in the spreadsheet, it looks reasonable that what is in the spreadsheet you provided is 

what was reported in 2002. 

I couldn’t find in my predecessors files a few of the entries – for example Cadmium and Nickel on emission point G10. 

But looking at what we have reported the past few years, the numbers in there look reasonable for that (though we are 

lower now). I stripped down the spreadsheet some so that I could review it, and that is attached if that 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, Renu M; Durham, William F 

Subject: EPA Request for NACAA Assistance 

To All, 

Several states have received information requests from 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 affect WV facilities affected by the chemical 

sector MACT. There were no WV facilities in the OSWRO 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 submittals 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 Technology 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 with your TRI submittals. Finally, I suggest that 

you look at their Risk and Technology Review data back-fills to make sure they are appropriate for your facility. 

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Martinsville, Marshall County, to Kanawha 

County. It also appears that there may have been some 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 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 is 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 would 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 57th Street, SE 

Charleston, WV 25304 
14

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 contacting several states for data review and 

information gathering. 

CHEMICAL SECTOR

For several chemical sector MACT rules we have identified as "key" states that are included in this request. This e-mail includes requests for data 

review and information related to several RTR source 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 records in the attached files ("NACAA Facility List - State 020413.xlsx" and "NACAA Facility List - MACT 

020413.xlsx" contain identical records, they are just organized differently) to ensure that they are accurate and that all facilities in each source 

category from each listed state are included. The files include data records for each facility that come 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 additional information regarding these facilities. 

Note that these records only contain entries at each facility for the source categories of interest; whole facility emissions are not included in these 

files, and we are not requesting review of our information regarding processes in other source categories at these facilities. The "NACAA Facility List 

- State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - MACT 020413.xlsx" file has separate tabs for each source 

category (please note that the tabs "ABS", "MBS", "PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 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 states in EPA Region 9 (AZ, CA, NV, HI). For each facility, we 

are requesting: 

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions information; and 

• Operating Permit. 

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request OSWRO-Facilities with Unquantified 

OSWRO Emissions.xlsx" that each state review the facility or facilities listed and provide the following:

• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions 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 regarding this request. I will be submitting a separate request 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 Standards 

Sector Policies and Programs Division/Policy and Strategies Group 
15

D205-02 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450 

shrager.brian@epa.gov
16

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 response)

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 response) 

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 received 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 they match our records for SABIC Innovative Plastics 

Washington facility for the 2005 emissions inventory and TRI. We have no comments or corrections to submit 

for this data. Thank you for the opportunity to review 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, Renu M; Durham, William F 

Subject: EPA Request for NACAA Assistance

 

To All,

Several states have received information requests from 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 affect WV facilities affected by the chemical 

sector MACT. There were no WV facilities in the OSWRO 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 submittals 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 Technology 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 with your TRI submittals. Finally, I suggest that 

you look at their Risk and Technology Review data back-fills to make sure they are appropriate for your facility.

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Martinsville, Marshall County, to Kanawha 

County. It also appears that there may have been some 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 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 is 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 would 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 57th 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 contacting several states for data review and 

information gathering. 

CHEMICAL SECTOR

For several chemical sector MACT rules we have identified as "key" states that are included in this request. This e-mail includes requests for data 

review and information related to several RTR source 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 records in the attached files ("NACAA Facility List - State 020413.xlsx" and "NACAA Facility List - MACT 

020413.xlsx" contain identical records, they are just organized differently) to ensure that they are accurate and that all facilities in each source 

category from each listed state are included. The files include data records for each facility that come 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 additional information regarding these facilities. 

Note that these records only contain entries at each facility for the source categories of interest; whole facility emissions are not included in these 

files, and we are not requesting review of our information regarding processes in other source categories at these facilities. The "NACAA Facility List 

- State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - MACT 020413.xlsx" file has separate tabs for each source 

category (please note that the tabs "ABS", "MBS", "PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 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 the OSWRO source category from all states in EPA Region 9 (AZ, CA, NV, HI). For each 

facility, we are requesting:

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions information; and 

• Operating Permit.

