DEQ-CFW_00065392

Reeves, Gregory W
From: Waiters, Hope <[e-mail]>
Sent: Tuesday, April 11, 2017 10:52 AM
To: Reeves, Gregory W
Cc: Crews, Ross; He, Jia
Subject: Referencing Permit Section: A. Specific Conditions and Limitations, 9. Scrubber
Requirements, b. Monitoring Requirements (i),(ii)
Greg Reeves
Environmental Engineer
Division of Air of Air Quality
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Dear Greg:
Per our phone conversation yesterday, the following is a description of what was discussed:
Referencing Permit Section: A. Specific Conditions and Limitations, 9. Scrubber Requirements, b. Monitoring
Requirements (i),(ii)
it was discovered on Friday, April 7th that some of the historical files from the DCS system had been accidently deleted
by the Siemens Technician when he was servicing the system. Therefore, if the IP21 system which is the data historian
was down for any reason we would not have data for a given day. The DCS and the IP21 systems run in parallel so that
we have a backup in case one of the systems is down for any reason. It was discovered that even though the DCS was
functioning and collecting data it was not being saved. We are evaluating the possible solutions to making sure the
backup data is stored and saved in the proper way. We will have the solution in place within ten business days, so that
this is corrected and does not happen again. There is an interlock in place to prevent initiating a condensation batch if
scrubber water flow is low. This means we can say with confidence that we did not charge any batches with low water
flow, we Just can't prove this due to the loss of DCS data on any day that IP21 was down. After going back and looking
at the log book there were no indications that we had any deviations or exceedances.
If you have any questions, or need any additional information please let me know.
Best regards
Hope A. Walters
Environmental Specialist
Kuraray Interlayer Solutions
Fayetteville Site
PVB Division
22824 Highway 87 West
Fayetteville, NC 28306
phone: [phone]
mobile: [phone]
web: http://www•trosifol.com/
http://www,sentryglas.comZ
DEQ-CFW 00065392

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DEQ-CFW 00065393