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

General Information Company Name: Styron LLC Facility Name: Dalton, Georgia Facility Address: 1468 Prosser Drive, SE Mailing Address (if different from facility address): Site Contact Name: Kim Leal Site Contact Title: Site Leader, Styron LLC Site Contact Phone Number: 706-277-8306 Site Contact Email Address: krleal@styron.comU.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Facility Information Is the facility a major source for HAP? Styron LLC Dalton, Georgia 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)? 1468 Prosser Drive, SE Are there one or more P&R I process units that do not “use or manufacture any organic HAP”? (See§63.480(b)) Kim Leal What is the base year for which information is being provided? Site Leader For this base year, what was the solid rubber production rate (tons/yr)? 706-277-8306 For this base year, what was the liquid latex production rate (tons/yr)? krleal@dow.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)

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 n/a

n/a See CBI submittal for details on production 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: Yes No
Yes No Yes No

Yes No
Yes No

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

### Dalton, Georgia If no, please explain.
If "Other", please explain: 

### Site Leader If yes, please provide details: 

### krleal@dow.com For the organic HAP emissions, are you implementing work practices or other control techniques beyond those required by the MACT standard? 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? Average emission factors Screening ranges approach EPA correlation approach Unit-specific correlation approach Yes No
Yes No

Yes NoU.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

If no, please explain. Dalton, Georgia If no, please explain.

Site Leader

Emission Unit ID Mass Emission Rate of Halogen Atoms (kg/hr) 1 0.00204

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)* 1 1Raw Material Monomer Continuous 8760

*(please use the base year identified in "Facility Information") Do you have a permit/emission limit for HCl emissions?If yes, please please complete the following section:

(add information for more emission units as

necessary) If "Other", please explain: 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? krleal@dow.com

(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. 1.5 pounds per hour; Performance testing and continuous parameter

monitoring required.
Caustic Scrubber If yes, please describe the control device or control strategy: 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. Stack Test Continuous Emissions Monitoring Engineering Calculations Other Yes No
Yes No

Yes No

Yes No

Yes No

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

If no, please explain. 

### Dalton, Georgia If no, please explain. 

### Product storage vessels If "Other", please explain: 

### 706-277-8306 Engineering Calcs
24 hours/day, 365 days/year (8760 hrs)
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. The facility has a 10 ton individual and 25 ton combined HAP limit. 

### Back end emissions included on storage vessel tab.

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

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

Storage Vessels Emissions InformationDalton, Georgia

Site Leader Emissions less than 10 lbs annually from backend product storage tanks 

### 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: 

### NEI data set does not include back end storage tanks NEI data set does not include back end storage tanks

TANKS Other engineering calculations Stack Test Other Yes No

Yes No

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

Wastewater If no, please explain. 

### Dalton, Georgia If no, please explain.
If "Other", please explain: 

### Site Leader If "Other", please explain: 

### krleal@dow.com Wastewater Management Unit ID Control Control Efficiency

(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): No Group 1 water streams
No Group 1 water streams TANKS Other engineering calculations Stack Test WATER9 Other Yes No
Yes No

Engineering calculations WATER9 Other

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

Startup and Shutdown Events

krleal@dow.com If no for any of the above, please explain: Do you wish to recommend a standard that would apply during startup and shutdown? If so, please:

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
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 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 Yes No Yes No Yes No Yes No Yes No

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