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request OSWRO-Facilities with Unquantified 

OSWRO Emissions.xlsx" that each state review the facility or facilities listed and provide the following:

• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions 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 regarding this request. I will be submitting a separate request 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 Standards 

Sector Policies and Programs Division/Policy and Strategies 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 around the laws." - 

Plato
20

 

 

This e-mail and any attachments are for authorized use 

by the intended recipient(s) only. They may contain 

proprietary material or confidential information and/or 

be subject to legal privilege. They should not be copied, 

disclosed to, or used by any other party. If you have 

reason to believe that you are not one of the intended 

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 and/or 

be subject to legal privilege. They should not be copied, 

disclosed to, or used by any other party. If you have 

reason to believe that you are not one of the intended 

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 MaterialScience 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 MaterialScience 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 emissions data 

related to the chemical sector MACT rules. 

You suggested that I just send you the emails we received 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 facility. One comment about the spreadsheets. For each of our 

HAP’s there are two line items for each HAP. Each line item includes the process (vent) and fugitive for 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, Renu M; Durham, William F 

Subject: EPA Request for NACAA Assistance

To All,

Several states have received information requests from 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 affect WV facilities affected by the chemical 

sector MACT. There were no WV facilities in the OSWRO 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 submittals 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 Technology 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 with your TRI submittals. Finally, I suggest that 

you look at their Risk and Technology Review data back-fills to make sure they are appropriate for your facility. 

Our preliminary review indicates that EPA may have mislocated one of the Bayer facilities from New Martinsville, Marshall County, to Kanawha 

County. It also appears that there may have been some 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 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 is 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 would 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 57th 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 contacting several states for data review and 

information gathering. 

CHEMICAL SECTOR
23

For several chemical sector MACT rules we have identified as "key" states that are included in this request. This e-mail includes requests for data 

review and information related to several RTR source 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 records in the attached files ("NACAA Facility List - State 020413.xlsx" and "NACAA Facility List - MACT 

020413.xlsx" contain identical records, they are just organized differently) to ensure that they are accurate and that all facilities in each source 

category from each listed state are included. The files include data records for each facility that come 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 additional information regarding these facilities. 

Note that these records only contain entries at each facility for the source categories of interest; whole facility emissions are not included in these 

files, and we are not requesting review of our information regarding processes in other source categories at these facilities. The "NACAA Facility List 

- State 020413.xlsx" file has separate tabs for each state, and the "NACAA Facility List - MACT 020413.xlsx" file has separate tabs for each source 

category (please note that the tabs "ABS", "MBS", "PET", "PS", and "SAN" are all part of the Polymers and Resins IV MACT category). 

(See attached file: NACAA Facility List - State 020413.xlsx)(See attached file: NACAA Facility List - MACT 020413.xlsx)

OFF-SITE WASTE RECOVERY OPERATIONS

The other source category that we are requesting NACAA's assistance with is the Off-site Waste Recovery 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 states in EPA Region 9 (AZ, CA, NV, HI). For each facility, we 

are requesting: 

• Emissions inventory for the facility; 

• Details on the processes covered by OSWRO, including emissions estimates and other emissions information; and 

• Operating Permit. 

2. We are requesting that for the facilities listed, by state, in the attached spreadsheet "NACAA Request OSWRO-Facilities with Unquantified 

OSWRO Emissions.xlsx" that each state review the facility or facilities listed and provide the following:

• Is the facility subject to OSWRO? 

• Details on the processes covered, including any emissions 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 regarding this request. I will be submitting a separate request 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 Standards 

Sector Policies and Programs Division/Policy and Strategies 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 privileged. 

Inadvertent disclosure of this message does not constitute a waiver of any privilege. If you receive this message in error, please do not directly or indirectly use, 

print, copy, forward, or disclose any part of this message. Please also delete this e-mail and all copies and notify the sender. Thank you. 
24

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