## U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

General Information Company Name: Zeon Chemicals L.P. Facility Name: Kentucky Plant Facility Address: 4100 Bells Lane, Louisville, KY 40211 Mailing Address (if different from facility address): Site Contact Name: Thomas R. Herman Site Contact Title: Corporate Environmental Manager Site Contact Phone Number: 502-775-7719 Site Contact Email Address: herman@zeonchemicals.com

Page 1 of 8U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Facility Information Is the facility a major source for HAP? Zeon Chemicals L.P. Kentucky Plant Are there one or more process units at the facility subject to the Polymers and Resins I (P&R I) MACT (40 CFR 63, subpart U)? 4100 Bells Lane, Louisville, KY 40211 Are there one or more P&R I process units that do not “use or manufacture any organic HAP”? (See§63.480(b)) Thomas R. Herman What is the base year for which information is being provided?Corporate Environmental Manager For this base year, what was the solid rubber production rate (tons/yr)? 502-775-7719 For this base year, what was the liquid latex production rate (tons/yr)? herman@zeonch emicals.com For each elastomer product process unit (EPPU), please provide the primary product, capacity, and annual production information: EPPU ID Primary Product Capacity (tons/yr) Annual Production

(tons/yr) Not assigned NBR Confidential Confidential
Please provide EPPU IDs that are flexible operating units which produce other products. Are any P&R I operations scheduled to be discontinued? Are any P&R I operations scheduled to be added or expanded? (If no, you need not complete any further portions of this survey)

2009

Confidential Confidential If yes, please explain:

(add information for more EPPUs as necessary)

If yes, please provide date(s) that addition(s) and/or expansion(s) will begin production and explain changes: If yes, please provide dates of closure and explain changes: Not Applicable Yes No
Yes No

Yes No

Yes No
Yes No

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### U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production
If no, please explain. 

### Kentucky Plant If no, please explain.
If "Other", please explain: 

### Corporate Environmental Manager Modified EPA correlation approach with actual field survey If yes, please provide details: 

### herman@zeonchemicals.com Area workspace monitoring GC; LEL alarms Equipment Leaks Have you verified and/or corrected the equipment leak emissions for your P&R I processes in the dataset? Have you completed all control information fields for your P&R I equipment leaks in the dataset? What emissions calculation approach was used to estimate the equipment leak emissions? For the organic HAP emissions, are you implementing work practices or other control techniques beyond those required by the MACT standard? Screening ranges approach EPA correlation approach Unit-specific correlation approach Other Yes No
Yes No

Yes No



### Page 3 of 8U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production
If no, please explain. Kentucky Plant If no, please explain.
Corporate Environmental Manager

Emission Unit ID Mass Emission Rate of Halogen Atoms (kg/hr)

Are you controlling these HCl emissions?

EPPU ID Front-End Process

Vent ID Originating source of

chlorinated compounds Batch or continuous? If batch, operating schedule (hrs/yr)*

*(please use the base year identified in "Facility Information") Please complete the following table for each elastomer product process unit (EPPU) for which there HCl emissions that result from combustion of a halogen in a control device. Do you have a permit/emission limit for HCl emissions?If yes, please please complete the following section: herman@zeonchemicals.com None; Recovery is neither front- nor back-end All of the above plus residual monomer lab analysis

(add information for more emission units as

necessary) If "Other", please explain:

(add information for more EPPUs as necessary) If yes, what is the limit and how are you required to demonstrate compliance (e.g., source testing, continuous emissions monitoring, continuous or periodic parameter monitoring, etc)? Please describe or provide a copy of these requirements. If yes, please describe the control device or control strategy: Front-End Process Vent Emissions Information Have you verified and/or corrected the front-end process vent emissions for your P&R I processes in the dataset? Have you completed all control information fields for your P&R I front-end process vent streams in the dataset? What emissions calculation approach was used to estimate the front-end emissions? From P&R I processes, are there HCl emissions that result from combustion of a halogen in a control device? Stack Test Continuous Emissions Monitoring Engineering Calculations Other Yes No
Yes No

Yes No

Yes No

Yes No

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### U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

If no, please explain. 

