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

General Information Company Name: STYRON LLC Facility Name: S/B Latex Facility Address: 743 Building Mailing Address (if different from facility address): 1604 Building Site Contact Name: Jamie Dole Site Contact Title: Dow Chemical Company - EH&S Delivery Site Contact Phone Number: (989) 636-5895 Site Contact Email Address: jsdole@dow.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? 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)? Are there one or more P&R I process units that do not “use or manufacture any organic HAP”? (See§63.480(b)) What is the base year for which information is being provided? For this base year, what was the solid rubber production rate (tons/yr)? For this base year, what was the liquid latex production rate (tons/yr)? 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 yes, please provide dates of closure and explain changes: (If no, you need not complete any further portions of this survey)

2006 NA 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: 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. If no, please explain.
If "Other", please explain:
If yes, please provide details: 

### 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



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

Emission Unit ID Mass Emission Rate of

Halogen Atoms (kg/hr) N/A

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") (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: 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: 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? Vent stack sampling and applied DRE

(add information for more emission units as

necessary) If "Other", please explain: From P&R I processes, are there HCl emissions that result from combustion of a halogen in a control device?

Please provide the Emission Unit ID and mass emission rate of halogen atoms 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. If no, please explain.

If "Other", please explain: Engineering Calculations 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 plant has a source wide limit for 1,3-butadiene which includes the back end vents. 

### 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

Less than 10 pounds annually 

### 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:



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

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

(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 wastewater streams No Group 1 wastewater streams
Mass balance based on water sampling. TANKS Other engineering calculations Stack Test WATER9 Other Yes No
Yes No

Engineering calculations WATER9 Other



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### 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: Do you wish to recommend a standard that would apply during startup and shutdown? If so, please:

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

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



### Page 8 of 8