Schleusener, Paul (DEQ) From: Sent: To: Cc: Subject: Attachments: Colleen Laginess <[email protected]> Friday, February 07, 2014 5:11 PM Schleusener, Paul (DEQ) Noel Frye ([email protected]); [email protected]; [email protected]; Avery Williams; Teri Whitehead Detroit Bulk Storage, Inc.'s PTI additional information L-P Schleusener re PTI additional Information. pdf Dear lvlr. Schleusener: Attached is a letter regarding your request for additional information regarding DES' Permit to Install. If you have any questions, please call our office. Very truly yours, Coffeen A. L'aginess Secretary to 2JavidA. 2Jomza! AndTeri }f//iitefiead fYi!llams Acost4 P££C 535 {iriswoMSt., Suite 1000 2Jetroit.. .:Jv!J48226 313-963"3873 X124 313-961-6879 To comy[y witfi. 'U.S. Treasury regu[ations, 1ve aavise you tfi.at any discussion oj :reaera[ tax issues in tfi.is communication was not intenaea or written to 6e used; ana cannot 6e used; 6y any yerson (i) for tfi.e ywyose of avoiding yena[ties tfi.at may 6e imyosea 6y tfi.e Interna[ 'Revenue Service, or (ii) to yromote, market or recomntena to any otfi.er yarty any matter aarfressea fi.erein. Tfi.is Internet message may contain information tfiat is yrivi[eged; cmifiaentia[, ana exemyt from disc[osure. It is intenaeafor use on[y 6y tfi.e yerson to wfi.om it is aacfressecf. If you fiave receiver[ tfi.is in error, yfease (J) ao not forwara or use tfi.is information in any way; ana (2) contact me immediate[y. Neitfier tfi.is information 6[ock., tfie tyyea name of tfie senaer, nor anything efSe in tfiis message is intenaea to constitute an e[ectronic signature un[ess a syecific statement to tfie contrary is incfuaea in tfi.is message. 1 William sA costa A Professiollal Limited Liability Company Teri Whitehead Of Counsel [email protected] Attomeys and Counselors 535 Griswold Street, Suite 1000 Detroit, MI 48226-3692 Phone: (313) 963-3873 Fax: (313) 961-6879 www.williamsacosta.com Febmary 7, 2014 Via Electronic and First Class Mail Paul Schleusener, Senior Engineer Specialist Michigan Depattment of Environmental Quality Air Quality Division Constitution Hall, I st Floor 525 West Allegan Street P.O. Box 30473 Lansing, MI 48909-7973 Re: Detroit Bulk Storage, Inc. Permit to Install Application No. 189-13 Dear Mr. Schleusener: In response to your correspondence of February 6, 2013, Detroit Bulk Storage, Inc. ("DBS") integrated information from an existing dry bulk handling facility, The C. Reiss Coal Company ("C. Reiss") located in Escanaba, Michigan. The Michigan Department of Environmental Quality, Air Quality Division, granted C. Reiss a permit to install on or about December of 2012. DBS investigated C. Reiss and selected the data utilized at C. Reiss' facility as DBS and C. Reiss parallel in the following critical areas: 1) Processing - DBS and C. Reiss utilize the same procedures for handling various aggregates, delivered to the site by truck or vessel. 2) Equipment • DBS a11d C. Reiss utilize the same equipment (i.e., hopper, water pump (77.5 hp), stacking conveyors (100 hp), trucks, and vessels. 3) Materials - DBS and C. Reiss handle the same materials, including, sand, asphalt, petroleum coke, crushed stone, limestone, and trap rock. WHriams Acosta1 PLLC 4) Wind Speed 1 - DBS and C. Reiss have the same wind speed throughout the year. DBS' facility over the course of the year has typical wind speeds that vary from 0 mph to 17 mph, but rarely exceeding 23 mph. The highest average wind speed for DBS facility is 10 mph which occms around January 18, at which time the average daily maximum wind speed is 16 mph. C. Reiss's facility over the course of the year has the same typical wind speeds as DBS, varying from 0 mph to 15 mph, and rarely exceeding 23 mph. The highest average wind speed of 9 mph for C. Reiss occurs around December 1, at which time the average daily maximum wind speed is 15 mph. 5) Climate - DBS and C. Reiss are located in the Great Lakes Region, where both facilities experience similar weather conditions. For example, the average temperature of DBS' facility during the winter months is about 34°F as compared with 29°F for C. Reiss. Humidity is 40-89% throughout the year for DBS as compared with 44-93% for C. Reiss. And, precipitation for DBS and C. Reiss are 33.5 inches and 28.7, respectively. 6) Control Technology - DBS and C. Reiss presented analogous fugitive dust control plans to control fugitive particulate from material storage and operations. 7) Throughput- DBS and C. Reiss have the same material handling, ship uploading, truck loading throughput of 4,380,000 tons per year. For these reasons, DBS submits that the calculations as presented in its permit to install application are appropriate. If you have any questions, please call me. Kind regards, WILLIAMS ACOSTA, PLLC Teri Whitehead 1 See http:i/weatherspark.com/averagcs/30042/Detroit-Michigan-United-States; See also, http://weatherspark.com/averages/30198/Escanaba-Michigan-United-States ~~~~ Williams Acosta1 PLLC TW/cal cc: Mr. Noel Frye (via electronic mail) Ms. Tammy Yaek-Ryall (via electronic mail) Avery K. Williams (via electronic mail) Lori Shink (via electronic mail) I I I