### Kentucky Plant If no, please explain. 

### Blend tanks and finishing lines If "Other", please explain: Residual monomer data
6,120
If yes, what is the limit/requirement and how are you required to demonstrate compliance (e.g. source testing, continuous emissions monitoring, continuous or periodic parameter monitoring, etc)? Please describe or provide a copy of these requirements. Plant-wide daily VOC limit of 4,133 #/day; 85% reduction from Front-end residual monomer amounts; facility production limits; local STAR regulation emission limits 

### What type of emission sources are there from your back-end processes? Do you have any permit limits or conditions for the emissions from the back-end process operations? Back-End Process Operations Have you verified and/or corrected the back-end process operation emissions for your P&R I processes in the dataset? Have you completed all control information fields for your P&R I back-end processes in the dataset?

What emissions calculation approach was used to estimate the back-end emissions? Are the back-end process operations continuous or batch? If the back-end process operations are batch, what is the operating schedule (hrs/yr) (please use the base year identified in "Facility Information") Please describe the back-end emission processes at this facility (i.e., the operations in an EPPU following the stripping operations): Stack Test Continuous Emissions Monitoring Other
Continuous Batch

Stack Fugitive (not including equipment leaks) Yes No Yes No
Yes No



### Page 5 of 8

### U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Storage Vessels Emissions Information Have you verified and/or corrected the storage vessels emissions for your P&R I processes in the dataset? Have you completed all control information fields for your P&R I storage vessels in the dataset? What emissions calculation approach was used to estimate the storage vessels, surge control vessels, and bottoms receivers emissions? If no, please explain.
If no, please explain.
If "Other", please explain:



### No control required -- Group 2 TANKS Other engineering calculations Stack Test Other Yes No

Yes No



### Page 6 of 8

### U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Wastewater If no, please explain. If no, please explain.
If "Other", please explain:
If "Other", please explain: 

### Wastewater Management Unit ID Control Control Efficiency Not assigned Not required Not required All Process WW Group 2



### (add information for more waste management units as necessary) Have you verified and/or corrected the wastewater emissions for your P&R I processes in the dataset? Have you completed all control information fields for your P&R I wastewater in the dataset? What emissions calculation approach was used to estimate the emissions from tanks, containers, and oil-water separators? What emissions calculation approach was used to estimate the emissions from surface impoundments and drain systems? Please list all waste management units that receive, manage, or treat Group 2 wastewater streams and their controls (these waste management units may not match the wastewater unit ID in the dataset): Not Applicable Not Applicable
Not Applicable
Not Applicable TANKS Other engineering calculations Stack Test WATER9 Other Yes No
Yes No

Engineering calculations WATER9 Other



### Page 7 of 8

### U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Startup and Shutdown Events

If no for any of the above, please explain: Not Applicable Do you wish to recommend a standard that would apply during startup and shutdown? If so, please: Startup and shutdown emissions are included in normal operations and not differentiated. 

### 1. Describe the event(s) to which the standard would apply 2. Provide the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period 3. Provide a compliance determination method 4. Provide the basis for the recommended standard 5. Explain why and how the standard would minimize emissions during the event For each emission source type, can you comply with the emissions limitation and/or work practices in the regulation that apply during normal operation during startup and shutdown events? Equipment Leaks Front-End Process Vents Back-End Process Operations

Storage Vessels Wastewater For each emission source type, do the annual emissions estimate in the dataset "Emissions (TPY)" field include the annual emissions from startup and shutdown events that you added in the "STARTUP EMISSIONS (TPY)" and "SHUTDOWN EMISSIONS (TPY)" fields? Equipment Leaks Front-End Process Vents Back-End Process Operations

Storage Vessels WastewaterYes

No Yes No Yes No Yes No Yes No

Yes No Yes No Yes No Yes No Yes No Yes No



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