






MEMORANDUM

TO:	Bill Schrock and Allison Costa, U.S. EPA/OAQPS/SPPD  -  Natural Resources Group

FROM:	Eastern Research Group, Inc.

DATE:	September 25, 2018

SUBJECT:	Clarification of Hazardous Air Pollutant (HAP) Usage Data for S.B. Foot Tanning Co., Submitted by the Minnesota Pollution Control Agency


This memorandum documents a telephone conversation clarifying the hazardous air pollutant usage data for S.B. Foot Tanning Company in response to comments submitted by the Minnesota Pollution Control Agency. The documentation of the telephone conversation is included in Attachment A.



                                       
                                 Attachment A
                                       
Documentation of Telephone Conversation Clarifying SB Foot HAP Usage Information




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TELEPHONE CALL RECORD

x   Incoming Call
 _ Outgoing Call


Account & Task Number:
0305.04.022.001



Project Name: Leather Finishing RTR



Date
07/25/2018

Time


Person Calling: Bob Dahl, EHS Director, SB Foot


Activity:  


Person Called: Roy Oommen, ERG


Telephone No.: 651-385-1433 (Bob Dahl)

General Subject: Clarification on SB Foot HAP usage information

                                       
                      Topics Discussed and Actions Taken

During the comment period for the Leather Finishing RTR, EPA received a comment letter from the state of Minnesota that contained an excel file with information on HAP usage over a four year period at SB Foot. Ms. Anne Jackson from the State of Minnesota indicated the spreadsheet was obtained from SB Foot, and suggested contacting Mr. Dahl for questions. Mr. Dahl called in response to an email and voicemail Mr. Oommen sent him requesting clarification on an excel spreadsheet containing SB Foots HAP usage information.

ERG had the following questions:

 For September and October 2016, the HAP actual monthly emissions are much higher than for the other months, but the spreadsheets do not indicate there is anything different happening in those 2 months than the other months. Is there a reason why the numbers are higher for those 2 months? For example, were a higher number of hours worked?
 In February and April of 2016, there are negative numbers for HAP actual monthly emissions. Was this an error? If not, what do the negative numbers mean?
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Mr. Dahl responded that the significant contributor to HAP emissions calculations are primarily from Glycol EP  -  cutting agent  -  that was stored in a tank. The process of measuring the volume in the tank and the timing of the deliveries resulted in the anomalous readings. Mr. Dahl added that the data in question resulted from the inaccurate process of measuring the material's volume, or the tank being filled in the previous month to a different level and giving anomalous readings. Mr. Dahl also added that the 4 data points in question are not representative of the typical HAP usage, and EPA should look at the HAP usage information for the other entries to characterize. Please note, the material is no longer stored in a tank so the data points of material received and used are more accurate. 



