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.com
U.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

No
U.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 1 Raw 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 Information

Dalton, 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